September 17, 1998

Mr. William D. Hanline
12 Baldwin Road
Decatur, AL 35603

Dear Brother Hanline:

This is in response to your letter to me dated July 22, 1998, and your letter to Brother Yokich dated August 3, 1998. We appreciate you sharing your observations, thoughts, political positions, and questions with us.

You say you have been researching Joint Programs since September 1996, with the help of two lawyers, an actuary, a CPA, the IRS and the DOL -but remain confused.

The Joint Programs are the creations of our National Agreements, particularly in GM, Ford, and Chrysler. The training and other benefits are delivered through joint, non-profit corporations, created for that purpose. Each is exempt under provisions of §50i(c) of the IRS Code. These corporations receive, disburse, and account for their own funds.

The work of the Joint Programs is performed by employees of GM, Ford or Chrysler, as the case may be.. Some of those employees are members of management on assignment. For example, the HRC reimburses GM for the costs of these members of management. Some of those employees are active hourly workers, i.e., members of our bargaining unit, who are on special assignment to the Program. Some of those employees are commissioned International Representatives, assigned to work on these Programs. The HRC reimburses the UAW for the cost of these International Representatives. Beyond this, the Programs hire clerical and other direct employees, and make their own decisions about when to contract with outside firms for goods and services.

Enclosed are copies of IRS Form 990, with the incorporated LM-2 for 1997. As you know, Schedule 10 includes a full listing of the salary, expenses, and allowances paid to all employees receiving more than $10,000. The job of each employee is indicated. In accounting terms, these are nothing more than

exchange transactions. Even so, in compliance with OLMS requirements, we include these International Representatives on Schedule 10, treating the related payroll as disbursements, and treating the balancing reimbursement as receipts. "Footnote: Statement B." added by our outside CPA. discusses this treatment.

Like all other major national unions, in recent years, the UAW was audited by the DOL's OLMS under their "International Compliance Audit' Program" (I-CAP). That process took some 6 months, and was wide-ranging. As you would expect, the audit covered these Joint Program "exchange" issues. If, as you say, you are consulting with investigators from the OLMS, we would gladly supply the OLMS with the names of their colleagues, who are considerably more experienced, and certainly much less confused on this subject.

We believe that this explanation, with the accompanying documents, should answer your questions. If this is not so, next time please refer to particular lines or figures, and explain why you think there is an error, problem, or contradiction. As always, we will do our best to answer your question, or refer you to someone who might.

Fraternally,

INTERNATIONAL UNION, UAW

Ruben Burks, Secretary-Treasurer

RB/Jeb

opeiu494

Enclosure

cc/enc: Stephen P. Yokich, President - International Union, UAW

January 21, 2000
Allen Nielsen
1841 Old State Road
Norwalk, Ohio 44857
Phone 419/663/2289

U.S. Department of Labor Employment Standards Administration Office of Labor-Management Standards, Room N-5610 200 Constitution Avenue, NW Washington, DC 202 10

Dear OLMS:

Bill Hanline, a friend of mine, gave me a copy of the (enclosed) letter of September 17, 1998, that he received in response to an inquiry he made on our International Union UAW.

SEE Page 2, IN YELLOW. This response from Mr. Ruben Burks, our International Union UAW Secretary-Treasurer indicates our UAW was audited on our UAW's Joint Program exchange issues, by the DOL's OLMS under their "International Compliance Audit Program" ("I-CAP").

I would like to make a public records demand for all the information, correspondence, etc. given to the DOL by our UAW for this audit, and all correspondence, reports, audit information, etc. generated by the DOL on this audit. If it is less than 1000 pages. Please send to me and bill me at the above address. If it is more than 1000 pages, tell me how many pages.

Sincerely,

Allen Nielsen

Mr. Allen Nielsen
1841 Old State Road
Norwalk, Ohio 44857

Dear Mr. Nielsen:

This is in response to both your January 21 and February 16 letters in which you seek information pertaining to the audit of the United Automobile Workers (UAW) that was performed under the International Compliance Audit Program (I-CAP). Your inquiries have been processed as requests made under the Freedom of Information Act (FOIA).

