January 2011 

Introduction 

When the Labor-Management Reporting and Disclosure Act (LMRDA) was enacted in 1959, 

Congress declared, “it is essential that labor organizations, employers and their officials adhere 

to the highest standards of responsibility and ethical conduct in administering the affairs of 

their organizations, particularly as they affect labor-management relations.” The LMRDA 

primarily promotes union democracy and financial integrity in private sector labor unions 

through standards for union officer elections and union trusteeships and safeguards for union 

assets. Additionally, the LMRDA promotes transparency through reporting and disclosure 

requirements for labor unions and their officials, employers, labor relations consultants, and 

surety companies. The Office of Labor-Management Standards (OLMS) continues today to 

pursue this important mission through criminal and civil enforcement of the LMRDA. 

The major provisions of the LMRDA, by title, are: 

 Title I: Bill of Rights for union members 

 Title II: Requirements for reporting and disclosure by labor unions, union officers and 

employees, employers, labor relations consultants and surety companies 

 Title III: Rules for establishing and maintaining trusteeships 

 Title IV: Standards for conducting fair elections of union officers 

 Title V: Safeguards for protecting union funds and assets 

OLMS also administers provisions of the Civil Service Reform Act of 1978 and the Foreign 

Service Act of 1980, which extend comparable protections to Federal labor unions. In addition, 

OLMS’ Division of Statutory Programs administers the Department’s responsibilities under the 

Federal Transit Act by ensuring that fair and equitable arrangements protecting mass transit 

employees are in place before the release of Federal transit grant funds. 

OLMS is the front line agency responsible for enforcing the LMRDA through its criminal and 

civil investigations. Criminal investigations include embezzlement, deprivation of rights by 

violence, extortionate picketing, willful failure to file reports, filing false reports, prohibited 

union office holding or employment of convicted persons, and fraud related to union elections. 

Civil investigations include violations of the LMRDA involving union election procedures, 

financial disclosure requirements, and trusteeship standards. 

OLMS conducts audits of union finances, administers a comprehensive compliance assistance 

program, and offers information and technical support to union officers and members to further 

the goals of financial integrity, union democracy, and transparency. 

2010 Annual Report 

Office of Labor-Management Standards

U.S. Department of Labor 

John Lund, Director 
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Compliance assistance also plays a central role in the OLMS enforcement strategy. OLMS has 

an active compliance assistance program to promote voluntary compliance with the LMRDA by 

informing union officers and employees of their responsibilities and informing members of 

their legal rights. 

Summary 

This report consists of six sections, with related tables and charts. 

 Section 1 presents key criminal enforcement results pursuant to LMRDA Title V (financial 

safeguards for labor organizations), for FY 2010 and the preceding four-year average, 

together with noteworthy criminal enforcement actions in FY 2010. A more complete listing 

of these actions is located at www.dol.gov/olms/regs/compliance/enforcement_1.htm on 

the OLMS website. 

 Section 2 presents key civil enforcement results pursuant to LMRDA Title III (trusteeships) 

and Title IV (union officer elections) together with noteworthy union officer election case 

summaries for FY 2010. Listings of union officer election voluntary settlement agreements 

are located at www.dol.gov/olms/regs/compliance/civil_actions.htm (2001-2009) and 

www.dol.gov/olms/regs/compliance/civil_actions_2010.htm (2010). Final decision letters 

in election and trusteeship cases are located on the OLMS website at 

www.dol.gov/olms/regs/compliance/OLMS_FOIA.htm. 

 Section 3 presents reporting and disclosure data and related program activity pursuant to 

LMRDA Title II (reporting requirements). Reports are available for public disclosure on the 

OLMS Online Public Disclosure Room, www.unionreports.gov. 

 Section 4 summarizes grant certification activity pursuant to Section 13(c) of the Federal 

Transit Act, ensuring fair and equitable arrangements protecting mass transit employees. 

 Section 5 presents major regulatory activities in FY 2010. 

 Section 6 briefly describes compliance assistance activities conducted in FY 2010. 

