Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Boston District Office
JFK Federal Building
Boston, MA 02203
(617)624-6690 Fax: (617)624-6606
April 14, 2008
Mr. Daniel Meagher, President
Harvard University Security, Parking, and Museum Guards Union
IBPO Local 558
2 Nashua Street
Shirley, MA 01464
LM File Number 540-609
Dear Mr. Meagher:
This office has recently completed an audit of the Harvard University Security Parking and Museum Guards Union (HUSPMGU) 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 you, Mr. Matt McDonough, vice president, and Mr. William Duarte, treasurer, on April 11,2008, no violations of the LMRDA were disclosed in areas of financial activity included in the CAP. This does not exhaust all possible problem areas, however, since the audit conducted was limited in scope and did not include all areas of your union's operation.
1. Executive Board Authorization of Disbursements
Practices and Procedures (d) of HUSPMGU's constitution and bylaws requires that the union's executive board authorize the disbursement of union funds. It also stipulates that the union's membership may authorize the disbursement of funds at official meetings. During the audit, both you and Mr. Duarte explained that only the president and treasurer authorize disbursements. The authorization of disbursements by the executive board and/or the membership is an effective method of verifying the authenticity and purpose of union expenses. Minutes of all membership or executive board meetings must report any disbursement authorizations made at those meetings. OLMS recommends that HUSPMGU review these procedures to improve internal control of union funds.
2. LM-30 Reporting Requirements
Article 29 of HUSPMGU's collective bargaining agreement with Harvard University allows for union representatives to take "reasonable time" away from work to conduct union business. Union representatives will be compensated for time lost from work during regular working hours at the regular straight-time hourly rate. According to reporting requirements for the Form LM-30, income received from this arrangement for union leave/no-docking pay must be reported only if the union officer or employee receives more than 250 hours of union leave/no-docking payments per year. OLMS recommends that union officers keep track of hours lost from work to conduct union business for the fiscal year beginning 07/01/08 in order to determine their reporting requirements for the subsequent fiscal year.
I want to extend my personal appreciation to HUSPMGU 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: Mr. William Duarte, Treasurer
Mr. Matt McDonough, Vice President