2024 Annual Report

January 2025

Introduction

The Office of Labor-Management Standards (OLMS) is the lead agency responsible for safeguarding labor union assets, promoting democracy by enforcing the Labor-Management Reporting and Disclosure Act (LMRDA) through its criminal and civil investigations, and creating transparency through public disclosure of various required forms.  OLMS conducts criminal investigations into potential offenses such as embezzlement, deprivation of rights through violence, extortionate picketing, willful failure to file required reports, destruction of records, filing false reports, and election fraud within unions.  Additionally, the LMRDA prohibits individuals convicted of certain crimes from holding union office or employment, or from occupying positions with employers or employer associations where they possess “specific collective bargaining authority or direct responsibility in the area of labor-management relations.”  Civil investigations encompass violations of the LMRDA, including those related to union elections, financial disclosures by unions, union officers and employees, employers, and labor relations consultants, and the imposition of trusteeships on labor unions.  OLMS also conducts audits of the financial conditions and operations of unions.

The Law

When the Labor-Management Reporting and Disclosure Act (LMRDA) was enacted in 1959, Congress declared “it is essential that labor organizations, employers and their officials adhere to the highest standards of responsibility and ethical conduct in administering the affairs of their organizations, particularly as they affect labor-management relations.”  The LMRDA primarily promotes union democracy and financial integrity in private sector labor unions through standards for union officer elections and union trusteeships and safeguards for union assets.  Additionally, the LMRDA promotes transparency through reporting and disclosure requirements for labor unions and their officials, employers, labor relations consultants, and surety companies.

In enacting the LMRDA, Congress reiterated what it had found in 1935 when it enacted the National Labor Relations Act, stating that “in the public interest, it continues to be the responsibility of the Federal Government to protect employees’ rights to organize, choose their own representatives, bargain collectively, and otherwise engage in concerted activities for their mutual aid or protection[.]”  To help achieve that end, Congress declared that “it is essential that labor organizations, employers, and their officials adhere to the highest standards of responsibility and ethical conduct in administering the affairs of their organizations, particularly as they affect labor-management relations.”  OLMS continues today to protect union members and their right “to organize, choose their own representatives, bargain collectively, and otherwise engage in concerted activities for their mutual aid or protection” by pursuing this important mission through criminal and civil enforcement.

The major provisions of the LMRDA cover, by title:

• Title I:  Bill of Rights for union members
• Title II:  Requirements for reporting and disclosure by labor unions, union officers and employees, employers, labor relations consultants and surety companies
• Title III:  Rules for unions in establishing and maintaining trusteeships
• Title IV:  Standards for conducting fair elections of union officers
• Title V:  Safeguards for protecting union funds and assets

Unions representing U.S. Postal Service employees became subject to the LMRDA with the passage of the Postal Reorganization Act of 1970.  OLMS also administers provisions of the Civil Service Reform Act of 1978 and the Foreign Service Act of 1980, which extend comparable protections to labor unions representing federal employees.  

Compliance assistance is a cornerstone of OLMS’ enforcement strategy.  OLMS actively promotes voluntary compliance with the LMRDA through a comprehensive compliance assistance program.  This program aims to educate union officers and employees, as well as employers and employer-consultants, about their legal obligations and to inform union members of their rights under the law.

In addition to the LMRDA, OLMS administers the Department’s responsibilities under the Federal Transit Act by ensuring that fair and equitable arrangements protecting mass transit employees’ collective bargaining rights are in place before the release of federal transit grant funds.

Summary

This report consists of six sections, with related tables and charts.

• Section 1 presents key fiscal year (FY) 2024 criminal enforcement and performance results regarding LMRDA Title V (financial safeguards for labor organizations) together with noteworthy criminal enforcement actions. A complete listing of calendar year (CY) 2024 criminal actions is located on the OLMS website along with those for previous calendar years.
• Section 2 presents key FY 2024 civil enforcement and performance results regarding LMRDA Title III (trusteeships) and Title IV (union officer elections) together with noteworthy union officer election case summaries for FY 2024. A listing of all CY 2024 voluntary agreements for OLMS-supervised union officer elections is located on the OLMS website along with those for previous years. Calendar year 2024 court actions resulting from election investigations are located on the OLMS website along with those for previous years. Final decision letters in election and trusteeship cases are located on the OLMS website in the FOIA reading room. 
• Section 3 presents reporting and disclosure data and related program activity pursuant to LMRDA Title II (reporting requirements). Section 3 also presents key FY 2024 reporting, enforcement and performance results. Reports are available for public disclosure on the OLMS Online Public Disclosure Room.
• Section 4 summarizes grant certification activity pursuant to the section 13(c) program, which ensures fair and equitable arrangements protecting the collective bargaining rights and agreements for mass transit employees, as required by the Federal Transit Act.
• Section 5 briefly describes compliance assistance activities conducted in FY 2024.
• Section 6 discusses OLMS outreach efforts undertaken in FY 2024.