Your requests are therefore denied. I am withholding the I-CAP audit of the UAW in its entirety. Exemptions 2, 4, 5, and 7(E) of the FOIA are the bases for the denial. Exemption 2 protects information related to internal rules and practices of an agency. In addition, this exemption protects internal agency instructions to investigators to the extent that they constitute confidential investigatory techniques and procedures, the disclosure of which would seriously hamper the detection of violators. Exemption 2 applies to the audit because disclosure would outline agency guidelines and discussions regarding the manner in which OLMS carries out its enforcement activities, and thus permit individuals to circumvent the enforcement programs of this Office.

Similarly, Exemption 7(E) allows for withholding information from the I-CAP audit because it discusses approaches and sets forth guidelines for carrying out law enforcement proceedings. This

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exemption provides for the withholding of material which would reveal law enforcement and investigative techniques and procedures, if disclosure could reasonably be expected to risk circumvention of the law. It is apparent that information which could serve to allow violators to evade the law should not be subject to public disclosure. I believe that the investigative techniques described in the audit could, if disclosed, enable violators to frustrate the efforts of our investigators to enforce the law.

Exemption 4 of the FOIA was used primarily to protect union records. It protects, in part, commercial or financial information obtained from a person or an organization (including a labor union), which is privileged or confidential. It exempts from disclosure material that would not customarily be made public by the party who furnished it to the Federal Government. Information that comes within the protection of Exemption 4 is that which, if disclosed, could cause substantial harm to the competitive position of the submitter or would likely impair or inhibit the Government's ability to obtain similar information in the future. This exemption also protects information which is given to a Federal agency in confidence. When the Government has obligated itself in good faith not to disclose information it receives, it should be able to honor the obligation.

Exemption 4 has also been invoked because there is a good possibility that the competitive position of the union would be jeopardized if certain documents were disclosed. Release of the information withheld would provide competitors with valuable insight into the strengths and weaknesses of the union and might be used to ferment dissention within the union and undermine its vitality and competitive position. As disclosure would harm identifiable private or Government interests which Congress sought to protect by enacting Exemption 4, release of certain information and documents in the audit file is being denied.

Finally, Exemption 5 was asserted because some of the material withheld would disclose the opinions and recommendations of Department of Labor personnel. Exemption 5 exempts from disclosure inter-agency or intraagency memorandums or letters which would not be available by law to a private party in litigation with the agency. It has been interpreted to permit an agency to withhold documents or parts of documents which reflect opinions, recommendations, and deliberations of agency personnel which are part of the process of formulating government decisions and policies. Exemption 5 is designed to insure that agency personnel express their full and frank views and recommendations in deliberations regarding the programs they administer.

Section 70.22 of the Department of Labor regulations provides that an applicant whose request for a record has been denied may file an appeal 90 days from the date of the denial. The appeal must be in writing and must state the grounds for appeal,

3

including any supporting statements or arguments. If an appeal is made, it should be addressed to the Solicitor of Labor, Department of Labor, 200 Constitution Avenue, NW, Washington, D.C. 20210. To expedite processing, the envelope and the appeal should be clearly labeled: "F.O.I.A. Appeal."

Sincerely,

John Kotch

Acting Deputy Assistant

Secretary

By:

S/ Kay H. Oshel, Chief

Division of Interpretations

and Standards

PAUL E. GILLMOR

5TH DISTRICT, OHIO

COMMITTEE ON COMMERCE

VICE CHAIRMAN

COUNTIES: DEFIANCE, ERIE, HENRY, HURON,

LORAIN (PART), MERCER (PART), OTTAWA

(PART), PAULDING, PUTNAM, SANDUSKY,

SENECA, VAN WERT, WILLIAMS, WOOD (PART)

S UBCOMMITTEES:

TELECOMMUNICATIONS, TRADE AND

CONSUMER PROTECTION

FINANCE AND HAZARDOUS MATERIALS

DEPUTY MAJORITY WHIP

COMMITTEE ON

INTERNATIONAL RELATIONS

Congress of the United States

SUBCOMMITTEES:

A SIA AND THE PACIFIC

THE WESTERN HEMISPHERE

WASHINGTON DEFIANCE NORWALK PORT CLINTON

1203 LONGWORTH HOUSE OFFICE BUILDING 613 WEST THIRD STREET 130 SHADY LANE DRIVE 120 JEFFERSON STREET, 2D FLOOR

WASHINGTON, DC 20515-3505 DEFIANCE, CH 43512 NORWALK, CH 44857 PORT CLINTON, CH 43452

202-225-6405 419-782-1996 419-668-0206 419-734-1999

TOLL FREE IN OHIO 1-800-541-6446

TOLL FREE FAX IN OHIO 1-800-278-8203

March 27, 2000
Allen Nielsen
1841 Old State Road
Norwalk, Ohio 44857
Phone 419/663/2289

