Labor Organization and Auxiliary Reports

Paperwork Reduction Act Notice: Public reporting burden for this collection of information is estimated to

average 84.12 hours per response. 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
GENERAL INSTRUCTIONS
I. WHO MUST FILE
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:
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
appoints or selects a majority of the
members of the trust’s governing
board; or

contributes greater than 50% of the
trust's receipts during the one-year
reporting period.
Any employer contributions made
pursuant to a collective bargaining
agreement shall be considered the labor
organization’s contributions.
The parent labor organization (i.e., the
national/international or intermediate
labor organization) may file the Form
T-1 report for covered trusts in which
both the parent labor organization and
its affiliates meet the above financial
domination or managerial control test.
The affiliates must continue to identify
the trust in their Form LM-2 Labor
Organization Annual Report, and
include a statement that the parent labor
organization will file a Form T-1 report
for the trust.
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 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 T-1
need be filed for any trust that is an
employee benefit plan within the
meaning of 29 U.S.C. 1002(3) that is
subject to Title I of the Employee
Retirement Income Security Act of 1974
(“ERISA”), pursuant to 29 U.S.C. 1003,
and that filed an annual report with the
Employee Benefits Security
Administration (EBSA) in accordance
with 29 U.S.C. 1021 and 1024, and
applicable rules and requirements, for a
plan year ending during the reporting
period of the labor organization. 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. No Form T-1 need be filed for
any trust that constitutes a credit union
subject to the Federal Credit Union Act,
12 U.S.C. 1751.

note in Item 69 (Additional Information)
of their Form LM-2 that another labor
organization is filing the Form T-1 on its
behalf, along with the name of that labor
organization and the name of the trust.
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.
A labor organization may complete only
Items 1 through 15 and Items 26-27
(Signatures) of Form T-1 if an annual
audit is 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 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 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.

When more than one Form LM-2 filing
labor organization jointly dominates a
trust, that is, the organizations jointly
appoint or select a majority of the
members of the trust’s governing board
or jointly contribute greater than 50% of
the trust's receipts during the one-year
reporting period, only one organization
must file a Form T-1. A single
organization may voluntarily assume
responsibility for the filing of the Form T1. For the exemption to hold, 1) the
volunteer, filing labor organization must
list in Item 25 all of labor organizations
for which it is filing the Form T-1, and 2)
the non-filing labor organizations must

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

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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.

Where the trust and labor organization
have different fiscal years

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.

II. WHEN TO FILE

•

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, 2021 and must be filed
not later than December 29, 2021.

•

The trust’s fiscal year ends on
June 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
June 30, 2021 and must be filed
not later than March 31, 2022.

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

The Form T-1 requirements apply to a
labor organization whose fiscal year and
the fiscal year of its section 3(l) trust
begin on or after July 1, 2020. 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
ending on or before 90 days before the
union’s 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:
Where the trust and labor organization
have the same fiscal years
•

The trust and the labor
organization each has a fiscal year
that ends on June 30. The labor
organization’s first Form T-1 will be
for the trust’s fiscal year ending
June 30, 2021 and must be filed
not later than September 28, 2022.

III. HOW TO FILE

The trust and labor organization
have fiscal years ending on
December 31. The Form T-1 for
the fiscal year ending
December 31, 2021 must be filed
not later than March 31, 2023.

Form T-1 must be submitted
electronically to the Department via the
OLMS Electronic Forms System (EFS)
available on the OLMS website at:
http://www.dol.gov/olms. Form T-1 filers
will be able to file reports in paper format

3

timeframe specified above, the report
will be considered delinquent.

only if they assert a temporary hardship
exemption.
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) 693-0123.

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:

HARDSHIP EXEMPTIONS
A labor organization that must file Form
T-1 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.

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 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.

TEMPORARY HARDSHIP
EXEMPTION:
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) 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 202-693-0123.

Note: If either the paper filing or the
electronic filing is not received in the
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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.”

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.

VI. RECORDKEEPING

VIII. COMPLETING FORM T-1

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.

INTRODUCTION
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.

SPECIAL INSTRUCTIONS
FOR CERTAIN
ORGANIZATIONS
VII. LABOR ORGANIZATIONS IN
TRUSTEESHIP

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.