OLMS Annual Reports for 2004–2023 are located on the OLMS website.

Program Activities

1. Safeguarding Union Assets

As part of the effort to protect and safeguard the union funds and assets belonging to hard-working union members, OLMS investigates possible embezzlement from unions and other violations of criminal laws.  Union officers, employees, and representatives have a duty to manage the funds and property of the union solely for the benefit of the union and its members in accordance with the union’s constitution.  When a union officer or employee violates their position of trust by embezzling or misappropriating union funds or assets, they commit a federal crime punishable by imprisonment, fine, or both.  OLMS is responsible for investigating these crimes. 

Further, Section 504 of the LMRDA prohibits individuals convicted of certain crimes from holding union office or employment or serving in other specified capacities with both unions and employers.  The bar runs for 13 years after conviction or after the end of imprisonment, whichever is later.  OLMS is responsible for investigating violations of section 504 in addition to other violations including embezzlements of union funds and the willful failure to file complete and accurate financial and other reports with OLMS or to maintain records.  These investigations may result in legal enforcement actions.

Through its Compliance Audit Program, OLMS conducts audits of labor unions to promote compliance with the LMRDA and to detect possible embezzlements.  This effort extends to every level of labor organizations, from local unions to intermediate bodies, to national and international unions.  OLMS conducts compliance audits of unions covered by the LMRDA and of Federal sector unions under the standards of conduct provisions of the Civil Service Reform Act (CSRA).  Compliance audits also are designed to detect potential civil violations of the law, and to provide compliance assistance to help unions meet statutory requirements.  When OLMS discovers a violation during an audit, it attempts to enable the labor union to remedy the problem by providing on-the-spot compliance assistance before the audit concludes.  For example, if a compliance audit reveals that a union carries insufficient bonding to protect its financial operations from fraud or embezzlement, OLMS will assist the union to bring its bonding level to statutory standards.  Once a compliance audit is completed, OLMS sends a closing letter to the union describing any reporting deficiencies, recordkeeping violations, and internal control problems identified during the audit.  The compliance audit closing letters located on the OLMS website.  If the union has not remedied the violation by the conclusion of the audit, OLMS will open a “fall-out” case to obtain compliance.  In FY 2024, OLMS exceeded its new performance goal of resolving 73% of audit violations through voluntary compliance by successfully assisting unions in resolving 83.3% of such violations.

Below are summaries of several notable cases resulting from OLMS criminal investigations during FY 2024:

Former Union Officer Sentenced for Wire Fraud Tied to Embezzling Over $126,000

On October 5, 2023, in the United States District Court for the Southern District of Ohio, Eastern Division, Fred T. Lee, former President of American Federation of Government Employees Local 4071, located in Columbus, Ohio, was sentenced to one year of supervised release and ordered to pay $126,872 in restitution. On April 10, 2023, Lee pleaded guilty to wire fraud, in violation of 18 U.S.C. 1343. Although the union had a program to issue recruitment rebates and provided some rebates in cash, Lee withdrew an additional $126,872 in cash from the union account for his own personal use by making 140 ATM withdrawals, 30 unauthorized counter withdrawals, and receiving 6 unauthorized checks. The joint investigation was conducted with the Department of Veterans Affairs’ Office of Inspector General.

Former ILA Local 1740 President and Other Individuals Sentenced for Crimes Impacting the Union in the Port of San Juan, Puerto Rico

In FY 2024, a joint investigation of International Longshoremen’s Association (ILA) Local 1740, located in the Port of San Juan, San Juan, Puerto Rico, produced multiple criminal convictions in the United States District Court for the District of Puerto Rico. Carlos Sanchez Ortiz, former President of ILA 1740 and a former Vice President of the ILA International, pleaded guilty to one count of labor racketeering conspiracy (RICO Act), in violation of 18 U.S.C. 1962(d). ILA 1740 members Pedro Pastrana Gonzalez and Iara Clemente Rivera, as well as Jorge Batista Maldonado, a supervisor of the Puerto Rico Port Authority, also pleaded guilty to labor racketeering conspiracy. In their plea agreements, Sanchez Ortiz, Pastrana Gonzalez, and Clemente Rivera admitted that they participated in a scheme to collect unlawful payments from shipping companies at the piers, and that those unlawful payments were concealed in part through a company called “JCPY,” which Pastrana Gonzalez admitted to being the president of since 2012. Members of the enterprise threatened these union employers with economic harm by threatening to use picket lines to block cargo if the unlawful fees were not paid. Batista Maldonado admitted to providing information and advice to the enterprise.

