Labor Organization and Auxiliary Reports

Paperwork Reduction Act Notice: Public reporting burden for this collection of information is estimated to average
[X] hours per response in 20XX, [X] hours per response in 20XX, and [X] hours per response in 20XX and subsequent
years. This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining data
needed, and completing and reviewing the collection of information. Persons are not required to respond to the collection
of information unless it displays a currently valid OMB control number. Reporting of this information is mandatory and is
required by the Labor-Management Reporting and Disclosure Act of 1959, as amended, for the purpose of public
disclosure. See 29 C.F.R. Part 403. As this is public information, there are no assurances of confidentiality. If you have
any comments regarding this estimate or any other aspect of this information collection, including suggestions for
reducing this burden, please send them to the U.S. Department of Labor, Office of Labor-Management Standards,
Division of Interpretations and Standards, Room N-5609, 200 Constitution Avenue, NW, Washington, DC 20210.

INSTRUCTIONS FOR FORM T-1
TRUST ANNUAL REPORT
contributes greater than 50% of the
trust's receipts during the one-year
reporting period.

GENERAL INSTRUCTIONS
I. WHO MUST FILE

Any contributions made pursuant to a
collective bargaining agreement shall be
considered the labor organization’s
contributions.

Every labor organization subject to the
Labor-Management Reporting and
Disclosure Act, as amended (LMRDA), the
Civil Service Reform Act (CSRA), or the
Foreign Service Act (FSA), with total
annual receipts of $250,000 or more
(labor organization), must file Form T-1
each year for each trust in which it is
interested, as defined in the LMRDA at 29
U.S.C. 402(l), if the following conditions
exist:

Only the parent labor organization (i.e.,
the national/international or intermediate
labor organization) must file the Form T-1
report for covered trusts in which both the
parent labor organization and its affiliates
meet the above financial or managerial
domination test. The affiliates must
continue to identify the trust in their Form
LM-2 Labor Organization Annual Report,
and, including a statement that the parent
labor organization will file a Form T-1
report for the trust.

The trust is a trust defined by section 3(l)
of the LMRDA, that is, the trust is a trust
or other fund or organization (1) that was
created or established by a labor
organization or a labor organization
appoints or selects a member to the trust’s
governing board; and (2) the trust has as
a primary purpose to provide benefits to
the members of the labor organization or
their beneficiaries (29 U.S.C. 402(l)); and
the labor organization alone, or in
combination with other labor
organizations, either

No Form T-1 should be filed for any trust
that meets the statutory definition of a
labor organization and already files a
Form LM-2, LM-3, or LM-4, nor should a
report be filed for any entity that is
expressly exempted from reporting in the
LMRDA. No report need be filed for a
subsidiary organization, as defined in Part
X of the instructions for the Form LM-2
Labor Organization Annual Report. No
report need be filed for a trust established
as a Political Action Committee (PAC) if
timely, complete, and publicly available
reports on the PAC are filed with a

appoints or selects a majority of the
members of the trust’s governing
board; or

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Federal or state agency, or for a trust
established as a political organization
under 26 U.S.C. 527 if timely, complete,
and publicly available reports are filed with
the Internal Revenue Service. No Form T1 need be filed for any trust that is an
employee benefit plan that files a Form
5500, under the Employee Retirement
Income Security Act of 1974 (“ERISA”), 29
U.S.C. 1021 and/or 1024, for a plan year
ending during the reporting period of the
union. Filing the Form 5500–SF is not
included within this exemption. No report
need be filed for federal employee health
benefit plans subject to the provisions of
the Federal Employees Health Benefits
Act (FEHBA), nor for any for-profit
commercial bank established or operating
pursuant to the Bank Holding Act of 1956,
12 U.S.C. 1843.

that were granted at more favorable terms
than were available to others; and loans
made to officers and employees that were
liquidated, reduced, or written off. The
audit must be accompanied by schedules
that disclose: a statement of the assets
and liabilities of the trust, aggregated by
categories and valued at current value,
and the same data displayed in
comparative form for the end of the
previous fiscal year of the trust; a
statement of trust receipts and
disbursements aggregated by general
sources and applications, which must
include the names of the parties with
which the trust engaged in $10,000 or
more of commerce and the total of the
transactions with each party.
Form T-1 must be filed with the Office of
Labor-Management Standards (OLMS) of
the U.S. Department of Labor
(Department). The labor organization
must file a separate Form T-1 for each
trust that meets the above requirements.

An abbreviated report may be filed for any
covered trust or trust fund for which an
independent audit has been conducted, in
accordance with the standards (as
adopted from 29 CFR 2520.103-1) as
discussed in the next paragraph.

The LMRDA, CSRA, and FSA cover labor
organizations that represent employees
who work in private industry, employees of
the U.S. Postal Service, and most Federal
government employees. Questions about
whether a labor organization is required to
file should be referred to the nearest
OLMS field office listed at the end of these
instructions.

A labor organization may complete only
Items 1 through 15 and Items 26-27
(Signatures) of Form T-1 if annual audits
are prepared according to the following
standards and a copy of the audit is filed
with the Form T-1. The audit must be
performed by an independent qualified
public accountant, who after examining
the financial statements and other books
and records of the trust, as the accountant
deems necessary, certifies that the trust’s
financial statements are presented fairly in
conformity with Generally Accepted

II. WHEN TO FILE
The Form T-1 requirements take effect on
[YEAR]; they apply to a labor organization
whose fiscal year and the fiscal year of its
section 3(l) trust begin on or after January
1, [YEAR]. Form T-1 must be filed within
90 days of the end of the labor
organization’s fiscal year. The Form T-1
shall cover the trust’s most recently
completed fiscal year, i.e., the fiscal year
ending on or before the closing date of the
labor organization’s own fiscal year. The
penalties for delinquency are described in
Section V (Officer Responsibilities and
Penalties) of these instructions. Examples
of filing dates for the Form T-1 follow:

Accounting Principles (GAAP) or Other
Comprehensive Basis of Accounting
(OCBOA). The audit must include notes
to the financial statements that disclose:
losses, shortages, or other discrepancies
in the trust’s finances; the acquisition or
disposition of assets, other than by
purchase or sale; liabilities and loans
liquidated, reduced, or written off without
the disbursement of cash; loans made to
labor organization officers or employees

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ceased. See Section IX (Trusts That
Have Ceased to Exist) of these
instructions for information on filing a
terminal financial report.

