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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
Boston District Office
JFK Federal Building, Suite E-365
Boston, MA 02203
(617) 624-6690 Fax: (617) 624-6606




August 12, 2013

Mr. Brian.Whelan, President
Communications Workers AFL-CIO LU 31032
47 Willard Street
Quincy, MA 02169
Case Number: 110-17642 LM Number: 021921

Dear Mr. Whelan:

This office has recently completed an audit of Communications Workers AFL-CIO LU 31032 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 August 12, 2013, 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 ofLocal31032's 2012 records revealed the following recordkeeping violations:

1. Lack of Salary Authorization

Local 31032 did not maintain records to verify that the salaries reported on Item 56, a reference to Item Number 17 ofthe LM-3 was the authorized amount and therefore was correctly reported. The union must keep a record, such as meeting minutes, to show the current salary authorized by the entity or individual in the union with the authority to establish salaries.

Mr. Brian Whelan
August 12, 2013
Page 2 of2




Based on your assurance that Local 31032 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 fmancial condition and operations. The Labor Organization Annual Report (Form LM-3) filed by Local 31032 for the fiscal year ended September 30, 2012, was deficient in the following areas:

1. Disbursements to Officers

The union must report most direct disbursements to Local 31032 officers and employees and some indirect disbursements in Items 45-54. Items 45, 46, 50, and 54 are left blank, though based on the audit investigation, some or all of these items should be filled in.

2. Cash Reconciliation

It appears that the cash figures reported in Item 25 (Cash) are not the figures according to Local
31032'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 shown on bank statements.

Local31032 must file an amended Form LM-3 for the fiscal year ended September 30, 2012, to correct the deficient items discussed above. I encourage Local 31032 to complete, sign, and mail the amended LM-3 to the Boston District Office. Reporting forms and instructions can be downloaded from the OLMS website, www.olms.dol.gov. The amended Form LM-3 should be submitted to this office at the above address no later than August, 28, 2013. Before mailing, review the report thoroughly to be sure it is complete and accurate. Paper reports must be signed with original signatures.

I want to extend my personal appreciation to Communications Workers AFL-CIO LU 31032 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.



cc: Mr. William Brotherton, Secretary/ Treasurer
Mrs. Dawn Bauman, Executive Office Manager