Program Activities 

1. Safeguarding Union Assets 

As part of the effort to protect and safeguard union funds and assets, OLMS investigates 

possible embezzlement from unions and other violations of criminal laws. Over the past 10 

years, restitution of $104,650,293 has been paid or ordered to be paid to defrauded unions and 

other parties. OLMS also conducts audits of labor unions to ensure and promote their 

compliance with the LMRDA. Compliance audit closing letters are located at 

www.dol.gov/olms/regs/compliance/CA_closing_letters.htm on the OLMS website. 
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Union officers, employees, and representatives have a duty to manage the funds and property 

of the union solely for the benefit of the union in accordance with its constitution. A union 

officer or employee who embezzles or misappropriates union funds or assets commits a federal 

crime punishable by fine and/or imprisonment. OLMS is responsible for investigating these 

crimes. The following are some of the most significant criminal enforcement actions from FY 

2010. 

Former Officer Feeds Gambling Habit with $217,528 in Embezzled Union Funds 

In August 2010, Thomas Pokrywczynski, former financial secretary-treasurer of the 

Amalgamated Transit Union (ATU) Local Division 1342 in Buffalo, New York, and treasurer of 

the ATU New York State Legislative Conference Board in Syracuse, New York, was sentenced 

to 24 months imprisonment following his guilty plea. He pled guilty to embezzling 

approximately $71,000 from the local division and $183,000 from the conference board between 

January 2002 and March 2008. As treasurer of the New York State Conference Board, 

Pokrywczynski used an ATM card to make over 400 unauthorized cash withdrawals from that 

body’s bank account. Pokrywczynski also failed to deposit all incoming receipts payable to 

Local Division 1342 into the local’s bank account. In some instances, Pokrywczynski kept the 

cash he received and, on other occasions, he deposited local division funds into the conference 

board’s bank account to replenish funds he took from that body. Pokrywczynski told the 

sentencing judge that he stole the money to gamble at casinos. In addition to his term of 

imprisonment, Pokrywczynski was ordered to make total restitution of $217,528 to the two 

labor organizations. 

Former Local President and Former International Trustee Both Guilty of Embezzlement 

Wayne Mitchell, former president of Communications Workers of America (CWA) Local 14170 

in New York, New York, pled guilty on April 21, 2010, to one count of embezzlement of union 

funds, which totaled between $200,000 and $400,000. From 2006 through 2008, Mitchell 

perpetrated the embezzlement through salary overpayments and writing checks to himself. 

Mitchell’s plea followed an investigation that arose from an OLMS compliance audit of the 

local. During the course of the investigation, OLMS also discovered an embezzlement by 

former CWA International Trustee Lawrence DeAngelis, who had been appointed trustee over 

Local 14170 by the International because of Mitchell’s embezzlement. DeAngelis wrote checks 

and made wire transfers to himself from the union’s account. On April 23, 2010, DeAngelis was 

charged and pled guilty to one count of embezzlement of union funds in excess of $60,000. 

DeAngelis was sentenced to one year in prison, three years supervised release, and was ordered 

to pay restitution of $63,000 and a $3,000 fine. 

OLMS Enforcement Statistics – Financial Integrity FY 2010 FY 2006 – FY 2009 

Yearly Average 

Criminal Cases Processed 355 386

Indictments 129 119

Convictions 130 119

Compliance Audits Conducted 541 763
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Former Transit Employees Secretary-Treasurer Causes Detour of Local’s Funds 

While serving as secretary-treasurer of the Transit Employees Union, an unaffiliated union 

based in South Euclid, Ohio, Lisa Wright embezzled $71,470 in union funds. Wright issued 

herself 120 unauthorized union checks, forging signatures and providing false purposes for the 

checks. Additionally, Wright made nine unauthorized withdrawals from the union’s savings 

account. In February 2010, she pled guilty to one count of embezzlement, and on May 19, 2010, 

was sentenced to three years probation and full restitution. 

Former UAW Local Bookkeeper Pleads Guilty to Embezzling Over $200,000 

While serving as bookkeeper for United Auto Workers (UAW) Local 383 in Benton Harbor, 

Michigan, Robbin Wolff embezzled $200,397 by issuing 194 extra salary checks to herself and 

using union credit cards to make personal charges. Wolff attempted to conceal her 

embezzlement by falsifying union records. Wolff pled guilty to one count of embezzlement and 

one count of falsifying union records. She was sentenced to 24 months imprisonment for the 

embezzlement and an additional 12 months for falsifying union records, with time to be served 

concurrently. Upon release from imprisonment, Wolff will be on supervised release for two 

years for the former offense and one year for the latter offense; the time to be served 

concurrently. Wolff was ordered to pay full restitution and a special assessment of $125. 

