January 3, 2022

DOL Publishes Final Rule to Rescind Form T-1

In March 2020, the Department of Labor (DOL) published a final rule establishing the Form T-1, Trust Annual Report. Under this rule, labor organizations with $250,000 or greater in annual receipts that file a Form LM-2 would be required to file a separate report covering the finances of certain trusts in which they were interested, such as apprentice training plans, labor-management cooperation committees, strike funds, and building corporations.
On March 29, 2021, the DOL announced that it would not enforce the filing of a Form T-1 for one year from the date a labor organization’s first Form T-1 is due. On May 27, 2021, the notice of proposed rulemaking was published to the Federal Register to rescind the Form T-1 Final Rule, and on December 30, 2021, the Final Rule rescinding Form T-1 was published with an effective date of January 31, 2022.

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