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Department of Labor Employment Standards Administration

Office of Labor-Management Standards
Denver District Office
1999 Broadway
Suite 2435
Denver, CO 80202-5712
(720) 264-3232 Fax:(720) 264-3230

August 31,2007

Mr. David Steinbach, President

APWU Local 3477
PO Box 260211
Littleton, CO 80613-0211
LM File Number: 507-547

Dear Mr. Steinbach,

This office has recently completed an audit of American Postal Workers Local 3477
under the Compliance Audit Program (CAP) to determine your organiz tion's
compliance with the provisions of the Labor-Management Reporting an Disclosure
Act of 1959 (LMRDA). As discussed during the exit interview with David Steinbach on
August 31,2007, 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 I1 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

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
Mr. David Steinbach
August 31,2007
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source of that money. The labor organization must also retain bank records for all

The audit of Local 3477's 2006 records revealed the following recordkeeping violations:

1. Failure to Maintain Union Records, Credit Card Receipts

Local 3477 officers failed to maintain adequate documentation for credit card
expenses for travel expenses that were direct-paid by the union. The date, amount,
and business purpose of every expense must be recorded on at least one union
record. The union had multiple purchases of, but did not maintain a receipt for
the purchase and simply kept a copy of the reservations as proof of the purchase.
The local used a credit card monthly billing statement as the receipt which was
inadequate because the billing statement did not specifically list what items were
purchased, who traveled and where the travel was to. The audit showed that these
disbursements were made to purchase airline tickets for officer travel. However,
the local only maintained a credit card billing statement as a receipt and did not
have the original signed receipt or confirmation from the website used to make the

The union must maintain itemized receipts provided by vendors to officers and
employees. These itemized receipts are necessary to determine if such
disbursements are for union business purposes and to sufficiently fulfill the
recordkeeping requirement of LMRDA Section 206.

2. Failure to Maintain Union Records, Union Meeting Minutes

Local 3477 failed to maintain meeting minutes for monthly membership meetings
held in June, August, and November 2006. The LMRDA does not require that local
unions hold monthly meetings, but it does require that if the local does hold a
membership meeting, minutes be taken and maintained for five years. .

Based on your assurance that Local 3477 will retain adequate documentation in the
future, OLMS will take no further enforcement action at this time regarding the above
Mr. David Steinbach
August 31,2007
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I want to thank you and APWU Local 3477 officers for your cooperation and courtesy
during this compliance audit. If we can be of any assistance in the future, please do not
hesitate to contact me or any other representative of our office.



cc: Joanne Pearlman, Secretary Treasurer