Former AFSCME District Council President Embezzles More Than $180,000 

Paula Dorsey, former president of American Federation of State, County and Municipal 

Employees (AFSCME) District Council 48, located in Milwaukee, Wisconsin, embezzled more 

than $180,000 between 2004 and 2009. The money was stolen from an account funded by the 

AFSCME National Union for “Operation Big Vote,” a non-partisan program to encourage 

minority voting. The OLMS investigation disclosed that Dorsey made at least 76 cash 

withdrawals from the union account, totaling over $180,000, at a casino in conjunction with 

gambling losses. On August 11, 2010, Dorsey pled guilty to embezzlement. On December 15, 

2010, Dorsey was sentenced to three years probation and was ordered to pay restitution in the 

amount $180,000. 

Former Machinists District Lodge Employee Sentenced for Embezzlement 

Linda Tickle, former office manager of International Association of Machinists (IAM) District 

Lodge 711 in Chattanooga, Tennessee, was also assigned similar responsibilities at Lodge 56 

and Lodge 1458. While so employed, Tickle embezzled money from Lodge 56 and Lodge 1458 

by writing checks to herself. The OLMS computer cadre of forensic investigators retrieved the 

lodge’s computer records for analysis, which was instrumental to the success of this 

investigation. Tickle pled guilty to two counts of embezzlement of union funds totaling $40,048 

and was sentenced to five months imprisonment, three years probation, and was ordered to pay 

restitution of $40,048 and a $200 assessment.

Former Machinists Local Lodge Secretary-Treasurer Sentenced to Prison 

Hugo Vargas, former secretary-treasurer of the International Association of Machinists (IAM) 

Local Lodge 845, located in Las Vegas, Nevada, embezzled $106,294 by making 33 unauthorized 

in-person bank withdrawals, 131 unauthorized ATM withdrawals, and 12 unauthorized debit 

card purchases and payments. Of the 131 unauthorized ATM withdrawals, 27 were made at 

casino locations, two were made in Thailand, and three were made in Mexico. Vargas was 

arrested and pled guilty to one count of embezzlement in the amount of $106,294. He was 
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sentenced to 13 months in prison, followed by a 3-year period of supervised release, and was 

ordered to pay restitution of $106,294 and a $100 assessment. 

Former Secretary-Treasurer Receives Prison Sentence for Embezzlement 

An OLMS joint investigation with the Internal Revenue Service (IRS) of James L. Miles, former 

secretary-treasurer of International Brotherhood of Electrical Workers (IBEW) Local 1023, 

located in Barstow, California, resulted in Miles entering a guilty plea to embezzling union 

funds totaling $93,283 and filing a false tax return. Miles misappropriated these funds by 

signing more than 350 checks payable to himself or to his creditors. Miles was sentenced to one 

year in federal prison followed by three years of supervised release. He was also ordered to 

pay $78,283 in restitution to the Local, $15,000 to the bonding company, and $14,466 to the IRS. 

Former Local Bookkeeper Sentenced for Embezzling Union Funds 

Cheryl Staley, former bookkeeper for International Union of Operating Engineers (IUOE) Local 

501 in Los Angeles, California pled guilty to a complex scheme that resulted in her embezzling 

$231,653 in union funds. Staley embezzled cash receipts over the course of a five-year period 

and concealed her theft by manipulating the electronic dues records database, which recorded 

cash dues payments for the union’s Las Vegas members. Staley used the majority of the stolen 

money at local casinos to feed an apparent gambling addiction. Staley was sentenced to five 

years probation, during which time she is restricted from entering a casino without first 

notifying her probation officer. She was also ordered to attend gambling addiction classes and 

pay $231,653 in restitution. 

Former AFGE Local President Guilty of Embezzlement 

Sid Mannetti, former president of American Federation of Government Employees (AFGE) 

Local 1170, located in Seattle, Washington, embezzled $50,463 between January 2006 and 

February 2008. On January 25, 2010, Mannetti was charged with and pled guilty to a single 

count of embezzling union funds. Mannetti embezzled Local 1170 funds by his unauthorized 

use of the union credit card and unauthorized cash withdrawals. The credit card charges 

totaled $32,928, the bulk of which was used to pay personal debts, such as $2,546 worth of car 

repairs at a Chevrolet dealership. The cash withdrawals totaled $18,578, with one withdrawal 

totaling $6,000. On July 12, 2010, Mannetti was sentenced to 24 months of probation with six 

months of home confinement, in addition to a court ordered restitution payment of $50,463. 

