Office of Labor-Management Standards (OLMS)

Printer-Friendly Version

Form LM-2 Frequently Asked QuestionsQuestions on Schedules 14 - 19

Additions are made regularly to the Frequently Asked Questions, so please check these pages often for updates. If you have a question that is not addressed here, you may email your question to olms-public@dol.gov.

• How do I complete Schedules 14 through 19?
• What will happen if items are mistakenly posted and reported in the wrong schedule?
• In many instances labor organizations will make a single disbursement to a vendor for multiple purposes that fall under more than one functional category. How can a labor organization accurately allocate a single disbursement to multiple functional categories?
• If a union pays a printing company to print a monthly newsletter, is the union required to analyze the content of the newsletter each month to determine what percentage of the payment to the printer should be reported in Schedules 15, 16, 17, 18 or 19? Would it be acceptable for the union to analyze the content of the newsletter for one month and then extrapolate those same percentages throughout the rest of the year?
• New! Would it be a fair statement to make that we do not need to track disbursements into functional categories for per capita tax, strike benefits, fines, assessments, supplies for resale, purchase of investments and fixed assets, loans made, repayments of loans obtained, direct taxes, withholding taxes and payroll deductions as they are reported elsewhere on Statement B?
• With the instructions requiring the reporting of direct and indirect payments in Schedules 15 through 19, how would a labor organization report the payment made to an organization such as the Kaiser Family Foundation that directly produces research and writes papers, which may be indirectly used by others to impact legislation? This research can also be used indirectly in contract negotiations. Should the payment be characterized as political activity under Schedule 16, a contribution under Schedule 17, or could it be union administration in Schedule 19? What if the labor organization's subjective motivation in supporting the foundation is to generate factual evidence which will influence legislation or, for example, provide targeted information for negotiations? What if the payments are made to an entity without nonprofit or not-for-profit status?
• New! Wages for a local union's officers are paid by a district council and the local then reimburses the district council for the wages and associated benefits. How should this be reported by the local and district council?
• What about disbursements that don't seem to fit anywhere?
• New! Should cell phone charges and telephone calling cards for officers and employees be reported in Schedules 11 and 12 or should they be reported in Schedules 15 through 19? If they should be reported in Schedules 15 through 19, would it be reasonable to allocate each individual's telephone charges to Schedules 15 through 19 based on the time allocation percentages for each officer or employee?
• The IU has an apartment in another city - does the expense for that go in overhead or is it allocated by use?
• Some members might earn enough to pay working dues of $5,000 or more. Would the union have to complete an Initial Itemization Page for each of those members?
• For credit card transactions, should the union use the date of the charge or the date of the payment?
• New! If a credit card charge and credit appear on the same statement should the charge and credit not be reported since no money has been paid out or received?
• How detailed do the "break outs" have to be for credit card charges?
• How are multiple credit cards that are charged to a single credit account grouped?
• What date is to be listed for the aggregated amounts? Can the union list the end of the year or does it have to list each item of the aggregate with the date of the disbursement?
• If a labor organization makes a payment to a vendor (e.g., a travel agency) who thereafter makes payments to third party vendors (airlines, rental car agencies), how are the disbursements to be reported? Who is the vendor for purposes of completing the itemization pages?
• If a union uses Expedia to book its travel on line, do the same requirements relating to identifying the vendor on credit card charges still apply?
• For credit card payments for air travel, do you aggregate the costs of plane tickets from different carriers such as United and USAir?
• Regarding airline travel, how do I assign separate credit card charges to functional categories?
• When paying credit card charges, such as room rent charges on hotel bills and airline travel, does the union have to attribute the charges to union officers and employees by name?
• If a union pays several invoices from a law firm with one check, how should that be reported?
• If a law firm is handling several cases in one category, is it necessary to separate them by case?
• If you have a lawyer that supports you in many different areas, is there a schedule for each category?
• Some legal bills list details by date but not case. Does the union have to go through each bill and categorize them?
• How are retainers for law firms reported?
