DOL LM-30 burden spreadsheet 12-3-07

Department of Labor
Form LM-30 PRA Burden
Form LM-30 PRA Respondents		Section	Total Universe	Percent of Potential Filers / Impacted by the LM-30 Rule	Total Number of Potential Filers/Impacted by the LM-30 Rule	Notes (Explanation of Estimates and Assumptions)
Labor Organization Officers		404.1(h)	160,253	3.38%	5416	OMB: Please include the definition of an officer and specify the requirements that would trigger the need to file Form LM-30. DOL: The LMRDA definition of labor organization officer is "any constitutional officer, any person authorized to perform the functions of president, vice president, secretary, treasurer, or other executive functions of a labor organization, and any member of its executive board or similar governing body." See 29 USC 402(n). This definition has also appeared at 29 CFR 404.1(b) which was renumbered in the final rule as 29 CFR 404.1(h). The definition has not changed; the new language at 29 CFR 404.1(h) (1) through (4) merely repeats examples used in 29 CFR 452.17-18. See the attached list of the requirements that would trigger the filing of Form LM-30.
Labor Organization Employees		404.1(g)	44,371	3.38%	1500	OMB: Please include the definition of employees and specify the requirements that would trigger the need to file Form LM-30. DOL: The definition of labor organization employee that was at 29 CFR 404.1(c) and is now at 404.1(g), was originally "any individual (other than an individual performing exclusively custodial or clerical services) employed by a labor organization" and now has the phrase "within the meaning of any law of the United States relating to the employment of employees" at the end. That change does not expand the scope of the definition. However, the Final Rule did clarify that for purposes of Form LM-30, stewards receiving union leave or no-docking payments from an employer or lost time payments from a labor organization are considered employees of the labor organization (see the discussion of stewards immediately below). DOL estimated in the NPRM that the then current filing rate was .03% of all union officers and employees. DOL estimated that the filing rate would increase to approximately 1% annually due to the proposed reforms, as well as increased compliance assistance and enforcement initiatives. Subsequent to the NPRM, the filing rate increased to 1.69% due to increased compliance assistance and enforcement. In the Final Rule DOL increased the estimate to 3.38%, taking into account the concerns of commenters relating to union leave and no-docking payments, reporting by union stewards paid by employers for union work, and other changes. The attached list of requirements that would trigger the filing of Form LM-30 applies to employees as well as officers.
Stewards (Labor Organization Employees)			18,460	10%	1,846	OMB: Stewards receiving union leave/no-docking payment from an employer or lost time payments from a union are considered to be employees of the union. Reports are required of all stewards if the union leave/no-docking payments are not made pursuant to a collective bargaining agreement. A steward that receives more than a total of 250 hours of union leave/no-docking and/or lost time payments is subject to all the Form LM-30 reporting requirements. Public comments report 100,000 to 150,000 "stewards." Does DOL concur with these estimates? If not, what data can DOL provide to suggest another estimate better represents the universe of "stewards?" DOL: As explained in the Final Rule, the estimates that DOL received of the number of stewards were unsupported by data and did not provide a basis for DOL to make an estimate. Since DOL received no reliable numbers through notice and comment, the decision was made to take stewards into account in increasing the estimated percentage of filers to 3.38% as explained above. For the reasons discussed on pages 4 through 6 of the attached comments, DOL is unable to accept the estimates recently provided to OMB in Professor John Lund’s study. As noted on pages 8 through 10 of the attached comments, for purposes of this exercise, we believe that a better way of interpreting the limited available information (from which Professor Lund, based on some assumptions that DOL cannot credit, derived substantially higher estimates) would be to assume 18,460 stewards will receive payments from their employer with 90% (16,614) receiving 250 or fewer hours of union leave or no-docking payments pursuant to a collective bargaining agreement and thus having no reporting obligation and 10% (1,846) who will have a reporting obligation.
						OMB: Final rule estimates include 204,634 "officers and employees" (6,916 filers and 197,718 non-filers). The final rule did not include "stewards" in the universe of filers. Public comments report there are as many as 325,000 union officers and employees (including stewards). DOL: As discussed above, DOL believes that a better estimate would be 18,460 stewards who receive some employer pay for union work of which 1,846 would have a reporting obligation.

