# Presentation: 376691

## Financial DisclosureNet-Training Conference

- Natural Resources Conservation Service
- Ethics Office
- 5601 Sunnyside Avenue, MS 5476
- Beltsville, MD  20705
- January 23, 2007
- 11:00 a.m. – 12:00 p.m.

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- AUTHORITIES
- The collection of confidential financial information from employees is based on the following statutory/regulatory authorities:
-  Ethics in Government Act of 1978 (5 U.S.C. § App)
-  Executive Order 12674 (as modified by Executive           Order 12731)
-  5 C.F.R. § 2634, Subpart I

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- PURPOSE
- The purpose of the confidential financial disclosure report is to assist employees and their agencies avoid conflicts between official duties and private interests and affiliations.
- Notes:
-  5 C.F.R. § 2635.402, Conflict of Interest
-  5 C.F.R. § 2635.502, Conflict of Interest (Impartiality)

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- PENALTIES
-  Falsification of information or failure to file or to report information required to be reported subjects the filer to disciplinary action.
-  Knowing and willful falsification of information required to be reported also subjects the filer to criminal prosecution.

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- PENALTIES
- ACCESS TO CONFIDENTIAL FINANCIAL DISCLOSURE REPORTS
- “No member of the public is permitted access to confidential financial disclosure reports, except pursuant to the order of a Federal court or as provided under the Privacy Act. These records may be reviewed only by authorized personnel, including the Office of the Inspector General, upon written application to the Mission Area [DEO, Kevin Brown for NRCS]. These reports must be secured in locked cabinets when not in use and should be kept apart from all other personnel documents."
- Unauthorized disclosure of information from an OGE Form 450 will serve as the basis for appropriate disciplinary action.

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- FILING TIME FRAME
- _New Entrant Report_. The report is due within 30 days of assuming a position designated for filing and covers the preceding 12 months. If a new entrant filed an OGE Form 450 on 11/1/06 or thereafter, no additional report is due.
- _Annual Filers_. The report is due February 15, 2007. It covers 10/01/05 - 12/31/2006.
- Note: State employees must file their reports with their servicing SEA by February 15. States will have until _March 15, 2007_ to forward their “bundles” to the NRCS Ethics Office.
- Note: OGE Form 450s should _not_ disclose $$ amounts or %s of ownership.

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- ACCEPTABLE FORMS
- » New OGE Form 450, available at _[www.usoge.gov](http://www.usoge.gov/)__ or __[http://www.nrcs.usda.gov/intranet/ethics/FinancialDisclosure/RevisedOGE4502006.pdf](http://www.nrcs.usda.gov/intranet/ethics/FinancialDisclosure/RevisedOGE4502006.pdf)_
- » OGE Optional Form 450-A (08/2005)
- This form may only be used by incumbent filers who have a long form [OGE Form 450] on file with our Office. (Note: New entrants may _not_ use this form.)

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

-  ACCEPTABLE FORMS (continuation)
- OGE Optional Form 450-A (08/2005).  An incumbent must be able to certify that he/she, his/her spouse, or his/her dependent children has:
-  No new reportable assets/incomes or liabilities (debts);
-  No new reportable outside positions (Filer only);
-  No new reportable agreements/arrangements for past, present or
-      future employment (Filer only);
-  No new reportable gifts or travel reimbursements; and
-  Not changed jobs *i.e*., new P.D. or significant change in duties, (Filer
-      only)

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

| Employee’s Name (Print last, first, middle initial)
Doe, Dale W. |  |  |  | E-mail Address
Dale.Doe@wdc.usda.gov |
| --- | --- | --- | --- | --- |
| Position/Title
 Director |  |  |  | Grade
15 |
| Branch/ Unit and Address:
Procurement Division, 5601 Sunnyside Avenue, MS  5476, Beltsville, MD  20705
 |  |  |  | Work Phone & Ext.
(301) 504-2000, ext.11 |
| Agency
NRCS |  | Reporting Status
□   New Entrant   
  Annual | If New Entrant, Date of Appointment to  Position
(mm/dd/yy) |  |
| Check Box if Special Government Employee (SGE) □ | If an SGE, Home Address (Number, Street, City, State, ZIP Code)
 |  |  |  |

