Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
Nashville District Office
233 Cumberland Bend Drive, Suite 110
Nashville, TN 37228
(615) 736-5906 Fax: (615) 736-7148
July 12, 2011
Mrs. Theresa Morrow, Treasurer
Stage & Picture Operators Local 492
4610 Charlotte Pike
Nashville, TN 37209
LM Number: 541825
Dear Mrs. Morrow:
This office has recently completed an audit of Stage & Picture Operators Local 492 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 8, 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.
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 492’s 2010 records revealed the following recordkeeping violations:
1. General Reimbursed Expenses
Local 492 did not retain adequate documentation for reimbursed expenses incurred by
union officers and employees totaling at least $500. For example, the local failed to retain
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July 15, 2011
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receipts for reimbursement of child care service benefits to an employee and some lodging
for union business by union officers.
As noted above, labor organizations must retain original receipts, bills, and vouchers for all
disbursements. The president and treasurer (or corresponding principal officers) of your
union, who are required to sign your union’s LM report, are responsible for properly
maintaining union records.
2. Reimbursed Auto Expenses
Union officers who received reimbursement for business use of their personal vehicles did
not retain adequate documentation to support payments to them totaling at least $100
during 2010. The union must maintain records which identify the dates of travel, locations
traveled to and from, and number of miles driven. The record must also show the business
purpose of each use of a personal vehicle for business travel by an officer or employee who
was reimbursed for mileage expenses.
3. Lack of Salary Authorization
Local 492 did not maintain records to verify that the salaries reported in Item 24 (All
Officer and Disbursements to Officers) of the LM-3 was the authorized amount and
therefore was correctly reported. The union must keep a record, such as meeting minutes,
to show the current salary authorized by the entity or individual in the union with the
authority to establish salaries.
Based on your assurance that Local 492 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violations.
The audit disclosed the following other violation:
The audit revealed a violation of LMRDA Section 502 (Bonding), which requires that
union officers and employees be bonded for no less than 10 percent of the total funds those
individuals or their predecessors handled during the preceding fiscal year.
Local 492’s officers and employees are currently bonded for $20,000, but they must be
bonded for at least $25,151.91. Local 492 should obtain adequate bonding coverage for its
officers and employees immediately. Please provide proof of bonding coverage to this
office as soon as possible, but not later than August 5, 2011.
I want to extend my personal appreciation to Stage & Picture Operators Local 492 for the
cooperation and courtesy extended during this compliance audit. I strongly recommend that you
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July 15, 2011
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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.