5/15/15: Labor organizations submit annual reports to the DOL's Office of Labor-Management Standards. These reports detail the receipts, disbursements, assets, and liabilities of covered labor organizations during their previous fiscal year. The Form LM–2 is the most detailed report, for those labor organizations with $250,000 or more in total annual receipts.
The Form LM–3 is available for those labor organizations with fewer than $250,000 in total annual receipts, and the Form LM–4 is available for those labor organizations with fewer than $10,000 in total annual receipts.
Currently, only Form LM–2 filers are required to submit their reports electronically using EFS, although the Form LM–2 instructions provide a temporary and continuing hardship exemption process. Form LM–3 and LM–4 filers can choose instead to print off the completed form, sign manually, and mail the form to OLMS.
The DOL now proposes to require electronic filing for all three forms, and to modify the hardship exemption so it’s more like a temporary delay. A union would be permitted to file on paper to meet the form’s due date, if it claims a temporary hardship exemption, but it would still be required to submit an electronic report submitted within ten business days after their required due date. (Seems like a 30 day extension would make more sense-- under current rules there are no provisions for any extension of time.)
DOL is seeking comments on the proposal.
