MANSFIELD, Circuit Judge:
Henderson Trumbull Supply Corp. (the “Company” herein) seeks review, and the National Labor Relations Board (the “Board” herein) seeks enforcement, of a Board order issued against the Company on August 6, 1973, directing it to bargain collectively in good faith with Local 191, International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America (the “Union” herein) as the certified bargaining representative for the Company’s employees. Certification was granted on October 31, 1972, based on the Union’s narrow victory (by one vote) in an election held on June 14, 1972. Because the Board granted certification and subsequently issued its order without affording the Company an evidentiary hearing on certain objections it raised with respect to the pre-election conduct of the Union, we deny enforcement of the Board’s order and remand for an eviden-tiary hearing on those objections.
The Company is a small retail seller of building materials and home supplies in Trumbull, Connecticut. Upon the Union’s filing of a petition with the Board for certification as collective bargaining representative for the Company’s employees, an election was held at the Company on June 14, 1972, which the Union won by a vote of 7 to 6 in a unit of only 15 eligible voters, two of whom did not cast ballots. Shortly after the election the Company filed timely objections with the Board, alleging that following the Union’s distribution in early June of a letter to the employees stating that the Company “had been making a great deal of money through you and your fellow employees,” the Union’s Business Agent, two days before the election, had made material misrepresentations of fact to the employees, to which the Company had had no opportunity to respond before the election. Specifically the Company charged that at a meeting of its employees held at the Union’s offices on June 12, 1972, the Union’s Business Agent, Anthony Rossetti, stated that in the previous year the Company had “made a profit ... of $1,300,000.-00” and that the Company’s Vice-President, Fred Salvati, had “just built a new residence for himself costing $75,000 to $80,000.” Both statements, according to the Company, were “absolutely false, un[1226]*1226true and misleading.” During the year prior to the election the Company’s [t] otal gross sales let alone profit, were “[only] $970,000” 1 (emphasis supplied) and its profit was a much smaller amount.
Pursuant to § 102.69 of the Board’s Rules and Regulations, 29 C.F.R. § 102.-69, the Board’s Acting Regional Director conducted an independent investigation of the Company’s objections. In a report dated August 1, 1972, he found that the Union had held a meeting at its offices in Bridgeport, Connecticut, on the evening of June 12, 1972, which was attended by eight of the Company’s employees. During this meeting, after Rossetti had explained the Board’s election procedures and urged the employees to vote for the Union, the subject of discussion turned to the Company’s ability to pay the employees more money. Rossetti denied that he initiated' the discussion concerning Vice-President Salvati’s new home or placed any value on it, and the Regional Director found no evidence to contradict him. The Regional Director stated:
“Seven of the eight attending employees were interviewed by a Board Agent. Five of these employees say flatly that Rossetti did not bring the house into discussion but rather that an employee did. Two do not recall who brought the matter up. All seven agree that Rossetti placed no value on the house.”
However, four of the employees interviewed did recall that Rossetti had discussed what the Company had “made” during the previous year:
“One stated in an affidavit that Rossetti had said the Employer had made 1.3 million dollars. A second employee claimed Rossetti said the Employer had made one million dollars, without identifying the figure as gross, net or profit. This same employee, in a second statement to the Board agent made two weeks later, revised his original figure and stated that he ‘believed’ that Rossetti had claimed the Employer made 1.2 or 1.3 million dollars. He would not sign either statement. A third employee recalled that Rossetti had said ‘something about the Employer making a million dollars last year and being able to afford to pay us more.’ (The employee would not sign a statement.)
“The fourth of the employees who recalled a specific figure states that during the meeting ‘someone,’ I believe it was Rossetti, ‘said the company grossed at least one million dollars last year’ and says also that this statement was made in a context of the Company’s ability to pay increases. (This employee signed a statement.)”
