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






December 12, 2014



Mr. Gregg Peters, Treasurer
Graphic Communications IBT Local 38
1722 Olive Street
St. Louis, MO 63103
Case Number: 510-6002924
LM Number: 013037


Dear Mr. Peters:

This office has recently completed an audit of Graphic Communications IBT Local 38 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 December 5, 2014, the following problem was disclosed during the CAP. The matter listed below is not exhaustive of all possible problem areas since the audit conducted was limited in scope.

Reporting Violations

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to file annual financial reports accurately disclosing their financial condition and operations. The Labor Organization Annual Report Form LM-3 filed by Local 38 for the fiscal year ended December 31, 2013, was deficient in the following area:

Disbursements to Officers (LM-3)

Local 38 did not report the names of some officers and the total amounts of payments to them or on their behalf in Item 24 (All Officers and Disbursements to Officers). The union must report in Item 24 all persons who held office during the year, regardless of whether they received any payments from the union. The union must report most direct disbursements to Local 38 officers and some indirect disbursements made on behalf of its officers in Item 24. A "direct disbursement" to an officer is a payment made to an officer in the form of cash, property, goods, services, or other things of value. See the instructions for Item 24 for a discussion of certain direct disbursements to officers that do not have to be reported in Item 24. An "indirect disbursement" to an officer is a payment to another party (including a credit card company) for cash, property, goods, services, or other things of value received by or on behalf of an officer. However, indirect disbursements for temporary lodging (such as a union check issued to a hotel) or for transportation by a public carrier (such as an airline) for an officer traveling on union business should be reported in Item 48 (Office and Administrative Expense).

Local 38 must file an amended Form LM-3 for the fiscal year ended December 31, 2013, to correct the deficient item discussed above. I encourage Local 38 to complete, sign, and file its report electronically using the Electronic Forms System (EFS) available at the OLMS website at report electronically using the Electronic Forms System (EFS) available at the OLMS website at report electronically using the Electronic Forms System (EFS) available at the OLMS website at

I want to extend my personal appreciation to Graphic Communications IBT Local 38 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