		Number of Respondents	Percent of the Total Number of Potential Filers Impacted by the LM-30 Rule		Number of Responses		Time Spent (hour)	Revised Estimate of Total Annual Burden	Original Estimate of Total Annual Burden Hours	Notes (Explanation of assumptions and estimates)
404.2	Preparations for Potentially Needing to File Form LM-30	Example 100,000	90.0%		90,000		0.60
	Understanding the types of documents needed prior to filing the LM-30. Includes time required to read instructions, FAQ document, and LM-30 Form.	204,634	100%		This includes filers and non-filers.		0.25	51,159	51,159	OMB: All union members must keep records to determine whether the 250-hour threshold is exceeded. All union members who do any union-related work on company time must keep a written log of every minute of their time, even if they know they will never reach the 250 hours threshold. Please explain in this box how DOL derived the revised estimate- taking into account the public comments received. What assumption were made, etc? DOL: The Final Rule estimated 15 minutes for the universe of 204,634 officers and employees to read the instructions to the extent necessary to determine whether they must complete the form. This is the burden described in the chart on the left and reflected in the accompanying numbers. DOL did not include in this burden estimate the time spent reading the FAQs. The FAQs were not issued subsequent to the Final Rule. They were created as compliance assistance and in all but a few instances were created by restating portions of the instructions into a question and answer format. FAQs can be more accessible to new filers, and they can guide individuals to their areas of concern quickly. The FAQs on the whole, however, provide no new information and, therefore, do not need to be read in order for a filer to complete an accurate and timely form. In a few instances, the FAQs make clear a point that was ambiguous in the rule. This is the sort of guidance agencies regularly provide and are not, to our knowledge, included in burden analyses, particularly when, as here, they are issued after the Final Rule. The record keeping burden described in the OMB comment above is overstated and is a different type of burden from that described to the left. (See the discussion below on steward logs and other recordkeeping.) With respect to reviewing the form and instructions, DOL estimates that 100% of the 16,614 non-filing stewards will need 10 minutes reading time to determine the sole fact relevant to them: that stewards who receive fewer than 250 hours under a collective bargaining agreement need not file. This results in a burden of 166,140 minutes or 2,769 hours. The reading time for the 185 stewards who will file is 55 minutes to review the form and instructions in their entirety. This results in a yearly additional burden of 10,175 minutes or 170 hours. This additional reading time for stewards is approximately 6% of the estimate in the Final Rule for all officers and employees, so it would not have a material effect on that estimate.
	Gathering receipts and records during the fiscal year prior to filing the Form LM-30 [This represents 8 minutes of the 15 minutes that the Final Rule estimated non-filers spent on maintaining and gathering records. The remaining 7 minutes are reflected in contacting financial institutions as described below.]	197,718	100%		197,718		.13	25,703	25,703	OMB: Please list in this box all the types of documents needed in order to know whether to file the LM-30. For example, are director's fees paid to union officers and employees reportable? Please make the list as comprehensive as possible. DOL: The main thing that a union officer needs to know to determine whether he or she must file a Form LM-30 is whether he or she received payments from or had dealings or arrangements with an employer of the type described in Item 6 of Form LM-30 or a business of the type described in Item 7. If the union official answers either or both of those questions "Yes," he or she needs to retain business and personal documents relating to those events and to track the dates and value of payments and other things of value received. Therefore, for example, if a union official is on the board of directors of an employer whose employees the union represents or of an insurance company that deals with the union, documents relating to payments, including reimbursed expenses, received for service as a director should be retained.
