Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Seattle District Office
1111 Third Avenue
Seattle, WA 98101-3212
(206)398-8099 Fax: (206)398-8090
April 12, 2007
Mr. Douglass Scott, Treasurer
5306 W. Dradie Street
Pasco, Washington 99301
Re: Case Number
LM File Number: 002-081
Dear Mr. Scott:
This office has recently completed an audit of Maintenance of Way Employees Local Lodge 159 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 April 5, 2007, 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 Violations
Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206 requires, among other thin s, that adequate records be maintained for at least 5 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, all records used or received in the course of union business must be retained. This includes, in the case of disbursements, not only the retention of original bills, invoices, receipts, and vouchers, but also adequate additional documentation, if necessary, 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 note can be written on it providing the additional those cases where 1) other equally des 2) there is evidence of actual oversight. In the case of receipts, the date, amount the union must be recorded in at least retained for all accounts.
An exception may be made only in those cases where 1)other equally descriptive documentation has been maintained, and 2) there is evidence of actual oversight and control over disbursements.
In the case of receipts, the date, amount, purpose, and source of all money received by the union record. Bank records must also be retained for all accounts.
The audit of LG 159's 2006 records revealed the following recordkeeping violations:
Inventory of Fixed Assets
LG 159 failed to maintain an inventor typewritten, fax and digital recorder. Records must be maintained that account for all union property.
LG 159 failed to keep a bank deposit slip for the amount of $125.00. Union receipts records must include an adequate identification of each receipt of money. The records should show the exact date the money was received, the identity of the source of the money, and the individual amount received from each source.
As agreed, provided that LG 159 maintain the future, no additional enforcement action will be taken regarding these violations.
I want to extend my personal appreciation extended during this compliance audit letter and the compliance assistance materials provided to you are passed onto future officers. If we can provide any additional assistance, please do not hesitate to call.
cc: President Darrell Niles