Office of Labor-Management Standards (OLMS)
February 9, 2007
Form LM-2 Deficiencies Alert
This alert is issued by the U.S. Department of Labor's Office of Labor-Management Standards (OLMS) and concerns certain deficiencies that have appeared on Form LM-2 reports filed with OLMS. The Form LM-2 is the annual financial report required to be filed by labor organizations with $250,000 or more in total annual receipts and those in trusteeship. In many instances these deficiencies are serious enough that filers will be required to file amended reports.
In multiple cases, filers are not completing the itemization pages correctly or in the detail required by the instructions to the Form LM-2. An itemization page must be completed for Schedules 14 through 19 for each payer or payee that received or disbursed $5,000, individually or in the aggregate. The itemization page must include in Column (A) the full name and business address of the payer or payee and in Column (B) the type of business or job classification of the payer or payee. Filers are erroneously entering in Column (B) information on the "type or classification" of the payment, instead of the payer or payee. The information in Column (B) cannot, for example, merely repeat the name of the schedule such as "overhead" or "administration," but must describe the payer or payee, such as printing company, lobbyist, marketing firm, legal counsel, etc.
Likewise, Column (C) must include the purpose of each receipt or disbursement of $5,000 or more. Column (C) requires a brief statement or description of the reason the receipt or disbursement was made. Common errors include filers merely repeating the name of the schedule such as "overhead" or "administration," referring to an invoice number, or making a general reference such as "consulting services." The instructions to Form LM-2 include examples of adequate descriptions such as contract negotiations, preparing organizing campaign pamphlets, staffing a help desk, opposition research, litigation regarding a refusal to bargain charge, grievance arbitration, get-out-the vote, voter education, advocating or opposing legislation, job retraining, printing of election ballots, etc.
Another error that has been noted on a few reporting forms is the inclusion of Social Security numbers. Forms LM-2, LM-3, and LM-4 are public information and should not include Social Security numbers. Filers should review their report closely before submitting it to ensure that no such numbers have been inadvertently pulled from electronic records during the process of completing the form.
If a Form LM-2 filer has questions about the proper completion of the form, they may call 202-693-0124 or send an email to firstname.lastname@example.org
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Last Updated: 02/09/07