U.S. Department of Labor

Office of Labor-Management Stanaards San Francisco-Seattle District Office 300 5th Avenue, Suite 1290
Seattle, WA 98104-3308
(206) 398-8099 Fax: (206) 398-8090

 

June 21, 2016

 


Cherri Wagner, Treasurer AFGE LU 2157
PO Box 1034
Portland, OR 97239

Case Number: 530-600749..
LM Number: 501880

Dear Cherri Wagner:

This office has recently completed an audit of AFGE LU 2157 under the Compliance Audit Program (CAP) to determine your organization's compliance with the provisions of the Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. 7120, and the Department's regulations, 29 CFR
458. As discussed during the exit interview with you on June 9, 2016, 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 of the LMRDA and Title 29 of the Code of Federal Regulations (C.F.R.) Section 403.7 require, among other things, that labor organizations maintain 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, this recordkeeping provision of the LMRDA applies to labor organizations subject to the requirements of the Civil Service Reform Act of 1978 (CSRA) as well. Therefore, as a general rule, labor organization must retain 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. Ifan 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 2157's 2015 records revealed the following recordkeeping violations: General Reimbursed and Credit Card Expenses

Cherri Wagner
June 21, 2016
Page 2 of 2

Local 2157 did not retain adequate documentation for reimbursed expenses and credit card expenses incurred by the former president and treasurers totaling at least $65,314.82. For example, expenses for travel, printing, food, postage, arbitration, mediation, organizing, and contributions were not supported with a union record to support the expense.

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.

Based on your assurance that Local 2157 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 AFGE LU 2157 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. Ifwe can provide any additional assistance, please do not hesitate to call.

Sincerely,

 

Investigator