Office of Labor-Management Standards (OLMS)
U.S. Department of Labor Employment Standards Administration
Office of Labor-Management Standards
Cleveland District Office
1240 East Ninth Street
Cleveland, OH 44199
(216)357-5455 Fax: (216)357-5425
October 22, 2008
Ms. Patricia Cox, Financial Secretary
8404 Hoofbeat Trail
Jamestown, OH 16134
LM File Number 517-381
Case Number: -
Dear Ms. Cox:
This office has recently completed an audit of Steelworkers Local 811 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 on August 26, 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 receked in the course of union business.
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 811's 2007 records revealed the following recordkeeping violation:
Disposition of Property
In fiscal year 2007 the union purchased approximately $550 in gift certificates. Local 811
did not maintain an inventory of gift certificates it purchased and gave away to
members. The union must report the value of any union property on hand at the
beginning and end of each year in Item 30 (Other Assets) of the LM-3. The union must
retain an inventory or similar record of property on hand to verify, clarify, and explain
the information that must be reported in Item 30.
Based on your assurance that Local 811 will retain adequate documentation in the future, OLMS will take no further enforcement action at this time regarding the above violations.
I want to extend my personal appreciation to Steelworkers Local 811 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.
cc: Rachel Clark, President