U.S. Department of Labor

Employment Standards Administration
Office of Labor-Management Standards
Denver District Office
1999 Broadway, Suite 2435
Denver, CO 80202-5712
(720)264-3232 Fax: (720)264-3230


January 25, 2008

Jim Curran
Stage and Picture Operators
Local 30B
P.O. Box 21735
Denver, CO 80221

LM File Number: 040-560
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Dear Mr. Curran:

This office recently completed an audit of Stage and Picture Operators Local 30B under the Compliance Audit Program (CAP) to determine your organization’s compliance with the provisions of the Labor Management Reporting and Disclosure Act (LMRDA). As discussed during the exit interview with you on January 25, 2007, the following problem was discovered during the CAP. The matter listed below is not an exhaustive list of all possible problem areas since the audit conducted was limited in scope.

Record-keeping Violation

Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206 requires, among other things, that labor organizations maintain adequate records for at least five 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, labor organizations must maintain all records used or received in the course of union business.
For disbursements, this includes not only original bills, invoices, receipts, vouchers, and applicable resolutions, but also documentation 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 union officer or employee should write a note on it providing the additional information. For money it receives, the labor organization must keep at least one record showing the date, amount, purpose, and source of that money. The labor organization must also retain bank records for all accounts.

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to file annual financial reports accurately disclosing their financial condition and operations. The Labor Organization Annual Report Form Lm-3 filed by Local 30 B for fiscal year ending December 31, 2006, was deficient in that the union did not include professional charges in the appropriate category. The professional charges were included in the office and administration expenses category.

I am not requiring that Local 30B file an amended LM report for 2006 to correct the deficient item, but Local 30B has agreed to properly report the deficient items on all future reports it files with OLMS.

I want to extend my personal appreciation to Stage and Picture Operators Local 30B for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you pass on this letter and the compliance assistance materials provided to future officers. If we can provide any additional assistance, please do not hesitate to call.


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