Compliance Blog

What's the LM-30?  It is a report that certain unionized individuals must file each year on behalf of themselves, their spouse, or children.  According to the Department of Labor, the reporting requirements are designed to disclose possible conflicts between personal interests and the union officer's or employee's duty to the union and its members. 

What does this have to do with credit unions? Pamela Yu, NAFCU Associate Director of Regulatory Affairs did a nice job of summarizing the unique effect that the LM-30 has on credit unions.  In her words (which were in a NAFCU comment letter to DOL) the burden involves the following,:

"...(U)nionized credit union members are obligated to file annual reports disclosing personal information about their family’s mortgages, student loans, car loans, or other financial benefits received from a credit union if (1) the credit union does a substantial part (i.e., 10% or more) of its business with employers whose workers are part of the member’s union; (2) the credit union does any business with the member’s union; or (3) any part of the credit union’s business consists of dealing with a trust in which the member’s union is interested."

You can read the rest of NAFCU's comment letter here. Here's a recent NAFCU Today article about the report that also talks about how the LM-30 affects credit unions.

Let's be clear: the credit union does not have to file a thing.  The duty to file an LM-30 rests with the union officer or employee.  But credit unions may receive inquiries from unionized members who want to know whether the credit union falls into one of the three categories listed above. 

For that reason, credit unions may want to familiarize themselves with the LM-30.  Here's a Department of Labor website that contains a boat-load (legal term) of information about the LM-30 process.