Sharing of Pension Fund Information with Affiliated Union

[Robert B]

Our firm serves as counsel to the local union and the associated pension fund. The union asked the pension fund staff for mailing labels (name and address). The union intends to give the information to a third-party so that participants will be mailed information (unrelated). Issues?

[Peter Gulia]

That you describe your firm as counsel to a union and a pension trust regarding the union suggests that your firm advises the labor-side pension trustees.

Do the employer-side pension trustees have their counsel?

[Effen]

Are you asking if it is ok for the fund office to give the union office a mailing list of all of the pension participants so they can send them a non-pension related mailing?  Those participants would be all union members, right?  I guess there could be non-union people in the plan, but wouldn't the union have access to this information anyway?  

I don't know if this is common practice or not, but most funds I work with keep the union business separated from the fund business. 

 

[david rigby]

What does the CBA say?  What does the plan say?  Just an opinion, but there might be some embarrassment at the union office for realizing they don't ALREADY have the relevant names and addresses.  🤨