Is a payment to a union officer for compensation for service as a member of the board of directors of a financial institution reportable on Form LM-10?
A49(A). Yes. Section 203(a)(1)(A) of the LMRDA does not exempt payments of directors’ fees to a union official who serves on the board of directors of a financial institution. The Form LM-10 Instructions, promulgated in 1960 after notice and comment, clarify that “[p]ayments or loans made in the regular course of business as a national or state bank, credit union, insurance company, savings and loan association or other credit institution” are nonreportable. Form LM-10 Instructions, Part A, Item 8. Compensation paid by a financial institution to a director who is a union official is not within this exemption and must therefore be reported. The “payments or loans” exempted by section 203(a)(1)(A) encompass the transactions engaged in during the regular course of business of a financial institution. Financial institutions are in the business of providing financial services to customers and to this end they routinely, for example, make interest and dividend payments, sell financial produc
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