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Department of Labor To Propose Reversal of Form T-1; OLMS Decides Not to Enforce Filings

Yesterday, on March 29, the Department of Labor issued a statement on its intent to rescind the implementation of the Form T-1. In the meantime, with initial Form T-1 reports due to be filed by September 28, 2021, the Office of Labor-Management Standards “will not seek to enforce the filing of a Form T-1 for one year from the date a labor organization’s first Form T-1 is due.”

“In the spring 2021 Semi-Annual Regulatory Agenda, the Office of Labor-Management Standards (OLMS) will publish notice of an intended rulemaking to propose rescission of the Form T-1 Trust Annual Report, established by a March 2020 final rule. See: www.dol.gov/agencies/olms/laws/regulations/final-rule-t1. Fundamental questions exist regarding the rule’s legal basis and policy justifications, but, under the current rule, initial Form T-1 reports must be filed by September 28, 2021.”

Click here to read the the full notice from Department of Labor.

For additional information regarding your T-1 filing, please view our guidance videos here or reach out to a member of our Labor Team.

Labor Union Services

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