During November and December 2023, the four individuals were sentenced. Pastrana Gonzalez was sentenced to 21 months of imprisonment, one year of supervised release, and he was ordered to pay $242,042 in restitution. Clemente Rivera was sentenced to three years of probation and ordered to pay $150,000 in restitution. Sanchez Ortiz was also sentenced to three years of probation and ordered to pay $10,000 in restitution. Batista Maldonado was sentenced to two years of probation and ordered to pay $50,000 in restitution. In addition, several other ILA 1740 union members were sentenced to probation following their guilty pleas for conspiracy to convert funds and falsify the records of an ILA Local 1740 benefit fund, in violation of 18 U.S.C. 371. The joint investigation was conducted with the Department of Labor’s Employee Benefits Security Administration and Office of Inspector General, the Federal Bureau of Investigation, and the U.S. Attorney’s Office for the District of Puerto Rico.

Former Union Officer Sentenced for Embezzling Approximately $100,000

On November 29, 2023, in the United States District Court for the Northern District of Alabama, Ray La Vondie Williams, former Financial Secretary of United Steelworkers Local 9-2140-S, located in Birmingham, Alabama, was sentenced to three years of probation and ordered to pay $68,325 in restitution. On June 27, 2023, Williams pleaded guilty to embezzling approximately $100,000 in union funds, in violation of 29 U.S.C. 501(c), previously refunding the union $32,774 prior to sentencing. The OLMS investigation found that while Williams served as the union financial secretary, he converted the funds to his personal use by making unauthorized purchases using the union’s debit card and unauthorized withdrawals at the local’s bank. He also initiated and received unauthorized transfers from the union’s account to his personal bank account via the Zelle App and via the union’s electronic banking account to check.

Two Former Union Officers Found Guilty of Embezzlement at Trial and Sentenced to Prison, Several Former Union Employees Also Convicted

In FY 2024, a long-term joint investigation of International Brotherhood of Electrical Workers (IBEW) Local 98, located in Philadelphia, Pennsylvania, produced numerous criminal convictions in the United States District Court for the Eastern District of Pennsylvania. In December 2023, John Dougherty and Brian Burrows, former IBEW Local 98 Business Manager and former Local 98 President, respectively, were found guilty following a jury trial of conspiracy to embezzle from a labor union and employee benefits plan, embezzlement of union funds, filing false LM reports, falsifying union records, and filing false federal income tax returns, in violation of 18 U.S.C. 371, 29 U.S.C. 501(c), 29 U.S.C. 439(b), 29 U.S.C. 439(c), and 26 U.S.C. 7206(1), respectively. Dougherty was also found guilty of wire fraud, in violation of 18 U.S.C. 1343. Dougherty was previously found guilty following a November 2021 public corruption trial along with co-defendant Robert Henon, a former employee of Local 98 and a Philadelphia City Councilman, for conspiracy to commit honest services fraud and honest services wire fraud, in violation of 18 U.S.C. 371 and 18 U.S.C. 1343 and 1346, respectively. Henon was also convicted of bribery, in violation of 18 U.S.C. 666 (a)(1)(B).

On June 26, 2024, Burrows was sentenced to 48 months of imprisonment, three years of supervised release, and he was ordered to pay $135,689 in forfeiture. Burrows was later ordered to pay $926,133 in restitution and $10,357 to the Internal Revenue Service (IRS). On July 11, 2024, Dougherty was sentenced to 72 months of imprisonment, three years of supervised release, and 100 hours of community service. He was also ordered to pay forfeiture of $353,941. Dougherty was later ordered to pay more than $1.6 million in restitution (jointly and severally with his co-conspirators) to Local 98 and approximately $126,000 to the IRS.

Additionally, four other former Local 98 employees were sentenced this year, following guilty pleas for embezzlement and related crimes. They were collectively ordered to pay $128,503 in restitution. The joint investigation was conducted with the Department of Labor’s Employee Benefits Security Administration and Office of Inspector General, the Federal Bureau of Investigation, the IRS, the Pennsylvania State Police, and the Pennsylvania Attorney General’s Office.

Former Union President and Benefits Coordinator Sentenced to Prison for Defrauding and Misappropriating from Union Member Annuity Funds

On January 17, 2024, in the United States District Court for the Southern District of New York, Kenneth Wynder Jr., former President of the Law Enforcement Employees Benevolent Association (LEEBA), located in New York, New York, was sentenced to 40 months in prison followed by three years of supervised release. Wynder was ordered to pay $838,683 in restitution and $529,000 in forfeiture. On the same date, Andrew Brown, the union’s former Benefits Coordinator, was sentenced to 18 months in prison followed by three years of supervised release and ordered to pay $529,000 in restitution as well as $3,049 in forfeiture.