	Stewards are required to keep a log of the amount of time expended and compensation received while on union business paid by the employer for purposes of determining whether the 250 hour threshold has been met.	16,614 non-filing stewards 1,842 filing stewards	5% 5% 10%		non-filers 1,842		2.0 1.0 2.0	1,662 831 370	Not included	OMB: What should be reported and how would a steward know when it is necessary to report? Specifically, would the steward need to complete the entire LM-30 form? Please clarify in this box the kinds of documents a steward is required to keep throughout the year. DOL: A steward must report if he or she meets either of the following conditions: (1) if a steward receives 250 or fewer hours of union-leave or no docking payments from the employer that are not paid pursuant to a bona fide collective bargaining agreement, those payments must be reported, but nothing else and (2) if a steward receives more than 250 hours of union leave or no-docking payments, those payments must be reported as well as any other payments required to be reported on Form LM-30. With respect to recordkeeping by stewards, it is DOL’s judgment that employers do not ordinarily permit union stewards to perform union work on employer time without any accounting. Assuming some present-day relevance of the 1980 BLS study, collective bargaining agreements regularly limit the amount of time a steward could perform union work on company time. These terms could not be enforced absent recordkeeping. Thus no additional record keeping would be required for tracking those hours. In addition, some stewards, whether they are already keeping records or not, will know from the beginning of the year that they will not work more than 250 hours, and that no records will need be maintained for Form LM-30 purposes. Therefore, DOL estimates that 90% of the 16,614 non-filing union stewards who received some payments from an employer for union work, will have no additional recordkeeping beyond the records they must already keep. DOL estimates that 5% of the 16,614 non filing stewards will need 120 minutes to keep records in preparation for the possibility of filing, for a total of 1,662 hours. These stewards will work for employers that do not require tracking of union work, so they will need to track it for the Form LM-30. The Department estimates that the remaining 5% of the 16,614 non-filing stewards (831) will need 60 minutes each in annual recordkeeping for a total of 831 hours. Of the 1,846 stewards who will need to file, DOL believes that 90% of them (1,661) will keep records in the ordinary course of business. Of the remaining 185 stewards who will file, DOL assumes that they will spend 120 minutes tracking time they would not otherwise have tracked, resulting in a total burden of 370 hours.
OMB: The FAQ document clarified the reporting requirements for stewards by stating that stewards who receive 250 or fewer hours of union-leave or no-docking payments from an employer pursuant to a bona fide collective bargaining agreement will not be required to file LM-30. A steward who receives 250 or fewer hours not paid pursuant to a collective bargaining agreement will need to file LM-30. A steward who receives more than 250 hours of union leave or no-docking payments will be required to file. Since "stewards" are considered "employees" under LM-30, how are these requirements above going to impact other “employees?” An employee in this category is not required to report any interests or receipts that would otherwise be reportable under the instructions, but may be required to report the continued receipt of his or her normal wages and benefits during the time spend handlings grievances. Please clarify in the spreadsheet if this is the case. Answer 43 of the FAQ document states a steward who is paid lost-time by the union is subject to full LM-30 reporting requirements while a steward who is paid for no more than 250 hours of grievance-handling by the employer needs to report nothing more than the receipt of that pay. This is a bit confusing. Please clarify in the spreadsheet. DOL: The provisions for union stewards do not impact other employees. As noted above, there are several reporting scenarios for union stewards. Union stewards who receive 250 or fewer hours of union leave or no-docking payments from the employer or lost time payments from the union are not required to report anything except union leave or no-docking payments not made pursuant to a collective bargaining agreement. FAQ 43 does not discuss reporting requirements for union stewards who receive lost time from the union, but merely states that the guidance in the FAQ does not apply to those stewards. A union steward who receives 250 or fewer hours of lost time pay from the union is not required to file Form LM-30.
	Spouses and Children	6,916	1.5%	103		Not applicable		Not applicable	Not applicable	OMB: Union officers or employees must file Form LM-30 if they or their spouse or minor child had any of the following interests or dealings related to an employer or employees their union represents or is actively seeking to represent: held any stock, bond, security or other interest; derived any income or any other benefit with monetary value (including reimbursed expenses) from such an employer; received a loan from, or made a loan to, such an employer; engaged in any other business transaction or arrangement with such an employer that was not a purchase or sale of goods or services in the regular course of business at prices generally available to any employee of the employer. What percent of union officers/employees does DOL expect this requirement to trigger the need to file the Form LM-30? Please clarify in this box DOL: The requirement for a union officer or employee to file a Form LM-30 if his or her spouse or minor child engages in any of the reportable payments or transactions has always been in the statute. It is DOL's experience that only a small percentage of reports are required solely because of the activities of a spouse or minor child. The current Form LM-30 reports do not indicate whether the payment was made to a spouse or minor child, except in narrative, making it difficult to quantify. The 1.5% figure is based on the impression of DOL employees who have worked with, and reviewed, Form LM-30 filings for decades. It was also based on an inquiry described in the Notice of Proposed rulemaking, in which OLMS attempted to obtain anecdotal evidence on Form LM-30 delinquency rates. Of the reports OLMS obtained in that inquiry, about 1.5% were the result of payments to spouses or minor children