Former CWA Local Financial Secretary Sentenced for Embezzling More Than $110,000 

Sherrell Mitchell, former financial secretary of Communications Workers of America (CWA) 

Local 86823, located in St. Louis, Missouri, was charged with embezzling union funds in the 

amount of $110,139. The OLMS investigation disclosed that between January 2002 and May 

2009, Mitchell wrote herself 358 unauthorized checks totaling $58,709 and made 225 

unauthorized cash withdrawals totaling $51,430. Mitchell concealed the theft from other 

officers by having the bank statements sent to her home instead of the union’s P.O. Box, 

shredding the bank statements, and giving inflated financial reports at meetings. When 

confronted by investigators, Mitchell stated that the money was used to support her gambling 

habit. On April 8, 2010, Mitchell was sentenced to six months home detention and five years 

probation. Full restitution was also ordered. 
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2. Protecting Union Democracy 

The LMRDA establishes democratic standards for conducting union officer elections, such as 

the frequency and method of election, the right of members in good standing to be candidates, 

rights of candidates, and voting rights of members. When a union member files a timely 

complaint protesting a regularly scheduled election of union officers following a timely and 

proper internal protest, OLMS conducts an investigation. If the investigation reveals a violation 

of the union-democracy provisions of the LMRDA that may have affected the outcome of the 

election, OLMS asks the union to agree to allow OLMS to supervise a new election. If the union 

agrees, a voluntary compliance agreement is signed. If the union does not voluntarily agree to 

remedy the violation, OLMS may take legal action seeking a new election supervised by OLMS. 

The agency also conducts investigations to determine the validity of the imposition or 

continuation of trusteeships imposed by national unions on subordinate bodies. Trusteeship 

investigations are conducted upon receipt of a complaint from a member or subordinate body. 

OLMS Enforcement Statistics – Union Democracy FY 2010 FY 2006 – FY 2009 

Yearly Average 

Election Investigations Conducted 145 127

Lawsuits Filed 8 8

Voluntary Compliance Agreements Obtained 23 25

Supervised Elections Completed 29 32

Trusteeship Investigations 10 12

The following are highlights of some of the most significant OLMS election and trusteeship 

cases during FY 2010. 

Local Postal Workers Union Voluntarily Agrees to Rerun Election for President 

On November 4, 2009, OLMS entered into a voluntary settlement agreement with Postal 

Workers Local 497 in Springfield, Massachusetts, to conduct a new election for the office of 

president under OLMS supervision. OLMS investigation of the local’s regularly scheduled May 

5, 2009 election found that an ineligible member had been permitted to run for the position of 

president. In addition, the local agreed to open and count 120 ballots that had been voided in 

the original election due to a missing signature or employee number on the return ballot 

envelope. These return ballot envelopes, however, contained preprinted member address labels 

that OLMS determined were sufficient to verify voter eligibility. OLMS’ tally of these 

additional 120 ballots did not change the previous outcome of any of the contested races. The 

OLMS supervised election for the office of president was conducted by mail ballot and was 

completed on January 22, 2010. 

Operating Engineers Local 150 Holds OLMS-Supervised Election 

On December 14, 2009, International Union of Operating Engineers (IUOE) Local 150, located in 

Countryside, Illinois, signed a Stipulation of Settlement and Order in the U.S. District Court for 

the Northern District of Illinois. The Order mandated that OLMS supervise the next regularly 

scheduled IUOE Local 150 officer election during calendar year 2010. During its investigation 

of the local’s August 2007 election, OLMS found that both union and employer funds had been 

used to promote the incumbent slate. The Secretary of Labor filed suit in September 2008 to 

overturn the election. The local’s approximately 23,000 members are divided into eight districts 
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located in three states and are employed by hundreds of employers throughout Northern 

Illinois, Northern Indiana, and Northwestern Iowa. OLMS supervised the multi-step 

nominations process, beginning with the nominations meetings held at each local district office, 

for the 21 positions included on the ballot. The mail ballot election included the tally of 10,227 

valid ballots. The OLMS-supervised election was completed on August 28, 2010. 

