Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
Boston-Buffalo District Office
JFK Federal Building, Suite E-365
Boston, MA 02203
(617) 624-6690 Fax: (617) 624-6606
July 11, 2016
Mr. Thomas A. Stedman, President
PO Box 4217
Rome, NY 13442
Case Number: 110-6006878
LM Number: 008802
Dear Mr. Stedman:
This office has recently completed an audit of UAW Local 2367 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, Treasurer, Michael Bambury, Trustee, Scott Johnson and Vice Shop Chairman Justin Hansen on July 8, 2016, 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.
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 filed by Local 2367 for the fiscal year ended December 31, 2015, was deficient in that:
Failure to File Bylaws
The audit disclosed a violation of LMRDA Section 201(a), which requires that a union submit a copy of its revised constitution and bylaws with its LM report when it makes changes to its constitution or bylaws. OLMS had constitution and bylaws dated 1999 on file. Local 2367 amended its constitution and bylaws several times between 1999 and 2015 but did not file the latest copy with its LM report(s) when amendments were made.
Local 2367 has now filed a copy of its current constitution and bylaws.
I want to extend my personal appreciation to Local 2367 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. Michael C. Bambury, Treasurer