November 16, 2009

LM File No. 516-974


Larry Landon, Executive Director
Professional Hockey Players’ Association
One St. Paul Street, Suite 701
St. Catharines, Ontario L2R 7L2

Dear Mr. Landon:

This is in response to your continuing hardship exemption request for the Professional Hockey Players’ Association, LM File Number 516-974, for the fiscal year ending April 30, 2009.  Your request dated October 19, 2009 was received by the Office of Labor-Management Standards (OLMS) on October 26, 2009.  A continuing hardship exemption request requires the requesting union to demonstrate that it cannot file Form LM-2 electronically without undue burden or expense.

In your letter, you stated that you purchased the electronic signatures and made attempts to comply with the requirement to file your Form LM-2 electronically.  However, you asserted that because of software incompatibility you are unable to download the electronic signature and validate the form.

OLMS grants your continuing hardship exemption request for filing Form LM-2 electronically for the fiscal year ending April 30, 2009, based on the information provided, as you stated that you have spoken with individuals at both IdenTrust and the U.S. Department of Labor about your continuing difficulties downloading the electronic signature and validating the form, but you did not receive resolution of the problems.  I also note that you filed a paper copy of your Form LM-2 with OLMS on July 21, 2009.

If you have any further questions about filing Form LM-2 pursuant to the hardship exemption, please call 202-693-0123 and reference your organization’s LM file number.



Andrew R. Davis, Chief
Division of Interpretations
  and Standards

cc: Larry King, Chief, Division of Reports, Disclosure & Audits