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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
Seattle District Office
1111 Third Avenue, Suite 605
Seattle, WA 98101
(206) 398-8099 Fax: (206) 398-8090
March 25, 2011

Chris Romischer, Secretary-Treasurer
ILWU - Puget Sound District Council
7000 – 15th Avenue NW
Seattle, WA 98117

Case Number:

LM Number: 047450

Dear Chris Romischer:

This office has recently completed an audit of ILWU - Puget Sound District Council 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 March 22, 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.

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 ILWU Puget Sound District Council’s 2010 records revealed the following
recordkeeping violations:

1. General Expenses
The District Council did not retain adequate documentation for general expenses incurred by

the District Council totaling at least $803.60. For example, 5 out of 17 disbursements were


Chris Romischer
July 6, 2011
Page 2 of 2

not supported with a union record. These payments were for meeting expenses, donations,
and reimbursements to members.

As previously 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. Receipt Dates not Recorded
Entries in the District Council’s excel spreadsheet do not reflect the date the union deposited
money, or the date money was received. Union receipt records must show the date of
receipt. The date of receipt is required to verify, explain, or clarify amounts required to be
reported in Statement B (Receipts and Disbursements) of the LM-3. The LM-3 instructions
for Statement B state that the labor organization must record receipts when it actually
receives money and disbursements when it actually pays out money. Failure to record the
date money was received could result in the union reporting some receipts for a different year
than when it actually received them

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

Reporting Violation

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. The ILWU Puget Sound District Council amended its
bylaws, but did not file a copy with its LM report. The ILWU Puget Sound District Council

I want to extend my personal appreciation to ILWU - Puget Sound District Council 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

has now filed a copy of its constitution and bylaws.