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Union Training Funds Receive Needed Relief

April 1st, 2021

In March 2020, the Office of Labor-Management Standards (OLMS) introduced the establishment of Form T-1, Trust Annual Report, which effectively required annual reporting of Apprenticeship programs. The effective date for the Form T-1 requirement was April 6, 2020, and first filings were due for the first fiscal year that began on or after June 4, 2020.

On March 29, 2021, the OLMS issued Number 01-21 which advised they will publish notice of rescission of the Form T-1. OLMS also advise that will apply a nonenforcement policy for initial Forms T-1.

Please see the OLMS news release below.

OLMS-News 01-2021

Number: 01-21

March 29, 2021

OLMS New 01-21: Notice of a non-enforcement policy in connection with an intended rulemaking to rescind the Form T-1 Trust Annual Report

In the spring 2021 Semi-Annual Regulatory Agenda, the Office of Labor-Management Standards (OLMS) will publish notice of an intended rulemaking to propose rescission of the Form T-1 Trust Annual Report, established by a March 2020 final rule. View this report for more information. Fundamental questions exist regarding the rule’s legal basis and policy justifications, but, under the current rule, initial Form T-1 reports must be filed by September 28, 2021.

OLMS has determined that it would not be a good use of resources to bring enforcement actions based upon a failure to file the initial Form T-1 report in light of fundamental questions relating to the legal basis and policy justifications of the rule, the anticipated regulatory action to propose rescinding the Form T-1, and the rapidly approaching filing deadline and associated recordkeeping burden for would-be filers. Under the current rule, Form T-1 reports are due to be filed commencing on September 28, 2021. Consistent with this non-enforcement policy and intent to pursue notice-and-comment rulemaking, OLMS will not seek to enforce the filing of a Form T-1 for one year from the date a labor organization’s first Form T-1 is due.

If anything in this memo pertains to you, please do not hesitate to reach out to our trusted experts to discuss your specific situation.

This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.

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Jess LeDonne
Director, Policy and Legislative Affairs