Any labor organization that has placed a
subordinate labor organization in
trusteeship is responsible for filing the
subordinate’s annual financial reports.
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.

5

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.

1. FILE NUMBER — EFS will enter the
labor organization’s 6-digit file number
here and at the top of each page of
Form T-1. This is the number you
entered when you downloaded Form T1. 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 website at
http://www.unionreports.gov, or by
contacting the nearest OLMS field
office.

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 T-1 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.

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 the 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.
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.

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

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.
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 25
(Additional Information) that the report is

6

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.

downloaded Form T-1. If the name is
incorrect, you must download another
form using the correct name.
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
pre-filled identifying information.

This item cannot be edited by the filer. If
the labor organization needs to change
this information, contact OLMS at (202)
693-0123.
5. DESIGNATION — 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.

11. TRUST EMPLOYER
IDENTIFICATION NUMBER (EIN) —
Enter the Employer Identification
Number assigned to the trust by the
Internal Revenue Service.

6. DESIGNATION NUMBER — EFS
will enter the number or other identifier,
if any, by which the labor organization is
known. This field cannot be edited by
the filer.

12. PURPOSE — Enter the purpose of
the trust. For example, if the trust is an
apprenticeship and training plan that
provides training to labor organization
members, the purpose may be
“training.”

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.

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.

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.

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 labor organization.

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.
10. NAME OF TRUST — The software
will enter the name of the trust. This is
the trust name you entered when you

Note: The president and treasurer of the

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.

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 completed within the
preceding 12 months 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.

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.
For assets that were traded in, enter in
Item 25 the cost, book value, and tradein allowance.

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.

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.

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

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
8

REPORT ONLY DOLLAR AMOUNTS

represent the flow of cash in and out of
the trust and should not be reported as
receipts and disbursements.

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.

Since Items 23 and 24 report cash
flowing 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.

Enter a single “0” if there is nothing to
report.
REPORTING CLASSIFICATIONS

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.

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
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.

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.

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.

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.

RECEIPTS AND
DISBURSEMENTS

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

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

9

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

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

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.

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.

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.

Exemptions

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.

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.

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

10

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.

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
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).

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

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.

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
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.

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.
Enter in Column (C) the purpose of the
receipt/disbursement, which means a

11

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.

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;

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 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.
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.
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.

•

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

•

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 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,

•

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

Special Procedures for Reporting
Confidential Information
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

In Item 25 (Additional Information), the
labor organization must identify each
schedule from which any itemized

12

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.

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.
SCHEDULE 3 — DISBURSEMENTS
TO OFFICERS AND EMPLOYEES OF
THE TRUST

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 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.

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 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.

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 endanger the health or
safety of an individual.

For purposes of completing the Form
T-1,

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, would violate a non-disclosure

•

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.

These definitions will require a factspecific inquiry by filers to determine

13

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.

the trust for "lost time" or time devoted
to trust activities.
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” 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.

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 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:

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.

•

•

Column (B): Enter the gross salary of
the officer or employee (before tax
withholdings and other payroll
deductions). Include disbursements by

14

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.

• Maintenance and operating costs of the
trust’s assets, including buildings, office
furniture, and office equipment;
however, see “Special Rules for
Automobiles” below.

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:

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.

• Payments to individuals, other than
officers and employees of the trust, who
perform work or service for the trust;
• 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;

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 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.

• 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
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;

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

SPECIAL RULES FOR
AUTOMOBILES

• Office supplies, equipment, and facilities
furnished to officers or employees by
the trust for use in conducting official
business; and

Include in Column (E) of Schedule 3 that
portion of the operating and
maintenance costs of any automobile

15

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).

signatories conduct official business.
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

The amount of decrease in the market
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.

If a trust has gone out of existence as a
trust in which a labor organization is
interested, the president and treasurer
of 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.

ADDITIONAL
INFORMATION
AND SIGNATURES
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.
26-27. SIGNATURES — Before
entering the date and signing the form,
enter the telephone number at which the

The terminal financial report must be
filed electronically with OLMS, via EFS,
within 30 days after the date of

16

termination.
To complete a terminal report on Form
T-1, follow the instructions in Section
VIII and, in addition:

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

• 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 LaborManagement 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
http://www.unionreports.gov. Copies of
reports for the year 1999 and earlier can
be ordered through the website.

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

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

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

March 2020
17