OLMS Supervises Southwest Airlines Pilots Association March 2010 Election 

Following an election investigation conducted in 2008, which revealed that certain union 

officials used union laptops and union time to campaign, the Southwest Airlines Pilots 

Association (SWAPA) in Dallas, Texas, entered into a voluntary settlement agreement on 

February 13, 2009, to have OLMS supervise a new election for the second vice president 

position. OLMS and SWAPA agreed to conduct the election by paper mail ballot. On March 11 

and 12, 2010, following the mail ballot voting period, OLMS picked up the voted ballots, 

checked voter eligibility, and counted the voted ballots. OLMS ensured the 6,000 SWAPA 

members a democratic union officer election. 

Union Insular de Trabajadores Industriales y Construcciones Electricas 

On June 17, 2010, OLMS negotiated a voluntary settlement agreement with the Union Insular de 

Trabajadores Industriales y Construcciones Electricas (UITICE), an independent union located 

in Guaynabo, Puerto Rico. UITICE has approximately 1,680 members and represents mostly 

construction workers, technicians, and installers of One-Link Communications, Suiza Dairy, 

Ryder Hospital, and the Autoridad de Energía Eléctrica (Power Company) in Puerto Rico. 

UITICE agreed to conduct nominations and an election under the OLMS supervision for the 

positions of president, vice-president, secretary-treasurer, sub-secretary-treasurer, marshall and 

four vocals (trustees). During the investigation, OLMS found that UITICE had not held an 

election of officers in at least 12 years. The supervised election was held in 17 different polling 

sites throughout Puerto Rico. Twenty-six (26) investigators and managers from different OLMS 

offices nationwide volunteered to work 14 to 16 hour shifts over a two-day period. Over 70% of 

the union members voted. The supervised election was completed on October 29, 2010. 

Voluntary Settlement Agreement for AAUP Election 

OLMS and the American Association of University Professors (AAUP) entered into a voluntary 

settlement agreement in which AAUP agreed that OLMS would rerun the position of Assembly 

of State Conferences (ASC) Chair. The OLMS investigation revealed that delegate elections 

were not properly held in many of the state conferences. The violations included having a 

single polling site where all members from an entire state where required to vote and 

appointing, instead of electing, delegates. A supervised election for the ASC Chair was 

conducted by referendum and was completed in June 2010. 

Unlawful Trusteeship Lifted and Election Supervised for AFT Local 

OLMS received a complaint alleging that a trusteeship imposed on Federation of Indian Service 

Employees Local 4524, in Albuquerque, New Mexico, by its parent body, American Federation 

of Teachers (AFT), had been in effect longer than the 18 months presumptively allowed by law. 

The OLMS investigation found that the continuation of the trusteeship was unlawful. OLMS 

and AFT then entered into a voluntary agreement to lift the trusteeship and conduct 

nominations, an election and the installation of officers under OLMS supervision. The OLMSsupervised election was completed and the new officers were installed in June 2010. 
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Successful Lawsuit Results in Rerun of Election of Officers of Transport Workers Local 

In accordance with a consent order signed on July 19, 2010, OLMS supervised a new election of 

officers for Transport Workers Local 234 in Philadelphia, Pennsylvania. The consent order 

followed an OLMS investigation and resulting April 25, 2008 lawsuit. The lawsuit sought to 

nullify the local’s September 27, 2007 election. The complaint alleged that Local 234 improperly 

disqualified an entire slate of candidates after one member of that slate was disqualified for 

inadvertently accepting nominations for two different offices. The supervised election was for 

all officer positions and included the offices of president, executive vice-president, three vice 

presidents, financial-secretary, recording secretary and seven executive board members. On the 

day of the election, 36 investigators representing offices from each of the four OLMS regions 

supervised voting at 20 polling sites throughout the city of Philadelphia. There were 3,605 

ballots casts, representing a voter turnout of over 70%.