• Assume a union has three different invoices from the same caterer for catering three different meetings: 1st meeting $1,700 - all representational - meeting took place October 1 2nd meeting $1,700 - all representational - meeting took place October 15 3rd meeting $1,700 - all representational - meeting took place November 1 The union's accounting software combines open invoices of the same vendor in the system and issues one check for $5,100. How does this get reported?
• If a union makes only a minimum payment on a credit card, how does it report that?
• Does the union have to allocate rent, telephone, utilities, etc. according to the five categories?
• If an employee is typing a letter, must the union allocate his/her time by what he/she is typing?
• Which category does an officer put for the time spent learning about the new reporting requirements and completing the forms?
• Where should a union report "sympathy" strike benefits for workers who are not its members?
• What do I report in Schedule 14-Other Receipts?
• New! Pursuant to a dues checkoff arrangement, contractors withhold working dues from members and remit the dues monthly to the union. The remittance from a contractor will usually exceed $5,000 but the amount for each member will never exceed $5,000. Does the receipt from the contractor need to be itemized on an initial itemization page for Schedule 14 (Other Receipts)?
• If a labor organization makes payments to different hotels within a chain (such as a Hyatt in Washington and a Hyatt in New York), do the different hotels count as a single entity for determining whether the disbursements are major for purposes of Schedules 15 through 19?
• What do I report in Schedule 15 - Representational Activities?
• What is the relationship between the percentage of the labor organization's disbursements used for representation activities and the portion of nonmember fees that is chargeable to nonmembers under Beck and other Supreme Court decisions?
• If a federal union disburses funds to lobby Congress for the passage of legislation that will provide better job security and wages to its members, are those disbursements reportable in Schedule 15 or 16?
• If a union disburses funds to fight the implementation of the new LM-2 and T-1 reports, are those disbursements reportable in Schedule 15 or 16?
• New! Where should a union report strike operating expenses like burn barrels, picket signs, shelters, etc?
• A union has a targeting fund by which the local makes payments to union contractors in order to make them competitive with non-union contractors. These amounts would total or exceed $5,000 in a reporting year. The union does not want to name these union contractors in Schedule 15 because this would become an enormous advantage to a nonunion contractor when bidding on jobs. This situation is not one of the examples in the LM-2 instructions for which confidentiality can be claimed. Can confidentiality be cited for the situation described by this union?
• What do I report in Schedule 16 - Political activities and Lobbying?
• What must I report in Schedule 17 - Contributions, Gifts and Grants?
• On Schedule 17, what is a contribution and what would be considered time spent in this category?
• How should a labor organization report expenditures which are made in support of the members of other labor organizations (strike or litigation support), or on behalf of working people more generally (litigation or public demonstrations of support), where the objective is not to influence legislation and not to organize new members or negotiate an agreement on behalf of existing members? May expenditures on Schedule 17 (Contributions) include those made to entities which are not non-profit or not-for-profit institutions?
• New! My union made a payment of $6,000 to an employer pursuant to the union's job targeting program. Is it appropriate to report the payment in Schedule 17 (Contributions, Gifts, and Grants) on the revised Form LM-2 with a notation that the purpose was a job targeting payment to increase member work opportunities?
• What is the difference between Schedule 18, General Overhead, and Schedule 19, Union Administration?
• What must I report in Schedule 18 - General Overhead?
• Does the phone bill for the political department go in General Overhead?
• Where would disbursements for telephone costs and for the IT and accounting department be reported?
• New! Since the Form LM-2 no longer has disbursement categories for office and administrative expense, education and publicity expense, and professional fees, how should a union categorize disbursements such as utilities, office supplies, accountant fees, and telephone book listings?
• If a building housed three employees, one of which spent 100% of the time organizing, one of which spent 100% of the time on union administration, and one of which spent 100% of the time on lobbying, how do you functionally report the light bill for the building? Do you split the light bill equally among the three functions or is it to be recorded as general overhead?
• Should the time of employees who perform payroll functions for the union be allocated to Schedule 18, General Overhead, or Schedule 19, Union Administration?
• What do I report in Schedule 19 - Union Administration?
• Are the costs of a labor organization's day-to-day operations allocated to Schedule 18, General Overhead, or Schedule 19, Union Administration?
• If a labor organization has its own printing department, are those costs allocated or do they go into overhead?
• Are the costs of magazines and other periodicals considered to be for Union Administration and reported in Schedule 19?