U.S. Department of Labor

Employment Standards Administration

Office of Labor-Management Standards, Room N-5605

ATTN: Kay H. Oshel, Chief Division of Interpretations and Standards

200 Constitution Avenue, NW`

Washington, DC 202 10

RE: Enclosed DOL letter of February 25, 2000.

Dear Kay H. Oshel:

1, Allen Nielsen, am a member in good standing of UAW Local 425, in Lorain, Ohio.

According to your letter of February 25, 2000, 1 have 90 days in which to file an appeal with the DOL, for the information that I requested, on the UAW Joint Funds I-CAP (International Compliance Audit Program) investigation. (This is not an Appeal.) Our International Union Leadership will not give us this I-CAP audit information. SEE enclosed 2 1/2 inch stack of information, documentation and correspondence over the last year and a half, in trying to get information from our International Union UAW on UAW Joint Funds and other Union financial information.

Sometimes it is just asking the right person, hopefully yourself, where or how to get this information from another source or asking the right format to get this I-CAP information. I did review DOL Exemptions 2, 4, 5, and 7(E) in your letter of February 25, 2000. Is there any information the DOL can give us on what our overtime penalty Joint Fund money is being used for, an overview of what the Joint Fund organization chart break down looks like? I believe our UAW membership has a right to know whether the monies from our overtime penalty Joint Fund money is being properly spent from our point of view. It appears the enclosed DOL Labor-Management Reporting and Disclosure Act of 1959, As Amended, ....Declaration of Findings, Purposes, and Policy (29 U.S.C. 401), Sec 2., offers protection to the membership from wrong doing, self serving interests, corruption, unethical conduct of our Union Leadership? 29 USCS 431 appears to support membership rights to this type of Union financial information from our International Union Leadership. Getting it is another problem.

Our International Union Leadership has refused to give up Joint Fund information and other requested information, even though I believe I have a right to this information, SEE enclosed, under our UAW ETHCIAL PRACTICES CODES, under Financial Practices, .......The membership is also entitled to be reasonably informed as to how Union funds are invested or used."

Everything that I have found in the 1959 LMRA, even court cites under 431 Report of labor organization doesn't appear to cover the unique arms length distancing and Company Union Joint Funds relationship, from membership scrutiny or grievance procedure. SEE enclosed letter of June 26, 1998 from Mr. Ellis Boal, Esq., that it is Mr. Boal's opinion, this relationship is outside the grievance procedure, even though our overtime penalty money is used to support the UAW/Company Joint Fund Relationship.

Your letter said this audit was opened on May 5, 1994 and closed on June 30, 1995. Please read the enclosed May 27, 1995 Detroit Free Press news article, "UAW-GM program has trail of losses, lawsuits." Did the DOL have knowledge of this alleged wrongdoing and information before the I-CAP was concluded on June 30, 1995? If this .was 3% of the UAW-GM Joint Funds budget and only one of the three Auto Companies, we are probably looking at 1% overall of the window of what Joint Funds were being, as I contend, is being improperly used. This is WHY I want to see what the other 99% or overall financial expenditures of the Joint Funds and whether these other programs are in the best interest of the membership. I believe the Joint Programs are necessary, in that we have to work with the Company to remain competitive. The Company is a money making machine. From this relationship, we have to be able to determine if we are getting our fair share. In our last National Contract, the money was there to bring us up to the level of most major Unions, with-SS on top of that. It didn't happen. The bottom line question is: Due to the Joint relationship with the company, it appears our Union is administering the agenda of the Company, without the membership benefiting. Our membership has no way to monitor these financial relationships and activities, to see if our International has lost sight of who they are representing and who is paying their wages, as evidenced in the May 27, 1995 news article, IN YELLOW, "The center's bylaws require the UAW and GM to agree on major decisions. In practice, according to officials on both sides, the UAW gets what it wants." "We look the other way," says a GM official, who asked not to be named, "to keep the Union happy." I believe you can see our concern. Does this relationship give the workers better wages, better working conditions, better retirement, or does this relationship allow the Company to outsource, ship work to other countries, modular assembly, two tier wages, etc. In our last National contract, our International allowed all the above and a 24% reduction in the workforce over the 4 year contract. And in return for WHAT? The use of this Joint Fund money would be better served giving UAW members better retirement benefits, so they wouldn't have to go back out after they retire, take a job away from a younger worker that needs the job. Can a Democratic Union really exist when it is totally controlled by a one-party totalitarian institution? SEE enclosed, Bolsheviks in UAW Boardroom. Just funning our International with the TRUTH.

