The Department of Labor’s Office of Labor Management Standards (“OLMS”) has released its long-anticipated revisions to its interpretation of the rules for the reporting of employer engagements with third parties to provide services designed to influence employees’ choices of collective bargaining representation. This is known as “persuader activity.” Employers who enter an agreement with an outside organization for persuader services must report the agreement on an official form, the LM-10 within 90 days of the end of the year. The outside organization must also file a report, the LM-20. These forms must be filed within 30 days of the making of the agreement. Then, after the end of each calendar year, the persuader must file an LM-21 form, which reports all of its labor-related activities (even non-persuader activity) for all employers.
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