Back to Top

Q. How do I complete Schedules 14 through 19?

A. Before completing the Detailed Summary Page for Schedules 14 through 19, complete an Initial Itemization Page and a Continuation Itemization Page(s), as necessary, for each payer/payee for whom there is (1) an individual receipt/disbursement of $5,000 or more or (2) total receipts/disbursements that aggregate to $5,000 or more during the reporting period. A separate set of continuation pages must be used for these schedules.

An Initial Itemization Page must be completed for each such payee/payer. If the union is using the reporting software provided by the Department, the Initial Itemization Page will expand to fit the number of receipts/disbursements from the payee/payer. If the union is completing the report in paper format and more than one page is needed for a single payee/payer, the Continuation Itemization Page should be used for all subsequent pages.

Q. What will happen if items are mistakenly posted and reported in the wrong schedule?

A. If mistakes are discovered, an amended report can be filed.

Q. In many instances labor organizations will make a single disbursement to a vendor for multiple purposes that fall under more than one functional category. How can a labor organization accurately allocate a single disbursement to multiple functional categories?

A. Labor organizations should use all available data in order to accurately allocate disbursements to the appropriate functional categories. When it is not possible to be precise, good faith estimates are acceptable.

Q. If a union pays a printing company to print a monthly newsletter, is the union required to analyze the content of the newsletter each month to determine what percentage of the payment to the printer should be reported in Schedules 15, 16, 17, 18 or 19? Would it be acceptable for the union to analyze the content of the newsletter for one month and then extrapolate those same percentages throughout the rest of the year?

A. The extrapolation method would be acceptable if the monthly newsletter selected is generally representative of the content of the newsletter throughout the year. However, the percentages should be modified for any month if circumstances warrant. A union may also choose to report the entire cost of the newsletter as general overhead or union administration if it wishes.

Q. Would it be a fair statement to make that we do not need to track disbursements into functional categories for per capita tax, strike benefits, fines, assessments, supplies for resale, purchase of investments and fixed assets, loans made, repayments of loans obtained, direct taxes, withholding taxes and payroll deductions as they are reported elsewhere on Statement B?

A. That is correct. Disbursements that are reported in Items 55 through 67 are not allocated among the functional categories in Schedules 15 through 19.

Q. With the instructions requiring the reporting of direct and indirect payments in Schedules 15 through 19, how would a labor organization report the payment made to an organization such as the Kaiser Family Foundation that directly produces research and writes papers, which may be indirectly used by others to impact legislation? This research can also be used indirectly in contract negotiations. Should the payment be characterized as political activity under Schedule 16, a contribution under Schedule 17, or could it be union administration in Schedule 19? What if the labor organization's subjective motivation in supporting the foundation is to generate factual evidence which will influence legislation or, for example, provide targeted information for negotiations? What if the payments are made to an entity without nonprofit or not-for-profit status?

A. The purpose of the disbursement should determine where it is reported. If it is a disbursement for research used to affect legislation, it should be reported as political activity on Schedule 16. If it is primarily a charitable contribution the disbursement should be reported as such on Schedule 17. If the research is to aid union administration the disbursement should be reported on Schedule 19. The profit or non-profit status of an entity may help shed light on the purpose of a disbursement, but it is not necessarily a relevant factor.

Back to Top

Q. Wages for a local union's officers are paid by a district council and the local then reimburses the district council for the wages and associated benefits. How should this be reported by the local and district council?