Where the trust and labor organization
have the same fiscal years
•

•

The trust and labor organization
have fiscal years ending on
December 31. The Form T-1 for
the fiscal year ending
December 31, [YEAR] must be
filed not later than March 31,
[YEAR].

III. HOW TO FILE
Form T-1 must be submitted electronically
to the Department via the OLMS Electronic
Forms System (EFS) available on the
OLMS website at: www.dol.gov/olms.
Form T-1 filers will be able to file reports in
paper format only if they assert a
temporary hardship exemption.

The trust and the labor
organization each has a fiscal year
that ends on September 30. The
labor organization’s first Form T-1
will be for the trust’s fiscal year
ending September 30, [YEAR] and
must be filed not later than
December 29, [YEAR].

If you have difficulty navigating EFS, or
have questions about its functions and
features, call the OLMS Help Desk at:
(866) 401-1109. For questions
concerning the reporting requirements,
please send an e-mail to
[email protected] or call (202) 6930123.

Where the trust and labor organization
have different fiscal years
•

•

The trust’s fiscal year ends on
June 30. The labor organization’s
fiscal year ends on September 30.
Its first Form T-1 for this trust will
be for the trust’s fiscal year ending
June 30, [YEAR ]and must be filed
not later than December 29,
[YEAR].

HARDSHIP EXEMPTIONS
A labor organization that must file Form T1 may assert a temporary hardship
exemption. If a labor organization files
both Form LM-2 and Form T-1, the
exemption must be separately asserted
for each report, although in appropriate
circumstances the same reasons may be
used to support both exemptions. If it is
possible to file Form LM-2, or one or more
Form T-1s, electronically, no exemption
should be claimed for those reports, even
though an exemption is warranted for a
related report.

The trust’s fiscal year ends on
September 30. The labor
organization’s fiscal year ends on
December 31. Its first Form T-1
for this trust will be for the trust’s
fiscal year ending September 30,
2010 and must be filed not later
than March 31, [YEAR].

TEMPORARY HARDSHIP EXEMPTION:

If a trust for which a labor organization
was required to file a Form T-1 goes out of
existence, a terminal financial report must
be filed within 30 days after the date it
ceased to exist. Similarly, if a trust for
which a labor organization was required to
file a Form T-1 continues to exist, but the
labor organization’s interest in that trust
ceases, a terminal financial report must be
filed within 30 days after the date that the
labor organization’s interest in the trust

If a labor organization experiences
unanticipated technical difficulties that
prevent the timely preparation and
submission of an electronic filing of Form
T-1, it may be filed in paper format by the
required due date. An electronic format
copy of the filed paper format document
shall be submitted to the Department
within ten business days after the required
due date. Indicate in Item 3 (Amended,
Hardship Exempted, or Terminal Report)

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that the labor organization is filing this
form under the hardship exemption
procedures. Unanticipated technical
difficulties that may result in additional
delays should be brought to the attention
of OLMS by email at [email protected] or by phone at 202-6930123.

any information required to be submitted
with it. Under the CSRA and FSA and
implementing regulations, false reporting
and failure to report may result in
administrative enforcement action and
litigation. The officers responsible for
signing Form T-1 are also subject to
criminal penalties for false reporting and
perjury under Sections 1001 of Title 18
and 1746 of Title 28 of the United States
Code.

Note: If either the paper filing or the
electronic filing is not received in the
timeframe specified above, the report
will be considered delinquent.

The reporting labor organization and the
officers required to sign Form T-1 are also
subject to civil prosecution for violations of
the filing requirements. Section 210 of the
LMRDA (29 U.S.C. 440), provides that
“whenever it shall appear that any person
has violated or is about to violate any of
the provisions of this title, the Secretary
may bring a civil action for such relief
(including injunctions) as may be
appropriate.”

IV. PUBLIC DISCLOSURE
The LMRDA requires that the Department
make reports filed by labor organizations
available for inspection by the public.
Reports may be viewed and downloaded
from the OLMS Web site at
http://www.unionreports.gov. Reports
may also be examined and copies
purchased through the OLMS Public
Disclosure Room (telephone: 202-6930125) at the following address:

VI. RECORDKEEPING
The officers required to file Form T-1 are
responsible for maintaining records that
will provide in sufficient detail the
information and data necessary to verify
the accuracy and completeness of the
report. The records must be kept for at
least five years after the date the report is
filed. Any record necessary to verify,
explain, or clarify the report must be
retained, including, but not limited to,
vouchers, worksheets, receipts, applicable
resolutions, and any electronic documents
used to complete and file the report.

U.S. Department of Labor
Office of Labor-Management Standards
200 Constitution Avenue, NW
Room N-1519
Washington, DC 20210-0001

V. OFFICER RESPONSIBILITIES
AND PENALTIES
The president and treasurer or the
corresponding principal officers of the
labor organization required to sign Form
T-1 are personally responsible for its filing
and accuracy. Under the LMRDA, officers
are subject to criminal penalties for willful
failure to file a required report and for false
reporting. False reporting includes
making any false statement or
misrepresentation of a material fact while
knowing it to be false, or for knowingly
failing to disclose a material fact in a
required report or in the information
required to be contained in the report or in

SPECIAL INSTRUCTIONS
FOR CERTAIN
ORGANIZATIONS
VII. LABOR ORGANIZATIONS IN
TRUSTEESHIP
Any labor organization that has placed a
subordinate labor organization in
trusteeship is responsible for filing the
subordinate’s annual financial reports.

