Public Overwhelmingly Opposes Labor Department Proposal to Loosen Union Financial Disclosures
Over 97% percent of comments oppose proposal to let union bosses hide more political spending from workers
The National Right to Work Foundation recently filed detailed comments in opposition to a Department of Labor Office of Labor Management Standards (OLMS) proposed rule to significantly reduce financial disclosures union officials are required to file. With the comment period concluding last week, it is now clear that commenters overwhelmingly agree with the Foundation that the rule should be rejected.
Of 299 public comments submitted, over 97% strongly opposed the rule change.
The full comment submitted by the National Right to Work Foundation can be read here.
The Foundation’s comments note that the rule cannot be justified because workers’ rights will be undermined if union officials are permitted to more easily hide their spending of dues money, including money seized from workers forced to pay dues or else be fired:
“OLMS data for the past year…shows over 7,700 filings from unions with receipts under $450,000 that are located in states that lack Right to Work laws. These unions reported combined annual receipts of over $523 million, annual disbursements of over $514 million, and over 4 million members… The lack of more detailed reporting requirements for these unions therefore harms over 4 million workers by denying them meaningful details…”
These sentiments were echoed by hundreds of Americans, including rank-and-file workers, who are furious with the OLMS for proposing to deprive millions of workers of vital information on how union officials spend their dues payments, especially spending on union political and ideological activities. As over 225 of the comments point out, this change would allow over 850 unions, spending over $200 million annually, to hide their activities from detailed financial disclosure accessible to workers and the public.
Former union members used the public comments to share their personal experiences with union misconduct, and their desire for more accountability:
- A former member of the International Brotherhood of Teamsters shared retaliation he experienced for speaking out about errors in union financial reports.
- A former professor recalled being forced to pay union dues and being coerced into supporting union candidates and policies.
- A former member of the International Brotherhood of Electrical Workers remembers union chiefs spending lavish amounts of money on politicians he would never vote for.
- A former member of the Communications Workers of America felt betrayed by union bosses and urges the Department to make them account for every cent they misuse.
Other detailed comments opposing the rule came from the National Institute for Labor Relations Research, Institute for the American Worker, Yankee Institute, and Coalition for a Democratic Workplace, as well as others.
Of the just seven comments that actually favored the change, a majority were filed by union officials who predictably want more leeway to hide their spending of dues money from the rank-and-file they claim to “represent.”
Among them was the National Education Association (NEA) which unsuccessfully attempted to hide its controversial 2025 handbook from the public just as comments were being solicited.
Meanwhile, union bosses at the AFL-CIO and AFSCME actually argued for even less disclosure to workers than the rule proposed, with AFL-CIO even suggesting that thresholds should be automatically raised every year.
The United States establishes a government of the people, by the people, and for the people. OLMS should reject these union bosses’ personally-motivated requests, and instead listen to the voice of the overwhelming majority calling for this change to be withdrawn.
National Right to Work Foundation Submits Comments Opposing Proposed DOL Rule Loosening Union Financial Disclosures
Comments: Rule will let huge number of unions escape meaningful scrutiny over how union bosses spend worker funds while providing no tangible benefits
Washington, DC (July 31, 2025) – The National Right to Work Foundation has just submitted comments regarding the Office of Labor Management Standards’ (OLMS) proposed rule to significantly reduce financial disclosures union officials are required to file with the Department of Labor. The comments warn that the slated rule will deprive millions of rank-and-file workers of vital information on how union officials spend their dues payments, especially spending on union political and ideological activities.
Current financial disclosure rules for unions mandate that unions with $250,000 or more in annual receipts file an LM-2 report with the Department of Labor, while unions with less revenue must only submit less-detailed LM-3 or LM-4 reports, both of which consist of only a few pages. The OLMS’ proposed rule would eliminate the requirement to turn in an LM-2 for all unions except those with $450,000 or more in annual receipts, meaning a large number of unions currently subject to LM-2 reporting would only be required to provide substantially less-comprehensive filings.
“The ‘cost’ of the proposed rule—the information that workers and others will no longer be able to learn about unions—is considerable,” the comments say. “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.”
New Rule Will Block Millions of Workers From Seeing Basic Details About Union Spending
The comments emphasize the wide impact of the proposed rule, especially among those who work in states that lack Right to Work protections and for that reason can be forced to pay union dues or fees just to keep their jobs. “OLMS data for the past year…shows over 7,700 filings from unions with receipts under $450,000 that are located in states that lack Right to Work laws,” the comments say. “These unions reported combined annual receipts of over $523 million, annual disbursements of over $514 million, and over 4 million members.
“The lack of more detailed reporting requirements for these unions therefore harms over 4 million workers by denying them meaningful details” regarding how union officials spend their hard-earned money, the comments explain.
Much of this omitted information will include details on how much money union officials spend on overhead and administration as opposed to representational activities in the workplace, not to mention what union bosses are contributing to often-divisive political causes. While LM-2 forms let workers quickly see these figures, the comments say, “[t]he proposed rule will deprive workers of this information about many unions because the LM-3 does not include these reporting categories.”
Knowing less about union political spending will also impede workers’ ability to enforce their rights under the Foundation-won Communications Workers of America v. Beck Supreme Court decision, the comments point out. Beck blocks union bosses from forcing nonmember workers under their control to pay for union ideological expenses or anything unrelated to representational activities. The comments point to contributions disclosed on LM-2s to groups such as ActBlue, Black Lives Matter, and the Democratic National Committee that would no longer be disclosed to workers if the proposed rule were implemented.
Comments Debunk Union ‘Burden’ Arguments Cited by OLMS
The comments also reveal that the main impetus OLMS cites for pushing this proposed rule – that the regulatory burden for unions is too large – has very little evidence to support it. An estimate that OLMS put out about the number of hours that the proposed requirements would save unions is “out of date, fails to account for modern…software, and is not even an estimate of the time it takes impacted unions to complete LM-2 reports, but rather is an estimate of the average time it takes all unions to complete LM-2 reports,” the comments say.
The comments conclude by asking OLMS to eliminate the current system of graduated filing thresholds and instead require all unions to file LM-2 reports. “The benefit of this change is self-evident: workers, the public, and the Department will receive more information about union finances, which in turn will lead to more informed workers and deter and uncover more union corruption,” the comments explain.
“America’s top union bosses are routinely caught abusing the funds they demand from millions of workers across the country, all while promoting divisive and often radical political causes at every level of government,” commented National Right to Work Foundation President Mark Mix. “Acting in the best interests of workers means providing more clarity on how employee money is spent, not less.
“Make no mistake: The OLMS’ proposed rule will benefit union bosses at the expense of rank-and-file workers. Every worker deserves to know the basic details of how their money is being spent by those who claim to ‘represent them,’ and the slated rule would deprive millions of workers of what little information they already have,” Mix added.