Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
Philadelphia District Office
The Curtis Center, Suite 760 W
170 S. Independence Mall West
Philadelphia, PA 19106
(215) 861-4818 Fax: (215) 861-4819
April 4, 2013
Mr. James Snyder, Secretary-Treasurer
Postal Workers American, AFL-CIO
Pennsylvania State Association
PO Box 4123
Scranton, PA 18505-6123
Case Number: 140-11123
LM Number: 092-907
Dear Mr. Snyder:
This office has recently completed an audit of American Postal Workers Union (APWU), Pennsylvania State Association 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 March 28, 2013, the following problem was 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 APWU Pennsylvania State Association’s 2011 records revealed the following recordkeeping violation:
Credit Card Expenses
APWU Pennsylvania State Association did not retain adequate documentation for credit card expenses incurred by Director of Legislation and Publicity Joseph Szocki totaling at least $2,253.13. For example, Mr. Szocki made two authorized union charges totaling $1,752.63 for travel expenses to a legislative conference held in Washington, DC in March 2011; however, supporting documentation for the charges were not maintained.
As 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 APWU Pennsylvania State Association 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 APWU Pennsylvania State Association 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. Francis Friel, President