The Labor-Management Reporting and
Disclosure Act (LMRDA) requires unions to file annual financial
reports, and copies of their constitution and bylaws with DOL.
Under certain circumstances, reports are required of union officers
and employees, employers, labor relations consultants, and surety
companies. All reports are available for public disclosure. Filers
are required to retain supporting records for five years; unions
are required to retain election records for one year.
US Code:
29 USC 401 et. seq. Name of Law: Labor Management Reporting and
Disclsoure Act of 1959 (LMRDA)
US Code: 5 USC
7120 Name of Law: Civil Service Reform Act
US Code: 2 USC
1301 Name of Law: Congressional Accountability Act of 1995
(CAA)
US Code: 22
USC 4117 Name of Law: Foreign Service Act (FSA)
In comparison to the previous
submission (33,684 responses and 4,411,641 burden hours), this ICR
requests 2,183 fewer responses, while burden hours increase by
170,729. There is actually a decrease of 42,610 hours attributable
as a program change. These changes are a result of the estimated
hourly reporting burden reduction for the Forms LM-2, LM-3, and
LM-4 since the release of EFS. Details on those changes are
described in the next few paragraphs. Additionally, the Department
has updated its estimates with the most recent data available. That
information suggests a burden increase of 213,339 hours, primarily
due to a significant increase in the number of Form LM-2 filings
that are not the result of program changes. For Form LM-2 filers,
it is no longer necessary to obtain a digital signature from the
third-party vendor, which results in an immediate savings of 4.0
hours, according to the 2003 LM-2 standard's burden estimate. In
addition, because of improved context-sensitive help and access to
instructions, a time savings for review of the instructions is also
factored in. Finally, the new electronic signatures and
verification save the filer significant time. We estimate that
total burden reduction for LM-2 filers, moving from the first to
the second generation system to be 5.8 hours, even when the minimal
additional time is added to obtain the union PIN and for the
officers to register. The Department therefore estimates that the
Form LM-2 reporting burden is 140.2 hours, rather than the previous
estimate of 146 hours. 6,073 responses x 5.8 hours = 35,223 hours.
Form LM-3 and -4 users are still not required to use electronic
filing, and consequently, until 2010, few of them did. Form LM-3
has a number of areas where electronic filing can significantly
reduce burden besides those described for Form LM-2. These
additional areas include the fact that the electronic forms
pre-populate a significant amount of informational items on the
first page and the beginning year asset and liability category
balances are brought forward from the end of year balances of the
previous year's form, thus saving a significant amount of data
entry. But in addition, the electronic form also totals dependent
items, such as summing total assets, total liabilities, total
receipts, total disbursements and total payments to officers,
obviating the need to use a calculator, double-check answers, and
enter data manually; to estimate the time required, a
time-and-motion study was performed to determine the burden
reduction. It should be noted that Form LM-4, the simplest of all
three forms, lacks any beginning versus end of year balance
reporting and has no arithmetic to be performed in the form itself,
so the burden reduction is more modest. We also estimate a
reporting burden reduction in filing Form LM-4 electronically from
8.0 to 7.18 hours. Thus, the total burden for the LM-4 is now
approximately 9 hours, a reduction from the previous estimate of 10
hours. 7,387 responses x 1 hours = 7,387 hours
$5,105,108
No
No
No
No
No
Uncollected
Andrew Davis 202 693-1253
davis.andrew@dol.gov
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.