	Contact financial institution to ask them how much business they do with other union employers; contact DOL for assistance; and make good faith estimates [This represents 7 minutes of the 15 minutes that the Final Rule estimated non-filers spent on maintaining and gathering records. The remaining 8 minutes are reflected in gathering receipts and records as described above.]	197,718	10%	19,771			.12	23,726	23,726	OMB: Please explain in this box the recordkeeping requirements associated with contacting financial institutions. When is it necessary to contact a financial institution? Please also include the CFR reference to this provision. Does everyone need to contact a financial institution? DOL: There is no general requirement that union officers or employees must contact financial institutions and there is no CFR citation. First, a report is not required if an officer or employee does not receive a loan from a financial institution. If a union officer or employee receives a loan from a financial institution that is based upon the financial institution's own criteria and is made on terms unrelated to the official's status in a labor organization, a report is required only if (1) the official's union represents or is actively seeking to represent the financial institution's employees (the official would not have to contact the financial institution to determine this); (2) the financial institution is a trust in which the official's union is interested (again, the official would not have to contact the financial institution because union officials are well aware when a financial institution is a union trust); (3) the financial institution does any business with the union (in many instances a union official will be aware of which financial institutions the union deals with and it is reasonable to expect that the union could provide this information to all officers and employees); or (4) 10% of the financial institution's business is with an employer whose employees the union represents or is actively seeking to represent. In many cases it is obvious, without further inquiry, that a large financial institution does not receive 10% of its annual receipts from an employer of the union members. A union officer who makes reasonable efforts in good faith to obtain information required to be kept or reported by the final rule has satisfied his or her obligations.
OMB: DOL estimated the number of LM-30 filers would increase by 3,450. Public comments state as many as 57,566 union stewards alone would need to file Form LM-30. Based on the requirements listed in the spreadsheet, the likelihood that one will "trigger" the need to file is significantly higher than initially estimated. For example, the Department revised in the 88 FAQ document the "bona fide loans or interest from a banking institution" exception in two ways: by formally excluding loans and interest payments from union-sponsored credit unions; and by reinterpreting the exception to exclude loans from financial institutions that are union-represented employers or that do any business with the union or union-trusts or a substantial amount of business with union-represented employers. Does excluding these two types of transactions from the "bona fide loan or interest" exception mean that these transactions are now reportable? As a result, will union officers and employees - including stewards be required to report personal financial transactions, such as interest earned on savings accounts at union-affiliated credit unions and loans at market rates from commercial banks that do business with the union or a union benefit fund? Would this include a home loan? It's likely almost everyone will need to report such financial transactions as a result of the revision. Please clarify. DOL: As discussed above, DOL does not accept as credible Professor Lund’s estimate as to the number of stewards. The two Form LM-30 FAQ “revisions” to the financial institution exemption referenced above are totally consistent with the Form LM-30 instructions that are part of the final rule and are not revisions. Page 5 of the instructions specifically provides that the exemption for bona fide loans or interest from a banking institution “does not apply to national or state banks, credit unions, savings or loan associations, insurance companies, or other bona fide credit institutions that constitute a ‘trust in which your labor organization is interested.’” The instructions address the four sources of reportable transactions under § 202(a) of the LMRDA: An employer whose employees the official’s labor organization represents or is actively seeking to represent, Certain other employers, Employers that make a payment or transaction for any of five enumerated improper purposes; and Businesses that (n) deal with the labor organization, (b) deal with a trust in which the labor organization is interested or (c) deal in substantial part with an employer whose employees the official’s labor organization represents or is actively seeking to represent, as evidenced by such a business’ receipt  of ten percent of its annual receipts from such an employer.  As noted on page 2 of the instructions, the exceptions and examples in the instructions apply “only to the specific type of transaction where they are listed.”  This is necessary because the various subsections of § 202(a) of the LMRDA have different statutory exemptions.  Therefore, the exemptions on page 5 of the instructions apply only to the “certain other employers” category which derives from § 202(a)(6) which requires union officials to report ‘‘any payment of money or other thing of value (including reimbursed expenses)’’ received from ‘‘any employer’’ or any labor relations consultant to an employer.   The reporting requirements for businesses and the applicable exemptions are described on page 7 of the instructions.  Likewise the disclosure requirements and the applicable exemptions relating to payments from an employer whose employees the official's labor organization represents or is actively seeking to represent are described on pages 2 to 3 in the instructions.  In neither instance is there an exemption for loans. Therefore union officers and employees must report loans from employers and businesses described in 1), 3), and 4) above, but do not have to report if the loan is from an “other” employer (that is not a trust in which the labor organization is interested) and is based upon the financial institution’s own criteria and made on terms unrelated to the official’s status in a labor organization. As noted in FAQ 70, the Department is not requiring union officials to report credit card transactions (including unpaid balances) and interest and dividends paid on savings accounts, checking accounts or certificates of deposit if the payments and transactions are based upon the financial institution’s own criteria and made on terms unrelated to the official’s status in the labor organization.
