100% public sector intermediate bodies would be covered if international or national union is  mixed public/private sector

The Office of Labor-Management Standards (OLMS) published, on December 17, 2019, a Notice of Proposed Rulemaking (NPRM) to promulgate a rule governing intermediate bodies that are wholly composed of public sector organizations but are subordinate to national or international labor organizations that are covered by the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), 29 U.S.C. 401 et seq.  See: https://www.govinfo.gov/content/pkg/FR-2019-12-17/pdf/2019-26699.pdf.  Under the proposed rule, such intermediate bodies would now be covered by the LMRDA, and would be required to file the annual union financial reports.