Retired Union Associate Member, SHUPER, DONALD

Regarding my previous comments Document: LMSO-2008-0002-0197 - partly copied here . . .These comments are directed to the following portion of the LM-2 revisons noted in 29 CFR Parts 403 and 408 RIN 1215–AB62 Final Rules published on Jan 21,2009 FR 3678 which has been delayed until late 2009 pending comments due 21 May 2009 : A- RE LM2 item 21, Dues and Fees and Schedule 13 Item A Dues and Fees. Improvement in disclosure is needed in this area to be combined with Schedule 13 information. . For some reason, my attempts to attach the pdf file failed, so I will repeat the two portions referencing that document here I Suggest that a monthly count of member/Feepayer and Fee or dues rates number(s) be provided for each category of Feepayers. Expansion on this item follows. See also attached pdf file FEEPAYERS v LM2 . . Again this shows a need for a monthly count by dues income by kind of member/Feepayer if, as intended, the members are to have ANY chance of checking or discovering dues skimming or even getting a hint there may be a problem. . . . . . . . The attached pdf file FeePAYERS v LM2 is an example of the above. Just how many Beck objectors, Agency Feepayers, Associate members, and religious objector make up the total non member Feepayers is unknown. So how can any member determine any dues skimming or the amount without the sacrosanct monthly dues income breakdown? attachment follows . . . and I have added the complete text of my previous comment in pdf form as additional pages. Don Shuper