The Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) requires records be maintained which provide accountability and transparency of financial activity within a labor organization. Specifically, Section 206 of the LMRDA requires a labor organization to “maintain records that are sufficient to permit filed reports to be verified, explained and checked for accuracy and completeness.”
Sufficient detail should include the “5 Ws”
In most instances, the terms “what,” “when” and “where” are satisfied on the face of the receipt. The remaining terms usually requiring documentation are “who” and “why.” Notations should be written on the receipt providing information to satisfy any and/or all “5 Ws” if not clearly indicated on the receipt.
For credit card expenses, the labor organization must maintain original, itemized receipts for each credit card charge, including itemized hotel invoices, transportation costs and itemized meal receipts from restaurants. As for meal expenses when dining with another person or persons, records must also include a written explanation of the specific business conducted and full names and titles of those persons in attendance who incurred the food and beverage charges. In the case of lodging, airfare and other travel expenses, additional information identifying the purpose or reason for the travel must be recorded.
Reimbursed meal and entertainment expenses require the names of the individuals present for such expenses, the location(s) where those expenses were incurred and the nature of the business requiring the expenses. If a vendor is unable to provide documentation for an expense, the individual incurring the expense should clearly identify the date, amount, purpose and location where the expense was incurred, separately indicating that a receipt was not provided for the expense. It is recommended that individuals record the required information on the receipt or invoice at the time the expense was incurred.
Another reimbursed expense is mileage for personal vehicles used for union business travel. Records must be maintained which identify the date of travel, locations traveled to and from, number of miles driven and the business purpose of each use.
Refer to the U.S. Department of Labor Office of Labor-Management Standards for further information, or visit www.dol.gov/olms/regs/compliance/
By Chad Fennell, Manager, firstname.lastname@example.org