The U.S. Department of Labor’s (DOL), Office of Labor-Management Standards (OLMS), issued a final rule that will provide union members with more complete information about finances held in union trusts. Union trusts are established and maintained primarily to provide benefits to union members and their beneficiaries, and common examples include credit unions, strike funds, redevelopment or investment groups, training funds, apprenticeship programs, building funds and educational funds. Under the rule, unions will be required to annually file a Form T-1 for trusts in which a union, alone or in combination with other unions, possesses managerial control or financial dominance.
The Form T-1 will use the same basic template as the existing Form LM-2. Only labor unions with total annual receipts of $250,000 or more will need to file a Form T-1. Additionally, labor unions will not be required to file a Form T-1 on trusts subject to certain other disclosure requirements.
The union-trust transparency rule was issued on the same day as the regulations dealing with the Family and Medical Leave Act (FLMA).