U.S. Department of Labor

Employment Standards Administration
Office of Labor-Management Standards
Seattle District Office
1111 Third Avenue
Room 605
Seattle, WA 98101-3212
(206)398-8099 Fax: (206)398-8090

March 20, 2009

Mr. Nathan Cooley, Secretary-Treasurer
Longshore & Warehouse Union AFL-CIO
Local 21
617 - 14th Avenue
Longview, WA 98632

LM File Number 036-769
Case Number: 540 08426(77)

Dear Mr. Cooley:

This office has recently completed an audit of ILWU LU 21 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 March 13, 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.

Reporting Violation

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 21 for fiscal year ending December 31, 2007, was deficient in that the local failed
to file its most recent bylaws.

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 21 amended its constitution and bylaws in
2005, but did not file a copy with its LM report for that year. Local 21 has now
provided an updated a copy of its constitution and bylaws to OLMS.

Other Violation

The audit disclosed the following other violation:

Inadequate Bonding

The audit revealed a violation of LMRDA Section 502 (Bonding), which requires that
union officers and employees be bonded for no less than 10 percent of the total funds
those individuals or their predecessors handled during the preceding fiscal year.

Local 21’s officers and employees are currently bonded for $50,000, but they must be
bonded for at least $63,846. Local 21 should obtain adequate bonding coverage for its
officers and employees immediately. Please provide proof of bonding coverage to this
office as soon as possible, but not later than April 17, 2009.

I want to extend my personal appreciation to ILWU LU 21 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.

Sincerely,

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Investigator

cc: Dan Coffman, President