U.S. Department of Labor

Employment Standards Administration
Office of Labor-Management Standards
Denver District Office
Suite 2435
1999 Broadway
Denver, CO 802025712
(720) 264-3232 Fax:(720) 264-3230


December 16, 2009

Mr. Matt Groskie, President
Ironworkers, Rocky Mountain Council
7338 S. Alton Way, Ste. A
Englewood, CO 80155-4347

LM File Number: 042-198
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Dear Mr. Groskie:

This office has recently completed an audit of Ironworkers, Rocky Mountain Council 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 you on November 30, 2009, 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.

Recordkeeping Violations

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 of Ironworkers Rocky Mountain District Council 2009 records revealed the following recordkeeping violations:

Failure to Maintain Records

Ironworkers Rocky Mountain District Council did not retain adequate documentation for credit card expenses totaling at least $131. For example, the union did not have a receipt for a purchase of $113.74 at Costco. The union also did not have a receipt for a purchase of $17.50 at the U.S. Postal Service.

As previously noted above, labor organizations must retain original receipts, bills, and vouchers for all disbursements. The president and treasurer (or corresponding principal officers) of your union, who are required to sign your union’s LM report, are responsible for properly maintaining union records.

I want to extend my personal appreciation to Ironworkers, Rocky Mountain Council 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.



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