U.S. Department of Labor
Office of Labor-Management Standards
St. Louis District Office
1222 Spruce Street, Suite 9.109E
St. Louis, MO 63103
(314) 539-2667 Fax: (314) 539-2626
April 19, 2011
Mr. Aaron M. Ellinger, Financial Secretary
Carpenters Local 295
1215 Lindenwood Ave
Edwardsville, IL 62025
Case Number:
LM Number: 007781
Dear Mr. Ellinger:
This office has recently completed an audit of Carpenters Local 295 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 April 4, 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
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 295’s 2010 records revealed the following recordkeeping violation:
Mr. Aaron Ellinger
June 28, 2011
Page 2 of 2
Disposition of Property
Local 295 did not maintain an inventory of hats, jackets, and other property it purchased, sold, or
gave away. The union must report the value of any union property on hand at the beginning and
end of each year in Item 30 (Other Assets) of the LM-3. The union must retain an inventory or
similar record of property on hand to verify, clarify, and explain the information that must be
reported in Item 30.
The union must record in at least one record the date and amount received from each sale of
union hats, jackets and other items.
Based on your assurance that Local 295 will retain adequate documentation in the future, OLMS
will take no further enforcement action at this time regarding the above violations.
I want to extend my personal appreciation to Carpenters Local 295 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
cc:
Mr. Brian McDonald, President
Mr. Michael P. Keck, Treasurer