I just found in the 1995 LM-2 report of our UAW International, enclosed "FORM 990-PF, PART VII, LINE 2, UAW-GM HUMAN RESOURCE CENTER, Year Ended December 31, 1994," NASCAR related funding, (tracks May 27, 1995 news article), I don't consider to fall under the guidelines and intent of our UAW Letters of Understanding, Articles of Incorporation and Bylaws, on our overtime penalty Joint Funding. It stated, I MARKED IN YELLOW, "The Team Motorsports program was created to promote the spirit of cooperation and teamwork between the UAW and General Motors, as embodied in the joint training, education, and "people programs" of the UAW-GM Human Resource Center. The goal is to demonstrate the effectiveness of these HRC programs and the UAW-GM partnership in improving the quality and competitiveness of the UAW-GM workforce." All I can see is our Union Leadership and Company eating, drinking and partying at the expense of the Union membership while our Company Union allows our work to be outsource outside the country, modular assembly by outside non-Union companies, etc., further reducing our Union membership. I don't see the membership of the UAW growing. This country would not be in the economic prosperity it is, without unions to establish a high level of wages, medium of exchange, health and safety, etc. Without unions to maintain checks and balances, protect the rights of workers, big companies do what they want, export work to cheaper markets, which appears to be what they are doing anyway. We are suppose to be dragging the rest of the world up to our level, not being dragged down to their level. I just feel our Union Leadership has lost sight of what Unions are supposed to be about, and are getting theirs. The one that galls me the most, is our International and Staff have been getting COLA on their pensions since 1976, (Information we got from DOL). Our Retirees still don't get it. Some that retired in the 70s and 80s are getting way less than a $ 1000 a month in retirement from the Company because they don't have COLA on their pensions as our International and Staff have.

I have gotten over 60 pounds of information from the DOL, primarily ERISA information on our UAW International. Quite exposing. Since we now know a Federal Agency, DOL, Audits our UAW overtime penalty Joint Funds, their should be some way to find out the audit results, since it appears the law affords protection to Union membership from elements of possible wrong doing, in our UAW member/worker overtime penalty funded, UAW Joint Fund relationship with the Company.

I believe with the files that I hold on the UAW International, like the above information and news article, our UAW International has managed to stay in the legal gray area of the law, unlike other major unions in the past such as the Teamsters, Long Shoremen, etc. for obvious reasons. Whatever you can you do to help me on this, I would appreciate it. I need as much of the UAW ICAP information as you can give me, in any other form of information, or other sources to draw on. As I said, I believe the membership has a right to know, if they ask. The law appears to support this.

Sincerely, Allen Nielsen

April 9, 2000 Allen Nielsen 1841 Old State Road Norwalk, Ohio 44857 Phone 419/663/2289 U.S. Department of Labor Employment Standards Administration Office of Labor-Management Standards, Room N-5605 ATTN: Kay H. Oshel, Chief Division of Interpretations and Standards 200 Constitution Avenue, NW Washington, DC 20210

Dear Kay H. Oshel:

Since these are probably closed investigations and the DOL should have been coordinating with the IRS and FBI in conjunction with the DOL I-CAP on these matters, I am requesting whatever information the DOL has on this under FOIA.

It is going to be interesting what the status of the Joint Funds motor sports program is today, because I have a recent full 2 page advertisement from USA today newspaper of a NASCAR racecar with a big yellow UAW logo on the side of it.

How often does the DOL conduct an I-CAP audit? Indications are from your letter of February 25, 2000 that the last I-CAP audit opened on May 5, 1994 and closed on June 30, 1995. What are the guidelines on how often an audit is conducted?

