BAUER, Circuit Judge.
Reebie Storage and Moving appeals from a decision rendered by the National Labor Relations Board (“Board”) holding that Reebie had applied its contract on a “members-only” basis in violation of section 8(a)(3) of the National Labor Relations Act (“Act”). 29 U.S.C. § 158(a)(3). We find that the allegation in the complaint upon which this finding was based was not closely related to any of the allegations contained in the initial charge and should have been stricken. Reebie’s petition for review of the Board’s decision is therefore granted, and the General Counsel’s petition for enforcement is denied.
Reebie engages in the moving and storage of commercial and household goods and has its main facilities in Franklin Park, Illinois. Depending on the demands of the season, Reebie has employed somewhere between 4 and 100 workers at that location. For many years, the union of Truck Drivers, Oil Drivers, Filling Station and Platform Workers, Local No. 705 (“Union”) represented several of Reebie’s workers. Reebie, in turn, belonged to the Movers’ Association of Greater Chicago (“Association”), a confederation of local movers which collectively represented its members in negotiating and drafting labor [607]*607agreements with the Union. The agreement between the Union and the Association relevant to this case ran from March of 1987 to March of 1990. Included in this agreement was a “favored nations clause” which entitled Reebie to the benefits of any subsequent contract entered into by the Union if the subsequent contract included terms more favorable than those in Reebie’s agreement. The agreement also included a “union security clause” which required all employees performing designated unit work to become members of the Union within thirty days of employment.
Despite this latter requirement, Reebie operated for the course of the agreement with only twelve of the approximately thirty unit members as part of the Union. Because only employees covered by the contract were entitled to welfare and pension benefits, Reebie avoided making contributions on behalf of the non-union employees. Acknowledging that Reebie was not as large as other employers within the Association and therefore could not viably provide contract coverage to all of its employees, Dan Ligurotis, the Union’s Secretary-Treasurer, acquiesced in this arrangement on the Union’s behalf and no grievances were filed against Reebie. But in July of 1989, apparently unaware of Liguro-tis’s agreement, union representatives William Dicks and Gerald Rzewnicki visited Reebie’s Franklin Park facility and signed up as union members between twenty and twenty-five Reebie employees. Their intent was for these workers to receive contract coverage, but that never occurred.
As the agreement neared expiration and negotiations for a new agreement were underway, the Union sent Reebie the following request:
In order to determine compliance with the contract, please forward as soon as possible, a weekly list from the first week of September, 1989 through the last week in January 1990, showing names, addresses, rates of pay, and hours worked per day for all employees performing any movers work. The list should be broken down between regular employees and all other employees — excluding summer replacements.
Salvatore Manso, Reebie’s president, responded to the letter first by noting that under the “favored nations clause,” Reebie was entitled to see any contracts into which the Union had entered that contained terms more favorable than those in Reebie’s contract. Manso suggested that the parties get together and exchange the requested information, but when the Union neglected to pursue this matter further, Manso assumed the issue had been dropped.
Relations between Reebie and the Union reached their most bitter point on March 21, 1990, when frustrated by failed attempts to reach a new agreement, Reebie finally declared an impasse in negotiations. On the following morning, Manso called a meeting of his staff and announced his intention to unilaterally implement as the new- terms of employment the terms of Reebie’s final offer to the Union. He informed his employees that if they chose to strike in protest, Reebie was legally permitted to replace them permanently. Manso also told unionized employees that if a strike was called and those employees continued to work, they would be subject to discipline from the Union.
Based on the foregoing events, the Union filed a charge with the Board claiming that by Manso’s words and actions, Reebie had attempted to discourage employees from belonging to the Union in violation of section 8(a)(3) of the Act. The charge also claimed that by failing to furnish the information requested, Reebie had violated its duty to bargain under section 8(a)(5). Upon an investigation, the Board’s General Counsel issued a complaint alleging that Reebie: (1) discouraged its employees from affiliating with the Union by threatening them with discharge and by conditioning their continued employment on resignation from the Union; (2) failed to provide the Union with requested information; and (3) encouraged union membership by applying the terms and conditions of the agreement to union employees only.1
[608]*608The case was presented to an Administrative Law Judge (“ALJ”), who held first that the evidence failed to establish that Reebie had done anything to discourage its employees from belonging to the Union. The ALJ also held that by failing to respond to Man-so’s suggestion that each side exchange the requested information, the Union had dropped its request for information. On the complaint’s third allegation, however, the ALJ ruled in favor of the Union, reasoning that although “members-only” agreements were not per se illegal, not offering similar terms to non-Union workers was unlawful conduct. In a 2-to-l decision, the Board affirmed. The Board’s dissenting member believed that the third allegation should have been stricken from the complaint because it was not closely related to the original charge. Reebie asks us to reverse the Board’s decision either on the grounds set forth in the Board’s dissent or because the decision was unsupported by substantial evidence. Because we find that the allegation of pro-union discrimination was not sufficiently related to the conduct initially complained of by the Union, we need not evaluate the evidentiary basis of the Board’s decision.
