Should Form LM-10 filers be interested in the Form LM-30 rulemaking?
A75. Yes. In the Federal Register of August 29, 2005 (70 FR 51166), the Department published a Notice of Proposed Rulemaking that would revise the form that officers and employees of labor organizations are required to file under the LMRDA (Form LM-30). There are several reasons why Form LM-10 filers should be interested in the proposed revision to the Form LM-30. Among other things, both the Form LM-30 and Form LM-10 have similar de minimis standards. In addition, the proposed rule changes the Form LM-30’s definition of “bona fide employee” to eliminate the exemption for payments to employees for activities other than productive work, such as payments from employers to union officers for work performed for the union. The Form LM-10 has a comparable provision. Further, the Department proposes to eliminate the provisions for a special report found in the regulations and the Instructions for the Form LM-30. The Form LM-10 and its implementing regulations have a comparable provision. The
