greater than 10,000 reportable individual disbursements and several thousand

reportable individual receipts. Ruttenberg Report at § (q(iii).

I Such enormous masses of data do nothing to simplify, condense and
aggregate financial information into meaningful totals that unions' members
could use to understand the financial status of their union. Rather, the
proposal would disclose massive amounts of non-material financial data, with
the result that union members will be distracted and confused in their efforts
I to parse out what is meaningful in the LM -2 versus what is simply noise.

Because the information is disaggregated and non-material, the

I proposed disc10sures also do nothing to advance the Department's desire to
provide more useful information to union members. Throughout the NPRM,
the Department makes plain its premise that itemization will "meet the
I objectives of the statute by providing union members with useful data that will
enable them to be responsible and effective participants in the democratic
governance of their unions." 67 Fed. Reg. at 79281 . See also id. at 79288
I ("This individual identification of receipts and disbursements will enable union
members to meaningfully assess the financial operations of the union, but will
not require unnecessary reporting of all minor receipts and disbursements.").
I But, in light of the accounting principles reviewed above, the

I Department's policy argument for itemization is absurd on its face. While

FASB and AlCPA principles teach that appropriate aggregation gives meaning
to financial minutiae, the Department argues that itemization will enable union
I members to "meaningfully assess" a union's finances, and that aggregate totals
"offer an unhelpful and vague picture of the financial condition and operations
of the union." Id. In this case, the Department's position directly contradicts
I FASB and AICPA core accounting concepts and cannot be justified.

Looking more closely at the Department's actual complaints about the

I current reporting categories, it becomes apparent that the Proposed Rule has
simply no relation to the Department's professed concerns. The NPRM
complains that "union members currently have no meaningful way to evaluate
I the appropriateness of large expenditures for generalized purposes," id. at
79281, and that "the current form Imakesl it difficult to determine whether
these amounts were actually spent for the described activities." Id; see also id.
I at 79282 ("The large dollar amount and vague description of such entries make
it essentially impossible for members to determine whether or not their dues
were spent appropriately.").
I As should be obvious, however, listing individual items does not help

I members determine what unions "actually spent for described activities. "24 If

24 To the extent the Department means by this that the allocations are

I unverified - rather than that a member cannot discern adequately the scope of

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I