Allegations of unfair labor practices are acted upon only after a two-step process is satisfied. A party must first file with the Board’s General Counsel a charge setting forth its allegations. Then, if the General Counsel decides that the allegations in the charge are worthy of prosecution, it will issue a complaint against the alleged wrongdoer and the case will be argued before an ALJ. In drafting the complaint, the General Counsel is substantively limited by the contents of the original charge. Though it need not be a verbatim restatement, the complaint must be “closely related” to the charge. The scope of the permissible variance between the charge and the complaint is at issue in this case.
In NLRB v. Fant Milling, 360 U.S. 301, 307-08, 79 S.Ct.
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BAUER, Circuit Judge.
Reebie Storage and Moving appeals from a decision rendered by the National Labor Relations Board (“Board”) holding that Reebie had applied its contract on a “members-only” basis in violation of section 8(a)(3) of the National Labor Relations Act (“Act”). 29 U.S.C. § 158(a)(3). We find that the allegation in the complaint upon which this finding was based was not closely related to any of the allegations contained in the initial charge and should have been stricken. Reebie’s petition for review of the Board’s decision is therefore granted, and the General Counsel’s petition for enforcement is denied.
Reebie engages in the moving and storage of commercial and household goods and has its main facilities in Franklin Park, Illinois. Depending on the demands of the season, Reebie has employed somewhere between 4 and 100 workers at that location. For many years, the union of Truck Drivers, Oil Drivers, Filling Station and Platform Workers, Local No. 705 (“Union”) represented several of Reebie’s workers. Reebie, in turn, belonged to the Movers’ Association of Greater Chicago (“Association”), a confederation of local movers which collectively represented its members in negotiating and drafting labor [607]*607agreements with the Union. The agreement between the Union and the Association relevant to this case ran from March of 1987 to March of 1990. Included in this agreement was a “favored nations clause” which entitled Reebie to the benefits of any subsequent contract entered into by the Union if the subsequent contract included terms more favorable than those in Reebie’s agreement. The agreement also included a “union security clause” which required all employees performing designated unit work to become members of the Union within thirty days of employment.
Despite this latter requirement, Reebie operated for the course of the agreement with only twelve of the approximately thirty unit members as part of the Union. Because only employees covered by the contract were entitled to welfare and pension benefits, Reebie avoided making contributions on behalf of the non-union employees. Acknowledging that Reebie was not as large as other employers within the Association and therefore could not viably provide contract coverage to all of its employees, Dan Ligurotis, the Union’s Secretary-Treasurer, acquiesced in this arrangement on the Union’s behalf and no grievances were filed against Reebie. But in July of 1989, apparently unaware of Liguro-tis’s agreement, union representatives William Dicks and Gerald Rzewnicki visited Reebie’s Franklin Park facility and signed up as union members between twenty and twenty-five Reebie employees. Their intent was for these workers to receive contract coverage, but that never occurred.
As the agreement neared expiration and negotiations for a new agreement were underway, the Union sent Reebie the following request:
In order to determine compliance with the contract, please forward as soon as possible, a weekly list from the first week of September, 1989 through the last week in January 1990, showing names, addresses, rates of pay, and hours worked per day for all employees performing any movers work. The list should be broken down between regular employees and all other employees — excluding summer replacements.
Salvatore Manso, Reebie’s president, responded to the letter first by noting that under the “favored nations clause,” Reebie was entitled to see any contracts into which the Union had entered that contained terms more favorable than those in Reebie’s contract. Manso suggested that the parties get together and exchange the requested information, but when the Union neglected to pursue this matter further, Manso assumed the issue had been dropped.
Relations between Reebie and the Union reached their most bitter point on March 21, 1990, when frustrated by failed attempts to reach a new agreement, Reebie finally declared an impasse in negotiations. On the following morning, Manso called a meeting of his staff and announced his intention to unilaterally implement as the new- terms of employment the terms of Reebie’s final offer to the Union. He informed his employees that if they chose to strike in protest, Reebie was legally permitted to replace them permanently. Manso also told unionized employees that if a strike was called and those employees continued to work, they would be subject to discipline from the Union.
