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Office of Labor-Management Standards (OLMS)



U.S. Department of Labor
Office of Labor-Management Standards
Pittsburgh District Office
Federal Office Building
1000 Liberty Avenue, Suite 1411
Pittsburgh, PA 15222
(412) 395-6925 Fax: (412) 395-5409
July 20, 2011

Mr. Casey Greene, Treasurer
Communications Workers Local 2011
270 E Main Street
Clarksburg, WV 26301

Case Number:
LM Number: 011142

Dear Mr. Greene:

This office has recently completed an audit of Communications Workers Local 2011 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 July 19, 2011, 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.

Reporting Violations

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to
file annual financial reports accurately disclosing their financial condition and operations. The
Labor Organization Annual Report (Form LM-3) filed by Local 2011 for the fiscal year ended
September 30, 2010, was deficient in the following areas:

1. Disbursements to Officers
Local 2011 did not include some reimbursements to officers totaling at least $155.00 in the
amounts reported Item 24 (All Officers and Disbursements to Officers). It appears the
union erroneously reported these payments in Item 48.

The union must report most direct disbursements to Local 2011 officers and some indirect
disbursements made on behalf of its officers in Item 24. A "direct disbursement" to an
officer is a payment made to an officer in the form of cash, property, goods, services, or
other things of value. See the instructions for Item 24 for a discussion of certain direct
disbursements to officers that do not have to be reported in Item 24. An "indirect
disbursement" to an officer is a payment to another party (including a credit card company)
for cash, property, goods, services, or other things of value received by or on behalf of an
officer. However, indirect disbursements for temporary lodging (such as a union check
issued to a hotel) or for transportation by a public carrier (such as an airline) for an officer
traveling on union business should be reported in Item 48 (Office and Administrative
Expense).


Mr. Casey Greene
August 2, 2011
Page 2 of 2

2. Failure to File Bylaws
The audit disclosed a violation of LMRDA Section 201(a), which requires that a union
submit a copy of its revised constitution and bylaws with its LM report when it makes
changes to its constitution or bylaws. Local 2011 amended its constitution and bylaws in
1995, but did not file a copy with its LM report for that year.

Local 2011 has now filed a copy of its constitution and bylaws.

I want to extend my personal appreciation to Communications Workers Local 2011 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,

Investigator

cc: Ms. Elaine Harris, CWA Representative