Additions are made to this frequently asked questions section on a regular basis. If you have a question that is not addressed here, you may e-mail it to OLMS-Public@dol.gov.
How is a union selected for a compliance audit?
OLMS considers a variety of factors when selecting a national or international union for an audit, including the size of the international union, its geographic location, the length of time since the last audit, and the availability of OLMS personnel resources. OLMS may also conduct an audit based on a complaint from a member(s) or when it appears necessary to determine whether any person has violated or is about to violate provisions of the Labor-Management Reporting and Disclosure Act (LMRDA) or the Civil Service Reform Act (CSRA).
What can a national or international union expect once it has been selected for a compliance audit?
The OLMS audit team notifies an international union official by mail when an international union has been selected for I-CAP. OLMS staff then contacts international union officials by telephone to discuss the I-CAP objectives, scope of the audit, obtain certain general information about the international union, answer any questions, and make arrangements for the audit. A letter confirming these details is sent to the international union along with a profile of I-CAP program and three I-CAP Questionnaires, which are to be completed by the union to help expedite the audit.
How long does a compliance audit take?
No absolute time frames can be placed on the duration of the compliance audit since much depends on the size of the union, the availability and condition of its records, the extent of cooperation by union officials, and the type of compliance problems found. OLMS is committed to conducting the I-CAP in a professional, efficient manner resulting in the least possible disruption to normal union operations.
What is the difference between an I-CAP and a CAP?
The Compliance Audit Program (CAP) and International Compliance Audit Program (I-CAP) are companion audit programs developed by OLMS to assess compliance with all aspects of the LMRDA and CSRA using specialized records review and investigative techniques. I-CAP is designed to audit the complex operating environment of national and international unions. CAPs are streamlined compliance audits for local unions and intermediate bodies.
Where and how is a compliance audit conducted?
OLMS will meet with union officials to conduct an opening interview. The purpose of this interview is to discuss I-CAP objectives and procedures and make necessary arrangements for the on-site audit. The compliance audit will usually cover the union’s most recently completed fiscal year, although the audit may be expanded to other periods as appropriate. The audit covers financial procedures of the international union, as well as compliance by the international union and its subordinate bodies.
Are employees required to be available to the audit team during the audit?
The availability of key personnel may affect the ability of the audit team to conduct the audit efficiently. The team will make every effort to conduct the audit in an unobtrusive manner and to minimize disruption to union operations. However, the team will require access to certain key employees on a regular basis. These might include union officers, the comptroller, accountants, information technology specialists, and bookkeepers.
The team will work with union personnel to avoid conflicts with their other duties. However, reasonable cooperation is expected from union officials and employees to ensure that the audit proceeds smoothly and without undue disruption.
Why can't OLMS accept the report of an IU's independent auditor?
OLMS recognizes the important role that independent auditors play in ensuring union compliance with financial accounting standards and norms. To a degree, the compliance audit team will rely on the union's auditors for opinions on various matters under consideration. However, the role of the compliance audit team is different from that of a typical auditor. External auditors concern themselves with the financial and business aspects of a union's operations, whereas the role of the OLMS audit team is assessing financial and business aspects of a union's operation as well as assessing compliance with all aspects of the LMRDA or CSRA. Because our role is much broader, our audits are typically more detailed and more thorough than a standard financial audit.
What records must the international union provide during a compliance audit?
The LMRDA and CSRA require labor organizations to maintain records necessary to verify the information contained in the union's financial disclosure reports for up to five years. The OLMS audit team may request any of these records in order to establish a clear picture of the union's finances and operational structure and to assess compliance with the requirements of the law. A record request list will be provided to the union at the onset of the audit.
When a compliance audit is complete, will OLMS share the audit results with the union?
When the audit is complete, the audit team will conduct an exit interview with key officials of the union to review the results of the audit and provide compliance assistance to correct any LMRDA or CSRA violations found and minimize the potential for future ones. Following the exit interview, OLMS will provide union officials with a closing letter that details the audit findings and recommendations. This closing letter will be posted on the OLMS website for easy access by union members.
Can a union review the findings and defend its position before OLMS publishes the closing letter?
It is expected that the union will provide all information to the audit team during the audit to ensure that the findings are accurate and complete. During the exit interview, the audit team explains the findings and recommendations. Union officials and key employees have an opportunity to express their positions and concerns at that time. If the union presents additional information that was not available during the audit itself, the I-CAP team may review the information and revise the findings, if warranted.
Are there follow-up activities by OLMS?
Approximately six months after the I-CAP closing letter is issued, OLMS contacts the international union officials to schedule a follow-up visit at union headquarters to ensure that any identified problems have been corrected and promises of future compliance have been kept. Additional compliance assistance and guidance will also be offered, as appropriate.
How do I obtain an I-CAP closing letter that was completed prior to the dates listed on your website?
A request must be made pursuant to the Freedom of Information Act (FOIA) in order to obtain copies of any closing letters dated prior to the timeframes listed on our website. See: https://www.dol.gov/olms/foia/request.htm.
Last Updated: 02-06-20