Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
New York District Office
201 Varick Street, Suite 878
New York, NY 10014
(646) 264-3190 Fax: (646) 264-3191
June 9, 2014
Mr. Granville Ganter, Treasurer
St. John's University Professors
8000 Utopia Parkway, Room 110-B
Jamaica, NY 11439
Case Number: 130-1315490
LM Number: 517-662
Dear Mr. Ganter:
This office has recently completed an audit of St. John's University Professors 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 Corresponding Secretary John Greg on June 9, 2014, 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 the St. John's University Professors’ records revealed the following recordkeeping violations:
St. John's University Professors did not maintain adequate receipts records for dues received directly from members. The union’s bank records show that nine deposits were made into the union’s account during the audit year. The deposits were in multiples of $20 and $50, consistent with what the union officers stated are the amount per member of annual dues. Of the nine deposits, the union provided copies of four deposit slips. Of the approximately 20 members that paid their annual dues by check, the union maintained copies of six. Union receipts records must
include adequate identification of all money the union receives. The records should show the date and amount received, and the source of the money. Deposit slips should also be maintained.
The union constitution states that at least four membership meetings shall be held each academic year; union officers stated that in addition to four annual membership meetings, two executive board meetings shall be held. Out of a possible six meetings, the union provided minutes for one. Said minutes were written by the treasurer, not the recording secretary as per the constitution. This violates the union’s constitution which states that the recording secretary shall take the minutes of the executive council meetings, the minutes shall be available to all chapter members, and all decisions of the executive council may be overruled by a simple majority of the chapter membership.
Based on your assurance that St. John's University Professors 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 St. John's University Professors 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: Frank Le Veness, President