A. The local should report the amount that it reimburses the district council for officers' wages in Schedule 11 of the Form LM-2 by each officer's name with an explanation in Item 69 (Additional Information) that the wages are paid by reimbursing the district council. The amount that the local reimburses the district council for benefits should be included in Schedule 20 (Benefits). The district council should report its disbursements to the local officers in Schedule 18 (General Overhead) with a notation in the purpose column that it was a salary payment to be reimbursed by Local xx.

Q. What about disbursements that don't seem to fit anywhere?

A. Every disbursement has to be reported somewhere on the forms. The labor organization must use its judgment to determine the most appropriate category.

Q. Should cell phone charges and telephone calling cards for officers and employees be reported in Schedules 11 and 12 or should they be reported in Schedules 15 through 19? If they should be reported in Schedules 15 through 19, would it be reasonable to allocate each individual's telephone charges to Schedules 15 through 19 based on the time allocation percentages for each officer or employee?

A. If the cell phones are provided to the union's officers and employees for business use, the cost and charges can be allocated to Schedules 15 through 19 on the revised Form LM-2. Using the time allocation percentages that each individual turns in at the end of the year would seem reasonable and acceptable. Alternatively, the cost and charges of the business use of the cell phones can be reported in Schedule 18, General Overhead. Telephone calling card charges may be treated in the same manner.

If identifiable excess costs are incurred because of personal use of the cell phone or calling card, such as long distance personal calls that are itemized on the phone bill and charged above the basic cost of the cell phone service, those excess costs must be reported in Column (G) of Schedules 11 and 12, as applicable.

Q. The IU has an apartment in another city - does the expense for that go in overhead or is it allocated by use?

A. If, for example, the union owns a condominium apartment in Washington D.C. for the use of officers and employees on official business whose workplace is in another city, the disbursements should, if possible, be allocated among the schedules identified with a particular function. If it is not possible to otherwise allocate the disbursements, the total disbursements should be reported as General Overhead. If, however, the apartment is for the use of a particular officer or employee, the disbursements should be reported in Schedule 11 or 12 by the officer's or employee's name.

Q. Some members might earn enough to pay working dues of $5,000 or more. Would the union have to complete an Initial Itemization Page for each of those members?

A. No, dues are reported in Statement B, Item 36, which does not require itemization.

Q. For credit card transactions, should the union use the date of the charge or the date of the payment?

A. In order for cash to balance, the date of the payment should be used.

Q. If a credit card charge and credit appear on the same statement should the charge and credit not be reported since no money has been paid out or received?

A. No report is required provided that the charge and credit apply to the same transaction (not merely the same vendor) and appear on the same statement.

Q. How detailed do the "break outs" have to be for credit card charges?

A. Each payee should be listed separately. For example, in arranging a convention, the union may contract for arrangements to be made by an event coordinator, such as a hotel or travel agency, including the hiring and payment of subcontractors providing services. In this situation, the event coordinator would be the sole payee listed. If, however, the event coordinator is paid a fee for its services and subcontractors providing services are to be paid directly by the union, then the event coordinator and the individual subcontractors should be listed as payees.

Q. How are multiple credit cards that are charged to a single credit account grouped?

A. Each charge is a separate item. The charges are grouped by the party that provided the goods and/or services that were charged in order to determine which charges must be itemized. The charges are also grouped by the activity in order to determine how they should be allocated among Schedules 15 through 19.

Back to Top

Q. What date is to be listed for the aggregated amounts? Can the union list the end of the year or does it have to list each item of the aggregate with the date of the disbursement?

A. Aggregated disbursements are not required to be itemized. The only disbursements which must be itemized and for which a date must be listed are individual disbursements of $5,000 or more.

Q. If a labor organization makes a payment to a vendor (e.g., a travel agency) who thereafter makes payments to third party vendors (airlines, rental car agencies), how are the disbursements to be reported? Who is the vendor for purposes of completing the itemization pages?

A. The third party vendors (e.g., airlines, rental car agencies) are considered the vendors for itemization purposes. There may, of course, be situations where a travel agency or other vendor sells a package that includes services or products from other vendors for whom the amount of the disbursement cannot be easily identified. In such a situation it is unnecessary to separately identify those vendors.

