In a stunning move the National Labor Relations Board, Region 16, labels FCGOA a "Nascent" Union who "is not the certified collective bargaining representative of any employees" "has no existing collective bargaining relationship with any security company" "has no dues-paying members, bylaws, or constitution". The Labor Board offers as a partial explanation: [T]he fact that it is an ineffectual representative. . . that certain of its officers or representatives may have criminal records, that there are betrayals of the trust and confidence of the membership, or that its funds are stolen or misused, cannot affect the conclusion which the Act then compels us to reach, namely, that the organization is a labor organization within the meaning of the Act..