Number 01-19


May 30, 2019

Notice of Proposed Rulemaking: Form T-1 Trust Annual Report

The Office of Labor-Management Standards (OLMS) today published a Notice of Proposed Rulemaking (NPRM) to establish a Form T–1 to require annual reporting on financial information pertinent to “trusts in which a labor organization is interested” (“section 3(l) trusts”). See:, this information has largely gone unreported despite the significant impact such trusts have on a labor organization’s financial operations and their members’ interests. This proposal is part of the Department’s continuing effort to better effectuate the reporting requirements of the Labor-Management Reporting and Disclosure Act (LMRDA).

The Department proposes to require a labor organization with total annual receipts of $250,000 or more to file a Form T–1, under certain circumstances, for each section 3(l) trust, as defined by 29 U.S.C. § 402(l) of the LMRDA. Under this proposed rule, the Form T-1 reporting requirements are triggered where the labor organization during the reporting period, either alone or in combination with other labor organizations, (1) selects or appoints the majority of the members of the trust’s governing board, or (2) contributes more than 50 percent of the trust’s receipts. 

Through transparency, the LMRDA’s various reporting provisions are designed to empower labor organization members by providing them the means to maintain democratic control over their labor organizations and ensure a proper accounting of labor organization funds. Labor organization members are better able to monitor their labor organization’s financial affairs and to make informed choices about the leadership of their labor organization and its direction when labor organizations disclose financial information as required by the LMRDA. By reviewing a labor organization’s financial reports, a member may ascertain the labor organization’s priorities and whether they are in accord with the member’s own priorities and those of fellow members. At the same time, this transparency promotes the labor organization’s own interests as a democratic institution and the interests of the public and the government. Furthermore, the LMRDA’s reporting and disclosure provisions operate to safeguard a labor organization’s funds from depletion by improper or illegal means. Timely and complete reporting helps to deter embezzlement or other improper use of such funds.

To Submit Comments: OLMS must receive comments by July 29, 2019, identified by RIN 1245-AA09, and submitted by the following method: Internet—Federal eRulemaking Portal. Electronic comments must be submitted through To locate the proposed rule, use key words such as “Labor-Management Standards” or “Labor Organization Annual Financial Reports for Trusts” to search documents accepting comments. Follow the instructions for submitting comments. Please be advised that comments received will be posted without change to, including any personal information provided.

Submit comments under the Paperwork Reduction Act by mail to the Office of Information and Regulatory Affairs, Attn: OMB Desk Officer for DOL-OLMS, Office of Management and Budget, Room 10235, 725 17th Street, N.W., Washington, DC 20503; by Fax: 202-395-5806 (this is not a toll-free number); or by email: Commenters are encouraged, but not required, to send a courtesy copy of any such comments to OLMS.

For Further Information Contact: Andrew R. Davis, Chief of the Division of Interpretations and Standards, Office of Labor-Management Standards, U.S. Department of Labor, 200 Constitution Avenue N.W., Room N-5609, Washington, DC 20210,, (202) 693-0123 (this is not a toll-free number), (800) 877-8339 (TTY/TDD).



Last Updated: 05-30-19