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This obligation includes the requirement to
file Form T-1 for any trusts in which the
subordinate labor organization is
interested. A trusteeship is defined in
section 3(h) of the LMRDA (29 U.S.C.
402) as “any receivership, trusteeship, or
other method of supervision or control
whereby a labor organization suspends
the autonomy otherwise available to a
subordinate body under its constitution or
bylaws.”

ITEMS 1 THROUGH 20
Answer Items 1 through 20 as instructed.
Select the appropriate box for those
questions requiring a "Yes" or "No"
answer; do not leave both boxes blank.
Enter a single "0" in the boxes for items
requiring a number or dollar amount if
there is nothing to report.
1. FILE NUMBER — EFS will enter the
labor organization’s 6-digit file number
here and at the top of each page of Form
LM-2. This is the number you entered
when you downloaded Form LM-2. If the
number is incorrect, you must download
another copy of the form using the correct
number. If the labor organization does not
have the number on file and cannot obtain
the number from prior reports filed with the
Department, the number can be obtained
from the OLMS Web site at
www.unionreports.gov, or by contacting
the nearest OLMS field office.

The report must be signed by the
president and treasurer or corresponding
principal officers of the labor organization
that imposed the trusteeship and by the
trustees of the subordinate labor
organization. In order for the trustees to
sign, click on the “Add Signature Block”
button on page 1 to open a signature page
near the end of the form.

VIII. COMPLETING FORM T-1
INTRODUCTION

The software will enter the trust’s 7-digit
(T### ###) file number in Item 1(b) and at
the top of each page of Form T-1. This is
the number you entered when you
downloaded Form T-1. If the number is
incorrect, you must download another
copy of the form using the correct number.
For an initial filing of a Form T-1, this
number may be obtained by calling the
OLMS Division of Reports, Disclosure &
Audits at (202) 693-0123.

Most pages have a “Save & Calculate”
button to total and transfer data to fields in
various parts of the form. You may click
on one or more of these buttons as you fill
out the form at any time.
You may click on the “Validate Form”
button at any time to check for errors. This
action will generate an “Errors Page”
listing any errors that will need to be
corrected before you will be able to sign
the form. Clicking on the signature lines
will also perform the validation function.
Items 1, 2, and 4 - 7 are “pre-filled” items.
These fields were filled in by EFS based
on information you entered when you
initially accessed the system. You cannot
edit these fields.

For future filings, if the labor organization
does not have the number on file and
cannot obtain the number from the trust or
from prior reports filed with the
Department, information on obtaining the
number can be found on the OLMS
website at http://www.olms.dol.gov.
2. PERIOD COVERED — EFS will enter
the beginning and ending dates of the
period covered by this report. These are
the dates you entered when you accessed
Form T-1 via EFS. If the dates are
incorrect, you must access another form
using the correct dates.

Be sure to click on the “Validate Form”
button after you have completed the form
but before you sign it. This action will
generate an “Errors Page” listing any
errors that must be corrected before you
sign the form.

5

If the labor organization changed its fiscal
year, the ending date in Item 2 should be
the labor organization’s new fiscal year
ending date and the labor organization
should indicate in Item 69 (Additional
Information) that the report is for a period
of less than 12 months because its fiscal
year has changed. For example, if the
labor organization’s fiscal year ending
date changes from June 30 to December
31, a report must be filed for the partial
year from July 1 to December 31.
Thereafter, the labor organization’s annual
report should cover a full 12-month period
from January 1 to December 31.

of its subordinate bodies, and all
subordinate bodies of the same parent
body are affiliates of each other.

3. AMENDED, HARDSHIP EXEMPTED,
OR TERMINAL REPORT — Do not
complete this item unless this report is an
amended, hardship exempted, or terminal
report. Select Item 3(a) if the labor
organization is filing an amended Form T1 correcting a previously filed Form T-1.
Select Item 3(b) if the labor organization is
filing under the hardship exemption
procedures defined in Section III. Select
Item 3(c) if the trust has gone out of
business by disbanding, merging into
another organization, or being merged
and consolidated with one or more trusts
to form a new trust, or if the labor
organization’s interest in the trust has
ceased and this is the terminal report for
the trust. Be sure the date the trust
ceased to exist is entered in Item 2
(Period Covered) after the word
“Through.” See Section IX (Trusts That
Have Ceased to Exist) of these
instructions for more information on filing a
terminal report.

5. DESIGNATION — Enter the specific
designation, if any, that is used to identify
the labor organization, such as Local,
Lodge, Branch, Joint Board, Joint Council,
District Council, etc.

If the labor organization has not reported
such an affiliation, EFS will enter the name
of the labor organization as currently
identified in the labor organization's
constitution and bylaws or other
organizational documents.
This item cannot be edited by the filer. If
the labor organization needs to change
this information, contact OLMS at (202)
693-0123.

6. DESIGNATION NUMBER — EFS will
enter the specific designation that is used
to identify the labor organization, such as
Local, Lodge, Branch, Joint Board, Joint
Council, District Council, etc. This field
cannot be edited by the filer.
7. UNIT NAME — EFS will enter any
additional or alternate name by which the
labor organization is known, such as
"Chicago Area Local." This field cannot be
edited by the filer.
8. MAILING ADDRESS OF UNION —
EFS accesses the union’s mailing address
on record in the OLMS database and
enters it in Item 8. The first and last name
of the person, if any, to whom such mail
should be sent and any building and room
number should be included. These fields
can be edited.

