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Office of Labor-Management Standards
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Office of Labor-Management Standards (OLMS)

U.S. Department of Labor
Office of Labor-Management Standards
Denver District Office
1999 Broadway, Suite 1150
Denver, CO 80202
(720) 264-3232 Fax: (720) 264-3230
January 11, 2011

Mr. Charles Bader, Secretary-Treasurer
Postal Workers, American, AFL-CIO (APWU)
Local 247
15 Iowa Ave.
Colorado Springs, CO 80935

Case Number:
LM Number: 506-084

Dear Mr. Bader:

This office has recently completed an audit of APWU Local 247 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, President Rob Preston, and the union's attorney
Richard Rosenblatt on December 16, 2010, 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.

Recordkeeping Violation

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.

Mr. Charles Bader
July 15, 2011
Page 2 of 3

The audit of Local 247s fiscal year ended March 31, 2010 records revealed the following
recordkeeping violation:

Credit Card Expenses

Local 247 did not retain adequate documentation for nine credit card transaction expenses
incurred by union officers totaling at least $1,757. For example, two credit card transactions on
September 23, 2009 to the Las Vegas Hilton and totaling $949.76 appeared on the credit card
statement but had no supporting documentation.

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.

Based on your assurance that Local 247 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violations.

Reporting Violations

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to
file annual financial reports accurately disclosing their financial condition and operations. The
Labor Organization Annual Report Form LM-3 filed by Local 247 for fiscal year ending
March 31, 2010, was deficient in the following areas:

1. Cash Reconciliation
It appears that the cash figures reported in Item 25 are not the cash figures according to the
union’s books after reconciliation to the bank statements. The instructions for Item 25 state that
the union should obtain account balances from its books as reconciled to the balances shown on
bank statements.

2. Receipts
It appears that the receipt figures reported in Items 38-44, are not the receipt figures according to
the union’s books, after consolidation with Local 247 Building Corporation and reconciliation to
the bank statements.

3. Disbursements
It appears that the disbursement figures reported in Items 45-55, are not the disbursement figures
according to the union’s books, after consolidation with Local 247 Building Corporation and
reconciliation to the bank statements.

Mr. Charles Bader
July 15, 2011
Page 3 of 3

Local 247 must file an amended Form LM-3 for fiscal year ending March 31, 2010, to correct
the deficient items discussed above. I will provide you with a blank form and instructions upon
request, and advised you that the reporting forms and instructions are available on the OLMS
website ( The amended Form LM-3 should be submitted to this office at the
above address as soon as possible, but not later than January 31, 2011. Before filing, review the
report thoroughly to be sure it is complete, accurate, and signed properly with original


Other Issues

Expense Policy

As I discussed during the exit interview with you, President Rob Preston, and the union's
attorney Richard Rosenblatt, the audit revealed that Local 247 does not have a clear policy
regarding the types of expenses personnel may claim for reimbursement and the types of
expenses that may be charged to union credit cards. OLMS recommends that unions adopt
written guidelines concerning such matters.

I want to extend my personal appreciation to APWU Local 247 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. Rob Preston, President