U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Pittsburgh District Office
1000 Liberty Avenue
Room 1411
Pittsburgh, PA 15222
(412)395-6925 Fax: (412)395-5409
February 4, 2008
Mr. James Wallace, Secretary Treasurer
United Transportation Union
Local 915
32 Evergreen Circle
Poca, WV 25159
LM File Number 003-499
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Dear Mr. Wallace:
This office has recently completed an audit of Local 915 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 and President Charles Veazey on January 29, 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.
Recordkeeping Violations
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 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 915’s 2007 records revealed the following recordkeeping violations:
Failure to Maintain Meeting Minutes
Local 915 was missing five months worth of meeting minutes. During the audit, you advised me that the membership must approve the monthly financial report, to include disbursements, at the membership meeting. Meeting minutes must be maintained to show proper approval of disbursements.
Based on your assurance that Local 915 will retain adequate documentation in the future, OLMS will take no further enforcement action at this time regarding the above violations.
Other Issues
Signing Blank Checks
During the audit, you advised that President Charles Veazey signs blank checks. Your union’s bylaws require that all checks be signed by the president and treasurer. The two signature requirement is an effective internal control of union funds. Its purpose is to attest to the authenticity of a completed document already signed. However, signing a blank check in advance does not attest to the authenticity of a completed check, and negates the purpose of the two signature requirement. OLMS recommends that Local 915 review these procedures to improve internal control of union funds.
I want to extend my personal appreciation to Local 915 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.
Sincerely,
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Investigator
cc: President Charles Veazey