On May 30, 2023, following a five-day jury trial, Wynder and Brown were both convicted of wire fraud and conspiracy to commit wire fraud, in violation of 18 U.S.C. 1343 and 1349, respectively. Wynder was also convicted of conspiracy to evade federal taxes and federal tax evasion, in violation of 26 U.S.C. 7201. Wynder and Brown participated in a scheme to embezzle money from the annuity fund and individual members’ retirement accounts. Specifically, they made hundreds of thousands of dollars in fraudulent transfers from the annuity fund to LEEBA’s operating account, which Wynder controlled. Wynder then regularly used those funds to enrich himself at the union members’ expense, including through unauthorized and excessive checks to himself, cash withdrawals for his own benefit, and to pay insurance benefits for which Brown received commissions. In addition, Wynder caused the union to pay for various personal expenses, such as the purchase of a Lexus automobile and personal travel expenses, all paid for by the union and none of which was contemporaneously reported to the Internal Revenue Service (IRS). The joint investigation was conducted with the Federal Bureau of Investigation and the IRS – Criminal Investigations.

Former Union Official Sentenced for Embezzling Over $70,000

On February 15, 2024, in the United States District Court for the Eastern District of Wisconsin, Marie “Malou” Noth, former Deputy Administrator of the trusteeship imposed on American Federation of State, County and Municipal Employees Local 777, located in Milwaukee, Wisconsin, was sentenced to two years of supervised release and ordered to pay $70,900 in restitution. On November 15, 2023, Noth pleaded guilty to embezzling union funds, in violation of 29 U.S.C. 501(c). The OLMS investigation found that between January 2016 and September 2019, Noth used her access to the union’s bank account to make unauthorized ATM and counter cash withdrawals. She also wrote unauthorized union checks to cash, unauthorized union checks to herself, and unauthorized union checks to third parties (including friends and family). Noth also made unauthorized electronic fund transfers. At times, Noth attempted to conceal her fraudulent activity by altering checkbook carbon copies to hide the checks' true payees and writing false union business purposes on the memo line of some checks.

Former Union Officer Sentenced for Wire Fraud Tied to Embezzling Over $55,000

On March 25, 2024, in the United States District Court for the District of Arizona, Elizabeth Dawn Talavera, former Secretary-Treasurer of American Federation of Government Employees Local 3694, located in Waddell, Arizona, was sentenced to four years of probation and ordered to pay $55,766 in restitution. On October 31, 2023, Talavera pleaded guilty to one count of wire fraud, in violation of 18 U.S.C. 1343. The OLMS investigation found that Talavera used her access to the union’s internet banking account to conduct wire transfers from the union’s checking account to herself, a family member, and friends. Talavera also fraudulently used the union’s debit card to make cash withdrawals and personal purchases. Additionally, Talavera generated checks from the local funds to herself, as well as diverted dues checks for the union into her personal bank account instead of the union’s account, solely for her own personal benefit.

Former Union Employee Sentenced for Embezzling Over $189,000 and Wire Fraud

On July 16, 2024, in the United States District Court for the District of Oregon, Emerald Keever, former bookkeeper for Sheet Metal, Air, Rail and Transportation Workers Local 16, located in Portland, Oregon, was sentenced to three years of supervised release. She was also ordered to pay restitution totaling $189,119. On April 16, 2024, Keever pleaded guilty to wire fraud and embezzling union funds, in violation of 18 U.S.C. 1343 and 29 U.S.C. 501(c), respectively. The OLMS investigation found that Keever redirected union money to her personal accounts in several ways. First, on multiple occasions Keever excluded herself from a list of payees that the union management reviewed so that she could separately pay her more than she was authorized to receive. Second, Keever added a second bank account to her payee profile so that she could receive additional payroll payments. Third, Keever created false payment entries to vendors to conceal unauthorized payroll disbursements to her, to which she was not entitled.

Former Union Officer Sentenced for Felony Theft of Property

On July 31, 2024, in the Washington County Circuit Court in the State of Arkansas, Thomas Hill, former Treasurer of National Association of Letter Carriers State Association, located in Fayetteville, Arkansas, pleaded guilty to one count of felony theft of property, in violation of Arkansas Code Annotated 5-36-103(b)(1)(A). He was then sentenced to 20 years of unsupervised probation and ordered to pay $82,204 in restitution. The joint investigation conducted with the Fayetteville Police Department found that between February 2016 and February 2023, Hill fraudulently wrote himself numerous unauthorized checks and illicitly used the union’s debit card to make unauthorized charges and cash withdrawals.