Based on the foregoing events, the Union filed a charge with the Board claiming that by Manso’s words and actions, Reebie had attempted to discourage employees from belonging to the Union in violation of section 8(a)(3) of the Act. The charge also claimed that by failing to furnish the information requested, Reebie had violated its duty to bargain under section 8(a)(5). Upon an investigation, the Board’s General Counsel issued a complaint alleging that Reebie: (1) discouraged its employees from affiliating with the Union by threatening them with discharge and by conditioning their continued employment on resignation from the Union; (2) failed to provide the Union with requested information; and (3) encouraged union membership by applying the terms and conditions of the agreement to union employees only.1
[608]*608The case was presented to an Administrative Law Judge (“ALJ”), who held first that the evidence failed to establish that Reebie had done anything to discourage its employees from belonging to the Union. The ALJ also held that by failing to respond to Man-so’s suggestion that each side exchange the requested information, the Union had dropped its request for information. On the complaint’s third allegation, however, the ALJ ruled in favor of the Union, reasoning that although “members-only” agreements were not per se illegal, not offering similar terms to non-Union workers was unlawful conduct. In a 2-to-l decision, the Board affirmed. The Board’s dissenting member believed that the third allegation should have been stricken from the complaint because it was not closely related to the original charge. Reebie asks us to reverse the Board’s decision either on the grounds set forth in the Board’s dissent or because the decision was unsupported by substantial evidence. Because we find that the allegation of pro-union discrimination was not sufficiently related to the conduct initially complained of by the Union, we need not evaluate the evidentiary basis of the Board’s decision.
Allegations of unfair labor practices are acted upon only after a two-step process is satisfied. A party must first file with the Board’s General Counsel a charge setting forth its allegations. Then, if the General Counsel decides that the allegations in the charge are worthy of prosecution, it will issue a complaint against the alleged wrongdoer and the case will be argued before an ALJ. In drafting the complaint, the General Counsel is substantively limited by the contents of the original charge. Though it need not be a verbatim restatement, the complaint must be “closely related” to the charge. The scope of the permissible variance between the charge and the complaint is at issue in this case.
In NLRB v. Fant Milling, 360 U.S. 301, 307-08, 79 S.Ct. 1179, 1183-84, 3 L.Ed.2d 1243 (1959), the Supreme Court noted that because the role of the General Counsel is to vindicate public rights, the General Counsel should be permitted to amend the allegations in the charge based on information it obtains during its investigation. Our interpretation of this rule has been quite deferential to the General Counsel. See, e.g., NLRB v. Braswell Motor Freight Lines, Inc., 486 F.2d 743, 746 (7th Cir.1973) (stating “so long as the Board entered the controversy pursuant to a formal charge it may allege whatever it finds as part of that controversy.”). Nevertheless, because the General Counsel is not vested with the authority to investigate labor practices on its own initiative, if the complaint includes allegations which are completely outside of the situation complained of in the charge, those allegations must be stricken. NLRB v. Complas Indus., Inc., 714 F.2d 729, 732 & n. 3 (7th Cir.1983).
Critical to a determination of whether allegations in a complaint are closely related to those in the charge is a comparison of the legal and factual bases of the allegations. Redd-I, Inc., 290 NLRB 1115, 1116 (1988). In comparing the legal similarity, we consider whether the new allegations are of the same class as the violations complained of in the charge. Relevant to this inquiry is whether the new allegations involve the same legal theory and the same section of the Act. Id. at 1118. The second inquiry is whether the new allegations arise from the same factual situation as those contained in the charge. Id. Applying this test, we fail to find a sufficient nexus between the charge’s allegations and the complaint’s allegation that Reebie discriminated against non-Union employees.
There is, in this case, an obvious tension between the charge and the complaint. The charge complains of several practices occurring upon expiration of the agreement, all of which are alleged to have been designed to discourage Union membership. The complaint on the other hand, after incorporating the claims of the charge, adds that in administering the contract, Reebie unfairly excluded certain employees from the contract’s coverage because they were not Union [609]*609members. In other words, the complaint accuses Reebie of both encouraging and discouraging Union membership. Because the charge was limited to complaints of anti-union conduct, Reebie contends that the new pro-union allegation cannot be considered “closely related” to the charge.
