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.
Please contact us if you need clarification or assistance.
