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U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
St. Louis District Office
1222 Spruce Street
Room 9 109E
St. Louis, MO 63103
(314)539-2667 Fax: (314)539-2626
January 16, 2008
Mr. Peter Boldt, Treasurer
United Brotherhood of Carpenters and Joiners of America
Local 2119
1401 Hampton Avenue
St. Louis MO 63139
LM File Number 041-285
Case Number:-------
Dear Mr. Boldt:
This office has recently completed an audit of Carpenters Local 2119 under the
Compliance Audit Program (CAP) to determine your organization's compliance with
the provisions of the Labor-Management Reporting and Disclosure Act of 1959
(LMRDA). As discussed during the exit interview with you and Walter Mabie on
January 4,2008, 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 requires, among other things, that labor organizations maintain adequate
records for at least five years by which each receipt and disbursement of funds, as well
as all account balances, can be verified, explained, and clarified. As a general rule, labor
organizations must maintain 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. If
an 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 2119's 2007 records revealed that the local did not retain adequate
documentation for disbursements and reimbursed expenses incurred by union officers
totaling at least $6,000; however, all but $929.75 were discussed or approved in the
regular monthly meeting minutes. Here is a sampling of disbursements that lacked the
proper back-up documentation: Check Number min the amount of $40.13 for
refreshments, Check Number the amount of $54.66 to ---
for office supplies, Check umber-in the amount of $58.40 to --for
flowers, Check Number---- amount of $198.32 and office supplies, and Check Number the amount of $89.31
to ---- flowers. The failure to retain receipts occurred with all the officers and was not just
isolated to one or a few, 85 percent of expenses were in the meeting minutes along with
completed vouchers that indicated the executive board, and trustees were aware of and
approved the disbursements.
As previously noted above, labor organizations must retain original receipts, bills, and
vouchers for all disbursements. The president and treasurer 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 2119 will retain adequate documentation in the
future, OLMS will take no further endorsement action at this time regarding the above
violations.
Other Issues
As I discussed during the exit interview with you and Mr. Mabie, the audit revealed
that Local 2119 does not have a clear policy regarding the way that the disbursement
vouchers are created and audited. A review of the policy and handling of Local 2119's
voucher system would enable Local $119 to optimize the internal controls the voucher
system offers.
I want to extend my personal appreciation to Carpenters Local 2119 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. If we can provide any additional assistance, please do not
hesitate to call.
Sincerely,
Investigator
cc: Walter Mabie, Financial Secretary
William Harland, President
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