**GUIDANCE TO OGE 450 FILERS\*\***

**[Preliminary]{.underline}**

\* Use ink or type - **DO NOT USE PENCIL**.

\* The **"None" block** must be checked where there is nothing to
report.

> \* **"Agency"** is Department of Commerce, National Oceanic and
> Atmospheric Administration

\* **"Branch/Unit and Address"** is **your line office** and your
**location address**

\* **Work Phone** -- Area code -- Phone Number

**\* Reporting Status:**

**"New Entrant"** refers to an individual who is filing his/her first
OGE 450. If you filed an OGE 450 last year, but are in a new position
this year, you are still considered an annual filer.

> **\* "Date of Appointment" for a new entrant** is the date of
> appointment to the position for which you are filing, not your date of
> appointment to the federal government.
>
> \* ***Annual filers need not report date of appointment.***

\* A **signed and dated original** is necessary for each required
filing.

\* Complete **"headers"** on all pages (name, work phone, and page
number).

\* **Retain** a copy for your files..

\* Submit the completed form to your supervisor, in an envelope with
your name and code on the outside.

\* Either you or your supervisor will submit the completed form to the
U.S. Department of Commerce, Office of the General Counsel, Ethics
Division.

**\* This guidance is intended as an aid to proper completion of the OGE
450. It is not exhaustive and in no way modifies or supercedes any
instructions accompanying the form.**

Part I: **[Assets and Income]{.underline}**

**\*** In addition to your own assets and income, you need to **list the
assets and investment income of your spouse and any dependent child.**

**\* Reportable holdings** include those held [at any time]{.underline}
during reporting year -- which is from October 1-September 30.

**\* Thresholds for reporting:**

> Assets with a fair market value of over \$1,000 at the end of the
> reporting period.

Income received or accrued over \$200 during the reporting period.

For example, if you owned McDonald's stock, but sold it on September
1^st^ for a profit of \$300, you will need to report this asset. Even
though you no longer own the stock at the end of the reporting period,
you received over \$200 of income from its sale; therefore, it gets
reported.

**\*** **Describe assets fully**; avoid abbreviations; give complete
names of stock, fund, corporations, institutions or individuals.
**Describe the nature of the holding completely** - [e.g]{.underline}.,
common stock, mutual fund.

**\* Make sure you fill in the block, Nature of Income**

\* [Do not]{.underline} report existence of and income from cash
accounts in depository institutions, money market accounts, money market
mutual funds, U.S. Government obligations and securities, IRAs held by
depository institutions.

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# Specific Types of Assets

> **I. MUTUAL FUNDS AND OTHER INVESTMENT FUNDS**

List the full name of the specific fund ([e.g]{.underline}., "T. Rowe
Price Growth and Income Mutual Fund"), not just the company's name
("T.R. Price"). *You do [not]{.underline} need to list the underlying
assets of diversified funds.*

> **Sector Funds** - The Office of Government Ethics (OGE) puts the onus
> on you, the filer, to determine if a fund is a diversified fund or a
> **sector fund.** If it is a sector fund, you are responsible for
> knowing the underlying assets of the fund, and repeatedly checking to
> see if there is a potential conflict of interest. OGE deems you, the
> filer, to have knowledge/constructive knowledge of the underlying
> assets of the sector fund by your receipt of the fund's quarterly,
> semi-annual or annual reports.
>
> **PLEASE MAKE SURE YOU CONTINUOUSLY REVIEW THESE REPORTS AND NOTIFY
> YOUR CHAIN AND/OR ETHICS COUNSELOR OF ANY POTENTIAL CONFLICT THAT MAY
> ARISE DURING THE YEAR!**
>
> \* A mutual fund is a "**sector fund"** if it concentrates its
> investments in an industry, business, single country other than the
> United States, or bonds of a single State within the United States."
> However, rather than looking at the current holdings of a particular
> fund, the proper focus is on the stated policy of the fund manager
> (usually contained in the prospectus) as evidenced by the fund's
> express statement of overall concentration philosophy.

Some likely sector funds are: Utilities, Telecommunications, Energy,
Health Care/Health Sciences, Life Sciences, Financial Services. Please
list the full name of the fund, e.g. Fidelity Health Care Fund, not just
Fidelity Fund.

> Our experience has been that generally, the funds are diversified.
> Most of the time you can tell by their name; e.g., Index Fund, Equity
> Fund, Growth Fund, Income Fund.

**II. PUBLICLY OFFERED UNITS OF LIMITED PARTNERSHIPS** - If the limited
partnership is publicly available, list full name of the limited
partnership and the nature of its investments [(e.g]{.underline}., real
estate). You need [not]{.underline} disclose its underlying investments.

**III. INDIVIDUAL RETIREMENT ACCOUNTS (IRAs)** - List by name and
institution. Report underlying assets of IRAs if not held by depository
institution ([e.g]{.underline}., if a broker holds IRA assets). An
underlying asset might be a mutual fund - [e.g]{.underline}., Fidelity
Growth and Income Fund. *Do not just list IRA/Fidelity*.

**IV. REAL PROPERTY**- list by geographic location and type
([e.g]{.underline}., rental, townhouse, San Diego, CA). If you have a
mortgage on this property, list this on Part II, Liabilities. If you do
not have a mortgage, please note "no existing mortgage."

**V. BONDS** - report by name of issuer. Need not list U.S. Government
bonds.

##### VI. EARNED INCOME

\* List y[our]{.underline} earned income from any one source over \$200
([e.g]{.underline}., salaries, fees, commissions, but not federal
employment salary or federal retirement benefits).