Q. If a union uses Expedia to book its travel on line, do the same requirements relating to identifying the vendor on credit card charges still apply?

A. Yes, regardless of whether travel is booked through a travel agency or an on-line travel service, the union's disbursements should be allocated to the vendors who provided the services (airline, hotel, etc.). However, if the union has purchased a pre-set package from a travel agency or on-line service where the consumer does not know how much of the cost was for individual components of the package, the travel agency or on-line service can be listed as the vendor.

Q. For credit card payments for air travel, do you aggregate the costs of plane tickets from different carriers such as United and USAir?

A. We would consider each carrier to be one vendor for purposes of aggregating disbursements for itemization. Therefore, all disbursements to USAir relating to a single schedule should be aggregated and reported on an initial itemization page for USAir. Single disbursements of $5,000 or more would be listed as itemized disbursements, with the purpose, date and amount of each such transaction. Disbursements that are less than $5,000 would be included in the total of all non-itemized transactions with USAir, on Line I of the initial itemization page. Disbursements to United would be reported similarly on an initial itemization page for that vendor.

Q. Regarding airline travel, how do I assign separate credit card charges to functional categories?

A. Your allocation should be based on a reasonable method and good judgment. For example, if a flight is for an employee of the union who will provide about 30% of his time on representational activities (assisting with contract negotiations) and 70% of is time on union administration (attending a convention), the allocation should be made to the schedules for these activities. If, however, the purpose of the trip was to attend the convention and while there the employee engaged in some incidental activities under other categories, the union could reasonably decide to report the airline charge entirely as union administration.

Q. When paying credit card charges, such as room rent charges on hotel bills and airline travel, does the union have to attribute the charges to union officers and employees by name?

A. No. You do not have to attribute indirect disbursements for temporary hotel lodging or transportation by public carrier to an officer or employee by name when the individual is in travel status away from his or her home and principal place of employment with the labor organization. You should allocate such disbursements to Schedules 15 through 19, as appropriate.

Q. If a union pays several invoices from a law firm with one check, how should that be reported?

A. Itemized information must be reported for disbursements that are over $5,000 in a particular category; the answer to this question depends on the amount of the check and whether it represents payment for services that may be attributable to more than one category. Assume the payment to the law firm for all of the invoices totals $45,000 and one third is attributable to representation activities, one third to overhead, and one third to lobbying. The union should report $15,000 in Schedule 15 (Representational Activities), $15,000 in Schedule 19 (Union Administration), and $15,000 in Schedule 16 (Political Activities and Lobbying), and itemized information should be provided for each payment in each schedule. If the check totals $45,000 and represents $40,000 for Representational Activities, $3,000 for Union Administration, and $2,000 for Political Activities and Lobbying, the relevant amounts should be reported in the appropriate schedules, but itemized information need only be reported for the $40,000 amount.

Q. If a law firm is handling several cases in one category, is it necessary to separate them by case?

A. No. The requirement is to report disbursements by purpose as indicated in Statement B, not by case.

Q. If you have a lawyer that supports you in many different areas, is there a schedule for each category?

A. The disbursements to outside attorneys must be allocated among the appropriate items and schedules indicating the services they provided.

Back to Top

Q. Some legal bills list details by date but not case. Does the union have to go through each bill and categorize them?

A. You should request the law firm to provide sufficient detail to complete the LM-2. If precise information is not available for each bill, the disbursements may be reported in appropriate categories based upon the proportion of work done by the firm in each category.

Q. How are retainers for law firms reported?

A. You should request the law firm to provide sufficient detail about the services rendered for the retainer to complete the LM-2.

Q. Assume a union has three different invoices from the same caterer for catering three different meetings:

1st meeting $1,700 - all representational - meeting took place October 1 2nd meeting $1,700 - all representational - meeting took place October 15 3rd meeting $1,700 - all representational - meeting took place November 1

The union's accounting software combines open invoices of the same vendor in the system and issues one check for $5,100. How does this get reported?