404.3	Completing and Filing Form LM-30
	Maintaining and gathering records								20	Captured above.
	Reading instructions to determine whether filer must complete the form								15	Captured above.
	Additional reading instructions [the form and the FAQ document] to determine how to complete the form	6,916	100%	6,916			.67	40	40	OMB: Please include in this box a discussion of how DOL derived the burden estimate - taking into account the public comments received and better data if provided. DOL: The burden estimate does not include the time required to read the FAQs. The FAQs were posted after the final rule was prepared and with only two exceptions are a restatement of information in the form and instructions. It is not necessary to read the FAQs to determine how to complete the form.
	Reporting file number in Item 1	6,916	100%	6,916			.01	30 seconds	30 seconds	OMB Note: The public comments state at least 57,566 union stewards would have to file LM-30 under the provision that union members who perform more than 250 hours of no-docking or union-leave work are required to file. Please include in this box an explanation of the total number (employees, stewards, etc.) that would need to complete the Part A section in Item 1. DOL: As discussed above, DOL does not accept as credible Professor Lund’s estimate as to the number of stewards. All filers must complete Part A, Item 1. If the filer has filed previously, they will copy the file number from their previous report or from the OLMS acknowledgement letter to complete Item 1. A new filer will leave the item blank.
	Reporting filer's fiscal year in Item 2	6,916	100%	6,916			.01	30 seconds	30 seconds	OMB: Please include in this box an explanation of the total number (employees, stewards, etc.) that would need to complete the Part A section in Item 2. DOL: All filers must complete Part A, Item 2. The beginning and ending dates of the 12-month period covered by the report is known to the filer.
	Report filer's name, address and contact information in Item 3 (A-I)	6,916	100%	6,916			.03	2	2	OMB: Please include in this box an explanation of the total number (employees, stewards, etc.) that would need to complete the Part A section in Item 3. DOL: All filers must complete Part A, Item 3. All the information is known to the filer.
	Reporting name, file number and address of filer's union or unions as well as filer's current position in the union in Item 4 (A-H)	6,916	100%	6,916			.03	2	2	OMB: Please include in this box an explanation of the total number (employees, stewards, etc.) that would need to complete the Part A section in Item 4. DOL: All filers must complete Part A, Item 4. All of this information is known to the filer with the possible exception of the union's file number, which is easily accessible from www.unionreports.gov.
	Adding total value of assets and the value of all income or other payments in Schedules 2	6,916	100%	6,916			.03	2	2	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: If the filer uses the electronic Form LM-30 from the OLMS Web site, Item 5 is completed automatically after the filer has completed Part B, so there is no burden. If the filer is using a paper copy of the form, the filer only needs to add the relevant figures.
	Indicating whether there is a reportable involvement with an employer or labor relations consultant during the FY in Item 6	6,916	100%	6,916			.03	2	2	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: To complete Item 6, the filer reads the list of seven types of employers. If he or she has received a payment from, or engaged in a transaction with, such an employer during the year, the filer determines if the payment or transaction is covered by a reporting exemption if he or she does not already know. For example, a union officer would more than likely know that regular wages from their unionized employer are exempt. If the filer does not know, he or she would look at the appropriate bulleted list of applicable exemptions in the instructions.
