U.S. Department of Labor

July 17, 2013

Office of Labor-Management Standards Buffalo District Office
130 South Elmwood Street, Suite 510
Buffalo, NY 14202-2465
(716) 842-2900 Fax: (716) 842-2901

Mr. James M. Wagner, President Communications Workers, AFL-CIO Local 1122
3775 Genesee Street
Buffalo, NY 14225
Case Number: 120-09278 LM Number: 055902

Dear Mr. Wagner:

This office has recently completed an audit of Communications Workers, AFL-CIO 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 Secretary/Treasurer Tom Revekant and Bookkeeper Melissa Brummer on June 18, 2013, 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 1122 for the fiscal year ended September 30, 2012, was deficient in that:

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 1122 amended its constitution and bylaws in June 2010, but did not file a copy with its LM report for that year.

Local 1122 has now filed a copy of its constitution and bylaws.

Other Issue

Inventory of Fixed Assets

As discussed during the course of the compliance audit and during the exit interview, it is recommended that the union establish and maintain an accurate inventory list of its assets. Specifically, union apparel which is purchased by the local then sold to its members. An inventory list will help you identify, account for, and determine the total value of what's on hand.

I want to extend my personal appreciation to Communications Workers, Local 1122 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.



cc: Mr. Thomas Revekant, Secretary/Treasurer Mr. John Mudie, Executive Vice President Ms. Melissa L. Brummer, Bookkeeper