U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Boston District Office
Room E-365
JFK Federal Building
Boston, MA 02203
(617) 624-6690 Fax: (617) 624-6606

June 19, 2006

Mr. Thomas Hiltz, Administrative Officer
Local 31032
645 Morrissey Boulevard
Boston, MA 02122-3563

    Re: Case No.

Dear Mr. Hiltz:

This office has recently completed an audit of TNG-CWA Local 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 President Brian Whelan and Thomas Hiltz on April 19, 2006, 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.

The CAP disclosed that union officers and employees failed to retain adequate documentation for reimbursed expenses, for expenses charged to union credit cards, and for lodging expenses which were direct-paid by the union. The date, amount, and business purpose of every expense must be recorded on at least one union record. With respect to documentation retained in support of specific disbursements (including those in payment of credit card charges), the record retention requirement includes not only the retention of original bills, invoices, receipts, and vouchers, but also additional documentation, if necessary, showing the nature of the union business requiring the disbursement, the goods or services received, and all the recipients of the goods or services. In most instances, this documentation requirement can be most easily satisfied with a sufficiently descriptive receipt. If a receipt is not sufficiently descriptive, a note can be written on it providing the additional information. 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.

As agreed, provided that Local 31032 maintains adequate documentation for its disbursements in the future, no additional enforcement action will be taken regarding this violation.

In addition, the CAP also disclosed that President Brian Whelan and former president         each received lost wages and per diem for one extra day, for attending the August, 2004 CWA Convention in Anaheim, CA. The local also covered one extra night's hotel charges for President Whelan. Both individuals have since reimbursed the local in full, for the amounts of $429.50 and $251.45 respectively. No further action will be taken regarding this violation.

I want to extend my personal appreciation to TNG-CWA Local 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.



Last Updated: 07/21/06