A “Copy and Paste” Campaign? Opponents Flood DOL with Identical Comments Against Proposed Union Rule

Washington, D.C, District of Columbia Aug 21, 2025 (Issuewire.com) - This week, LaborLab released analysis that found a coordinated campaign of identical comments flooded the Department of Labor in opposition to proposed rule changes on union financial reporting.

On July 1, 2025, the Office of Labor-Management Standards (OLMS) of the U.S. Department of Labor published a proposed rule raising the threshold for filing two key union annual reports, Form LM-2 and Form LM-3, noting that the filing thresholds had not been updated since 2003.

During the month-long comment period, a total of 299 comments were received and all can be viewed online. Interestingly, over a quarter of the comments (78) were submitted by anonymous, which is problematic for a number of reasons including the inability to verify whether the same commenter submitted multiple comments. Actually, of those who did identify themselves, 20 commenters filed 41 comments.

Most disturbing, however, is that there appears to have been a concerted effort to juice the number of comments against the rule change. 

Nearly 76% of comments used the almost verbatim identical language in their comment:

I strongly oppose the Department of Labors proposal to raise the LM-2 reporting threshold from $250,000 to $450,000. This change would allow over 850 unions, spending over $200 million annually, to hide from detailed financial disclosure. Workers, many of whom are forced to pay dues or else be fired, and the public deserve to know how union dues are spent not merely vague summaries and hidden expenses. This rule invites waste, corruption, and abuse, and should be withdrawn immediately.

One commenter wrote:

This is a comment that I copied and pasted from an email, but it expresses my concern extremely well. So I am using it.

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LaborLab's entire report can be read at LaborLab.us