**CONFIDENTIAL FINANCIAL DISCLOSURE REPORT**
- EXECUTIVE BRANCH

**Date Received by Agency**

**Page Number **

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

| I. I have reportable assets or sources of income for myself, my spouse, or my dependent children. | Yes □   | No □  |
| --- | --- | --- |
| II. I have reportable liabilities (debts) for myself, my spouse, or my dependent children | Yes □   | No □  |
| III. I have reportable outside positions for myself | Yes □   | No □  |
| IV.  I have reportable agreements or arrangements for myself | Yes □   | No □  |
| V.  I  have reportable gifts or travel reimbursements for myself, my spouse, or my dependent children  (This question is only for annual filers, not new entrants.) | Yes □ | No □  |

- Step 2: For _each_ statement below, check yes or no to describe your situation.

| On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations, except as noted in the “comments” box below. |  |
| --- | --- |
| Signature and Title of Supervisor/Other Intermediate Reviewer (if required by Agency)                            Date (mm/dd/yy)
Billy Preston, State Ethics Advisor          [State Ethics Advisors sign here.] |  |
| Email Address: Billy.Preston@wdc.usda.gov | Phone Number:  (301) 504- 2001 |

- For Reviewer’s Use Only

| Signature and Title of Agency’s Final Reviewing Official
 | Date (mm/dd/yy) |
| --- | --- |
| Comments of Reviewing Officials |  |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Types of Assets and Income

-  Stocks		 		 Dividends
-  Bonds (Corporate debt instruments)		 Rents
-  Tax Shelters			 Royalties
-  Mutual Funds			 Interest
-  Annuities (Variable)			 Capital Gains
-  Trust Holdings			 Fees
-  Trades & Businesses		 Salaries
-  Investment Life Insurance		 Commissions
-  Pensions				 Retirement Benefits
-  IRA/401(k) Holdings		 Honoraria
-  Commodity Futures
-  Partnership Interests
-  Collectibles (for investment)

- Assets

- Income

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part I : Assets and Income

- Report for Yourself, Spouse (S), and Dependent Children (DC):
- Assets held for investment with a value of $1000 or more at the end of the reporting period or which produced more than $200 in income during the reporting period:
-  Sector mutual funds (those funds invested in particular industry, business or location such as ABC Electronics Fund or XYZ Canada Fund (report the full name of the fund name)
-  Stocks, bonds, annuities, trust holdings, partnership interests, life insurance, investment real estate, or a privately-held trade or business
-  Retirement Plans (401k, IRAs). List each holding, _except_ diversified mutual funds
-  Defined benefit pension plans by previous employer (include the name of the employer)

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part I : Assets and Income

- Report for Yourself:
-  All sources of salary, fees, commissions, and other earned income > $200; honoraria > $200 and other non-investment income such as scholarships, prizes and gambling income > $200.
- Report for Spouse (S):
-  All sources of salary, fees, commissions, and other earned income greater than $1000 and honoraria greater than $200.

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part I : Assets and Income

- _Do not report_:
-  Federal Government retirement benefits
-  Thrift Savings Plan
-  Certificates of Deposit, Savings and Checking
-  Term Life Insurance
-  Money Market Mutual Funds and Money Market Accounts
-  Your personal residence, unless you rent it out

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part I : Assets and Income

- _Do not report_: (Continuation)
-  Dependent child’s earned income
-  Diversified mutual funds such as ABC Equity Value Fund or XYZ Large Capital Fund
-  U.S. Government Treasury bonds, bills, notes and savings bonds
-  Money owed to you, your spouse, or dependent child by a spouse, parent, sibling, or child
-  Veteran’s benefits
-  Social security benefits
-  Federal government salary

