Compliance Blog

You may remember that in December of last year The Compliance Guy blogged about the LM-30 form reporting requirements for labor union organization (“union”) officials. The purpose of LM-30 form, according to the Department of Labor (“DOL”), is to help ensure that union officials act in the best interest of their unions.  Union officials are defined as officers and employees of a union who perform more than clerical or custodial services.

In accordance with LM-30 reporting requirements, transactions between union officials and credit unions must be reported by the union official if the union he works for is or potentially will be representing the credit union’s employees or if the credit union is a trust (“trust” refers to situations in which a credit union is established to provide benefits to union members, etc.).  It should be noted that the reporting requirements require union officials, not credit unions, to report transactions to the DOL.

NAFCU was concerned that the LM-30 reporting requirements might have a disproportionate effect on credit unions and wrote to the DOL for clarification.  The DOL responded to NAFCU with a letter that clearly stated that not-for-profit organizations like credit unions are not considered “businesses” for purposes of these rules.  Because credit unions are not “businesses,” many aspects of the reporting requirements do not affect credit unions as some feared they would.

Nevertheless, credit unions may be faced with union officials who need assistance on this matter and may want to inform these members of the reporting requirements.  In addition, there are several other details of the reporting requirements that union officials should know.  This PowerPoint from the DOL website is a very useful tool for union officials.  Click here to access the LM-30 Information Page from the DOL website.

Bottom Line: Credit unions that are or may be unionized and credit unions that are acting as trusts for a union should be aware that their members may be subject to LM-30 reporting requirements.

If you have any further questions on this matter, please feel free to contact Pamela Yu at pyu@nafcu.org.

(The Compliance Guy wants to thank Thaddeus King, one of NAFCU's Regulatory Interns, for carrying the heavy water for this post.)