The National Right to Work Foundation has submitted formal comments opposing a proposed rule from the Office of Labor Management Standards (OLMS) that would change union financial disclosure requirements. The proposed regulation would raise the threshold for unions required to file detailed LM-2 reports with the Department of Labor from $250,000 in annual receipts to $450,000. Unions below this new threshold would only need to submit less comprehensive LM-3 or LM-4 forms.
According to the Foundation, this adjustment would mean that many unions currently providing detailed disclosures would instead submit shorter reports, reducing transparency for millions of workers. The Foundation’s comments state: “The ‘cost’ of the proposed rule—the information that workers and others will no longer be able to learn about unions—is considerable. The rule’s ostensible ‘benefit’—reducing union reporting burdens—is not supported by evidence and is insignificant…The costs of the proposed rule greatly outweigh its nonexistent benefits.”
The Foundation highlighted that over 7,700 unions with receipts under $450,000 are located in states without Right to Work laws. These unions reported combined annual receipts exceeding $523 million and more than 4 million members. The Foundation argues that without detailed reporting requirements, these workers would lose access to important information about how their dues are spent.