CWA · LM-2 Financial Analysis

Primary Source Document

This analysis is based on the LM-2 filed by the Communications Workers of America (CWA), National Headquarters, covering the reporting period from June 1, 2023 through May 31, 2024.

LM-2 (CWA) — Fiscal Year Ending 2024 (PDF)

Purpose and Scope

The purpose of this page is structural clarity. It summarizes how CWA’s parent union allocates resources across the functional categories used on the LM-2 (representation, political and lobbying activity, overhead, and administration), and it identifies which centralized activities plausibly provide broad benefit across sectors and districts.

This page does not compare unions. Cross-union comparisons are reserved for a separate report after the CWA ecosystem is fully documented.

Membership Scale (Context)

The LM-2 reports the following membership totals at the end of the reporting period:

Active members: 363,931
Retiree (dues-paying): 60,668
Retiree (non-dues-paying): 238,747
Total members: 663,346
Agency fee payers: 18,515
Total members + fee payers: 681,861

These figures matter because a parent union of this scale funds centralized functions that individual sectors and districts would be inefficient (or unable) to replicate independently.

Statement B (High-Level Receipts and Disbursements)

Statement B provides a standardized summary of receipts and disbursements for the reporting period. Selected headline totals from Statement B:

Receipts

Dues and agency fees: $124,224,565
Interest: $13,307,514
Rents: $3,097,710
Other receipts: $9,451,991
Total receipts: $304,837,647

Disbursements (Functional)

Representational activities: $56,801,560
Political activities and lobbying: $15,798,504
General overhead: $44,142,164
Union administration: $23,070,617
Benefits: $32,099,291
Strike benefits: $2,345,003
Total disbursements: $301,333,377

Interpretation note: These totals represent the parent union’s reported activity during the period. In a union-of-unions model, a complete dues-flow picture requires considering downstream entities and special-purpose categories (“on behalf of individual members”), which are reported separately on the LM-2.

Employee Disbursements as a Signal of What CWA Funds Centrally

The strongest functional signal in the LM-2 appears in employee disbursements (Schedule 12). The Schedule 12 totals include a functional allocation across the LM-2 categories. In aggregate, employee-related disbursements are allocated approximately as:

Representational activities: 88%
Political activities and lobbying: 1%
General overhead: 4%
Union administration: 7%

These percentages are reported within the LM-2 employee totals and reflect how staff compensation is attributed to functional categories. In practice, this indicates that CWA’s centralized staffing model is predominantly oriented toward representational work.

Representational Activity (What It Likely Covers)

The LM-2 does not measure “quality of service,” but it does show where expenditures are categorized as representational activity. In a parent-union context, representational spend and representational staffing commonly support:

contract negotiations support and bargaining strategy
grievance handling, arbitration, and legal support
organizing and campaign operations tied to bargaining coverage
research and policy work tied to negotiation and enforcement

For sectors and districts, the functional takeaway is that affiliation can provide access to centralized staff capacity and institutional continuity without each affiliate duplicating high fixed-cost functions.

Political Activities and Lobbying (Centralized by Design)

Political and lobbying activity is disclosed separately on the LM-2. In a multi-industry union, political activity frequently functions as shared infrastructure: legislative and regulatory engagement affecting multiple industries simultaneously. This activity is typically most efficient when centralized at the parent-union level.

Statement B reports $15,798,504 in political activities and lobbying for the reporting period. As with all functional categories, this number describes total outflow in the category; it does not assign benefit to specific sectors or districts.

Administration and Overhead (Scale Infrastructure)

General overhead and union administration are separately disclosed on the LM-2 and together represent major national infrastructure costs (facilities, systems, finance operations, compliance, executive operations, etc.). For FY 2024, Statement B reports:

General overhead: $44,142,164
Union administration: $23,070,617

In a union-of-unions model, these categories partially reflect the cost of maintaining a national organization that sectors and districts rely on. The analytic question is not whether these costs exist, but whether the centralized services funded by these costs are commensurate with the dues base and materially reduce duplication across affiliates.

Executive Compensation (Important, but Not the Whole Story)

Officer compensation is disclosed in Schedule 11 (All Officers and Disbursements to Officers). Executive compensation is a transparency anchor, but it must be evaluated alongside representational staffing and functional spending totals. The LM-2 also attributes officer time across functional categories (representation, political/lobbying, overhead, administration), reinforcing that governance roles and operational roles differ within the system.

This analysis treats executive compensation as context rather than a stand-alone proxy for “value.”

How Sectors and Districts Benefit (What Can Be Inferred)

The LM-2 does not label spending by sector or district, but affiliation benefits can be inferred from what the parent union funds centrally:

Shared legal and arbitration infrastructure that affiliates draw on as needed
National bargaining strategy and coordination supporting multi-employer or multi-unit campaigns
Organizing infrastructure that scales beyond what a single district or local might sustain
Legislative and regulatory access supporting cross-industry advocacy
Research and policy capacity that supports negotiations and enforcement

The central limitation is attribution: the parent-union LM-2 describes what CWA funds, but not which affiliate benefited in what proportion. That “other side” of the dues flow is evaluated by reviewing sector-level filings separately after the CWA report is completed.

What the LM-2 Does Not Show

direct allocation of parent-union spending to specific sectors or districts
downstream budgeting decisions made by affiliates
service quality, responsiveness, or effectiveness

As a result, claims about sector-level “value received” must be supported by pairing this parent-union analysis with sector-level LM-2 filings and related disclosures. That step follows after the CWA parent report is finalized and published.