The Regional Director found that although the evidence was “somewhat contradictory,” it “would support the assertion that some specific figure was stated.” Beyond this, however, he apparently did not seek to ascertain the impact of Rossetti’s statement by inquiring whether any of the interviewed employees had been influenced by it to vote in favor of the Union. Instead he concluded in effect that Business Agent Rossetti’s statements, as interpreted by him, were per se immaterial and hence that the Union's alleged misrepresentation of Company profits was meritless:
“[T]he evidence does not tend to establish that Rossetti was referring to ‘profits’ as distinguished from gross income. It is of course arguable that the use of the word ‘made’ implied a profit but there is enough ambiguity in the term, and so little an exaggeration in the figure, as to preclude a conclusion that a material misrepresentation was made. More importantly, it is clear from the nature of the statement allegedly made by Rossetti, that he was not talking from knowledge, but was expressing an opinion [1227]*1227or making a guess and this obviously was clear also to the employees he was addressing who were competent to appraise the statement in the light of their own knowledge — or lack of it— concerning the Employer’s profits from its operations.”
Accordingly, the Regional Director recommended that the Company’s objections be overruled and that the Board certify the Union as the exclusive collective bargaining representative of the Company’s employees.
The Company filed timely exceptions to the Regional Director’s findings, conclusions and recommendations. However, on October 31, 1972, the findings and conclusions were adopted by the full Board which certified the Union as the bargaining representative for the Company’s employees. In November 1972, upon the Company’s refusal to bargain collectively with the Union over wages, hours and working conditions, the Union filed an unfair labor practice charge with the Board and on December 14, 1972, the Board issued a complaint against the Company. In its answer the Company challenged the validity of the original certification. It also alleged that subsequent events, specifically the termination of 10 out of the 15 employees who had been eligible to vote in the election for theft of the Company’s money and materials, made a revocation of certification proper, since there was a strong probability, as a result of the post-election turnover, that only a small fraction of those in the unit, and possibly more, would currently be represented by a bargaining agent of their choice if effect were given to the certification.
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MANSFIELD, Circuit Judge:
Henderson Trumbull Supply Corp. (the “Company” herein) seeks review, and the National Labor Relations Board (the “Board” herein) seeks enforcement, of a Board order issued against the Company on August 6, 1973, directing it to bargain collectively in good faith with Local 191, International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America (the “Union” herein) as the certified bargaining representative for the Company’s employees. Certification was granted on October 31, 1972, based on the Union’s narrow victory (by one vote) in an election held on June 14, 1972. Because the Board granted certification and subsequently issued its order without affording the Company an evidentiary hearing on certain objections it raised with respect to the pre-election conduct of the Union, we deny enforcement of the Board’s order and remand for an eviden-tiary hearing on those objections.
The Company is a small retail seller of building materials and home supplies in Trumbull, Connecticut. Upon the Union’s filing of a petition with the Board for certification as collective bargaining representative for the Company’s employees, an election was held at the Company on June 14, 1972, which the Union won by a vote of 7 to 6 in a unit of only 15 eligible voters, two of whom did not cast ballots. Shortly after the election the Company filed timely objections with the Board, alleging that following the Union’s distribution in early June of a letter to the employees stating that the Company “had been making a great deal of money through you and your fellow employees,” the Union’s Business Agent, two days before the election, had made material misrepresentations of fact to the employees, to which the Company had had no opportunity to respond before the election. Specifically the Company charged that at a meeting of its employees held at the Union’s offices on June 12, 1972, the Union’s Business Agent, Anthony Rossetti, stated that in the previous year the Company had “made a profit ... of $1,300,000.-00” and that the Company’s Vice-President, Fred Salvati, had “just built a new residence for himself costing $75,000 to $80,000.” Both statements, according to the Company, were “absolutely false, un[1226]*1226true and misleading.” During the year prior to the election the Company’s [t] otal gross sales let alone profit, were “[only] $970,000” 1 (emphasis supplied) and its profit was a much smaller amount.