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part I : Assets and Income

| Specific stock, sector mutual fund, type/location of real estate, etc. (Indicate the full name of each specific asset or investment.  You may add the ticker symbol to the full name.
Name of Employer or Business, Source of Fees, Commissions, or Honoraria (Include brief description.) You may distinguish any entry for a family member by preceding it with S (spouse); DC (dependent child) or J (Jointly held) |   No longer held |
| --- | --- |
| (S) Artisian Water Supply Company (Phoenix, AZ) |  |
| (J)  Rental House (Biloxi, Mississippi) |  |
| (S) Take Time Café  (Variable Annuity*) 
Sagebrush Income Fund
Tooth Fairy Index Fund
Bubblegum Stock Fund
 |  |
| (J) Xama Bio-Technology Fund  (Note: This is a sector fund.) |  |
| (DC) Pepsico (Stock) |  |
| (DC) Coca Cola, Inc. (Stock) |   |
| Rutgers University (Rutgers, New Jersey) |  |

- *These funds do _not_ need to be reported since they are diversified mutual funds. If they were sector funds, they would need to be reported.

- }

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Definitions

- Diversified Mutual Fund – A fund, trust or plan that does not have a stated policy of concentrating its investments in one industry, business or country (other than the United States) or State.
- _Examples_: Laudus Income Fund, Manhattan High Fidelity Fund, Smith Index Fund, *etc*...
- (If the fund name contains the word "telecommunications" or "Canada" or "energy," it's a good indication that the fund is concentrated in those areas and therefore not diversified, but a Sector fund.)

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Definitions (continued)

- Sector Mutual Fund – A mutual fund that concentrates its investments in an industry, business, single country (other than the United States), or bonds of a single state within the United States.
- _Examples_*: Fidelity Select Healthcare, Fidelity Select Biotechnology, Fidelity Select Computers, Fidelity Select Home Finance, Fidelity Select Medical Delivery, Fidelity Select Retailing
- (*The names of these sector funds indicate that they are concentrated funds.)

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Definitions (continued)

- Special Government Employee (SGE) – An executive branch officer or employee who is retained, designated, appointed, or employed to perform temporary duties either on a full-time or intermittent basis, with or without compensation, for a period not to exceed 130 days during any consecutive 365-day period.
- Dependent Child (DC)– A son, daughter, stepson, or stepdaughter who is either unmarried and under age 21 and living in the filer’s house, or considered dependent under U.S. tax code.

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Research Tools

- When in doubt about a particular fund, do your research:
- _[www.dogpile.com](http://www.dogpile.com/)_
- _[http://finance.yahoo.com/lookup](http://finance.yahoo.com/lookup)_
- _[http://www.hoovers.com/free/](http://www.hoovers.com/free/)_
- _[http://www.morningstar.com/](http://www.morningstar.com/)_
- Note: A stock symbol or ticker symbol is a mnemonic used to uniquely identify shares of a publicly-traded corporation on a particular stock market. Examples:
- MSFT - Microsoft
- IFX - Infineon Technologies
- AMEX – American Express

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part II: Liabilities

| Report for Yourself, Spouse, and Dependent Child: |
| --- |
|  A liability over  $10,000 owed at any time during the reporting period, other than a loan from a financial institution or business entity granted on terms made available to the general public
→ A loan over $10,000 from an individual such as a friend or a business associate |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part II: Liabilities

| Do Not Report: |
| --- |
|  Any liability, such as a mortgage, a student loan, or a credit card account, from a financial institution or business entity granted on terms made available to the general public.
 Loans secured by automobiles, household furniture, or appliances, unless the loan exceeds the purchase price of the item it secures. 
  Liabilities that you owe to your spouse or to the parent, sibling, or child of you, your spouse, or your dependent child. |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part II: Liabilities

| Name of Creditor | Type of Liability |
| --- | --- |
| John Trujillo (Dover, DE) | Personal Loan |
|  Thrift Savings Plan (Personal Loan)  |  TSP Loan*   |
| ABC Corporation, Inc. (Burgess, MA) | Loan on Farm Equipment |

- *This is not the type of loan granted on terms made available to the general
- public.  It is only available to current Federal civilians employed by the Government
- members of the uniformed services. [www.tsp.gov]

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part III: Outside Positions

| Report For Yourself |
| --- |
| All positions outside the U.S. Government held at any time during the reporting period, whether or not you were compensated and whether or not you currently hold that position.  

