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LM-2 Prep Tips, Part 4: Schedules 15-19

Schedules 15 through 19 of the Form LM-2 are used to report the labor organization’s direct and indirect disbursements related to representational activities, political activities, contributions and grants, overhead and administrative costs.

What follows is a summary of each schedule and the types of vendors/transactions to be included in each.

Schedule 15 – Representational Activities

Use this schedule to report disbursements associated with:

  • Preparation for, and participation in, the negotiation of collective bargaining agreements.
  • Administration and enforcement of the agreements made by labor organization.
  • Efforts to become the exclusive bargaining representative for any unit of employees.
  • Efforts to keep from losing a unit in a decertification election or to another labor organization, or to recruit new members.
  • Rebates of dues, for example, those paid by a national or international organization to its local unions, affiliates or members.

Exclude strike benefits, which are reported in Item 57.

This schedule really represents the heart of what the union does- represent the membership. If the union feels that an expenditure was made for the direct purpose of representing members, report it in Schedule 15.

Schedule 16 – Political Activities and Lobbying

Use this schedule to report disbursements associated with, but not limited to, the following:

  • Political disbursements or contributions.
  • Dealing with the executive and legislative branches of the federal, state, and local governments.
  • Advance the passage or defeat of existing or potential laws or the promulgation or any other action with respect to rules or regulations (including litigation expenses).
  • Influence the selection, nomination, election, or appointment of anyone to public office or office in a political organization.
  • Support for or opposition to ballot referenda.
  • Communications with members (or agency fee-paying nonmembers) and their families for registration, get-out-the-vote and voter education campaign.
  • Establishing, administering and soliciting contributions to union segregated political funds (or PACs).

It does not matter whether the lobbying attempt succeeds; all payments related to the matters described above are reported on this schedule. Report expenditures made to influence the outcome of elections and referendums up for vote. Usually, anything that may give the hint of being political will most likely belong on Schedule 15.

Schedule 17 – Contributions, Gifts, and Grants

Use this schedule to report disbursements associated with contributions, gifts and grants (other than what may be reported on Schedules 15, 16 or 20). For example, charitable contributions or contributions to scholarship funds are reported on this schedule.

Schedule 18 – General Overhead

Use this schedule to report disbursements that cannot be allocated to any of the other disbursement categories. Examples of transactions that are typically included in this schedule are:

  • Rent payments
  • Maintenance and repairs
  • Bank, payroll or credit card processing fees
  • Legal services for internal HR matters
  • Interest payments
  • Building cleaning contracts
  • Utilities
  • Insurance
  • Security service contracts
  • Financial auditing costs
  • Office equipment leases
For any questions on how to complete Form LM-2, please contact a member of the Labor Organization Group.

Schedule 19 – Union Administration

Use this schedule to report disbursements associated with:

  • Nomination and election of union officers.
  • Regular membership meetings, intermediate, national and international meetings.
  • Union disciplinary proceedings.
  • Administration of trusteeships.
  • Administration of apprenticeship programs.
  • Member education programs (not including political education which should be reported in Schedule 16 or steward related training reported in Schedule 15.
  • Subsidies, for example, those paid by a national or international organization to its local unions or affiliates.
  • Conventions held for union affiliates and members.

The title of Schedule 19 confuses many preparers. The term Administration is not to be confused with what is normally thought of as general and administrative disbursements. These are the actual costs of governing the union. Any disbursements for what is traditionally considered general and administrative costs would go on Schedule 18.

Helpful Tips for Completing Schedules 15-19

Below are a few things to keep in mind as you prepare these schedules:

  • Complete an itemization page for each payer/payee for whom there is:
    • An individual receipt/disbursement of $5,000 or more.
    • Total receipts/disbursements that aggregate to $5,000 or more during the reporting period.

    Do not include disbursements to or on behalf of officers/employees that are reported in Schedules 11 and 12.

  • Examples of the type of business or job classification to enter in Column (B) are as follows:
    • Printing company
    • Office supplies vendor
    • Lobbyist,/li>
    • Think-tank
    • Marketing firm
    • Legal counsel
    • Hotel
    • Consulting firm
    • Political organization
    • Not-for-profit organization
    • Financial institution
    • Restaurant
    • Airline
    • Event planner
    • Trade show vendor
    • Printer
  • For individual transactions of $5,000 or more, examples of adequate descriptions to denote in Column (C) are as follows:
    • Preparing organizing campaign pamphlets
    • Staffing a help desk
    • Opposition research
    • Litigation regarding representation issues
    • Litigation regarding a refusal to bargain charge
    • Grievance arbitration
    • Get-out-the-vote
    • Voter education
    • Advocating or opposing legislation
    • Job retraining
    • Sponsorship
    • Donations
    • IT consulting support
    • Telecommunications
    • Office supplies
    • Staff meetings and training
    • Annual subscription

These schedules should be completed as accurately as possible. For the official instructions and to obtain more detailed information, please refer to the form instructions published by OLMS. If you are uncertain how to complete the schedules for unusual events or transactions that may have occurred during the reporting period, consult with a professional well-versed in the nuances of the Form LM-2.

Author: Ashleigh Hall, CPA | ahall@withum.com

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