Pursuant to § 102.69 of the Board’s Rules and Regulations, 29 C.F.R. § 102.-69, the Board’s Acting Regional Director conducted an independent investigation of the Company’s objections. In a report dated August 1, 1972, he found that the Union had held a meeting at its offices in Bridgeport, Connecticut, on the evening of June 12, 1972, which was attended by eight of the Company’s employees. During this meeting, after Rossetti had explained the Board’s election procedures and urged the employees to vote for the Union, the subject of discussion turned to the Company’s ability to pay the employees more money. Rossetti denied that he initiated' the discussion concerning Vice-President Salvati’s new home or placed any value on it, and the Regional Director found no evidence to contradict him. The Regional Director stated:
“Seven of the eight attending employees were interviewed by a Board Agent. Five of these employees say flatly that Rossetti did not bring the house into discussion but rather that an employee did. Two do not recall who brought the matter up. All seven agree that Rossetti placed no value on the house.”
However, four of the employees interviewed did recall that Rossetti had discussed what the Company had “made” during the previous year:
“One stated in an affidavit that Rossetti had said the Employer had made 1.3 million dollars. A second employee claimed Rossetti said the Employer had made one million dollars, without identifying the figure as gross, net or profit. This same employee, in a second statement to the Board agent made two weeks later, revised his original figure and stated that he ‘believed’ that Rossetti had claimed the Employer made 1.2 or 1.3 million dollars. He would not sign either statement. A third employee recalled that Rossetti had said ‘something about the Employer making a million dollars last year and being able to afford to pay us more.’ (The employee would not sign a statement.)
“The fourth of the employees who recalled a specific figure states that during the meeting ‘someone,’ I believe it was Rossetti, ‘said the company grossed at least one million dollars last year’ and says also that this statement was made in a context of the Company’s ability to pay increases. (This employee signed a statement.)”
The Regional Director found that although the evidence was “somewhat contradictory,” it “would support the assertion that some specific figure was stated.” Beyond this, however, he apparently did not seek to ascertain the impact of Rossetti’s statement by inquiring whether any of the interviewed employees had been influenced by it to vote in favor of the Union. Instead he concluded in effect that Business Agent Rossetti’s statements, as interpreted by him, were per se immaterial and hence that the Union's alleged misrepresentation of Company profits was meritless:
“[T]he evidence does not tend to establish that Rossetti was referring to ‘profits’ as distinguished from gross income. It is of course arguable that the use of the word ‘made’ implied a profit but there is enough ambiguity in the term, and so little an exaggeration in the figure, as to preclude a conclusion that a material misrepresentation was made. More importantly, it is clear from the nature of the statement allegedly made by Rossetti, that he was not talking from knowledge, but was expressing an opinion [1227]*1227or making a guess and this obviously was clear also to the employees he was addressing who were competent to appraise the statement in the light of their own knowledge — or lack of it— concerning the Employer’s profits from its operations.”
Accordingly, the Regional Director recommended that the Company’s objections be overruled and that the Board certify the Union as the exclusive collective bargaining representative of the Company’s employees.
The Company filed timely exceptions to the Regional Director’s findings, conclusions and recommendations. However, on October 31, 1972, the findings and conclusions were adopted by the full Board which certified the Union as the bargaining representative for the Company’s employees. In November 1972, upon the Company’s refusal to bargain collectively with the Union over wages, hours and working conditions, the Union filed an unfair labor practice charge with the Board and on December 14, 1972, the Board issued a complaint against the Company. In its answer the Company challenged the validity of the original certification. It also alleged that subsequent events, specifically the termination of 10 out of the 15 employees who had been eligible to vote in the election for theft of the Company’s money and materials, made a revocation of certification proper, since there was a strong probability, as a result of the post-election turnover, that only a small fraction of those in the unit, and possibly more, would currently be represented by a bargaining agent of their choice if effect were given to the certification.
