Office of Labor-Management Standards (OLMS)
U.S. Department of Liibor Employment Standards Administration
Office of Labor-Management Standards
St. Louis District Office
1222 Spruce Street
Room 9 109E
St. Louis, MO 63103
(31 4)539-2667 Fax: (31 4)539-2626
May 1, 2008
Mr. Steve Dowell, President
Iron Workers Local 577
2441 East County Road
La Harpe, IL 61450
LM File Number 028-315
Case Number: -
Dear Mr. Dowell:
This office has recently completed an audit of Iron Workers Local 577 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 Treasurer Douglas Crist on
April 25,2008, 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.
Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206 requires, among other things, that labor organizations maintain adequate records for at least five years by which each receipt and disbursement of funds, as well as all account balances, can be verified, explained, and clarified. As a general rule, labor organizations must maintain all records used or received in the course of union business.
For disbursements, this includes not only original bills, invoices, receipts, vouchers,
and applicable resolutions, but also documentation showing the nature of the union
business requiring the disbursement, the goods or services received, and the identity of the recipient(s) of the goods or services. In most instances, this documentation
requirement can be satisfied with a sufficiently descriptive expense receipt or invoice.
If an expense receipt is not sufficiently descriptive, a union officer or employee should write a note on it providing the additional information. For money it receives, the labor organization must keep at least one record showing the date, amount, purpose, and source of that money. The labor organization must also retain bank records for all accounts.
The audit of Local 577's 2007 records revealed the following recordkeeping violations:
1. Failure to h4ahtain Certificate of Deposit Statements
Iron Workers local 577 did not retain statements for all of the union's certificates
of deposit. Additionally, no other union record was retained stating the interest
earned or balance of the certificates of deposit. Thus, the local did not record in its receipts records interest earned on certificates of deposit totaling at least $700.
Union receipt records must include an adequate identification of all money the union receives. The records should show the date and amount received and the
source of the money.
2. Failure to Maintain Receipts
Iron Workers Local 577 did not maintain receipt records for all expenditures.
For example, a computer and printer cable were purchased from Staples on
February 10,2007 totaling $394.32. Labor organizations must retain original receipts, bills, and vouchers for all disbursements. The president and treasurer
of your union, who are required to sign your union's LM report, are responsible for properly maintaining union records.
Based on your assurance that Local 577 will retain adequate documentation in the future, OLMS will take no further enforcement action at this time regarding the above violations.
1. Signing Blank Checks
During the audit, you advised that Former President signed blank
checks. Your union's constitution requires that all checks be signed by the
president and treasurer. The two-signature requirement is an effective internal
control of union funds. Its purpose is to attest to the authenticity of a completed
document already signed. However, signing a blank check in advance does not
attesi to the authenticity of a completed check and negates the purpose of the
2. Business Manager Doug Crist Vacation Policy
During the audit, it was revealed that Treasurer/Business Manager
Doug Crist was paid an additional six paychecks in 2007. The
disbursement journal indicated these payments were for vacation.
Your by-laws state the business representative shall be entitled to
two weeks paid vacation for each elected year of his term of office.
The by-laws do not state that pay can be taken in lieu of time off, nor do they authorize vacation to be carried over from year to year. Additionally, the meeting minutes do not reflect membership approval for these disbursements. OLMS recommends that Local 577 establish a written review procedure relating to the vacation policy.
I want to extend my personal appreciation to Iron Workers Local 577 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: Douglas Crist, Treasurer