Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
A. Maceo Smith Fed. Bldg.
525 Griffin Street, Suite 300
Dallas, TX 75202
(972) 850-2500 Fax: (972) 850-2501
May 12, 2016
Ms. Rebecca Smith, Secretary Treasurer
Communications Workers Union
Local Union 6225
PO Box 750
Waco, TX 76703-0750
Case Number: 420-6006900
LM Number: 042707
Dear Ms. Smith:
This office has recently completed an audit of Communications Workers Union Local 6225 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 President Brandie Weir on April 26, 2016, the following problem was disclosed during the CAP. The matter listed below is 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 6225 for the fiscal year ended September 30, 2015, was deficient in that:
Disbursements to Officers (LM-3)
Local 6225 did not include some reimbursements to you totaling at least $895.20 in the amounts reported Item 24 (All Officers and Disbursements to Officers). It appears the union erroneously reported these payments in Item 48.
The union must report most direct disbursements to Local 6225 officers and some indirect disbursements made on behalf of its officers in Item 24. A "direct disbursement" to an officer is a payment made to an officer in the form of cash, property, goods, services, or other things of value. See the instructions for Item 24 for a discussion of certain direct disbursements to officers that do not have to be reported in Item 24. An "indirect disbursement" to an officer is a payment to another party (including a credit card company) for cash, property, goods, services, or other things of value received by or on behalf of an officer. However, indirect disbursements for temporary lodging (such as a union check issued to a hotel) or for transportation by a public carrier (such as an airline) for an officer traveling on union business should be reported in Item 48 (Office and Administrative Expense).
I am not requiring that Local 6225 file an amended LM report for 2015 to correct the deficient item, but Local 6225 has agreed to properly report the deficient item on all future reports it files with OLMS.
I want to extend my personal appreciation to Communications Workers Union Local 6225 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. Brandie Weir, President