The Labor-Management Reporting and Disclosure Act (LMRDA) contains recordkeeping requirements for financial records that clarify or verify reports filed with the Office of Labor-Management Standards (OLMS). A union’s treasurer and president (or other corresponding principal officers) are responsible for ensuring their union meets these recordkeeping requirements.
After a report is filed with the OLMS, records must be maintained for five years. This includes all records used in the normal course of doing business and used to complete, read, and file the report (i.e., electronic documents and recordkeeping software). These records verify OLMS reports are complete and accurate.
Per an OLMS Fact Sheet providing guidance on LMRDA recordkeeping requirements, examples of records that should be retained include, but aren’t limited to:
- Receipts and disbursement journals
- Cancelled checks and check stubs
- Bank statements
- Dues collection receipts
- Employer checkoff statements
- Per capita tax reports
- Vendor invoices
- Payroll records
In addition, unions should retain records that help explain or clarify financial transactions, including:
- Credit card statements and itemized receipts for each credit card charge
- Former members’ ledger cards
- Bank deposit slips
- Bank debit and credit memos
- Vouchers for union expenditures
- Internal union financial reports and statements
- Minutes of all membership and executive board meetings
- Accountants’ working papers used to prepare financial statements and reports filed with OLMS
- Fixed assets inventory
If you are not sure about whether to keep a record, you can contact the nearest OLM field office for advice.
A quick scan of Compliance Audit Program outcomes from audits conducted thus far in 2024 very clearly shows details matter. From failing to record a vending machine’s beverage sales and missing itemized receipts for meal expenses to not having an inventory of property that was discarded and failing to obtain countersignatures on all checks, audits are uncovering numerous issues (although many simply require the issue be fixed going forward).
Unions are subject to other recordkeeping requirements related to financial reports (where records must be retained for seven years), as well as staff, their pay, and benefits. Refer to your union’s policies and handbook for details.
As you work to keep your union in compliance with recordkeeping requirements, you can count on RBT CPAs for all of your accounting, advisory, audit, and tax needs. Learn how we can be Remarkably Better Together by contacting us today.
RBT CPAs never offshores work outside of the U.S., so you always know who is handling your financial information.
NOTE: RBT CPAs is not a law firm and the content in this article should not be construed as legal advice. Should you have questions, it’s in your best interest to contact your legal counsel.