Former Union Officer Sentenced to Prison for Embezzling $129,000

On August 21, 2024, in the United States District Court for the District of Kansas, Randal Dunlap, former Treasurer of National Association of Letter Carriers Branch 1018, located in Manhattan, Kansas, was sentenced to 13 months of imprisonment and two years of supervised release. He was also ordered to pay $129,000 in restitution. On May 1, 2024, Dunlap pleaded guilty to embezzling union funds, in violation of 29 U.S.C. 501(c). The OLMS investigation found that in 2007, Dunlap obtained a debit card attached to the union’s bank without the knowledge of other officers. Between 2007 and 2023, he used the card to make over $100,000 in ATM cash withdrawals and personal debit card purchases. In addition, he used his position as treasurer to write over $40,000 in checks to himself or to cash without the approval of other officers. To conceal his actions, Dunlap falsified the balance of Branch 1018’s checking account in financial reports to the union’s membership and in the union’s annual budget reports.

2. Protecting Union Democracy

Title IV of the LMRDA establishes standards for conducting democratic and fair union officer elections, such as the frequency and method of election, the right of members in good standing to be candidates, rights of candidates, and member voting rights.  Before filing a complaint with OLMS, union members must avail themselves of their union’s internal protest procedures.  If OLMS’ investigation reveals a violation of Title IV of the LMRDA that may have affected the outcome of the election, OLMS seeks a voluntary compliance agreement with the union to allow OLMS to supervise a new election.  If the union does not voluntarily agree to remedy the violation, OLMS takes legal action seeking to void the challenged election and conduct a new election supervised by OLMS.  OLMS Election Decisions are located on the OLMS website.

OLMS prioritizes the timely resolution of union officer election complaints.  This is measured by the average number of days between the agency’s receipt of a complaint and its resolution.  Prompt resolution is crucial, as it minimizes uncertainty and disruption stemming from contested election victories and diminishes the impact of potentially stale claims.  In FY 2024, OLMS demonstrated progress in reducing resolution times, exceeding its FY 2023 performance and narrowly missing the target of 65 average elapsed days.  The average resolution time this year was 66.3 days.  OLMS projects and tracks the number of election investigations and supervised elections, although both are dependent on the volume of election complaints received and are therefore outside of OLMS’ direct control.  The number of lawsuits filed, or voluntary compliance agreements reached, in a given year is even more difficult to predict, and OLMS thus does not set targets for those enforcement actions. 

Under Title III of the LMRDA, the agency also conducts investigations to determine the validity of the imposition or continuation of trusteeships imposed by national and international unions on subordinate bodies.  Trusteeship investigations are conducted upon receipt of a complaint from a member or subordinate body.  Unlike with election investigations, union members need not avail themselves of their union’s internal protest procedures before filing a complaint with OLMS.

The following highlights some of the most significant OLMS election investigations completed during FY 2024:

Roofers Local 74 Agreed to Hold a New Election Under OLMS Supervision

In October 2023, OLMS entered into a voluntary compliance agreement with Roofers Local 74, located in West Seneca, New York. The union agreed to conduct new nominations, a new election, and installation for the offices of business manager, business agent, president, vice president, recording secretary, sergeant at arms, and four executive board members under OLMS supervision. The investigation concluded that the union failed to comply with LMRDA Section 401(e) when it denied members in good standing the right to be candidates when it imposed an unreasonable membership meeting attendance requirement rendering approximately 94 percent of the membership ineligible to seek union office. The supervised election was conducted in February 2024.

IAM District Lodge 19 Agreed to Hold a New Election Under OLMS Supervision

In October 2023, OLMS entered into a voluntary compliance agreement with International Association of Machinists & Aerospace Workers (IAM) District Lodge 19, located in Denver, Colorado. The union agreed to conduct a new election, with new nominations, if necessary, for the offices of president/directing general chairman and secretary/treasurer under OLMS supervision. The investigation concluded that District Lodge 19 failed to re-mail election notices, even though forwarding addresses were provided by the U.S. Postal Service, for more than 104 members. The supervised election was conducted in May 2024.

AFGE Agreed to Hold a New Election Under OLMS Supervision

In November 2023, OLMS entered into a voluntary compliance agreement with American Federation of Government Employees (AFGE), located in Washington, D.C. The union agreed to conduct a new caucus election, including credentialing of all delegates, for the office of District 4 National Vice President under OLMS supervision. The investigation found that AFGE denied members the right to vote when some local unions did not receive the proper number of ballots to vote in the District 4 national officer election. The supervised election was conducted in March 2024.

