Project 2025 Tracker / What’s done, what’s next

18. Department of Labor and Related Agencies · Minor

Let OLMS open union investigations without a formal complaint

Not started

602 18. Department of Labor and Related Agencies

“Revise investigation standards. The Office of Labor-Management Standards should revise its investigation standards to authorize investigations without receiving a formal complaint.”

What has happened

  1. Not started

    Already true before the evidence window: OLMS's published investigation standards have authorized investigations without a formal complaint for as long as they have been published. Its Compliance Audit Program FAQ, last updated 2017-10-21 and still live, states that unions are selected for audit on "a variety of factors … including failure to file required annual financial reports with OLMS on a timely basis, discrepancies in financial reports filed, and complaints received", that "[a] number of unions are also selected for CAP on a random basis each year", and — the sentence that answers the ask outright — that "OLMS may also conduct an audit based on a complaint from a member(s) **or when it appears necessary to determine whether any person has violated or is about to violate provisions of the LMRDA**", which is the § 601(a) standard verbatim. The Compliance Audits page says the same structurally: OLMS "conducts compliance audits of all unions covered by" the LMRDA and the CSRA, and those audits are "designed to verify LMRDA or CSRA compliance, investigate potential violations of the law, and provide compliance assistance". Nothing inside the window revised those standards in either direction: OLMS's two rulemakings are both about reporting forms — the Form LM-30 minor-child definition (final 2026-03-23) and the labor organization annual financial reports (final 2026-06-01) — and neither touches the compliance-audit or investigation triggers. The Status stays `not-started` because a Status measures what this administration did, and on this ask it did nothing.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Negative search: chapter log, Cluster negative search — the OLMS asks (#1650, #1655, #1656).
  • Corrected 2026-09-06 (read-queue ticket 07), and the correction changes the answer. dol.gov is not a wall to the full header set — see #1622’s notes for the shape of it — and OLMS’s published investigation standards were read: dol.gov/agencies/olms/audits and dol.gov/agencies/olms/audits/faqs. They already authorize non-complaint-driven investigations, which is why the item now carries pre_satisfied: true rather than a bare negative. The internal CAP manual and operating procedures are still not published; what is published is the standard, and the standard is the object of the ask.
  • The statutory floor is LMRDA § 601(a), which gives the Secretary power to investigate “whenever he believes it necessary in order to determine whether any person has violated or is about to violate any provision of this Act”. The one investigative channel that does turn on a complaint is Title IV union elections, where § 402(b) requires a member complaint after exhaustion of internal remedies — but that is a statute OLMS cannot revise by changing its own standards, so it is not what this ask leaves outstanding.
  • The Department’s current agenda (reginfo.gov, agencyCd 1200, pubId 202510) lists two OLMS RINs, 1245-AA10 and 1245-AA15, both about filing thresholds and forms.
  • Checked 2026-09-06 (read-queue ticket 06, Already-true sweep): flag stands. The object is OLMS’s published investigation standards, and they were read on 2026-09-06 for the ticket-07 correction that set this flag in the first place - dol.gov/agencies/olms/audits and .../audits/faqs, both still authorizing an audit “when it appears necessary to determine whether any person has violated or is about to violate provisions of the LMRDA”. Nothing inside the window revised them in either direction; OLMS’s two in-window rulemakings are both about reporting forms. Neither branch of the 2026-09-06 amendment is reached.
Action
expand
Object
OLMS investigation standards
ID
1656