Communications Workers of America
Funding, Dues, and Financial Governance
How money moves through a union-of-unions — and why financial accountability cannot be inferred from a single filing.
Financial Governance
Financial governance determines who controls union resources, how priorities are funded, and which entities actually provide representational services to members. In large, centralized unions this can be difficult to evaluate. In the Communications Workers of America (CWA), it is structurally complex by design.
CWA’s union-of-unions architecture distributes authority and operations across multiple governing entities. As a result, dues collection and expenditure do not occur within a single, vertically integrated organization.
Dues Assessment and Collection
Member dues are typically assessed at the local or bargaining-unit level and collected through payroll deduction or direct payment mechanisms. While members experience dues as a single obligation, those funds do not remain with a single entity.
- Assessment: Established by constitutional provisions and local agreements.
- Collection: Often executed at the local or unit level.
- Member visibility: Limited to the gross amount deducted.
Per-Capita Flows and Internal Transfers
After collection, dues flow through a series of per-capita transfers. Portions of member dues are remitted upward to CWA, while other portions may be retained by locals, districts, or sector-level bodies depending on constitutional and policy rules.
- Locals: May retain funds for local administration and services.
- Districts: May receive per-capita allocations for regional governance and support.
- Sectors: May control operational budgets for industry-specific representation.
- CWA (parent union): Receives per-capita funding for national governance, administration, and strategic initiatives.
These flows are structural, not discretionary, and are central to understanding which entity controls resources at each stage.
Budget Authority and Spending Control
Budget authority within CWA does not reside uniformly across all entities. Different layers of the organization exercise control over different categories of spending.
- National budgets: Controlled through CWA governance bodies and executive authority.
- District budgets: Governed by district leadership within constitutional limits.
- Sector budgets: Often tied to operational responsibility for representation and bargaining.
Importantly, members do not vote on line-item budgets. Financial accountability is therefore indirect and mediated through governance structures.
Why LM-2 Filings Are Necessary — and Insufficient
LM-2 filings provide standardized disclosures of revenue, expenditures, officer compensation, and major spending categories. They are essential for transparency, but they do not, by themselves, explain how representational services are delivered inside a union-of-unions.
In CWA’s structure:
- One entity may collect dues.
- Another entity may control spending.
- A third entity may deliver day-to-day member services.
As a result, LM-2 analysis must be contextualized within CWA’s governance and financial architecture to avoid false conclusions.
Structural Implications for Financial Analysis
- Fragmented visibility: No single filing captures the full financial picture.
- Attribution risk: Services may be credited to entities that did not fund them.
- Overhead masking: Administrative layers can obscure cost efficiency.
- Comparability challenge: CWA cannot be evaluated using the same heuristics as vertically integrated unions.
These characteristics must be understood before any comparative assessment of dues efficiency or service delivery is attempted.
Next
With CWA’s financial governance structure defined, we can now examine the underlying disclosures that document how money is actually spent.