On August 6, 1973, the Board, on motion for summary judgment by the Board’s General Counsel, held that the Company had violated § 8(a)(5) and (1) of the Act, 29 U.S.C. § 158(a)(5) and (1), by refusing to bargain collectively in good faith with the Union and ordered it to cease and desist from this unfair labor practice and to take affirmative action to carry out its bargaining duties under the Act. Since the order was issued on motion for summary judgment the sole issue we must decide, on the Company’s petition to review and set aside and upon the cross-petition of the Board to enforce the order, is whether the Company’s objections to the election or exceptions to the Regional Director’s Report warranted a hearing. We hold that they did.
Discussion
The Board first argues that the Company was not entitled to a hearing on the factual statements set forth in its objections since it failed to support them with written affidavits or other independent evidence. While the Board’s own rules do not suggest that affidavits or other evidence must be submitted when objections to an election are filed,2 those rules also state that “[t]he party filing objections shall, upon request, promptly furnish to the regional director the evidence available to it to support the objections.” (Emphasis supplied). See 29 C.F.R. § 102.-69(a). The Board has presented us with a letter, which its Regional Director sent to the Company shortly after its objections had been filed, containing a request for supporting evidence. There is no indication that the Company ever responded to this letter.
We believe that, while the objections may not have qualified as “evidence” in the strict technical sense of that term, any such formal deficiency should not deprive the Company of a hearing to which it would otherwise have been entitled. The objections were not “nebulous and declamatory assertions, wholly unspecified,” see Fay v. Douds, 172 F.2d 720, 725 (2d Cir. 1949), nor based on [1228]*1228“equivocal hearsay,” NLRB v. O.K. Van Storage, Inc., 297 F.2d 74 (5th Cir. 1961), but referred to specific events and listed specific people who were witnesses to these events.3 See NLRB v. Douglas County Electric Membership Corp., 358 F.2d 125, 129 (5th Cir. 1966). Furthermore, the objections satisfied the underlying purpose of § 102.69(a) by furnishing sufficient factual detail to enable the Regional Director to evaluate them and sufficient identification of witnesses and sources to permit verification by the Director’s staff. Under the circumstances, to hold in this case that the objections were insufficient because they were not attested to or verified would be to exalt form over substance. Being signed by the Company’s counsel they should be accorded the same weight as would be attributed to a pleading so signed. See Rule 11, F.R.Civ.P. Furthermore, whatever may have been the result if the Regional Director’s investigation had failed to uncover specific supporting evidence, any deficiency must be deemed to have been waived or excused when, as here, it uncovers evidence calling for a hearing. See United States Rubber Co. v. NLRB, 373 F.2d 602, 606 (5th Cir. 1967) (“If the investigation itself reveals . . . that material factual issues exist which can be resolved only by a hearing, then a hearing must be held; once the investigator discovers facts by his investigation it becomes immaterial that there was a pre-investigation failure to supply him with specific evidence of what he later discovered.”). Otherwise, the “specific evidence” requirement could lead to absurd results and render the Regional Director’s independent investigation, which is mandated by the Board's own rules, see 29 C.F.R. § 102.-69(e), a superfluous formality.
