Advisory on Public Disclosure Reporting in Areas Affected by the Coronavirus (COVID-19)

Public Disclosure Reports

Labor unions, labor relations consultants, and employers affected by COVID-19 must make a good faith effort to file required public disclosure reports.  The failure to file a timely and complete report is an ongoing violation of the LMRDA.  OLMS (Office of Labor-Management Standards) has jurisdiction to file a civil enforcement action concerning a failure to meet reporting requirements.  OLMS will not, however, pursue a civil enforcement action with regard to a delinquent or deficient report when these reporting violations are attributable to COVID-19.  Unions, employers, and labor relations consultants wishing to take advantage of this enforcement policy should contact OLMS before the report is due, describe the circumstances necessitating additional time, and provide a date certain by which the report can reasonably be submitted.  Under these circumstances, OLMS will not lodge a civil enforcement action to obtain the delinquent or deficient report.

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