Number: 1-10

February 2, 2010

Notice of Proposed Rulemaking to Rescind the Form T-1 Regulation; Return Subsidiary Organization Reporting to the Form LM-2; and Revise Interpretation Regarding LMRDA Coverage of Intermediate Labor Organizations


The Office of Labor-Management Standards (OLMS) today published in the Federal Register a Notice of Proposed Rulemaking to rescind the Form T-1 regulation. See: http://edocket.access.gpo.gov/2010/pdf/2010-1912.pdf.

As part of its proposal to rescind the Form T-1, OLMS proposes to return to the Form LM-2 Labor Organization Annual Report, the reporting of entities that are wholly owned, controlled, and financed by a single union (i.e. “subsidiary organizations”). Additionally, in interpreting the definition of “labor organization” under the Labor-Management Reporting and Disclosure Act (LMRDA), OLMS in its notice proposes to return to its long held view that the statute’s coverage does not encompass intermediate bodies that are wholly composed of public sector labor organizations. In so doing, OLMS has reconsidered a definitional interpretation that it adopted in 2003, and now considers that its pre-2003 policy constitutes a better effectuation of the purposes of the statute.

Comments on the Department’s notice to rescind the Form T-1, return subsidiary organization reporting to the Form LM-2, and revise its interpretation regarding LMRDA coverage of intermediate labor organizations, must be received on or before April 5, 2010.

For additional information, including methods to submit comments, please visit the OLMS Web site at: http://www.dol.gov/olms/regs/compliance/t1_intro.htm.

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Last Updated: 05-20-10