U.S. Department of Labor

Employment Standards Administration
Office of Labor-Management Standards
Cincinnati District Office
36 East Seventh Street
Room 2550
Cincinnati, OH 45202
(513) 684-6840 Fax:(513) 684-6845

March 18, 2009


Mr. Charlie Ballard, Financial Secretary
Carpenters Local 64
4017 Dixie Highway
Louisville, KY 40216

LM File Number 013-460
Case Number: ||||||||||

Dear Mr. Ballard:

This office has recently completed an audit of Carpenters Local 64 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 Investigator Abbey Kepf discussed during the exit interview with Larry Hujo, Joe Schneiders, Cletus Gibson, and Julie Bensing on November 20, 2008the 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 the following:

Reporting Violations

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-2 filed by Local 64 for fiscal year ending June 30, 2008, was deficient in the following area:

1. Disbursements to Officers

Local 64 did not include payments made to you for replenishment of the local’s petty cash fund in Schedule 11 (All Officers and Disbursements to Officers). The union must report in Column F of Schedule 11 (Disbursements for Official Business) direct disbursements made to officers that are necessary for conducting the official business of the labor organization.

2. Failure to File Bylaws

The audit disclosed a violation of LMRDA Section 201(a), which requires that a union submit a copy of its revised constitution and bylaws with its LM report when it makes changes to its constitution or bylaws. Local 64 amended its constitution and bylaws in 2007, but did not file a copy with its LM report for that year.

Local 64 has now filed a copy of its constitution and bylaws.

I am not requiring that Local 64 file an amended LM report for 2008 to correct the deficient items, but Local 64 has agreed to properly report the deficient items on all future reports it files with OLMS.

I want to extend my personal appreciation to Carpenters Local 64 for the cooperation and courtesy extended to Investigator Abbey Kepf 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.



Lesta A. Chandler
District Director

cc: Cletus Gibson