Form T-1 Trust Annual Report

The Office of Labor-Management Standards (OLMS) published a final rule rescinding the Form T–1 Trust Annual Report on December 30, 2021.  The rescission rule will be effective on January 31, 2022.  See: https://www.govinfo.gov/content/pkg/FR-2021-12-30/pdf/2021-28266.pdf.  See also Frequently Asked Questions regarding the rescission of the Form T-1.

The Form T-1 required annual reporting by Form LM-2 filing labor organizations on financial information pertinent to “trusts in which a labor organization is interested.” See: https://www.govinfo.gov/content/pkg/FR-2020-03-06/pdf/2020-03958.pdf; see also the correction notice published on March 30, 2020.  For further information, view the Form T-1 and Instructions, as well as the Form T-1 Compliance Tip.

On May 27, 2021, OLMS published a notice of proposed rulemaking (NPRM) to rescind the Form T-1.  See: https://www.govinfo.gov/content/pkg/FR-2021-05-27/pdf/2021-10975.pdf.  The NPRM had a 60-day comment period that closed on July 26, 2021.  OLMS also had announced, on March 29, 2021, that it would not seek to enforce the filing of a Form T-1 for one year from the date a labor organization’s first Form T-1 was due.  See the OLMS Form T-1 filing advisory.  

For Further Information: Contact OLMS via email at olms-public@dol.gov or via phone at (202) 693-0123 (this is not a toll-free number) and (800) 877-8339 (TTY/TDD).

Last Updated: 12-30-21