4. NAME OF UNION —
EFS accesses this information from the
OLMS database and will enter the name of
the national or international labor
organization that granted the labor
organization a charter. "Affiliates," within
the meaning of these instructions, are labor
organizations chartered by the same
parent body, governed by the same
constitution and bylaws, or having the
relationship of parent and subordinate. For
example, a parent body is an affiliate of all

9. PLACE WHERE UNION RECORDS
ARE KEPT — If the records required to
be kept by the labor organization to verify
this report are kept at the address
reported in Item 8 (Mailing Address of
Union), answer "Yes." If not, answer "No"
and provide in Item 25 (Additional
Information) the address where the labor
organization's records are kept.

6

labor organization.
10. NAME OF TRUST — The software
will enter the name of the trust. This is the
trust name you entered when you
downloaded Form T-1. If the name is
incorrect, you must download another
form using the correct name.

Note: The president and treasurer of the
labor organization are responsible for
maintaining the records used to prepare
the report.
15. AUDIT EXEMPTION —
Answer “Yes” to Item 15 if the labor
organization will be submitting an
independent, certified audit in place of the
remainder of Form T-1. If an audit report
meeting the standards described in
Section I (Who Must File) is submitted
with a Form T-1 that has been completed
for Items 1 through 15 then it is not
necessary to complete Items 16 through
25, and Schedules 1 through 3. However,
Items 26-27 (Signatures) must be
completed.

This item cannot be edited. If the labor
organization needs to change this
information, contact the OLMS Division of
Reports, Disclosure, and Audits by
telephone at 202-693-0123 or by e-mail at
[email protected]. Indicate that the
subject of the inquiry is the Form T-1 prefilled identifying information.
11. TRUST EMPLOYER
IDENTIFICATION NUMBER (EIN) —
Enter the Employer Identification Number
assigned to the trust by the Internal
Revenue Service.

16. LOSSES OR SHORTAGES —
Answer “Yes” to Item 16 if the trust
experienced a loss, shortage, or other
discrepancy in its finances during the
period covered. A “loss or shortage of
funds or other property” within the
meaning of Item 16 does not include
delinquent contributions from employers,
delinquent accounts receivable, losses
from investment decisions, or
overpayments of benefits. Describe the
loss or shortage in detail in Item 25
(Additional Information), including such
information as the amount of the loss or
shortage of funds or a description of the
property that was lost, how it was lost, and
to what extent, if any, there has been an
agreement to make restitution or any
recovery by means of repayment, fidelity
bond, insurance, or other means.

12. PURPOSE — Enter the purpose of
the trust. For example, if the trust is a
credit union that provides loans to labor
organization members, the purpose may
be “credit union.”
13. MAILING ADDRESS OF TRUST —
The software will enter the current
address where mail is most likely to reach
the trust as quickly as possible. The first
and last name of the person, if any, to
whom such mail should be sent, and any
building and room number should be
included. These fields are pre-filled from
the OLMS database, but can be edited by
the filer.
14. PLACE WHERE TRUST RECORDS
ARE KEPT — If the records required to
be kept to verify this report are kept at the
address reported in Item 13 (Mailing
Address of Trust), answer “Yes.” If not,
answer “No” and provide in Item 25
(Additional Information) the address where
the trust’s records are kept. The labor
organization need not keep separate
copies of these records at its own location,
as long as members have the same
access to such records from the trust as
they would be entitled to have from the

17. ACQUISITION OR DISPOSITION OF
ASSETS — If Item 17 is answered “Yes,”
describe in Item 25 (Additional
Information) the manner in which the trust
acquired or disposed of the asset(s), such
as donating office furniture or equipment
to charitable organizations, trading in
assets, writing off a receivable, or giving
away other tangible or intangible property
of the trust. Include the type of asset, its
value, and the identity of the recipient or

7

donor, if any. Also report in Item 25 the
cost or other basis at which any acquired
assets were entered on the trust’s books
or the cost or other basis at which any
assets disposed of were carried on the
trust’s books.

Report all amounts in dollars only. Round
cents to the nearest dollar. Amounts
ending in $.01 through $.49 should be
rounded down. Amounts ending in $.50
through $.99 should be rounded up.
Enter a single “0” if there is nothing to
report.

A filer may group similar acquired or
disposed assets together, in a larger
category, as well as grouping multiple
assets acquired from or disposed of to the
same source. For example, if a trust
acquired various types of office equipment
as a donation, these assets may be
grouped together for purposes of the
description in Item 25.

REPORTING CLASSIFICATIONS
Complete all items and lines on the form
as given. Do not use different accounting
classifications or change the wording of
any item or line.

ASSETS AND LIABILITIES
For assets that were traded in, enter in
Item 25 the cost, book value, and trade-in
allowance.

21. ASSETS — Enter the total value of all
the trust’s assets at the end of the
reporting period including, for example,
cash on hand and in banks, property,
loans owed to the trust, investments,
office furniture, automobiles, and anything
else owned by the trust. Enter “0” if the
trust had no assets at the end of the
reporting period.

18. LIQUIDATION OF LIABILITIES — If
Item 18 is answered “Yes,” provide in Item
25 (Additional Information) all details in
connection with the liquidation, reduction,
or writing off of the trust’s liabilities without
the disbursement of cash.
19. LOANS AT FAVORABLE TERMS —
If Item 19 is answered “Yes,” provide in
Item 25 (Additional Information) all details
in connection with each such loan,
including the name of the labor
organization officer or employee, the
amount of the loan, the amount that was
still owed at the end of the reporting
period, the purpose of the loan, terms for
repayment, any security for the loan, and
a description of how the terms of the loan
were more favorable than those available
to others.

22. LIABILITIES — Enter the total
amount of all the trust’s liabilities at the
end of the reporting period including, for
example, unpaid bills, loans owed, the
total amount of mortgages owed, payroll
withholdings not transmitted by the end of
the reporting period, and other debts of
the trust. Enter “0” if the trust had no
liabilities at the end of the reporting period.

