Craig Rosenbaum, Executive Director LM File No. 033-692
Communications Workers of America
Local 34071
Chicago Newspaper Guild
17 North State Street, Suite 1700
Chicago, IL 60602

Dear Mr. Rosenbaum:

This is in response to your continuing hardship exemption request, dated November 16, 2013, for Communications Workers of America, Local 34071, LM File Number 033-692, for the fiscal year ending September 30, 2013. A continuing hardship exemption request requires the requesting union to demonstrate that it cannot file Form LM-2 electronically without undue burden or expense.

You based your request upon the following information stated in your letter:

Your Office Manager, recently suffered a stroke. As he is the only person who has the knowledge to file the labor organization’s Form LM-2, you are requesting an exemption from electronic filing so that you may adequately prepare to file your Form LM-2 electronically by March 31, 2014.

OLMS recognizes the hardship and, although the legal requirements for a temporary hardship are not met because the difficulty in filing does not arise from technical computer or network causes, OLMS will take no enforcement action until March 31, 2014, 90 days from the date your report is due. The OLMS Chicago District Office will be contacting you to offer assistance.

OLMS therefore denies your continuing hardship exemption request for filing Form LM-2 electronically for the fiscal year ending November 16, 2013, based on the information that you have provided.

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




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