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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
Los Angeles District Office
915 Wilshire Boulevard, Suite 910
Los Angeles, CA 90017
(213) 534-6405 Fax: (213) 534-6413
May 17, 2011

Mr. Kenneth Williams, President
Communications Workers of America (CWA) Local 9510
140 South Flower St.
Orange, CA 92868

Case Number:
LM Number: 043580

Dear Mr. Williams:

This office has completed an audit of Communications Workers of America (CWA) Local 9510
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 Treasurer Patti Cunningham on October 19,
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 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.

The audit disclosed a violation of the LMRDA Section 206, by failing to maintain the following
records during the audit period:

1. General Disbursements
Local 9510 did not retain adequate documentation for disbursements when it
failed to maintain backup documentation (receipt) for a $370 disbursement
made in April 2009 for tickets to a sporting event.

As noted above, labor organizations must retain original receipts, bills, and vouchers for all
disbursements. The president and treasurer of your union, who are required to sign your union’s
LM report, are responsible for properly maintaining union records.

Mr. Kenneth Williams
May 17, 2011
Page 2 of 2

Based on your assurance that Local 9510 will retain adequate documentation in the future,
OLMS will take no further enforcement action at this time regarding the above violations.

I want to extend my personal appreciation to Communications Workers of America (CWA)
Local 9510 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: Ms. Patti Cunningham, Treasurer