RECEIPTS AND DISBURSEMENTS
Receipts are money actually received by
the trust and disbursements are money
actually paid by the trust. The purpose of
Items 23 and 24 is to report the flow of
cash in and out of the trust during the
reporting period. Transfers between
separate bank accounts or between
special funds of the trust do not represent
the flow of cash in and out of the trust and
should not be reported as receipts and
disbursements.

20. WRITING OFF OF LOANS — If Item
20 is answered “Yes,” describe in Item 25
(Additional Information) all details in
connection with each such loan, including
the amount of the loan and the reasons for
the writing off, liquidation, or reduction.

FINANCIAL DETAILS
REPORT ONLY DOLLAR AMOUNTS

Since Items 23 and 24 report cash flowing

8

in and out of the trust, “netting” is not
permitted. “Netting” is the offsetting of
receipts against disbursements and
reporting only the balance (net) as either a
receipt or a disbursement.

information on the financial operations of
the trust.
All “major” receipts during the reporting
period must be separately identified in
Schedule 1. A “major” receipt includes:
1) any individual receipt of $10,000 or
more; or 2) total receipts from any single
entity or individual that aggregate to
$10,000 or more during the reporting
period. This process is discussed further
below.

Do not include in Item 23 or 24 the total
amount from the sale or redemption of
U.S. Treasury securities, marketable
securities, or other investments that was
promptly reinvested (i.e., “rolled over”) in
U.S. Treasury securities, marketable
securities, or other investments during the
reporting period. “Promptly reinvested”
means reinvesting (or “rolling over”) the
funds in a week or less without using the
funds for any other purpose during the
period between the sale of the investment
and the reinvestment.

All “major” disbursements during the
reporting period must be separately
identified in Schedule 2. A “major”
disbursement includes: 1) any individual
disbursement of $10,000 or more; or
2) total disbursements to any single entity
or individual that aggregate to $10,000 or
more during the reporting period. This
process is discussed further below.

Receipts and disbursements by an agent
on behalf of the trust are considered
receipts and disbursements of the trust
and must be reported in the same detail
as other receipts and disbursements.

Exemptions
Labor organizations are not required to
separately identify any individual or entity
on Schedule 1 from which the trust
receives receipts of $10,000 or more,
individually or in the aggregate, during the
reporting period, if the receipts are derived
from pension, health, or other benefit
contributions that are provided pursuant to
a collective bargaining agreement
covering such contributions. Additionally,
the labor organization is not required to
itemize benefit payments on Schedule 2
from the trust to a plan participant or
beneficiary, if the detailed basis on which
such payments are to be made is
specified in a written agreement.

23. RECEIPTS — Enter the total amount
of all receipts of the trust during the
reporting period including cash, interest,
dividends, realized short and long term
capital gains, rent, royalties, and other
receipts of any kind. Enter “0” if the trust
had no receipts during the reporting
period.
24. DISBURSEMENTS — Enter the total
amount of all disbursements made by the
trust during the reporting period including,
for example, net payments to officers and
employees of the trust, payments for
administrative expenses, loans made by
the trust, taxes paid, and disbursements
for the transmittal of withheld taxes and
other payroll deductions. Enter “0” if the
trust made no disbursements during the
reporting period.

Filers should not include on Schedules 1
and 2 the total amount from the sale or
redemption of U.S. Treasury securities,
marketable securities, or other
investments that was promptly reinvested
(i.e., “rolled over”) in U.S. Treasury
securities, marketable securities, or other
investments during the reporting period
“Promptly reinvested” means reinvesting
(or “rolling over”) the funds in a week or
less without using the funds for any other

SCHEDULES 1 THROUGH 3
SCHEDULES 1 AND 2 — RECEIPTS
AND DISBURSEMENTS
Schedules 1 and 2 provide detailed

9

purpose during the period between the
sale of the investment and the
reinvestment.

described above. Additional Itemization
Page(s) for additional payers/payees can
be generated and added to the end of
Form T-1 by pressing the “Add More
Receipts” or “Add More Disbursements”
button located at the top of the first Initial
Itemization Page. If the number of
receipts/disbursements exceeds the
number of space provided on the Initial
Itemization Page a Continuation
Itemization Page(s) can be generated and
added to the end of the Form T-1 by
pressing the “More Receipts for this
Payee” or “More Disbursements for this
Payer” button located below Column (A).
The software will automatically enter the
name, address, and type or classification
of the payee/payer on the Continuation
Itemization Page(s).

Note: Disbursements to officers and
employees of the trust who received more
than $10,000 from the trust during the
reporting period should be reported in
Schedule 3, and need not also be
reported in Schedule 2.
Example 1: The trust has an ongoing
contract with a law firm that provides a
wide range of legal services to which a
single payment of $10,000 is made each
month. Each payment would be listed in
Schedule 2.
Example 2: The trust received a
settlement of $14,000 in a small claims
lawsuit. The receipt would be individually
identified in Schedule 1.

Enter in Column (A) the full name and
business address of the entity or individual
from which the receipt was received or to
which the disbursement was made. Do
not abbreviate the name of the entity or
individual. If you do not have access to
the full address, the city and state are
sufficient.

Example 3: The trust made three
payments of $4,000 each to an office
supplies vendor for office supplies during
the reporting period. The $12,000 in
disbursements to the vendor would be
reported in Schedule 2 in line I of an Initial
Itemization Page for that vendor.

Enter in Column (B) the type of business
or job classification of the entity or
individual, such as printing company,
office supplies vendor, lobbyist, think tank,
marketing firm, bookkeeper, receptionist,
shop steward, legal counsel, union
member, etc.