At oral argument, counsel for the Board argued that even though the charge and complaint allege conduct diametrically opposed in motivation, they could be reconciled on a more general level because each presented an instance of discriminatory conduct. But at certain levels of legal abstraction, any two allegations are capable of being deemed “related.” Such a generous interpretation would improperly provide the General Counsel -with carte blanche to amend the charge as it pleases. Fant Milling, 360 U.S. at 309, 79 S.Ct. at 1184. Anchoring the General Counsel’s inquiry is the underlying fact situation. To prevent the General Counsel from engaging in an unprincipled enlargement of the charge, the complaint’s allegations must be true to the factual situation addressed in the charge. And, as the Board noted in its opinion, the complaint’s allegation of union favoritism is factually distant not only in nature but also in time from the charges of anti-union conduct.
Perhaps in recognition of this disparity, the General Counsel, in the alternative, defends the decision below on the grounds that the allegation of union favoritism stemmed from the charge’s “refusal to provide information” claim. Echoing the reasoning employed by the ALJ, the General Counsel states that the purpose for the request is intertwined with the request itself, and because the Union’s intent in requesting the information was to determine whether Reebie was applying the terms of its contract on a “members-only” basis, the request for information was factually related to Reebie’s discrimination in favor of the Union.
The Court of Appeals for the D.C. Circuit rejected a similar argument in Wilson & Sons Heating & Plumbing, Inc. v. NLRB, 971 F.2d 768 (D.C.Cir.1992). The court’s decision reversed an order of the Board which had held that an allegation in a complaint accusing the employer of unilaterally changing the wage rates specified in the collective bargaining agreement was closely related to a charge alleging a refusal to furnish the union with requested information. Id. at 763. Both allegations stemmed from purported violations of the employer’s bargaining obligations under section 8(a)(5) of the Act. The Board had concluded that because the purpose of the request was to confirm that the employer had deviated from paying the wage rates specified in the agreement, the two allegations were factually related. The court of appeals found, however, that this link was supported by less than substantial evidence and reversed the Board’s determination.
Careful scrutiny of this case reveals that the relationship between the allegations in this case are even more tenuous than the relationship which existed in Wilson & Sons. First of all, the two allegations in this case rest on different statutory provisions and different legal theories; these differences render the legal similarity between the two allegations more dubious. At least in Wilson & Sons, the union’s duty of representation was a legal issue common to both allegations.
More importantly, there is no evidence to justify the Board’s anomalous finding that the Union was requesting information so that it could uncover practices which benefitted Union members. A request for data pertaining to the terms of employment of all unit workers is not inherently related — and certainly not closely related — to an allegation of discrimination in favor of the Union. And without any evidence to suggest that Reebie was aware of the connection, this argument, as in Wilson & Sons, must fail.
Instead, the evidence consistently paints a picture of a union concerned only about the treatment of its own members. As the ALJ found, the Union was content in its arrangement with Reebie which provided coverage for members only, and it did not attempt to act on behalf of non-union workers. In fact, one of the stumbling blocks to a new agreement was the Union’s insistence that its members be guaranteed a more favorable benefits package than non-members.
[610]*610Consistent with this course of conduct, it appears that the request, coming on the heels of the Union’s discovery that Reebie was not making the appropriate union contributions for the new members signed up in July of 1989, resulted from concern about Reebie’s treatment of these new Union members and not from any concern over the terms which Reebie was providing to its nonunion employees. Suspicious that Reebie was misapplying the contract among its own members, the Union requested the information so that it could confirm this belief. That the Union requested information dating back only to September of 1989 reinforces this conclusion. Aware that the contract had been applied on a members-only basis since 1987, the Union nevertheless limited its request to the period in which most unit workers had already signed up as new members. Had the Union been acting on behalf of nonmembers, it would have solicited data from the period before the new members had signed up. Hence, the only supported inference pertaining to the Union’s intent is that the request was simply another example of the Union’s exclusive concern for its membership and was designed to confirm that the new Union members were not receiving contract coverage.
By our holding, we do not mean to comment on whether the arrangement between Reebie and the Union was lawful. We find merely that in including in the complaint the allegation that Reebie applied its contract on a “members-only” basis, the General Counsel strayed beyond the conduct complained of in the charge and was in essence acting on its own initiative. Because the Union’s charge took exception to conduct directed at its members and did not contemplate non-members, the allegation claiming discrimination against non-members should have been stricken. In accordance with the foregoing, we grant Reebie’s petition for review and deny the General Counsel’s cross-petition for enforcement.