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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
New York District Office
201 Varick Street
Room 878
New York, NY 10014
(646)264-3190 Fax: (646)264-3191

March 22, 2011

Mr. Johnnie Miranti, Recording Secretary-Treasurer
Novelty & Production Workers
Local 223
147 East 26th Street
New York, NY 10010

Re: Case Number:

Dear Mr. Miranti:

This office has recently completed an audit of Novelty & Production Workers Local 223
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 Johnnie Miranti and
Rocco Miranti on March 16, 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.

Recordkeeping Violations

Title II of the LMRDA establishes certain reporting and recordkeeping requirements.
Section 206 requires, among other things, that adequate records be maintained for at
least 5 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, all records used or
received in the course of union business must be retained. This includes, in the case of
disbursements, not only the retention of original bills, invoices, receipts, and vouchers,
but also adequate additional documentation, if necessary, 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 note can be
written on it providing the additional information. An exception may be made only in

Mr. Johnnie Miranti
March 22, 2011
Page 2 of 2

those cases where 1) other equally descriptive documentation has been maintained, and
2) there is evidence of actual oversight and control over disbursements.

In the case of receipts, the date, amount, purpose, and source of all money received by
the union must be recorded in at least one union record. Bank records must also be
retained for all accounts.

The audit of Local 223’s 2011 records revealed the following recordkeeping violations:

The union failed to maintain mileage logs that must be generated when using the union
owned and leased vehicles.

Conclusion/Recordkeeping Violation (s)

As agreed, provided that Local 223 maintains adequate documentation as discussed
above in the future, no additional enforcement action will be taken regarding this

The proper maintenance of records is the personal responsibility of the individuals who
are required to file Local 223’s LM report.
I want to extend my personal appreciation to Novelty & Production Workers Local 223
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.