Procedures for Completing Schedules 1
and 2
Complete an Initial Itemization Page and a
Continuation Itemization Page(s), as
necessary, for each payer/payee for
whom there is (1) an individual
receipt/disbursement of $10,000 or more
or (2) total receipts/disbursements that
aggregate to $10,000 or more during the
reporting period. For each major
receipt/disbursement, provide the full
name and business address of the entity
or individual, type of business or job
classification of the entity or individual,
purpose of the receipt/disbursement, date,
and amount of the receipt/disbursement.
Receipts/disbursements must be listed in
chronological order.

Enter in Column (C) the purpose of the
receipt/disbursement, which means a brief
statement or description of the reason the
receipt/disbursement was made.
Enter in Column (D) the date that the
receipt/disbursement was made. The
format for the date must be mm/dd/yyyy.
The date of receipt/disbursement for
reporting purposes is the date the trust
actually received or disbursed the money,
rather than the date that the right to
receive, or the obligation to disburse, was
incurred.

An Initial Itemization Page must be
completed for each payer/payee

Enter in Column (E) the amount of the

10

receipt/disbursement.

receipt(s) and statement(s). Similarly, if
the receipt(s) and statement(s) do not
include a full street address, the labor
organization should report as much
information as is available and no less
than the city and state.

The software will enter in Line (F) the total
of all transactions listed in Column (E).
The software will enter in Line (G) the
totals from any Continuation Itemization
Pages for this payee/payer.

Once these transactions have been
incorporated into the recordkeeping
system they can be treated like any other
transaction for purposes of assigning a
description and purpose.

The software will enter in Line (H) the total
of all itemized transactions with this
payee/payer (the sum of Lines (F) and
(G)).

In instances when a credit card
transaction is canceled and the charge is
refunded in whole or part by entry of a
credit on the credit card statement, the
charge should be treated as a
disbursement, and the credit should be
treated as a receipt. In reporting the credit
as a receipt, Column (C) of Schedule 1
must indicate that the receipt was in
refund of a disbursement, and must
identify the disbursement by date and
amount.

Enter in Line (I) the total of all other
transactions with this payer/payee (that is,
all individual transactions of less than
$10,000 each).
The software will enter in Line (J) the total
of all transactions with the payee/payer for
this schedule (the sum of Lines (H) and
(I))
Special Instructions for Reporting Credit
Card Disbursements

Special Procedures for Reporting
Confidential Information

Disbursements to credit card companies
may not be reported as a single
disbursement to the credit card company
as the vendor. Instead, charges
appearing on credit card bills paid during
the reporting period must be allocated to
the recipient of the payment by the credit
card company according to the same
process as described above.

Filers may use the procedure described
below to report the following types of
information:
•

Information that would identify
individuals paid by the trust to
work in a non-union bargaining
unit in order to assist the labor
organization in organizing
employees, provided that such
individuals are not employees of
the trust who receive more than
$10,000 in the aggregate in the
reporting year from the trust.
Employees receiving more than
$10,000 must be reported on
Schedule 3;

•

Information that would expose the
reporting labor organization’s
prospective organizing strategy.
The labor organization must be
prepared to demonstrate that
disclosure of the information would

The Department recognizes that filers will
not always have the same access to
information regarding credit card
payments as with other transactions.
Filers should report all of the information
required in the itemization schedule that is
available to the labor organization.
For instance, in the case of a credit card
transaction for which the receipt(s) and
monthly statement(s) do not provide the
full legal name of a payee and the trust
does not have access to any other
documents that would contain the
information, the labor organization should
report the name as it appears on the

11

harm an organizing drive. Absent
unusual circumstances information
about past organizing drives
should not be treated as
confidential;
•

•

•

1 or 2 would constitute a per se
demonstration of “just cause” for purposes
of this Act. Consequently, any labor
organization member (and the
Department), upon request, has the right
to review the undisclosed information in
the labor organization's possession at the
time of the request that otherwise would
have appeared in the applicable schedule
if the information is withheld in order to
protect confidentiality interests. The labor
organization also must make a good faith
effort to obtain additional information from
the trust.

Information that would provide a
tactical advantage to parties with
whom the reporting labor
organization or an affiliated labor
organization is engaged or will be
engaged in contract negotiations.
The labor organization must be
prepared to demonstrate that
disclosure of the information would
harm a contract negotiation.
Absent unusual circumstances
information about past contract
negotiations should not be treated
as confidential;

Information that is withheld from full
disclosure is not subject to the per se
disclosure rule if its disclosure would
consist of individually identifiable health
information the trust is required to protect
under the Health Insurance Portability and
Accountability Act of 1996 (HIPAA)
Privacy Regulation, violate state or federal
law, violate a non-disclosure provision of a
settlement agreement, or would endanger
the health or safety of an individual.

Information pursuant to a
settlement that is subject to a
confidentiality agreement, or that
the labor organization or trust is
otherwise prohibited by law from
disclosing; and,

NOTE: Under no circumstances should a
filer disclose the identity of the recipient of
HIPAA-related payments. Likewise, a filer
should not disclose the identity of the
recipient of any payment where doing so
would violate federal or state law, a nondisclosure provision of a settlement
agreement, or would endanger the health
or safety of an individual. Filers should
not include social security or bank account
numbers in completing the form.

Information in those situations
where disclosure would endanger
the health or safety of an
individual.

In Item 25 (Additional Information) the
labor organization must identify each
schedule from which any itemized receipts
or disbursements were excluded because
of an asserted legitimate interest in
confidentiality. The notation must
describe the general types of information
that were omitted from the schedule, but
the name of the payer/payee, date, and
amount of the transaction(s) is not
required.