The essential question, therefore, is whether, despite the Board’s denial of a hearing, the evidence relied upon by the Company, as verified by the Regional Director, entitled it to a hearing. We recognize that “[t]he conduct of representation elections is the very archetype of a purely administrative function, with no quasi about it, concerning which courts should not interfere save for the most glaring discrimination or abuse.” NLRB v. Olson Bodies, Inc., 2 Cir., 420 F.2d 1187, 1189 (1970), cert. denied, 401 U.S. 954, 91 S.Ct. 966, 28 L.Ed.2d 237 (1971). The Board has been entrusted with broad discretion in determining the nature and extent of pre-election propaganda that will be allowed, NLRB v. Millard Metal Service Center, Inc., 472 F.2d 647, 650 (1st Cir. 1973); NLRB v. Sauk Valley Mfg. Co., 486 F.2d 1127 (9th Cir. 1973); Follett Corp. v. NLRB, 397 F.2d 91, 94 (7th Cir. 1968), and it has prided itself on its toleration of “intemperate, abusive and inaccurate statements” made by the Union during attempts to organize employees. Linn v. Plant Guard Workers, 383 U.S. 53, 61, 86 S.Ct. 657, 15 L.Ed.2d 582 (1966); Modine Mfg. Co., 203 N.L.R.B. No. 77, 83 L.R.R.M. 1133 (1973), application for enforcement pending, 8th Cir., No. 73-1664; Hollywood Ceramics Co., Inc., 140 N.L.R.B. 221, 224 (1962) ; Stewart-Warner Corp., 102 N.L.R.B. 1153, 1158 (1953). Considerable deference must furthermore be given to the expertise of the Board in this area, and to the findings of its Regional Director. Undue appellate interference could threaten the essential functioning of a system that has, according to well-settled standards, governed the conduct of some 9,000 elections annually.
For these reasons the burden upon the party seeking a hearing is a weighty one. See Bausch & Lomb, Inc. v. NLRB, 404 F.2d 1222, 1226 (2d Cir. 1968). It must demonstrate by “specific evidence” that a “substantial and material factual issue” exists with respect to the employees’ exercise of a free choice, which could well have affected the elec[1229]*1229tion results. Of necessity the existence of such an issue depends greatly upon the nature of the misrepresentation relied upon by the challenging party and upon the surrounding circumstances. Among the factors to be considered besides the materiality of the factual misrepresentation itself are (1) the influence that it might reasonably have had upon the employees, (2) the extent to which the declarant could reasonably be viewed by the employees as a person in a position to know the facts, (3) the opportunity for reply, and (4) the ability of the employees to evaluate the statement on the basis of their own independent knowledge of the facts. NLRB v. Cactus Drilling Corporation, 455 F.2d 871 (5th Cir. 1972); NLRB v. Millard Metal Service Center, Inc., supra; Hollywood Ceramics Co., Inc., supra. In the present case the Board does not seriously dispute the fact that since Rossetti’s statement to the employees was made virtually on the eve of election there was an inadequate opportunity for reply. However, the Regional Director took the view that none of the other prerequisites was satisfied. He concluded that in referring to the specific dollar amount “made” by the Company during the previous year (1) the Union Business Agent was not describing “profits” as distinguished from “gross income,” (2) “he was not talking from knowledge, but was expressing an opinion or making a guess,” and (3) the employees “were competent to appraise the statement in the light of their own knowledge — or lack of it — concerning the Employer’s profit from its operations.” We disagree. In the absence of a hearing we are at a loss to comprehend how the Regional Director could have arrived at these conclusions. Cf. NLRB v. Janler Plastic Mold Corp., 82 L.R.R.M. 2175, 2178 (7th Cir. 1972).
In our view a statement that the Company had “made” $1.3 million in the previous year would clearly imply to the average non-accountant (and we can assume that a millhand with training in accountancy would be a rarity) that the Company had “gained” or “profited” by that amount. Indeed, we suspect that this same meaning would be attributed to the word “made” by some accountants. Use of the term “grossed” instead of “made” would have alerted the listener to the fact that the Union was referring to receipts, not profits, and would not have called for a hearing. See, e. g., NLRB v. Louisville Chair Co., 385 F.2d 922 (6th Cir. 1967). But, absent a hearing, we cannot agree that the statement that the Company had “made” $1.3 million during the previous year was not materially misleading.4
Nor can we agree with the Regional Director and Board that it must have been clear to the employees that the Union Business Agent, in stating that the Company had made $1.3 million, was merely “expressing an opinion or making a guess.” In most local unions the business agent, who may be the only full-time union employee, “has the greatest power and most important functions in the local union, frequently more important than the local’s president who may be a mere figurehead,” Kheel, I Labor Law § 3.03 [2], pp. 3-17 (Matthew Bender, 1972). His function, which is to organize and serve as liaison with management, requires him to learn as much as possible about the financial condition of the employer with whom he negotiates on behalf of its employees. His [1230]*1230position, coupled with his mention of a specific profit figure, could reasonably have led the employees to believe that he had ferreted out the information from financial books or records available to the Union through its bank or other sources or from initial conferences with Company officers. Nothing in the Regional Director’s Report supports the view that the employees believed otherwise.
