Financial Transparency Requirements for Union Intermediate Bodies

The following comments were submitted to on February 18, 2020.

The Department of Labor should subject union intermediate bodies which are composed of only public employees to the same financial transparency requirements as those which have private sector members. It would serve the interests of the public at large to be able to access information about how these organizations spend the money they collect from unions. Perhaps more importantly, the members of those union intermediate bodies should be able to access the information so that they can review the financial health of their unions, and ultimately hold their unions accountable for how dues are spent.

This is especially relevant when union money is spent on political activities. As one Alaska teacher stated in a 2018 op-ed to the Anchorage Daily News, “I have become increasingly frustrated with public sector unions using their members’ dues to support political agendas unrelated to their jobs or the people they serve.” In that same year, the National Education Association distributed $1.9 million to intermediate-level labor organizations in Alaska. Unfortunately, for some members, they are not even able to access the information which might disclose the details of this spending. The proposed rule would alleviate this situation where intermediate unions are operating in the dark.

Public sector unions today look very different than they did when the Labor-Management Reporting and Disclosure Act was passed in 1959. Most of the local, independent unions have become part of massive organizations with complex inter-relationships. Accordingly, disclosure stipulations should be modernized.

I urge the adoption of the proposed rule which would expand financial transparency requirements for public sector, intermediate-level unions to include financial and membership information.