Sincerely, Allen Nielsen

. (29 U.S.C. 401)

SEC. 2. (a) The Congress finds that, in the public interest, it continues to be the responsibility of the Federal Government to protect employees' rights to organize, choose their own representatives, bargain collectively, and otherwise engage in concerted activities for their mutual aid or protection; that the relations between employers and labor organizations and the millions of workers they represent have a substantial impact on the commerce of the Nation; and that in order to accomplish the objective of a free flow of commerce it is essential that

labor organizations, employers, and their officials adhere to the highest standards of responsibility and ethical conduct in administering the affairs of their organizations, particularly as they affect labor-management relations.

(b) The Congress further finds, from recent investigations in the labor and management fields, that there have been a number of instances of breach of trust, corruption, disregard of the rights of individual em0oyees, and other failures to observe high standards of responsibility and ethical conduct which require further and supplementary legislation that will afford necessary protection

of the rights and interests of employees and the public generally as they relate to the activities of labor organizations, employers, labor relations consultants, and their officers and representatives.

(c) The Congress, therefore, further finds and declares that the enactment of this Act is necessary to eliminate or prevent improper practices on the part of labor organizations, employers, labor relations consultants, and their officers and representatives which distort and defeat the policies of the Labor Manage-[61 Stat. 136; 29 U.S.C. 141.] ment Relations Act, 1947, as amended, and the Railway Labor Act, as amended,[44 Stat 577;] and have the tendency or necessary effect of burdening or obstructing commerce [45 U.S.C. 151.] by

(1) impairing the efficiency, safety, or operation of the instrumentalities of commerce;

(2) occurring in the current of commerce; (3) materially affecting, restraining, or controlling the flow of raw materials or manufactured or processed goods into or from the channels of commerce, or the prices of such materials or goods in commerce; or (4) causing diminution of employment and wages in such volume as substantially to impair or disrupt the market for goods flowing into or from the channels of commerce.

Definitions [73 Stat 520.] (29 U.S.C. 402)

SEC. 3. For the purposes of titles 1, 11, 111, IV, V (except section 505), and

VI of this Act:

(a) "Commerce" means trade, traffic, commerce, transportation, transmission, or communication among the several States or between any State and any place outside thereof.

(b) "State" includes any State of the United States, the District of Columbia, Puerto Rico, the Virgin Islands, American Samoa, Guam, Wake Island, the Canal Zone, and Outer Continental Shelf lands defined in the Outer Continental Shelf Lands Act (43 U.S.C. 1331-1343). 67 SWL 4a

(c) "Industry affecting commerce" means any activity, business, or industry in commerce or in which a labor dispute would hinder or obstruct commerce or the free flow of commerce and includes any activity or industry "affecting commerce" within the meaning of the Labor Management Relations Act, 1947, as amended, or the Railway Labor Act, as amended.

PAUL E. GILLMOR

5TH DISTRICT, OHIO

COMMITTEE ON COMMERCE

VICE CHAIRMAN

COUNTIES: DEFIANCE, ERIE, HENRY, HURON,

LORAIN (PART), MERCER (PART), OTTAWA

(PART), PAULDING, PUTNAM, SANDUSKY,

SENECA, VAN WERT, WILLIAMS, WOOD (PART)

SUBCOMMITTEES:

TELECOMMUNICATIONS, TRADE AND

CONSUMER PROTECTION

FINANCE AND HAZARDOUS MATERIALS

DEPUTY MAJORITY WHIP

COMMITTEE ON

INTERNATIONAL RELATIONS

SUBCOMMITTEES:
ASIA AND THE PACIFIC
THE WESTERN HEMISPHERE

WASHINGTON DEFIANCE NORWALK PORT CLINTON

1203 LONGWORTH HOUSE OFFICE BUILDING 613 WEST THIRD STREET 130 SHADY LANE DRIVE 120 JEFFERSON STREET, 2D FLOOR

WASHINGTON, DC 20515-3505 DEFIANCE, CH 43512 NORWALK, OH 44857 PORT CLINTON, OH 43452

202-225-6405 419-782-1996 419-668-0206 419-734-1999

TOLL FREE IN OHIO 1-80G-541-6446

TOLL FREE FAX IN OHIO 1-800-278-8203

0,

The Honorable Paul E. Gillmor
Member, United States House
Of Representatives
2d Floor
120 Jefferson Street
Port Clinton, Ohio 43452

Dear Congressman Gillmor:

This is in response to your recent inquiry on behalf of your constituent, Mr. Allen Nielsen. Mr. Nielsen seeks information in addition to what was supplied to him in my February 25 letter. In that letter I informed him of the existence of an audit of the United Automobile Workers (UAW) that was performed under OLMS' International Compliance Audit Program (I-CAP). Mr. Nielsen also asks in his letter to you for information on "UAW Joint Funds."