> \-- list source of your outside compensation and the nature of the
> income ([e.g]{.underline}., salary). List this outside position on
> Part III, as well.
>
> **\*** Spouse's earned income greater than \$1,000, if other than the
> federal government - list source of income and indicate nature of
> income ([e.g]{.underline}., salary). You do [not]{.underline} have to
> report the amount of your spouse's income. Indicate that this is your
> spouse's income.
>
> **\* NOTE**: You do [not]{.underline} have to report the earned income
> of a **dependent child**. However, such employment may present
> impartiality concerns if your child is working for a contractor and
> you take official action with respect to a matter involving that
> contractor. *You should bring this to your supervisor's attention
> immediately.*

**VII. EQUITY INTEREST**

> \* If you, your spouse or dependent child have an equity interest in a
> business ([e.g]{.underline}., general partner, proprietor), report

\-\--the name of the entity;

\-\--its location;

\-\--the form of business ([e.g]{.underline}., corporation); and

\-\--the nature of the business.

**VIII. RETIREMENT PLANS**

**\*** You must report your interest, as well as your spouse's interest
in a retirement plan (other than the government's Thrift Savings Plan or
other retirement plan that is part of federal employment). [Vested and
non-vested interests alike must be reported.]{.underline} If it is an
employer sponsored plan, list the name of the employer providing the
plan. Please identify the type of plan, e.g., defined benefit plan,
defined contribution plan, 401(k) plan, ESOP.

\* **If you exercise control over the assets** in which the plan
invests, then you must disclose those underlying assets. You can either
list those assets or attach an account statement that lists them. This
usually occurs in defined contribution plans or 401k plans where the
employee can choose among several mutual funds in which to invest.

> \* **401(k) Plans -** you must report the underlying assets of a
> 401(k) plan, as well as the name of the employer providing the plan.

**\* NOTE:** if [you]{.underline} have a retirement plan, you also need
to report this on Part IV.

**IX. ANNUITY WITH LIFE INSURANCE COMPANY**

\* You must report your interest (or that of your spouse or dependent
child) in an annuity with a life insurance company.

\* for a **fixed or variable annuity**, you must report

\- the name of the insurance company;

\- the type of annuity (fixed or variable) and; any investment choices
if in a variable account.

**X. LIFE INSURANCE POLICIES (not through federal government)**

**\*** You must report your interest (or that of your spouse or
dependent child) in a life insurance policy if you have a choice of
investments.

\* Specifically, you must report

\- the name of the insurance company;

\- the type of policy [(e.g]{.underline}., whole life, universal life,
variable life);

\- the investment option chosen ([e.g]{.underline}., growth stock
fund); - and type of income.

**XI. INVESTMENT CLUBS**

\* you must list each of the club's holdings as a separate line item as
if you (or your spouse or dependent child) held it directly. The
threshold for reporting applies to the overall amount that the
participants have invested, not to the value of your shares (or those of
your spouse or dependent child).

**XII. ESTATES & TRUSTS**

**\*** You need to report holdings and income from any estate or trust
from which you (or your spouse or dependent child) receive income, or in
which you (or your spouse or dependent child) hold a vested beneficial
interest in principal or income.

The underlying holdings of a trust DO NOT need to be listed if:

a\) the trust was not created by the filer, spouse or dependent children
AND

b\) they do not have specific knowledge of the underlying holdings or
sources of income, i.e., underlying assets.

The name of the creator of the trust or the financial manager or
trustee, and the date it was created (if known) is sufficient disclosure
for these types of trusts.

If the filer/spouse is a trustee, and receives income/compensation based
on a percentage of the trust's net worth, the filer must list the
underlying assets of the trust.

\* **if you, the filer, are the trustee**, you must also report this as
an outside position on Part III.

**XIII. SCHOLARSHIPS, PRIZES, AWARDS**

\* report for yourself, your spouse or dependent child.

**Part II: [Liabilities]{.underline}**

**\*** If greater than \$10,000, you must report this. Make sure you
also list the rental property on Part I.

\* List the name and address of the bank, including city and state,
e.g., First Alaska Bank, Anchorage Alaska. The type of debt must also be
identified (e.g., promissory note, mortgage, loan).

\* If you have rental property on Part I, but there is no existing
mortgage, please note that on Part II.

\* Do **[not]{.underline}** list a mortgage on your personal residence
unless it also is rented out.

> \* Do **[not]{.underline}** list revolving charge accounts where the
> outstanding liability does not exceed \$10,000 [at the end of the
> reporting period]{.underline}.

**Part III: [Outside Positions]{.underline}**

\* List **positions [you]{.underline} hold outside the government,
whether or not compensated.** Indicate the nature of the outside
position/business, and if compensated, make sure you list this income on
Part I. You need [not]{.underline} list positions in religious, social,
fraternal or political entities, or honorary positions.

\* If you are a **trustee** of a trust, list this position on Part III
and, as noted above, the underlying assets of the trust on Part I.

For listed positions, the following information should be provided:

a\. The name and location (city and state) for the organization;

b\. The specific position held or nature of activity with the
organization

**Part IV: [Agreements and Arrangements]{.underline}**

\* You must report **your participation in a retirement plan** with a
prior employer or with a current [outside]{.underline} employer (i.e.,
employer other than the federal government). Provide the name of the
employer providing the plan and the type of plan. This plan should also
be listed on Part I.

\* If the filer lists and agreement/arrangement concerning future
employment, the following should be included:

a\. The basic elements of the agreement/arrangement, such as employment
terms and effective dates;

b\. The parties identified with location (city and state);

c\. The date (month and year) for the agreement/arrangement.

**Part V: [Gifts and Travel Reimbursements]{.underline}**

The instructions on the form summarize what needs to be reported.
Usually, this block is checked none.