	Indicating whether there was a reportable involvement with a business during the FY in Item 7	6,916	100%	6,916			.03	2	2	OMB: Please include in this box a discussion of how DOL derived the burden estimate - taking into account the public comments received and better data if provided. DOL: To complete Item 7, the filer reads the list of three types of businesses and determines if he or she has received a payment from, or engaged in a transaction with, or had an interest in, such a business during the year. If it is a business that a union official or his or her spouse or minor child has an ownership interest in, the official would be expected to know whether the business deals with the union or whether 10% or more of its business is from dealing with an employer whose employees the union represents. In many instances a union official will be aware of which businesses the union deals with and it is reasonable to expect that the union could provide this information to all officers and employees if requested. In many cases it is going to be obvious that a large business does not receive 10% or more of its annual receipts from an employer of the union members. A union officer who makes reasonable efforts in good faith to obtain information required to be kept or reported by the final rule has satisfied his or her obligations. The burden estimate was based on these factors plus the assumption that the vast majority of union officers and employees receive no payments from businesses over the $250 exemption amount or if they receive any payments they know the payments are from a business that deals with their union, so the answer to Item 7 is known to them.
	Reporting name and address of the employer or business which the filer received a payment from or held an interest in, providing the contract name, telephone number , website address and whether filer has an associated with the business, employer or labor relations consultant at the end of the reporting period in Schedule 1.	6,916	100%	6,916			.08	5	5	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: To complete Schedule 1, the filer lists identifying information about the employer or business for which the filer answered yes to Item 6 or 7 and indicates whether he or she had a relationship with the entity at the end of the reporting period. This information should be known to the filer because by answering yes they are indicating that they had significant dealings with the entity in terms of payments, transactions, or interests.
	Reporting the nature and value of interested in, payment from, loans to or from and transactions with an employer or business and payments from a lobr relations consultant (includes date, whether the party to the transaction is a union officer or an employee or spouse or minor child thereof and a description and value of the interest or payment) in schedule 2.	6,916	100%	6,916			.08	5	5	OMB: Reporting financial transactions, such as interest earned on banks that do business with the union or a union benefit fund. Would this include reporting bona fide loans or interest? Please include in this box a discussion of how DOL derived the burden estimate - taking into account the public comments received and better data if provided. DOL: The filer reports in Schedule 2 what payments, interest, loan, transaction, or arrangement he or she had with the entity listed in Schedule 1. As noted above in the discussion of the recordkeeping requirements associated with financial institutions, loans are only reportable in certain situations. When a loan is reportable, the financial institution will have provided the filer with documents in the normal course of business that contain the information required to complete Schedule 2. Credit card transactions and interest on savings and checking accounts and certificates of deposit are not reportable if they are based on the financial institution's own criteria and made on terms unrelated to the official's status in a labor organization. As noted in the final rule, the filer would have maintained records throughout the year in the regular course of conducting his or her business and personal affairs that should easily provide the information required to be reported here.
	Completing either Schedule 3 if an employer or labor relations consultant is reported din Schedule 1, providing details of the employer's relationship with the filer's labor union; or Schedule 4 if a business is reported in Schedule 1, providing details regarding the entity the business dealt with (union, trust, or employer) and a description of those dealings.	6,916	100%	6,916			.13	8	8	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: A filer completes either Schedule 3 or Schedule 4 for the entity listed in Schedule 1, but never both. Schedule 3 is completed for an employer while Schedule 4 is completed for a business. In completing Schedule 3, the filer will have already determined in answering Item 6 that the employer had a relationship with the union and only needs to enter the details in Schedule 3. The instructions provide "if you do not know and cannot estimate the value, enter N/A and explain in the Additional Information Schedule." Likewise, in completing Schedule 4, the filer will have already determined in answering Item 7 that the business dealt with the union, with a trust in which the union is interested, or in substantial part with an employer whose employees the union represents or is actively seeking to represent. The filer only needs to explain the details in Schedule 4. Obviously, if it is a business that the filer has a personal interest in, the filers will have access to details of the business's transactions. In other instances, the instructions provide "If the exact value is not known and cannot be estimated, enter "N/A" and explain the situation in the Additional Information Schedule."
	Filer's signature, date and telephone number in Item 8	6,916	100%	6,916			.02	1	1	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: This information is known to the filer.
	Checking responses	6,916	100%	6,916			.08	5	5	OMB: Please include in this box a discussion of how DOL derived the burden estimate. DOL: DOL estimated that the information on most Form LM-30 reports will be limited so that a filer could review it in five minutes. No contrary estimates have been received.
TOTAL									2 hours