3. Labor Union and Labor-Management Transparency 

The LMRDA is predicated on the principle that union members, officers, and the general public 

benefit by having access to information about labor unions, their officers and employees, 

employers, labor relations consultants, and surety companies. To this end, OLMS administers a 

comprehensive reporting and disclosure program. OLMS also offers compliance assistance 

sessions for union members and officials on the financial reporting obligations under the 

LMRDA. Unions must file annual financial reports (LM-2, LM-3, LM-4, or simplified filings) 

with OLMS. Unions must also file trusteeship reports (LM-15, LM-16) when supervision or 

control is established over a subordinate body. Other entities – employers (LM-10), labor 

relations consultants (LM-20, LM-21), union officers and employees (LM-30), and surety 

companies (S-1) – are also required to file reports under certain circumstances. Reports are 

available for public disclosure on the OLMS Online Public Disclosure Room, 

www.unionreports.gov. OLMS also collects and maintains collective bargaining agreements 

(CBAs) filed by CBA signatories on a voluntary basis. CBAs covering 1,000 or more workers are 

maintained by OLMS and are located at www.dol.gov/olms/regs/compliance/cba/index.htm. 

OLMS received and processed the following public disclosure reports in FY 2010. 

OLMS LMRDA Reports Administration FY 2010 

LM-2 Labor Organization Annual Reports Processed 4,599 

LM-3 Labor Organization Annual Reports Processed 10,931 

LM-4 Labor Organization Annual Reports Processed 6,835 

Simplified Labor Organization Annual Reports Processed 1,510 

LM-10 Employer Reports Processed 1,023 

LM-15 Trusteeship Reports Processed (initial, semiannual, and 15A) 387 

LM-16 Terminal Trusteeship Reports Processed 97 

LM-20 Labor Relations Consultant Agreement and Activities Reports Processed 429 

LM-21 Labor Relations Consultant Receipts and Disbursements Reports Processed 97 

LM-30 Labor Organization Officer and Employee Reports Processed 1,485 

S-1 Surety Company Annual Reports Processed 84 

Total Reports Processed 27,477 
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Near the close of FY 2010, OLMS introduced its new Electronic Forms System (EFS). EFS is a 

web-based system for completing and submitting Labor Organization Annual Financial 

Reports. Currently, EFS is available for use by Form LM-2 filers only, but it will be expanded to 

include Forms LM-3 and LM-4 in the future. EFS allows any labor organization with a webenabled computer the ability to complete, sign, and electronically file an LM-2 without 

purchasing a digital signature or downloading special software. EFS performs all calculations 

for the LM report and completes a form error check prior to submission to OLMS. EFS also 

allows unions that maintain electronic accounting records to import financial data from their 

accounting programs directly into their LM form. 

When labor organization annual reports are not timely filed or the reports filed are not 

acceptable, OLMS opens an investigation to obtain compliance. Additionally, when reports due 

from employers, labor relations consultants, and union officers and employees are not timely or 

properly filed, OLMS pursues delinquent and deficient reports from these entities, as “Special 

Reports” cases. 

OLMS Enforcement Statistics – Reporting and Disclosure FY 2010 FY 2006 – FY 2009 

Yearly Average

LM-2/3/4 Delinquent Reports Cases Completed 2,570 2,162 

LM-2/3/4 Deficient Reports Cases Completed 570 750 

Special Reports Cases Completed 174 63 

4. Employee Protections 

OLMS’ Division of Statutory Programs (DSP) administers responsibilities under Federal transit 

law by ensuring that fair and equitable arrangements protecting mass transit employees are in 

place before the release of Federal transit assistance. When Federal funds are used to acquire, 

improve, or operate a transit system, Federal law requires that arrangements must be made to 

protect the rights of affected mass transit employees. These arrangements must be approved by 

OLMS before the U.S. Department of Transportation’s Federal Transit Administration (FTA) 

can release funds to mass transit employers. In FY 2010, DSP certified 2,490 Federal transit 

grants within an average processing time of 21 days per grant, well under a 45-day goal 

instituted by DSP. More information about employee protections under Federal transit law, 

including compliance assistance materials, can be located on the OLMS website at 

www.dol.gov/olms/regs/compliance/compltransit.htm. 

