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Office of Labor-Management Standards
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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 29, 2011

Mr. John Taylor, Treasurer
Letter Carriers, NATL, ASN, AFL-CIO Local 462
Post Office Box 12762
Huntsville, AL 35815

Case Number:
LM Number: 080062

Dear Mr. Taylor:

This office has recently completed an audit of Letter Carriers Local 462 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 President John Winston and you on July 25, 2010, 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 462’s 2010 records revealed the following recordkeeping violations:

1. Failure to Record Fund Transfer
Local 462 did not record in its disbursement records two fund transfers totaling at least

$6,000. For example, Local 432 transferred $3,000 from union account to another union

account. Union receipts and disbursements records must include an adequate identification


Mr. John Taylor
August 2, 2011
Page 2 of 2

of all money the union receives and disburses. The records should show the date and
amount received or disbursed, and the source of the money.

2. General Expenses
Local 462 did not retain adequate documentation for expenses totaling at least $800. For
example, the local purchased several Kroger gift cards for its retiree members and did not
retain the receipt.

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.

Based on your assurance that Local 462 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violations.

Other Issues

Use of One Signature

During the audit, President John Winston advised that it is Local 462’s practice for one officer to
sign all union checks. Two signatures is an effective internal control of union funds. Its purpose
is to attest to the authenticity of a completed document already signed. OLMS recommends that
Local 462 review these procedures to improve internal control of union funds.

I want to extend my personal appreciation to Letter Carriers Local 462 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: Mr. John Winston, President