Making corporate collection methods available to labor organizations

Any lawful method of soliciting and collecting SSF contributions (such as payroll deduction) that is used by a corporation may also be used by a labor organization that represents the corporation’s employees. Moreover, upon written request by a labor organization, a corporation and its subsidiaries must provide the labor organization with the same method used by the corporation for soliciting and collecting contributions for its own SSF or for a trade association’s SSF.

Reimbursement

A corporation must provide its solicitation and collection system to a labor organization at a cost sufficient only to reimburse the corporation for the expenses incurred in doing so. The reimbursement may not be waived, since that would result in the corporation’s absorption of the labor organization’s solicitation costs—a prohibited contribution. The Commission has approved a labor organization’s advanced payment of solicitation and collection costs to a corporation rather than reimbursement.

Exception

If neither a parent corporation nor its subsidiaries sponsor an SSF, they are not required to make any solicitation or collection method available to any labor organization, though a corporation may agree to make some system available at cost.

Twice-yearly solicitations

A corporation must make available to the labor organization the method it uses for soliciting and collecting contributions through a twice-yearly mailing.