Is a payment to a union officer for compensation for service as a member of a corporate board of directors reportable on Form LM-10?
A49. Yes, but as a matter of enforcement discretion the Department will not seek to require Form LM-30 or LM-10 reports of directors’ fees (or reimbursed expenses) for fiscal years commencing on or before December 31, 2005. Under section 203(a) of the LMRDA, employers who make payments to a labor organization or its officials must file a report, subject to multiple exceptions. 29 U.S.C. § 433(a). One of these exceptions exempts employers from disclosing “payments of the kind referred to in section 302(c)” of the Labor Management Relations Act. Section 302(c) excludes, among other things, payments “with respect to the sale or purchase of an article or commodity at the prevailing market price in the regular course of business.” 29 U.S.C. § 186(c). A 1983 letter from a senior Department official, responding to a request for an opinion concerning directors’ fees paid to union officers serving on a corporate board, concluded that the fees must be reported. Subsequently, in 1986, a senior De
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