We likewise cannot agree with the Regional Director’s conclusion that the employees were competent to appraise the Business Agent’s specific figure in the light of their own knowledge of the Company’s profit from its operations. Without casting any reflections upon the employees, who are “drivers, yardmen, fork-lift operators, millmen, store salesmen and stock clerks,” it strikes us as unreasonable to expect that they, with the possible exception of a store salesman, would have any knowledge as to the Company’s profits, much less access to such information. A person performing essentially manual labor within a limited sphere, such as a driver or mill-man, would normally have no exposure to his employer’s receipts, much less to its profits. Furthermore, it is irrelevant that the employees addressed by Rossetti could have conducted their own investigation into the truth or falsity of his representations. “[T]o excuse a flat misrepresentation on the ground that the deceived party, having no reason to do so, could have investigated and learned the truth, is contrary to both legal and ethical principles.” See NLRB v. Millard Metal Service Center, Inc., 472 F.2d 647 (1st Cir. 1973); Cross Baking Co. v. NLRB, 453 F.2d 1346, 1349 (1st Cir. 1971).
In sum, we hold that the evidence in this case as to the misrepresentation of the Company’s profits raised a “substantial and material factual issue” as to the employees’ exercise of a free choice. It supports the charge that a person apparently in a position to know the facts had misrepresented a material fact (i. e., the amount of money available for increase in employees’ wages and benefits) in a manner and at a time which deprived the Company of an opportunity to respond.5 This claim, together with the written statements obtained by the Regional Director himself, prima facie warranted setting aside the election which the Union won by only one vote. NLRB v. Bata Shoe Co., 377 F.2d 821 (4th Cir. 1967), cert. denied, 389 U.S. 917, 88 S.Ct. 772, 19 L.Ed.2d 825 (1968). Where, as here, an election is extremely close, even minor misconduct cannot be summarily excused on the ground that it could not have influenced the election. See NLRB v. Skelly Oil Co., 473 F.2d 1079, 1085 (8th Cir. 1973); NLRB v. Gooch Packing Co., 457 F.2d 361, 362 (5th Cir. 1972). In this case, absent a hearing, there was no justification for the Regional Director or the Board to assume that the employees must have interpreted the alleged statement !¿>y Rossetti as a reference to “gross” revenue or as an uninformed guess. Indeed the reasonably probable interpretations were precisely the opposite.
We agree with the Board that the Company’s allegation that Rossetti had told the employees that the Company’s Vice-President had purchased a new home worth between $75,000 and $80,000 did not by itself necessitate a hearing in light of the results of the Regional Director’s investigation into this charge. However, since a hearing is necessary with respect to the alleged misrepresentation of Company profits, we direct that the second allegation also be taken up at that hearing. The Company’s objection based on the subsequent discharge of 10 out of the 15 employees who had been eligible to vote in the election could not in any event provide a basis for setting aside the election, since it could not be sustained without destroy[1231]*1231ing “the finality sought to be given to Board-conducted elections.” See Orleans Storage Company, Inc., 123 N.L.R.B. 1757, 1758 (1959). Cf. Brooks v. NLRB, 348 U.S. 96, 103, 75 S.Ct. 176, 99 L.Ed. 125 (1959). Accordingly, that issue need not be heard.
Remanded for further proceedings not inconsistent with this opinion.