Mr. Nielsen's original inquiry was processed as a request made under the Freedom of Information Act (FOIA). His request for the audit was denied under the FOIA's exemptions. I would note that the audit was done on the UAW as an organization and not on the "UAW Joint Funds," per se, as specified by Mr. Nielsen. I am enclosing a copy of the I-CAP Profile which provides general information concerning the nature of an I-CAP audit, its objectives, the procedures used, and other relevant data. This Agency considers all I-CAP audits to be confidential proceedings and, therefore, does not disclose any substantive information from the audit case files. Under the FOIA, OLMS asserts appropriate exemptions to justify withholding I-CAP documents.

Finally, with regard to Mr. Nielsen's primary concerns, I asked my staff in the OLMS National Office and the OLMS Detroit District Office to conduct a search of various records outside of the UAW I-CAP for material relating to "Joint Funds." No records, files, or documents were located that relate to this subject.

2

I am sorry that I cannot be of more help, but I hope that this information will be useful to you in responding to Mr. Nielsen. If I can be of assistance to you in the future, please do not hesitate to contact me.

Sincerely,

S/John Kotch

Acting Deputy

Assistant Secretary

Enclosure

U.S. Department of Labor

Office of Labor-Management Standards

I-CAP PROFILE

The Office of Labor-Management Standards (OLMS) is part of the Employment Standards Administration, an agency within the U.S. Department of Labor. OLMS has the primary responsibility for administering and enforcing most provisions of the Labor-Management Reporting and Disclosure Act of 1959, as amended (LMRDA). The LMRDA was enacted by Congress to ensure basic standards of democracy and fiscal responsibility in labor organizations representing employees in the private sector. OLMS also administers and enforces the Standards of Conduct provisions of the Civil Service Reform Act of 1978 (CSRA) and related regulations, comparable to LMRDA requirements, for federal sector labor organizations. Among its various responsibilities, OLMS conducts compliance audits and investigations to determine if International/National Unions and their affiliates are complying with the law.

I-CAP The principal objectives of the International Compliance Audit Program

OBJECTIVES 0-CAP) are to:

• determine compliance by the International Union with the criminal and civil provisions of the Labor-Management Reporting and Disclosure Act of 1959, as amended (LMRDA), or provisions of the Civil Service Reform Act of 1978 (CSRA);

• review, to the extent possible, compliance by affiliated unions with the criminal and civil provisions of the LMRDA (or CSRA);

• increase communication and cooperation between OLMS and International Unions.

OPENING OLMS staff conduct an opening interview with International Union

INTERVIEW officials to:

• review I-CAP objectives,

• explain the scope and general conduct of the on-site compliance audit,

• obtain certain general information about the International Union, and

• answer questions about I-CAP procedures.

Logistical arrangements are also made concerning OLMS access to union records and staff. In order to expedite the compliance audit, OLMS provides a preliminary list of union records which will be needed and a detailed Financial Questionnaire for later review with International Union officials.

AUDIT the audit may be expanded to other years as deemed necessary. Various records required

PROCEDURES to be maintained, such as journals, cancelled checks, and back-up documentation, are selectively audited using sampling techniques and other specially designed procedures. In addition to reviewing internal financial controls and general receipt and disbursement procedures, several specific areas are examined such as officer/employee expenses, loans, and record retention. OLMS also verifies certain financial transactions with outside parties such as banks, credit card companies, and other vendors conducting business with the union.

COMPLIANCE OLMS examines various internal union records to determine compliance by the

EXIT At the conclusion of the compliance audit, OLMS staff meet with International Union

CLOSING OLMS sends a closing letter to the International Union outlining the other information
LETTER discussed at the exit inter view, emphasizing any voluntary compliance agreements reached with International Union officials to correct LMRDA (or CSRA) violations.

FOLLOW-UP Approximately six months after the I-CAP closing letter is issued, OLMS contacts