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Office of Labor-Management Standards (OLMS)

U.S. Department of Labor
Office of Labor-Management Standards
Los Angeles District Office
915 Wilshire Boulevard, Suite 910
Los Angeles, CA 90017
(213) 534-6405 Fax: (213) 534-6413
June 15, 2011

Mr. Laurence Hammett, Treasurer :
IATSE Local 150
PO BOX 1416
Adelanto, CA 92301

Case Number :

LM Number: 036331

Dear Mr. Hammett:

This office has recently completed an audit of IATSE Local 150 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 Business Manager Leonard Del Real, and President Lee Sanders on June 7, 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.

Record Keeping Violation

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 150’s 2010 records revealed the following recordkeeping violations:

General Reimbursed and Credit Card Expenses


Mr. Laurence Hammett
June 15, 2011
Page 2 of 2

Local 150 did not retain adequate documentation for reimbursed expenses incurred by the local
totaling at least $714.00. For example, receipts for supplies from Office Max were not retained
and there was no voucher describing the supplies that were purchased.

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 150 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violations.

Reporting Violation

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 150 for the fiscal year ended
December 31, 2010, was deficient in the following area:

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 150 amended its constitution and bylaws in 2002 and 2009, but did
not file a copy with its LM report for those years.

Local 150 has now filed a copy of its constitution and bylaws.

I want to extend my personal appreciation to IATSE Local 150 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