A. This is one disbursement of $5,100 and should be itemized on an initial itemization page for the caterer for Schedule 15, Representational Activities.

Q. If a union makes only a minimum payment on a credit card, how does it report that?

A. You must allocate all transactions charged to a credit card to one of the disbursement categories in Statement B. If you make a payment that is less than the full amount due for a particular credit card statement, you must continue to allocate subsequent payments against the unpaid balance until it has been paid in full.

Q. Does the union have to allocate rent, telephone, utilities, etc. according to the five categories?

A. Generally these disbursements would be reported in Schedule 18, "General Overhead." But if any disbursements can be attributed to a specific activity, such as a phone bank set up to coordinate an organizing campaign, they should be included in the appropriate schedule for that activity.

Q. If an employee is typing a letter, must the union allocate his/her time by what he/she is typing?

A. A rule of reason should be used in allocating time. If a support staff member works in a department where all of his or her time can be allocated to a specific function, such as representational activity, that should be done. However, salary and other disbursements for general support staff can be reported in Schedule 18, General Overhead. If an employee supports a specific officer, however, the employee's salary should be allocated in the same way as the officer he/she supports.

Q. Which category does an officer put for the time spent learning about the new reporting requirements and completing the forms?

A. Schedule 19, "Union Administration."

Q. Where should a union report "sympathy" strike benefits for workers who are not its members?

A. Contributions in support of strikers in other unions should be reported in Schedule 17, Contributions, Gifts, and Grants.

Q. What do I report in Schedule 14-Other Receipts?

A. In this schedule report payments from persons or entities to your labor organization during the reporting period, other than those that must be reported elsewhere in Statement B, such as reimbursements from officers and employees for excess expense payments or travel advances not reported as loans in Schedule 2 (Loans Receivable); receipts from fundraising activities such as raffles, bingo games, and dances; funds received from a parent body, other unions, or the public for strike fund assistance; and receipts from another labor organization which merged into the reporting labor organization.

Q. Pursuant to a dues checkoff arrangement, contractors withhold working dues from members and remit the dues monthly to the union. The remittance from a contractor will usually exceed $5,000 but the amount for each member will never exceed $5,000. Does the receipt from the contractor need to be itemized on an initial itemization page for Schedule 14 (Other Receipts)?

A. Dues received through a checkoff arrangement are not reported in Schedule 14. They should be reported in Item 36 and do not have to be itemized. Schedule 14 is only for receipts not covered by Items 36-47.

Back to Top

Q. If a labor organization makes payments to different hotels within a chain (such as a Hyatt in Washington and a Hyatt in New York), do the different hotels count as a single entity for determining whether the disbursements are major for purposes of Schedules 15 through 19?

A. No. Only disbursements to the same entity or individual must be aggregated. A chain of hotels is not ordinarily a single entity. In these situations, if the disbursements are made payable to apparently distinct entities with different names, labor organizations need not conduct further investigation to determine whether they are actually a single entity.

Q. What do I report in Schedule 15 - Representational Activities?

A. In this schedule report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period associated with preparation for, and participation in, the negotiation of collective bargaining agreements and the administration and enforcement of the agreements made by the labor organization. Do not include strike benefits that must be reported in Item 57 (Strike Benefits) of Statement B. Also report disbursements associated with efforts to become the exclusive bargaining representative for any unit of employees, or to keep from losing a unit in a decertification election or to another labor organization, or to recruit new members.

Q. What is the relationship between the percentage of the labor organization's disbursements used for representation activities and the portion of nonmember fees that is chargeable to nonmembers under Beck and other Supreme Court decisions?

A. The reporting requirements for Form LM-2 are based on the disclosure purposes of the LMRDA. Information that is relevant for these purposes may also be relevant for purposes of the Supreme Court's decision in Beck, which requires affected unions, upon objection by an agency fee payer, to subtract from the amount of the dues required of members a sum that reflects the per capita share of the union's activities that are not germane to its representational function. It is not, however, the intent of the Department of Labor to collect information specific to the Beck requirements.