IUE-CWA Local 86116 Agreed to Hold a New Election Under OLMS Supervision

In March 2024, OLMS entered into a voluntary compliance agreement with Industrial Union of Electrical Workers - Communications Workers of America (IUE-CWA) Local 86116, located in St. Joseph, Missouri. The union agreed to conduct new nominations, a new election, and installation for the offices of president, vice president, financial secretary, recording secretary, sergeant-at-arms, chief stewards (2), and trustee under OLMS supervision. The investigation disclosed that Local 86116 failed to elect its officers by secret ballot, failed to provide adequate safeguards to ensure a fair election (by not including an additional polling site in the election notice), and failed to provide proper notice of election to all members. The supervised election was conducted in July 2024.

IBT Local 2750 Agreed to Hold a New Election Under OLMS Supervision

In April 2024, OLMS entered into a voluntary compliance agreement with International Brotherhood of Teamsters (IBT) Local 2750, located in Cincinnati, Ohio. The union agreed to conduct a new election of all contested officer positions under OLMS supervision. The investigation revealed that Local 2750 denied eligible members a reasonable opportunity to vote when it failed to notify members of a polling site opened at the union’s office on the day mail ballots were due to the union and when it instituted a 30-day mail balloting period that did not give members sufficient time to vote and return ballots due to the nature and locations of their employment. A significant number of members lived and worked overseas for extended periods. The supervised election was conducted by mail ballot in August 2024.

CWA Local 6215 Agreed to Hold a New Election Under OLMS Supervision

In April 2024, OLMS entered into a voluntary compliance agreement with the Communications Workers of America (CWA) Local 6215, located in Dallas, Texas. The union agreed to conduct a new election for the offices of president, vice president, and chief stewards of five jurisdictions within the local under OLMS supervision. The investigation determined that Local 6215 failed to accommodate a candidate’s reasonable request to distribute campaign literature via the union’s email address list. The investigation further found that the local failed to properly maintain its voter eligibility list, thereby denying eligible members the right to vote and permitting votes to be cast by ineligible members or non-members. The supervised election was conducted in July 2024.

Department Filed Suit Against BCTGM Local 1

In May 2024, in the United States District Court for the Northern District of Illinois Eastern Division, the Department filed suit against Bakery, Confectionery, Tobacco Workers & Grain Millers (BCTGM) Local 1, located in Lyons, Illinois, seeking to nullify the union’s 2023 election. The complaint alleged that the union denied members a reasonable opportunity to vote by failing to mail an election notice to all members at their last known home address not less than 15 days prior to the election and by failing to mail ballots to members in good standing, in violation of Section 401(e) of the LMRDA. In November 2024, a settlement order was signed by the court for OLMS to supervise the next regularly scheduled union officer election.

AFGE Local 2876 Agreed to Hold a New Election Under OLMS Supervision

In May 2024, OLMS entered into a voluntary compliance agreement with American Federation of Government Employees (AFGE) Local 2876 in Washington, D.C. The union agreed to hold a new election for the offices of president, vice president, and secretary-treasurer under OLMS supervision. The investigation determined that Local 2876 misaddressed the pre-printed envelopes that members used to return voted ballots in the mail ballot election. The investigation also found that Local 2876 did not maintain a record of the number of ballots mailed to the membership or retain voted ballots that were received after the election. The supervised election was conducted in July 2024.

Department Filed Suit Against SIA

In July 2024, in the United States District Court for the District of Utah, the Department filed suit against SkyWest InFlight Association (SIA), located in Salt Lake City, Utah, seeking to nullify the union’s 2023 election of representatives and the subsequent 2024 rerun, as well as prior elections for the officer positions of president, vice president, and secretary. The complaint alleges that the union violated Title IV of the LMRDA when it only allowed incumbent representatives to nominate and run for executive officer positions and required candidates for executive offices to first win a quasi-primary election among the incumbent representatives before allowing the membership to vote. The union also failed to mail an election notice to the last known home address of all members at least 15 days prior to the election. Additionally, the union failed to elect officers at least every three years but rather were electing representatives to terms of four years or longer, in violation of Section 401(b) of the LMRDA. Litigation is pending.

IATSE Local 333 Agreed to Hold a New Election Under OLMS Supervision

In July 2024, OLMS entered into a voluntary compliance agreement with International Alliance of Theatrical Stage Employees (IATSE) Local 333, located in Charleston, South Carolina. The union agreed to hold new nominations and a new election for the office of president under OLMS supervision. The investigation determined that Local 333 mailed the ballots too late to allow members to vote and return their ballots in time to be counted. In addition, the union failed to ensure voter secrecy when election officials at the ballot tally wrote voters’ initials on the ballot secrecy envelopes before the ballots were removed and counted. The supervised election was conducted in October 2024.

