U.S. Department of Labor proposes changes to union reporting requirements

U.S. Department of Labor proposes changes to union reporting requirements           

On Oct. 13, the U.S. Department of Labor announced a series of proposed changes to reporting requirements for unions subject to the disclosure provisions of the Labor-Management Reporting and Disclosure Act (LMRDA).


Enacted in 1959, LMRDA requires certain unions to file annual financial reports. These reports must include the following information:

  • The reporting union’s assets and liabilities at the beginning and end of the fiscal year.
  • All revenues and their sources.
  • Salary and other compensation for any union officer or employee receiving $10,000 or more from the union in a reporting year.
  • Direct and indirect loans made to union officers, employees, or members. 
  • Direct and indirect loans to businesses. 
  • Union membership figures. 

LMRDA grants the secretary of labor the “authority to issue, amend, and rescind rules and regulations prescribing the form and publication of reports” required under the law. Since 2012, the labor secretary has delegated this authority to the director of the Office of Labor-Management Standards. The forms used for these reports are referred to as LM-2 forms. 

Unions that represent public-sector workers exclusively are not subject to these requirements. Unions representing both private-sector and public-sector workers are required to file reports. 

Proposed changes  

The revised LM-2 forms would require unions to:  

  • Disclose whether an officer or employee receiving $10,000 or more from the union also received $10,000 or more from another union. 
  • Disclose the existence and, if applicable, amount of a union’s strike fund. 
  • Report the date of the latest change to a union’s bylaws. 
  • Report sales and purchases of investments and fixed assets as four distinct entries.
  • Report spending for political activities and lobbying as two distinct entries. 
  • Provide more detailed information about membership (e.g., membership status, how many members are paying full dues, etc.).

The proposed changes do not directly affect the exemption for unions representing only public-sector workers. 

What are the reactions, and what comes next?   

Edwin Hill, Jr., an international representative for the International Brotherhood of Electrical Workers, opposed the proposal: “I do not see the necessity to further burden local union offices with additional documentation regarding their financial responsibility to its members and in accordance with existing laws. … [The existing report form]  suits the needs of interested and regulatory parties as it stands today.” 

Writing for the National Legal and Policy Center, Carl Horowitz supported the proposed changes: “Labor leaders understandably oppose this. But the proposal rule change addresses real problems, which however frequently detected and punished, require adequate tools.” 

The proposal was published in the Federal Register on Oct. 13. The comment period for this proposed rule change is open through Dec. 14. For more information about the next steps in the rulemaking process, click here

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