SCHEDULE 3 — DISBURSEMENTS TO
OFFICERS AND EMPLOYEES OF THE
TRUST
List the names and titles of all officers of
the trust, whether or not any salary or
disbursements were made to them or on
their behalf by the trust. Report all direct
and indirect disbursements to all officers
of the trust and to all employees of the
trust who received more than $10,000 in
gross salaries, allowances, and other
direct and indirect disbursements from the
trust during the reporting period. Benefit

A labor organization member, however,
has the statutory right “to examine any
books, records, and accounts necessary
to verify” the financial report if the member
can establish “just cause” for access to
the information. 29 U.S.C. 431(c); 29
CFR 403.8. Any exclusion of itemized
receipts or disbursements from Schedules

12

payments made to an officer or employee
of the trust as a plan participant or
beneficiary should not be reported as a
payment to a particular individual if the
detailed basis on which such payments
are to be made is specified in a written
agreement. Any such payments, instead,
should be included in the total
disbursements in Item 24. If no direct or
indirect disbursements were made to any
officer of the trust enter 0 in Columns (B)
through (F) opposite the officer’s name.

means received by a party other than the
officer or employee of the trust for the
personal interest or benefit of the officer or
employee. Such payments include
payments made by the trust for charges
on an account of the trust for credit
extended to or purchases by, or on behalf
of, the officer or employee.
Column (A): Enter in Column (A) the last
name, first name, and middle initial of
each person who was either (1) an officer
of the trust at any time during the reporting
period or (2) an employee of the trust who
received $10,000 or more in total
disbursements from the trust during the
reporting period. Also enter the title or the
position held by each officer or employee
listed. If an officer or employee held more
than one position during the reporting
period, in Item 25 (Additional Information)
list each position and the dates during
which the person held the position.

For purposes of completing the Form T-1,
•

An “officer of the trust” means any
person designated as an officer in
the trust’s governing documents,
any person authorized to perform
the executive functions of the
trust, and any member of its
executive board or similar
governing body.

•

An “employee of the trust” means
any individual employed by the
trust.

Column (B): Enter the gross salary of the
officer or employee (before tax
withholdings and other payroll
deductions). Include disbursements by the
trust for "lost time" or time devoted to trust
activities.

These definitions will require a factspecific inquiry by filers to determine
whether trustees, the trust administrator,
and other individuals performing service to
the trust under its control or the trust
administrator’s control are officers or
employees of the trust.

Column (C): Enter the total allowances
made by direct and indirect disbursements
to the officer or employee on a daily,
weekly, monthly, or other periodic basis.
Do not include allowances paid on the
basis of mileage or meals which must be
reported in Column (D) or (E), as
applicable.

Continuation pages can be generated if
needed by clicking on the “Add More
Disbursements To Officers Of Trust”
button located at the top of Schedule 3.
NOTE: A “direct disbursement” to an
officer or employee is a payment made by
the trust to the officer or employee in the
form of cash, property, goods, services, or
other things of value.

Column (D): Enter all direct and indirect
disbursements to the officer or employee
that were necessary for conducting official
business of the trust, except salaries or
allowances which must be reported in
Columns (B) and (C), respectively.

An “indirect disbursement” to an officer or
employee is a payment made by the trust
to another party for cash, property, goods,
services, or other things of value received
by or on behalf of the officer or employee.
“On behalf of the officer or employee”

Examples of disbursements to be reported
in Column (D) include: all expenses that
were reimbursed directly to an officer or
employee, meal allowances and mileage
allowances, expenses for officers' or
employees’ meals and entertainment, and

13

various goods and services furnished to
officers or employees but charged to the
trust. Such disbursements should be
included in Column (D) only if they were
necessary for conducting official business;
otherwise, report them in Column (E).
Include in Column (D) travel advances
that meet the following conditions:
•

•

with the trust if payment is made by the
trust directly to the provider or through a
credit arrangement;
• Disbursements made by the trust to
someone other than an officer or
employee as a result of transactions
arranged by an officer or employee in
which property, goods, services, or
other things of value were received by
or on behalf of the trust rather than the
officer or employee, such as rental of
offices and meeting rooms, purchase of
office supplies, refreshments and other
expenses of meetings, and food and
refreshments for the entertainment of
groups other than the officers or
employees on official business;

The amount of an advance for a
specific trip does not exceed the
amount of expenses reasonably
expected to be incurred for official
travel in the near future, and the
amount of the advance is fully
repaid or fully accounted for by
vouchers or paid receipts within 30
days after the completion or
cancellation of the travel.
The amount of a standing advance
to an officer or employee who
must frequently travel on official
business does not unreasonably
exceed the average monthly travel
expenses for which the individual
is separately reimbursed after
submission of vouchers or paid
receipts, and the individual does
not exceed 60 days without
engaging in official travel.

• Office supplies, equipment, and facilities
furnished to officers or employees by
the trust for use in conducting official
business; and
• Maintenance and operating costs of the
trust’s assets, including buildings, office
furniture, and office equipment;
however, see “Special Rules for
Automobiles” below.

• Reimbursements to an officer or
employee for the purchase of
investments or fixed assets, such as
reimbursing an officer or employee for a
file cabinet purchased for office use;

Column (E): Enter all other direct and
indirect disbursements to the officer or
employee. Include all disbursements for
which cash, property, goods, services, or
other things of value were received by or
on behalf of each officer or employee and
were essentially for the personal benefit of
the officer or employee and not necessary
for conducting official business of the
trust. Benefits payments to the trust
officers and employees are not of the type
required to be reported in Schedule 3 if
the detailed basis on which such
payments are to be made is specified in a
written specific trust agreement.

• Indirect disbursements for temporary
lodging (room rent charges only) or
transportation by public carrier
necessary for conducting official
business while the officer or employee is
in travel status away from his or her
home and principal place of employment

Include in Column (E) all disbursements
for transportation by public carrier
between the officer or employee’s home
and place of employment or for other
transportation not involving the conduct of
official business. Also, include the
operating and maintenance costs of all the

Do not report the following disbursements
in Schedule 3, but they should be reported
in Schedule 2 if they meet the definition of
a major disbursement:
• Payments to individuals, other than
officers and employees of the trust, who
perform work or service for the trust;

14

trust’s assets (automobiles, etc.) furnished
to the officer or employee essentially for
the officer or employee’s personal use
rather than for use in conducting official
business.

value of an automobile used over 50% of
the time for the personal benefit of an
officer or employee must also be reported
in Item 25.

