New Web-Based Reporting System for Forms LM-2, LM-3 and LM-4 
by Michelle L. McCann, CPA, Partner
July 1, 2010

The Department of Labor (DOL) Office of Labor-Management Standards (OLMS) announced its plan to roll out Electronic Forms System (EFS), a web-based system for completing and submitting Labor Organization Annual Financial Reports. EFS will replace the current Adobe-based Forms LM-2, LM-3 and LM-4 and may be available as early as this summer. The DOL intends to run both systems (EFS and Adobe) in parallel for at least three months before discontinuing access to Adobe LM Forms.

 Using EFS, labor organizations can prepare, sign, and electronically file their LM-2, LM-3, or LM-4 without having to download software or pay for digital signatures.  Instead, users, including union officials responsible for signing the Form, and unions must register (at no cost) to gain access to the system.

User Registration

Labor organizations can say good-bye to the complicated process of purchasing and maintaining digital signatures through IdenTrust and say hello to the new process of registering for a unique EFS user ID and password. Each user, including union officials responsible for signing the Form, will need to register for an EFS individual user account and password through DOL's website. Users need to complete the registration process only once and the user account and password will be used from year-to-year. If a union official serves as a principal officer for more than one union, the union official needs only one user account and password to sign the LM Forms.

Union Registration 

Annually, a union representative will need to register for a unique private identification number (PIN) for the union. The union representative will then distribute the PIN to all individuals that need access to prepare, review, or sign the LM Form for that individual union.  If an active PIN becomes compromised, OLMS can be contacted to cancel the PIN and issue a new one.

Improved Functionality

The DOL did not change the reporting requirements. The new filing system is expected to be user-friendly with improved navigation options and validation reports for completing the annual report. Similar to the Adobe Forms, EFS includes an import feature for completing LM Schedules. The data specifications for the import files remain the same.

OLMS Webinar Available

We encourage users to catch a preview of the new EFS system. The DOL is hosting its next webinar on July 15, 2010. To register for the webinar, visit: http://www.dol.gov/olms/regs/compliance/efs/efswebinar.htm. 

Our firm will continue to monitor this area.  Please contact Michelle McCann at (925) 277-9100 or mmccann@lindquistcpa.com with any questions.

Michelle L. McCann, CPA, is a partner in Lindquist LLP's San Ramon office.  She is primarily responsible for overseeing quality control for preparation of exempt organization and employee benefit plan returns, including Forms 5500, 990, LM-2 and 199.  Michelle also provides QuickBooks training and support for the firm's clients.

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