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The Board concluded that the report did not satisfy its requirements national football league san francisco 49ers helmet crocband clog that an accountant independently confirm the reliability of the union’s financial figures in an audit consistent with standard accounting practices.

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In Street, we concluded that our interpretation of 2, Eleventh was “not only ‘fairly possible’ but entirely reasonable” … and we have adhered to that interpretation since. national football league san francisco 49ers helmet crocband clog We therefore decline to construe the language of 8 differently from that of 2, Eleventh on the theory that our construction of the latter provision was merely constitutionally expedient. Congress enacted the two provisions for the same purpose, eliminating “free riders,” and that purpose dictates our construction of 8 no less than it did that of 2, Eleventh, regardless of whether the negotiation of union-security agreements under the NLRA partakes of governmental action. First, consistent with Beck and existing Board precedent, we hold that lobbying expenses are chargeable to objectors if they are germane to collective bargaining,

contract administration, or grievance adjustment. Thus, we will carry out a “case-by-case analysis”40 to determine whether expenses incurred toward securing a specific legislative goal are sufficiently related to the union’s core representational functions. The remaining issues concern whether the Union unlawfully charged the Charging Party for expenses the Union incurred while lobbying for bills pending in the Rhode Island and Vermont legislatures. We hold that, like all other union expenses, lobbying expenses are chargeable to objectors to the extent that they are germane to collective bargaining, contract administration, or grievance adjustment. In KGW Radio, the union provided the objector a compilation of chargeable and nonchargeable expenses in a report prepared by the union’s accountant. The accountant did not audit or verify the accuracy of the expenditures in the report and relied solely on representations by the union’s executive director in compiling his report. …