Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
San Francisco District Office
90 7th Street, Suite 18100
San Francisco, CA 94103-6701
(415) 625-2661 Fax: (415) 625-2662
July 25, 2011
Mr. Patrick Mulligan, Financial Secretary
Carpenters Local 22
2085 Third Street
San Francisco, CA 94107
LM Number: 518971
Dear Mr. Mulligan:
This office has recently completed an audit of Carpenters Local 22 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 Bookkeeper Mary Brust on July 20, 2011, the following problem was
disclosed during the CAP. The matter listed below is not an exhaustive list of all possible
problem areas since the audit conducted was limited in scope.
Record Keeping Violations
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 22’s 2010 records revealed the following recordkeeping violation:
Disposition of Property
Local 22 did not maintain an adequate inventory of hats, jackets, and other property it
purchased, sold, or gave away. The union must report the value of any union property on
hand at the beginning and end of each year in Item 28 of the LM-2. The union must retain
Mr. Patrick Mulligan
August 2, 2011
Page 2 of 2
an inventory or similar record of property on hand to verify, clarify, and explain the
information that must be reported in Item 28.
The union must record in at least one record the date and amount received from each sale
of union hats, jackets and other items.
Based on your assurance that Local 22 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violation.
I want to extend my personal appreciation to Carpenters Local 22 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. James Halloran, President