February 4, 2010 Notice of Proposed Rulemaking to rescind Form T-1
Notice of Proposed Rulemaking to rescind Form T-1 (Trust Report)
The Department of Labor published a Notice of Proposed Rulemaking to rescind Form T-1 (Trust Report) and require labor unions to instead report on their Form LM-2 their wholly owned "subsidiary organizations." The NPRM will also propose to return to the Department's 50 year old policy that public sector intermediate labor unions are not covered by the LMRDA. The LMRDA was enacted to regulate private sector unions.
The Form T-1 required unions to report on certain of their trusts. Trusts are organizations established by the union or the union selects one or more of its trustees. A trust exists to provide benefits to union members and their families. Ever since the 2003 publication of the new Form LM-2, unions have not been required to report on wholly-owned union subsidiaries, like building corporations, on their Form LM-2 reports. OLMS will propose reinstituting subsidiary reporting on the Form LM-2, thereby providing union members with much needed information on organizations owned and operated by their unions.
All stakeholders will have the opportunity to state their views and opinions during the comment period. No final decisions will be made until after a full and fair process.
The T-1 NPRM was published in the Federal Register on Tuesday, February 2. The comment period will close April 5, 2010.
Information regarding the Form T-1 can be found on www.dol.gov.