Q. If a federal union disburses funds to lobby Congress for the passage of legislation that will provide better job security and wages to its members, are those disbursements reportable in Schedule 15 or 16?

A. These disbursements should be reported in Schedule 16.

Q. If a union disburses funds to fight the implementation of the new LM-2 and T-1 reports, are those disbursements reportable in Schedule 15 or 16?

A. These disbursements should be reported in Schedule 16.

Q. Where should a union report strike operating expenses like burn barrels, picket signs, shelters, etc?

A. Disbursements associated with strike operating expenses should be reported in Schedule 15 (Representational Activities). Strike benefits, however, should be reported in Item 57 of Statement B.

Q. A union has a targeting fund by which the local makes payments to union contractors in order to make them competitive with non-union contractors. These amounts would total or exceed $5,000 in a reporting year. The union does not want to name these union contractors in Schedule 15 because this would become an enormous advantage to a nonunion contractor when bidding on jobs. This situation is not one of the examples in the LM-2 instructions for which confidentiality can be claimed. Can confidentiality be cited for the situation described by this union?

A. A disbursement must be reported in the normal manner if it is not encompassed within one of the five types of information listed in the instructions for Form LM-2 for which special procedures for reporting confidential information can be used. Disbursement of job targeting funds that exceed the itemization threshold should thus be disclosed.

Q. What do I report in Schedule 16 - Political activities and Lobbying?

A. In this schedule report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period associated with political disbursements or contributions of money. Also report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period associated with dealing with the executive and legislative branches of Federal, state, and local governments and with independent agencies and staffs to advance the passage or defeat of existing or potential laws or the promulgation or any other action with respect to rules or regulations (including litigation expenses). It does not matter whether the lobbying attempt succeeds.

Also report any disbursement or contribution that is intended to influence the selection, nomination, election, or appointment of anyone to a Federal, state, or local executive, legislative or judicial public office, or office in a political organization, or the election of Presidential or Vice Presidential electors, and support for or opposition to ballot referenda. It does not matter whether the attempt succeeds. Include disbursements for communications with members (or agency fee paying nonmembers) and their families for registration, get-out-the-vote and voter education campaigns, the expenses of establishing, administering and soliciting contributions to union segregated political funds (or PACs), disbursements to political organizations as defined by the IRS in 26 U.S.C. 527, and other political disbursements.

Q: What must I report in Schedule 17 - Contributions, Gifts and Grants?

A. In Schedule 17 report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period associated with contributions, gifts, and grants, other than those reported in Schedules 15, 16, and 20. Include, for example, charitable contributions, contributions to scholarship funds, etc.

Q. On Schedule 17, what is a contribution and what would be considered time spent in this category?

A. Contributions include more than disbursements for charitable expenses. As an example, if the union sponsored a youth baseball team, then the percentage of time officers and employees spent in activities relating to the support of the team, arranging uniforms, etc would be allocated to Schedule 17 on Line I of Schedule 11 or 12. Other disbursements for the union's support of the team, such as payments for uniforms, would be reported in Schedule 17. If the union made total disbursements of $5,000 or more to a single payee for any disbursements reported in Schedule 17, it would complete an Initial Itemization Page for Schedule 17 for that payee.

Back to Top

Q. How should a labor organization report expenditures which are made in support of the members of other labor organizations (strike or litigation support), or on behalf of working people more generally (litigation or public demonstrations of support), where the objective is not to influence legislation and not to organize new members or negotiate an agreement on behalf of existing members? May expenditures on Schedule 17 (Contributions) include those made to entities which are not non-profit or not-for-profit institutions?

A. Labor organizations should use all available data in order to accurately allocate disbursements to the appropriate functional categories. To the extent that disbursements are made to enhance the union's ability to represent its members or to influence legislation or political elections, however circuitously, such as to strengthen the labor movement generally or to draw attention to adverse legislation or disfavored candidates, those disbursements should be allocated to the relevant schedule. Disbursements to be included in Schedule 17 are not limited to disbursements to non-profit or not-for-profit entities.

