View Information Collection Request (ICR) Package

OMB Control No: 1245-0003	ICR Reference No: 201306-1245-001
Status: Historical Active	Previous ICR Reference No: 201012-1245-001
Agency/Subagency: DOL/OLMS	Agency Tracking No:
Title: Labor Organization and Auxiliary Reports
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 08/19/2013
Retrieve Notice of Action (NOA)	Date Received in OIRA: 07/12/2013
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	08/31/2016	36 Months From Approved	10/31/2013
Responses	31,501	0	33,684
Time Burden (Hours)	4,582,390	0	4,411,640
Cost Burden (Dollars)	0	0	0

Abstract: 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.

Authorizing Statute(s): 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)

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	78 FR 20948	04/08/2013
30-day Notice:	Federal Register Citation:	Citation Date:
	78 FR 41953	07/12/2013
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	31,501	33,684	-2,183
Annual Time Burden (Hours)	4,582,390	4,411,640	170,750
Annual Cost Burden (Dollars)	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: 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

Annual Cost to Federal Government: $5,105,108

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Andrew Davis 202 693-1253 davis.andrew@dol.gov

View ICR - OIRA Conclusion