Office of Labor-Management Standards (OLMS)
U.S. Department of Labor Employment Standards Administration
Office of Labor-Management Standards
Denver District Office
1999 Broadway, Suite 2435
Denver, CO 80202-571 2
(720) 264-3232 Fax:(720) 264-3230
October 7, 2008
Mr. Joe Dwyer, Secretary-Treasurer
Teamsters Local 190
437 Kuelman Rd.
Billings, MT 50915
LM File Number: 017-236
Case Number: -
Dear Mr. Dwyer:
This office has recently completed an audit of Teamsters Local 190 under the
Compliance Audit Program (CAP) to determine your organization's compliance with
the provisions of the Labor-Management Reporting and Disclosure Act of 1959
(LMRDA). As discussed during the exit interview with you, Darla Durham and Susan
Kaiser, Bookkeeper, on July 24,2008, the following problems were disclosed during the
CAP. The matters listed below are not an exhaustive list of all possible problem areas since the audit conducted was limited in scope.
Title II of the LMRDA establishes certain reporting and recordkeeping requirements.
Section 206 requires, among other things, that labor organizations maintain adequate
records for at least five years by which each receipt and disbursement of funds, as well
as all account balances, can be verified, explained, and clarified. As a general rule, labor
organizations must maintain all records used or received in the course of union
For disbursements, this includes not only original bills, invoices, receipts, vouchers, and applicable resolutions, but also documentation showing the nature of the union business requiring the disbursement, the goods or services received, and the identity of the recipient(s) of the goods or services. In most instances, this documentation requirement can be satisfied with a sufficiently descriptive expense receipt or invoice. If an expense receipt is not sufficiently descriptive, a union officer or employee should write a note on it providing the additional information. For money it receives, the labor organization must keep at least one record showing the date, amount, purpose, and source of that money. The labor organization must also retain bank records for all accounts.
The audit of Local 190's 2007 records revealed the following recordkeeping violations:
General Receipt and Disbursement Records
Local 190 did not maintain adequate documentation for disbursements and receipts made from the petty cash fund during the audit year. As previously noted above, all labor organizations must retain original records for all disbursements and receipts. The President or Treasurer or corresponding principal officers are responsible for this.
Based on your assurance that Local 190 will maintain documentation of all petty cash account activity, OLMS will take no further enforcement action at this time regarding the above violation.
I want to extend my personal appreciation to Teamsters Local 190 for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance materials provided to you are passed on to future officers. If we can provide any additional assistance, please do not hesitate to call.