Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
San Francisco District Office
90 7th Street, Suite 2825
San Francisco, CA 94103
(415) 625-2661 Fax: (415) 625-2662
March 28, 2012
Joe Standley, Trustee/Administrator
Iron Workers Local 844
1660 San Pablo Ave., Ste. C
Pinole, CA 94564-2072
LM Number: 541668
Dear Mr. Standley:
This office has recently completed an audit of 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 and your bookkeeper Alma Alvarado on March 14, 2012, 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.
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-2) filed by Local 844 for the fiscal year ended June 30, 2010, was deficient in the following areas:
1. 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 844 amended its constitution and bylaws in 2008, but did not file a copy with its LM report for that year. Local 844 has now filed a copy of its constitution and bylaws.
2. Failure to Itemize Disbursement or Receipt
Local 844 did not properly report a “major” transaction in Schedule 18. A “major” transaction includes any individual transaction of $5,000 or more or total transactions to or from any single entity or individual that aggregate to $5,000 or more during the reporting period and which the local cannot properly report elsewhere in Statement B. The audit found that an individual transaction of $5,400 was reported with non-itemized transactions on the Itemization Page in Schedule 18.
I am not requiring that Local 844 file an amended LM report for 2010 to correct the deficient items, but Local 844 has agreed to properly report the deficient items on all future reports it files with OLMS.
I want to extend my personal appreciation to Iron Workers Local 844 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.