5. Regulatory Activities 

Form LM-2 and Form LM-3 Rulemaking 

On October 13, 2009, OLMS published in the Federal Register a final rule that rescinded 

regulations published in the Federal Register (74 FR 52401) on January 21, 2009, which had not 

yet gone into effect. The January 21, 2009 regulations (74 FR 3677) had revised Labor 

Organization Annual Report Form LM-2, used by the largest labor organizations to file their 

annual financial reports under the LMRDA and established a procedure by which the Secretary 

of Labor may revoke, under certain circumstances, a particular labor organization's 

authorization to file a simplified Form LM-3 annual report. 
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Form T-1 Trust Annual Report 

On December 1, 2010, OLMS published in the Federal Register (75 FR 74936) a final rule 

rescinding the Form T-1 Annual Report (75 FR 5456). The Form T-1 was an annual financial 

disclosure report that was to be filed by labor unions with total annual receipts of $250,000 or 

more about certain related organizations, called “trusts.” In addition, the final rule reinstituted 

a previously abandoned requirement that unions report financial information concerning their 

“subsidiary organizations.” Subsidiary organizations are entities that are wholly owned, 

controlled, and financed by a single union. Filers have the option of either consolidating the 

subsidiary information in the union’s disclosure report, or attaching a regular annual report for 

the subsidiary. Additionally, the final rule reinstated the OLMS policy that the LMRDA does 

not cover intermediate bodies that are wholly composed of public sector labor organizations. 

Executive Order 13496: Notification of Employee Rights Under Federal Labor Laws

On May 20, 2010, OLMS published in the Federal Register (75 FR 28368) a final rule 

implementing provisions of Executive Order (E.O.) 13496, signed by President Barack Obama 

on January 30, 2009 (74 FR 6107, February 4, 2009). E.O. 13496 requires Federal contractors and 

subcontractors to post a notice in their workplaces informing employees of their rights under 

Federal labor laws, and provides that the requirement to post the employee notice be included 

in Federal contracts and subcontracts. The rule established regulations implementing E.O. 

13496, and prescribed the form and content of the required notice. The notice outlines the 

fundamental rights regarding union activity and collective bargaining that employees have 

under the National Labor Relations Act (NLRA); provides examples of conduct that is illegal 

under the NLRA; and provides contact information in the event that an employee suspects that 

the law has been violated. The regulations also include enforcement procedures and provisions 

regarding sanctions, penalties, and remedies that may be imposed for violations. 

Form LM-30 Labor Organization and Employee Report

On August 10, 2010, OLMS published in the Federal Register for notice and comment (75 FR 

48416) a proposal to revise the Form LM-30, Labor Organization Officer and Employee Report. 

The purpose of the Form LM-30 is to make public any actual or potential conflict between the 

personal financial interests of union officers or employees and their obligations to the union and 

its members. The proposed Form LM-30 revisions would address the complexity of the 

form and its instructions, as well as the scope and extent of the LM-30 reporting 

obligations. 

6. Compliance Assistance 

In FY 2010, OLMS undertook the following initiatives as part of a comprehensive compliance 

assistance program to educate unions about the LMRDA: 

 OLMS continued its program of structured, nationwide compliance assistance seminars. 

The goal of this program is to provide an opportunity each year for the officers of every 

labor organization to attend a compliance assistance seminar. The content of the compliance 

assistance seminar is similar throughout the country so that every officer in attendance is 

exposed to the same material. In FY 2010, OLMS conducted 145 compliance assistance 

seminars for 4,332 attendees. In total, OLMS provided 25,966 contact hours of compliance 

assistance (i.e., the number of participants multiplied by the number of hours of instruction). 
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 OLMS continued to be responsive to all specific requests for compliance assistance 

seminars. 

 In FY 2010, OLMS established voluntary compliance partnerships with 10 national and 

international unions resulting in significant improvements in the reporting and bonding 

compliance of participating union affiliates, as well promoting training initiatives and 

development of best practices. 

 OLMS continued to promote and use an electronic mailing list system to send email 

messages to unions, accountants, union members, and other interested parties. The 

electronic mailing list currently has 2,196 subscribers. 

 OLMS created and implemented an “eLaws Advisor” guide for union officer elections, an 

interactive web-based tool for providing compliance assistance to union officials and 

members. 

 OLMS updated website pages for electronic annual financial disclosure forms for additional 

clarity and ease of use; created a “Compliance Tips” website page with five new compliance 

tips; and created an “Employer-Consultant Reporting” website page with links to a fact 

sheet, reporting forms, and instructions.