Court Ordered Rerun of IUEC Local 18 Election

In August 2023, in the United States District Court for the Central District of California, a settlement was reached between International Union of Elevator Constructors (IUEC) Local 18, located in Glendora, California, and the Department of Labor. The settlement agreement required IUEC Local 18 to conduct a new election for the offices of business manager, trustee, and executive board members (3) under OLMS supervision. The Department’s 2022 lawsuit alleged that during Local 18’s 2021 election, the union violated Title IV of the LMRDA when, after issuing a second ballot package eight days after issuing the first, it failed to provide sufficient voting instructions to members and failed to provide clear, timely notice that members who had already voted the first ballot were required to vote the revised ballot in order to have their vote counted. As a result, at least 135 members, who only voted the first ballot, were denied the right to vote when their ballots were not counted. The supervised election was conducted in June 2024 and certified by the court in August 2024.

3. Labor Union and Labor-Management Transparency

The LMRDA is predicated on the principle that union members, officers, and the public benefit by having access to information about labor unions, union officers and their employees, employers, labor relations consultants, and surety companies.  To this end, OLMS administers a comprehensive reporting and disclosure program.  OLMS also offers compliance assistance sessions for union members and officials as well as employers and labor-relations consultants surrounding the financial reporting obligations under the LMRDA. 

Title II of the LMRDA requires that unions file annual financial reports, known as Labor-Management (LM) Reports (Forms LM-2, LM-3, LM-4, or simplified filings), with OLMS. Unions must also file trusteeship reports (Forms LM-15, LM-16) when they establish supervision or control over a subordinate body. Other entities, such as employers (Form LM-10), labor relations consultants (Forms LM-20, LM-21), union officers and employees (Form LM-30), and surety companies (Form S-1), are also required to file reports under specified circumstances. Reports are available for public disclosure on the OLMS Online Public Disclosure Room website. OLMS also collects and maintains collective bargaining agreements (CBAs) filed by CBA signatories on a voluntary basis. These CBAs also are located on the OLMS website.

In FY 2024, OLMS maintained a “persuader” initiative to increase the disclosure of arrangements between employers and labor consultants.  “Persuader activity” refers to efforts by a consultant, working under an arrangement with an employer, to influence employees to exercise or not to exercise their rights to organize and engage in collective bargaining.  The initiative also encompasses employers that obtain information from employees or labor unions involved in a labor dispute.  In 2024, OLMS collected a combined 1,384 Form LM-10 employer persuader reports (checking Items 8.e. and 8.f) and Form LM-20 consultant reports disclosing such employer-consultant agreements or arrangements.

OLMS received, processed, and made the following reports publicly available in FY 2024.

OLMS utilizes a web-based Electronic Forms System (EFS) that filers use to complete and submit LM reports.  The system allows any of these filers to complete and electronically submit an LM report without special software or a digital signature.  When filing a report, EFS performs calculations for the LM report and completes a form error check prior to submission to OLMS.  EFS also allows unions that maintain electronic accounting records to import financial data from their accounting programs directly into their LM forms. 

When labor organization annual reports are not filed in a timely manner or the reports filed are deficient, OLMS opens an investigation to obtain compliance.  When reports due from employers, labor relations consultants, and union officers and employees are not timely or properly completed, OLMS also will pursue delinquent and deficient reports.  These investigations are known as “Special Reports” cases.  OLMS tracks the numbers of delinquent and deficient reports and special reports cases completed. 

During FY 2024, OLMS had success reducing the number of labor organizations on a “chronic delinquency” watch list. A union is chronically delinquent if it is late filing its report three years in a row. To prevent chronic delinquency, OLMS reaches out to unions who have filed late in the previous two years. These are the unions most in danger of becoming chronically delinquent. The goal was to remove 360 unions from the list by assisting them to file on time. By year’s end, OLMS had exceeded this goal and removed 501 filers from the chronic delinquency watch list.

4. Employee Protections

OLMS also administers responsibilities under federal transit law by ensuring that fair and equitable arrangements protecting mass transit employees are in place before the Federal Transit Authority releases federal transit assistance to state and local transit authorities.  See, e.g., 49 U.S.C. § 5333(b) When federal funds are used to acquire, improve, or operate a transit system, federal law requires that arrangements must be made to protect the rights of affected mass transit employees. These arrangements must be approved by OLMS before the U.S. Department of Transportation’s Federal Transit Administration can release funds to mass transit employers. 

In FY 2024, OLMS certified employee protections for 1,770 federal transit grants.  OLMS certified 99 percent of grants within a 45-day timeframe, well under the 60 days permitted by OLMS guidelines (29 CFR § 215).  Pursuant to 29 CFR § 215.7, OLMS notified unions and the public of 314 rural grants, to which the FTA applied the Special Warranty Arrangement that meets the Act’s requirements.  More information about employee protections under federal transit law can be found on the OLMS website.

