U.S. Department of Labor
July 11,2013
Mrs. Dorothy Fowler, President AFGE Local 2567 DCMA
Office of Labor-Me nagement Standards New York District Office 201 Varick Street, Suite 878 New York, NY 10 J14
(646) 264-3190 F 3X: (646) 264-3191
Case Number: 130-15401II1II LM Number: 503120
Dear Mrs. Fowler:
This office has recently completed an audit of AFGE Local 2567 DCMA under the Compliance Audit Program (CAP) to determine your organization 's compliance with the provisions ofthe Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). As discussed during the exit interview with you, Treasurer Chelisa Harris and Secretary Katherine Moeller on July 10, 2013, the following problems were disclosed during tne CAP. The matters listed below are not an exhaustive list of all possible problem areas since ' he audit conducted was limited in scope.
Record Keeping' iolation:
Title II ofthe LMRDA establishes certain reporting and recordkeeping requirements. Section 206 ofthe LMRDA and Title 29 ofthe Code of Fede al Regulations (C.F.R.) Section 403.7 require, among other things, that labor organizations naintain adequate records for at least five years after reports are filed by which the information on the reports can be verified, explained and clarified. Pursuant to 29 C.F.R. Section 458.3, tI is recordkeeping provision ofthe LMRDA applies to labor organizations subject to the requirem ~nts ofthe Civil Service Reform Act of 1978 (CSRA) as well. Therefore, as a general rule, 1:5 bor organization must retain all records used or received in the course ofunion business.
For disbursements, this includes not only original bil s, invoices, receipts, vouchers, and applicable resolutions, but also documentation showi ng the nature ofthe union business requiring the disbursement, the goods or services ree ~ived, and the identity ofthe recipient(s) of the goods or services. In most instances, this docum mtation requirement can be satisfied with a sufficiently descriptive expense receipt or invoice. r'an expense receipt is not sufficiently descriptive, a union officer or employee should writ! a note on it providing the additional information. For money it receives, the labor organi ~ation must keep at least one record showing the date, amount, purpose, and source ofthat money The labor organization must also retain bank records for all accounts.
Mrs. Dorothy Fowler July 11, 2013 Page 2 of2
The audit of Local 256Ts 2013 records revealed the f< Howing recordkeeping violations:
1. Disbursement/ Expense Documentation
Local 2567 did not maintain all documentation for disbursements. During the audit, President Fowler advised that the local entered into a contract to hire a tour bus service for $1,500 to provide transportation on a unio[ sponsored trip. Local 2567 could not locate a copy ofthe contract during the audit. 10wever, Local 2567 meeting minutes reference the trip, contain a confirmation of ag :!nda as well as an informational flier for the union's trip.
Based on your assurance that Local 2567 will retain a, {equate documentation in the future, OLMS will take no further enforcement action at this .ime regarding the above violation.
Other Issues
1. LM-3 Report Signatures
The initial LM-3 report filed by Local 2567 for ~011 states that the treasurer ofthe union received permission to sign the LM-3 report on )ehalf ofthe president who was out ofthe office at the time of the filing. The two signatUJ e requirement is an effective internal control. Its purpose is to attest to the authentici1 y ofthe completed document. 0 LMS recommends that Local 2567 review these proC( dures to improve internal controls.
Prior to the audit Local 2567 filed an amended) eport for 2011 containing the signature of both the president and treasurer.
I want to extend my personal appreciation to AFGE j ,oca12567 DCMA for the cooperation and courtesy extended during this compliance audit. I str Jngly recommend that you make sure this letter and the compliance assistance materials provid, :d to you are passed on to future officers. If we can provide any additional assistance, please do l' ot hesitate to call.
Investigator