Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Pittsburgh District Office
1000 Liberty Avenue
Pittsburgh, PA 15222
(412) 395-6925 Fax: (412) 395-5409
December 18, 2008
Mr. Ken Collinson, President
United Auto Workers AFL-CIO
608 Caperton Boulevard Ste. 1590
Martinsburg, WV 25403
LM File Number 067-364
Case Number: -
Dear Mr. Collinson:
This office has recently completed an audit of UAW Local 1590 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 and Financial Secretary James Doyle on December 12, 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 1590's 2007 records revealed the following recordkeeping violation:
General Reimbursed Expenses
Local 1590 did not retain adequate documentation for reimbursed expenses totaling at least $720.00. For example, the local reimbursed Domino's Pizza with check number for $528 and the receipt was not retained. Check number was written to Region 8 for $300 for a retiree conference and no documentation was attached to your voucher.
As previously noted above, labor organizations must retain original receipts, bills, and
vouchers for all disbursements. The president and treasurer (or corresponding
principal officers) of your union, who are required to sign your union's LM report, are responsible for properly maintaining union records.
I want to extend my personal appreciation to UAW Local 1590 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: James Doyle, Financial Secretary