For the first time since 2003, The Department of Labor is proposing changing the filing threshold for LM-2 forms for labor organizations in the United States. Starting in 2003, all labor organizations with $250,000 in annual receipts had to file LM2 forms with the DOL. Unions with less than $250,000 filed Form LM-3; and those with less than $10,000 filed Form LM-4.
According to the Proposed Rule by the Labor Management Standards Office LM2 forms…
“MUST BE USED BY LABOR ORGANIZATIONS WITH $450,000 OR MORE IN TOTAL ANNUAL RECEIPTS AND LABOR ORGANIZATIONS IN TRUSTEESHIP,” and proposes to revise the thresholds in the Form LM-2 Instructions, Section II, What Form to File, to read: “Every labor organization subject to the LMRDA, CSRA, or FSA with total annual receipts of $450,000 or more must file the Form LM-2. Labor organizations with total annual receipts of less than $450,000 may file the simplified Form LM-3, if not in trusteeship . . . . Labor organizations with total annual receipts of less than $25,000 may file the abbreviated annual report Form LM-4, if not in trusteeship.”
In its official announcement, the DOL emphasized repeatedly that the change in threshold is a means of keeping up with inflation and reducing the burden of reviewing the deluge of LM-2 reports received, consistent with the strictures set out under the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), the Regulatory Flexibility Act (5 U.S.C. 601 et seq.), and host of executive orders regarding federal governmental regulation.
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