ADDITIONAL INFORMATION
AND SIGNATURES

Column (F): The software will add
Columns (B) through (E) of each line and
enter the totals in Column (F).

25. ADDITIONAL INFORMATION — Use
Item 25 to provide additional information
as indicated on Form T-1 and in these
instructions. Enter the number of the item
to which the information relates in the Item
Number column if the software has not
entered the number.

The software will enter on Line 10 the
totals from any continuation pages for
Schedule 3.
The software will enter on Line 11 the
totals of Lines 1 through 10 for Columns
(B) through (F).

26-27. SIGNATURES — Before entering
the date and signing the form, enter the
telephone number at which the signatories
conduct official business.

SPECIAL RULES FOR
AUTOMOBILES
Include in Column (E) of Schedule 3 that
portion of the operating and maintenance
costs of any automobile owned or leased
by the trust to the extent that the use was
for the personal benefit of the officer or
employee to whom it was assigned. This
portion may be computed on the basis of
the mileage driven on official business
compared with the mileage for personal
use. The portion not included in Column
(E) must be reported in Column (D).

The completed Form T-1 that is filed with
OLMS must be signed by both the
president and treasurer, or corresponding
principal officers, of the labor organization.
If an officer other than the president or
treasurer performs the duties of the
principal executive or principal financial
officer, the other officer may sign the report.
If an officer other than the president or
treasurer signs the report, enter the correct
title in the title field next to the signature
and explain in Item 25 (Additional
Information) why the president or treasurer
did not sign the report.
Before signing the form, enter the
telephone number at which the signatories
conduct official business and the date.
Click the Validate button at the top of the
form to ensure that the report passes
validation.

Alternatively, rather than allocating these
operating and maintenance costs between
Columns (D) and (E), if 50% or more of
the officer or employee’s use of the
vehicle was for official business, the trust
may enter in Column (D) all
disbursements relative to that vehicle with
an explanation in Item 25 (Additional
Information) indicating that the vehicle
was also used part of the time for personal
business. Likewise, if less than 50% of
the officer or employee’s use of the
vehicle was for official business, the trust
may report all disbursements relative to
the vehicle in Column (E) with an
explanation in Item 25 indicating that the
vehicle was also used part of the time on
official business.

To sign the form, click the signature
spaces provided. Fill in the requested
information in the screen that pops up.

IX. TRUSTS THAT HAVE CEASED
TO EXIST
If a trust has gone out of existence as a
trust in which a labor organization is
interested, the president and treasurer of

The amount of decrease in the market

15

the labor organization must file a terminal
financial report for the period from the
beginning of the trust’s fiscal year to the
date of termination. A terminal financial
report must be filed if the trust has gone
out of business by disbanding, merging
into another organization, or being merged
and consolidated with one or more trusts
to form a new trust. Similarly, if a trust in
which a labor organization previously was
interested continues to exist, but the labor
organization’s interest terminates, the
labor organization must file a terminal
financial report for that trust.

If You Need Assistance
The Office of Labor-Management
Standards has field offices located in the
following cities to assist you if you have
any questions concerning LMRDA and
CSRA reporting requirements.
Atlanta, GA
Birmingham, AL
Boston, MA
Buffalo, NY
Chicago, IL
Cincinnati, OH
Cleveland, OH
Dallas, TX
Denver, CO
Detroit, MI
Grand Rapids, MI
Guaynabo, PR
Honolulu, HI
Houston, TX
Kansas City, MO
Los Angeles, CA
Miami (Ft. Lauderdale), FL
Milwaukee, WI
Minneapolis, MN
Nashville, TN
New Haven, CT
New Orleans, LA
New York, NY
Newark (Iselin), NJ
Philadelphia, PA
Pittsburgh, PA
St. Louis, MO
San Francisco, CA
Seattle, WA
Tampa, FL
Washington, DC

The terminal financial report must be filed
electronically with OLMS, via EFS, within
30 days after the date of termination.
To complete a terminal report on Form T1, follow the instructions in Section VIII
and, in addition:
• Enter the date the trust, or the labor
organization’s interest in the trust,
ceased to exist in Item 2 after the word
“Through.”
• Select Item 3(c) indicating that the trust,
or the labor organization’s interest in the
trust, ceased to exist during the
reporting period and that this is the
terminal Form T-1 for the trust from the
labor organization.
• Enter “3(c)” in the Item Number column
in Item 25 (Additional Information) and
provide a detailed statement of the
reason the trust, or the labor
organization’s interest in the trust,
ceased to exist. If the trust ceased to
exist, also report in Item 25 plans for the
disposition of the trust’s cash and other
assets, if any. Provide the name and
address of the person or organization
that will retain the records of the
terminated organization. If the trust
merged with another trust, report that
organization’s name and address.

Consult the OLMS Web site listed below
or local telephone directory listings under
United States Government, Labor
Department, Office of Labor-Management
Standards, for the address and telephone
number of the nearest field office.
Copies of labor organization annual
financial reports, labor organization officer
and employee reports, employer reports,
and labor relations consultant reports filed
for the year 2000 and after can be viewed
and printed at

Contact the nearest OLMS field office
listed below if you have questions about
filing a terminal report.

16

http://www.unionreports.gov. Copies of
reports for the year 1999 and earlier can
be ordered through the Web site.
Information about OLMS, including key
personnel and telephone numbers,
compliance assistance materials, the text
of the LMRDA, and related Federal
Register and Code of Federal Regulations
documents, is also available at:
http://www.olms.dol.gov

Month, Year

17