Q. My union made a payment of $6,000 to an employer pursuant to the union's job targeting program. Is it appropriate to report the payment in Schedule 17 (Contributions, Gifts, and Grants) on the revised Form LM-2 with a notation that the purpose was a job targeting payment to increase member work opportunities?

A. Yes, that is an appropriate way to report the payment.

Q. What is the difference between Schedule 18, General Overhead, and Schedule 19, Union Administration?

A. Generally, disbursements for union administration relate to the general governance of the union (such as officer elections, meetings, member education, etc.) and complying with obligations established by the government (such as filing Form LM-2 reports). Disbursements for operating expenses that cannot be allocated to any of the disbursement categories in Statement B of Form LM-2 should be included in General Overhead.

Q. What must I report in Schedule 18 - General Overhead?

A. In Schedule 18 report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period that cannot be allocated to any of the other disbursement categories in Statement B.

Some disbursements for overhead do not support a specific function, so these disbursements should be reported in this schedule. Include support personnel at the labor organization's headquarters, such as building maintenance personnel and security guards, and other overhead costs. Not all support staff should be included in General Overhead. For instance, the salary of an assistant, whenever possible, should be allocated at the same ratio as the person or persons to whom they provide support.

Q. Does the phone bill for the political department go in General Overhead?

A. If the union pays its total phone bill without differentiating the purpose for which calls are made, the payment for that bill may be reported in General Overhead. If the phone bill is for use of the phones identified with a particular purpose which fits within one of the schedules on Form LM-2, the payment should be reported in that schedule. Accordingly, a disbursement for a phone bill for the political department probably should be reported on Schedule 16 as a disbursement for Political Activities and Lobbying.

Back to Top

Q. Where would disbursements for telephone costs and for the IT and accounting department be reported?

A. Generally these would go in Schedule 18, General Overhead. But if a phone bank is used for a specific activity then it should be put in the appropriate schedule for that activity.

Q. Since the revised Form LM-2 no longer has disbursement categories for office and administrative expense, education and publicity expense, and professional fees, how should a union categorize disbursements such as utilities, office supplies, accountant fees, and telephone book listings?

A. These disbursements are the type that would be reported in Schedule 18, General Overhead, unless they are specifically related to one of the other functional categories.

Q. If a building housed three employees, one of which spent 100% of the time organizing, one of which spent 100% of the time on union administration, and one of which spent 100% of the time on lobbying, how do you functionally report the light bill for the building? Do you split the light bill equally among the three functions or is it to be recorded as general overhead?

A. If a reporting union can allocate the disbursement among the three functions they may do so or they may choose to report disbursements such as this under General Overhead.

Q. Should the time of employees who perform payroll functions for the union be allocated to Schedule 18, General Overhead, or Schedule 19, Union Administration?

A. Schedule 18, General Overhead.

Q. What do I report in Schedule 19 - Union Administration?

A. In Schedule 19 report the labor organization's direct and indirect disbursements to all entities and individuals during the reporting period associated with union administration. Union administration includes disbursements relating to the nomination and election of union officers, the union's regular membership meetings, intermediate, national and international meetings, union disciplinary proceedings, the administration of trusteeships, and the administration of apprenticeship and member education programs (not including political education which should be reported in Schedule 16).

Q. Are the costs of a labor organization's day-to-day operations allocated to Schedule 18, General Overhead, or Schedule 19, Union Administration?

A. This is a judgment call that must be made on a case-by-case basis, and the determination depends on what each cost is for.

Q. If a labor organization has its own printing department, are those costs allocated or do they go into overhead?

A. This is a judgment call that must be made depending on what the costs are for.

Q. Are the costs of magazines and other periodicals considered to be for Union Administration and reported in Schedule 19?

A. If the cost supports a specific activity category it should be reported in the appropriate schedule. Otherwise it would probably go in General Overhead, Schedule 18.

Last Updated: 03/23/07