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Office of Labor-Management Standards
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Office of Labor-Management Standards (OLMS)

U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Boston District Office
Room E365
JFK Federal Building
Boston, MA 02203

(617) 624-6690 Fax:(617) 624-6606
February 16, 2011

Ms. Doreen Arguin, Secretary-Treasurer
Electrical Workers UE IND, Local 204

P.O. Box 87
Taunton, MA 02780

LM File Number: 017-272

Case Number:

Dear Ms. Arguin:

This office has recently completed an audit of Electrical Workers Local 204 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 exit interview with you on February 14, 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


Ms. Doreen Arguin

February 16, 2011
Page 2 of 4

source of that money. The labor organization must also retain bank records for all
accounts.

The audit of Electrical Workers Local 204’s 2009 records revealed the following
recordkeeping violations:

1. General Expenses
Local 204 did not retain adequate documentation for rent and flower expenses
incurred by the union totalling $3,300. For example, the local paid $275 a month to
rent office space but did not retain any bills/receipts to validate the payments.

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. Lost Wages
Local 204 did not retain adequate documentation for lost wage reimbursement
payments to union officers and employees in at least two instances totaling $634.72.
The union must maintain records in support of lost wage claims that identify each
date lost wages were incurred, the number of hours lost on each date, the
applicable rate of pay, and a description of the union business conducted. The
OLMS audit found that Local 204 retained lost wage vouchers but the vouchers did
not note the number of hours lost or the hourly rate.

3. Receipt Dates Not Recorded
Entries in Local 204’s financial secretary’s book reflect the date the union deposited
money, but not the date money was received. Union receipts records must show the
date of receipts. 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.


Ms. Doreen Arguin
February 16, 2011

Page 3 of 4

Based on your assurance that Local 204 will retain adequate documentation in the
future, OLMS will take no further enforcement action at this time regarding the above
violations.

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 LM-3 filed by Local
204 for fiscal year ending December 31, 2009, was deficient in the following areas:

1. Cash Reconciliation
It appears that the cash figures reported in Item 25 are not the cash figures
according to the union’s books after reconciliation to the bank statements. The
instructions for Item 25 state that the union should obtain account balances from its
books as reconciled to the balances on bank statements.

2. Cash Receipts
Local 204 erroneously reported $1,200 in rent receipts in Item 38 (Dues) instead of
Item 43 (Other Receipts). Local 204 reported $61 in Item 41 (Interest & Dividends)
but the audit revealed $573 in interest/dividends during the audit year.

I am not requiring that Local 204 file an amended report for 2009 to correct the deficient
items, but Local 204 has agreed to properly report the deficient items on all future
reports it files with OLMS.

I want to extend my personal appreciation to Electrical Workers Local 204 for the
cooperation and courtesy extended during this compliance audit. I strongly


Ms. Doreen Arguin
February 16, 2011
Page 4 of 4

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