U.S. Department of Labor
Office of Labor-Management Standards
Seattle District Office
1111 Third Avenue, Suite 605
Seattle, WA 98101
(206) 398-8099 Fax: (206) 398-8090
March 4, 2011
LilyAnn Jolley, Secretary-Treasurer
APWU LU 3463
13600 NE 65th Street
Vancouver, WA 98682
Case Number:
LM Number: 506062
Dear LilyAnn Jolley:
This office has recently completed an audit of APWU LU 3463 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 on February 25, 2011, 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.
Recordkeeping Violations
Recordkeeping Violations
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 Local 3463’s 2010 records revealed the following recordkeeping violations:
1. General and Reimbursed Expenses
Local 3463 did not retain adequate documentation for general and reimbursed expenses
LilyAnn Jolley
July 6, 2011
Page 2 of 2
incurred by union officers totaling at least $1,119.49. For example, 6 out of 46
disbursements were not supported with a union record. These payments were for monthly
meeting expenses, per capita payments, a human relations payment, and an officer
reimbursement.
2. Lack of Salary Authorization
Local 3463 did not maintain records to verify that the monthly salaries totaling $8,789 was
the authorized amount. The union must keep a record, such as meeting minutes to show the
current salary authorized by the entity or individual in the union with the authority to
establish salaries.
As previously noted above, labor organizations must retain original receipts, bills, and vouchers
for all disbursements. The president and treasurer (or corresponding principal officers) of your
union, who are required to sign your union’s LM report, are responsible for properly maintaining
union records.
Reporting Violations
organizations to file annual financial reports accurately disclosing their financial condition
and operations. At the start of the compliance audit, the Labor Organization Annual Report
(Form LM-3) for the period ending 1/31/2010 was delinquent. The form LM-3 has now been
I want to extend my personal appreciation to APWU LU 3463 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.
Sincerely,
Investigator
Delinquent Form LM-3
The audit disclosed a violation of LMRDA Section 201(b), which requires labor
filed and forwarded to the Office of Disclosure.