5. Compliance Assistance

In FY 2024, OLMS undertook the following initiatives as part of a comprehensive compliance assistance program to educate unions, union officials, employers, and consultants about the LMRDA:

OLMS maintained its program of structured, nationwide compliance assistance seminars, but sought to reduce the number of sessions while increasing attendance through enhanced recruitment.  The goal of this program is to provide an opportunity each year for the officers of every labor organization to attend a compliance assistance seminar.  The content of the compliance assistance seminar is similar throughout the country so that every officer in attendance benefits from the same material.  In 2024, OLMS conducted 113 compliance assistance seminars. OLMS had a greater reach in FY 2024 than in FY 2023; OLMS provided formal compliance assistance events to 4,871 participants and recorded 14,483 contact hours (i.e., the number of participants multiplied by the number of hours of instruction).

• OLMS responded to all requests for compliance assistance seminars. OLMS also received and responded to hundreds of requests for information and policy interpretations.
• In FY 2010, OLMS began working with the nation’s most prominent international and national unions through the Voluntary Compliance Partnership (VCP) initiative, leveraging their resources to improve the compliance performance of their over 16,000 affiliates. During FY 2024, the VCP program included 50 partner national or international unions. VCP added three new union partners at the end of FY 2023 and officially welcomed them to the program in FY 2024. VCP continued to solidify its platform as a national compliance assistance effort focused on improving timely reporting, bonding coverage, accurate and complete reporting including the submission of union constitutions and bylaws, and the implementation of financial safeguards to prevent unions from becoming victims of financial fraud. VCP is a strategic leadership effort that requires executive level involvement from OLMS and officer level involvement from the union, which helps to drive compliance throughout the labor-management community by providing tools, information, and assistance. The overall on-time filing rate for unions under the VCP initiative is significantly higher than that of non-VCP unions, with the on-time filing rate increasing again in FY 2023 (the latest available union fiscal year) at 83% overall (85% for VCP unions and 70% for non-VCP unions). OLMS leadership met directly with the presidents and secretary-treasurers of 31 VCP member unions in FY 2024. In total, OLMS distributed 48 comprehensive annual VCP informational reports, specifically tailored for each international and national union.
• OLMS continued to advance its Persuader Reporting Orientation Program (PROP), a compliance assistance initiative to inform employers and their representatives about potential reporting obligations under the LMRDA. PROP enables OLMS to contact employers involved in representation elections – and any parties that have notified the National Labor Relations Board (NLRB) of their status as representatives for such employers – to inform them of potential LMRDA reporting requirements. OLMS provides information on where to locate reporting forms and instructions and how to contact OLMS to ask questions or obtain additional information. OLMS also provides a fact sheet on reporting employer-consultant agreements.
• In FY 2024, OLMS continued sending a PROP-type letter to labor unions who were petitioners seeking an NLRB representation election, notifying them of the employer and consultant reporting requirements on the employers whose employees they were seeking to represent. The letter also encouraged them to submit tips to OLMS concerning potentially delinquent or deficient reports.
• OLMS managed a public email address, enabling the agency to respond to over 2,000 inquiries and requests from the public in the year.
• OLMS continued its Labor Organization Orientation Program (LOOP), which distributes information letters to newly registered labor organizations. In FY 2024, OLMS continued sending LOOP letters to non-filing organizations that submitted union representation election petitions with the NLRB, notifying them of the LMRDA’s union reporting and other requirements.

6. Outreach

In FY 2024, OLMS continued its initiative to educate workers, unions, policy makers and the public more broadly about OLMS’ work and the important role labor unions play in the modern American economy. These efforts include:

• A series of blog posts by the OLMS Director under the website heading “From the Director’s Desk” discussing in a narrative form OLMS’ work and the role of the labor movement in the modern American economy.
• Presentations on varied labor topics (in person and virtually) by the Director to the regulated community.
• Maintaining the Labor-Management Partnership Program (LMPP), originally developed in the 1980s to explore and promote the benefits of labor-management collaboration. The program spearheads agency-wide and national initiatives to foster cooperative relationships that bring workers, employers and/or unions together to collaboratively address challenges, enhance decision-making, and improve workplaces. Serving as a resource hub for building and sustaining labor-management partnerships, the LMPP also offers guidance and tools for interested stakeholders. In FY 2024, OLMS launched a dedicated Labor-Management Partnerships (LMP) website featuring resources, inspiring examples of successful partnerships, and a platform for the public to share their personal LMP stories. This year, OLMS attended and presented at 15 events and conferences to build relationships with external stakeholders in myriad industries across the nation.

Originally Posted January 17, 2025 
Revised and Posted January 30, 2025

Last Updated: 2-03-25