DoL Rescinds T-1 Reporting Requirement for Union Trusts

December 1, 2010 ( – The U.S. Department of Labor has rescinded the Form T-1 reporting requirement for union trusts controlled by union officials.

The department’s decision will roll back a 2008 rule under which unions were required to annually file a Form T-1 for trusts in which a union, alone or in combination with other unions, possesses managerial control or financial dominance (see DoL Puts out Union Disclosure Final Rule). The T-1 provided information to union members and the public about the trusts, for which there was previously little, if any, financial disclosure.  

In the Office of Labor-Management Standards’ February proposal to rescind the rule, it said it believes that the trust reporting required under the rule is overly broad and is not necessary to prevent the circumvention and evasion of the Title II reporting requirements. In addition, OLMS said it views separate trust reporting requirements as unnecessary, in part because it also proposes to return “subsidiary organization” reporting to the Form LM-2 reporting requirements, which it believes is necessary to satisfy the purposes of the Labor-Management Reporting and Disclosure Act (LMRDA).  

In a statement against the DoL’s decision, Representative John Kline (R-Minnesota), the U.S. House Education and Labor Committee’s senior Republican member, said: “Regrettably, this decision will roll back commonsense financial reporting and disclosure requirements that would have given workers a better understanding of how union dues are spent.”