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 80202-5712
(720) 264-3232 Fax: (720) 264-3230
July 14, 2011
Mr. William Hutchison, Secretary Treasurer Case Number:
Steelworkers, Local 12-00477 LM Number: 022427
5800 West 73rd Avenue
Arvada, CO 80003
Dear Mr. Hutchison:
This office has recently completed an audit of Steelworkers, Local 477 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 on June 29, 2011, 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 12-00477s 2010 records revealed the following recordkeeping violation:
Mr. William Hutchison
July 15, 2011
Page 2 of 2
Receipt Dates not Recorded
Entries in Local 12-00477’s receipts journal reflect the date the union deposited money, but not
the date money was received. Union receipts records must show the date of receipt. The date of
receipt is required to verify, explain, or clarify amounts required to be reported in Statement B
(Receipts and Disbursements) of the LM-3. The LM-3 instructions for Statement B state that
the labor organization must record receipts when it actually receives money and disbursements
when it actually pays out money. Failure to record the date money was received could result in
the union reporting some receipts for a different year than when it actually received them.
Based on your assurance that Local 12-00477 will retain adequate documentation in the future,
OLMS will take no further enforcement action at this time regarding the above violation.
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) has not been filed by Local 12-00477 for the
fiscal year ended December 31, 2010.
Local 12-00477 must file the delinquent Form LM-3 for the fiscal year ended December 31,
2010 as soon as possible. I provided you with a blank form and instructions, and advised you
that the reporting forms and instructions are available on the OLMS website
Before filing, review the report thoroughly to be sure it is complete, not later than July 25, 2011.
The Form LM-3 should be submitted to this office at the above address
accurate, and signed properly with original signatures.
I want to extend my personal appreciation to Steelworkers, Local12-00477 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. Dean Alexander, President