 Positions include an officer, director, employee, trustee, general partner, proprietor, representative, executor, or consultant of any of the following:

» Corporation, partnership, trust, or other business entity
» Non-profit or volunteer organization
» Educational institution

 |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part III: Outside Positions

| Do Not Report: |
| --- |
|  Any position with a:
» Religious entity, social entity, fraternal, or political entity

 Any position held by your spouse or dependent children

 Any position that you hold as part of your official duties |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part III: Outside Positions

| Approval of Outside Employment |
| --- |
| ◘ The requirement to get approval before engaging in outside employment only applies to financial disclosure filers. 
◘ A financial disclosure report filer must obtain prior approval before engaging in any form of non-Federal employment or other outside business relationship or activity that involves giving personal services for direct, indirect, or deferred compensation (other than reimbursement for actual and necessary expenses). 
» (i) providing personal services as a consultant or professional, including service as an expert witness or as an attorney; and 
» (ii) Providing personal services to a for-profit entity as an officer, director, employee,  agent, attorney, consultant, contractor, general partner, or trustee, which involves decision-making or policymaking for the non-Federal entity, or the provision of advice or counsel. [5 C.F.R. § 8301.102(b)]
◘ No NRCS employee is required to get prior approval to be an officer in a non-profit organization unless compensated. (The position still needs to be reported on the OGE Form 450.)
 |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part III: Outside Positions

| Organization | Type of Organization | Position | No longer held |
| --- | --- | --- | --- |
| 1. SWCS (Dover, TX) | Non-profit | President |  |
| 2. Conservation Technology, Inc. (Wiley, TX) | For-Profit Corporation | Director/
Employee |  |
| 3. University of Egypt (Bugaboo, ME) | Educational Institution | Adjunct Professor |  |
| 4. Liaison, Ducks Unlimited, Inc.
(Peace, MN) | Wetlands Conservation Group/Non-Profit | Officer |  |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part IV: Agreements and Arrangements

| Report Your Agreements and Arrangements for:  |
| --- |
|  Continuing participation in an employee pension or benefit plan maintained by a former employer
 A leave of absence
 Future employment, including date you accepted employment offer
 Continuation of payment by a former employer (including severance payments) |
| Do Not Report |
|  Any agreement or arrangement related to your employment by the Federal Government
 Spouse’s and dependent child’s agreements or arrangements |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part IV: Agreements and Arrangements

| Entity with which you have an agreement or arrangement (include city and state where entity is located) | Terms of Agreement or Arrangement |
| --- | --- |
| 1. Abba, Inc. (Utopia, Maine) | Pension benefits from former employer |
| 2. University of Platonics (Plato, Alaska) | Leave of absence from teaching position |
| 3. Hawaiian Tropic Resort (Lulakani, Hawaii)  | Employment agreement effective as of January 31, 2007. |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part V: Gifts and Travel Reimbursements

|  Report for Yourself, Spouse, and Dependent Child: |
| --- |
|  Travel-related reimbursements (items such as lodging, transportation and food) totaling more than $305* from any one source during the reporting period; include where you traveled, the purpose, and date of trips.  
 Any other gifts totaling more than $305* from any one source during the reporting period. |
| *If you received more than one gift from one source:
 Determine the value of each item received from that  source
Ignore each item valued at $122 or less
Add the value of items over $122, if they total more than $305 list them out.  |

-  [Only annual filers fill out this section, not New Entrants]

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part V: Gifts  and Travel Reimbursements

|  Do Not Report: |
| --- |
|  Anything received from relatives, the U.S. Government, state, or local governments,  |
|  Gifts of travel reimbursement given to your agency in connection with your official travel.  (Do not list 1353s) |
|  Anything received by your spouse or dependent child totally independent of their relationship to you |
|  Gifts of hospitality (food, lodging, entertainment) at the donor’s residence or personal premises |
|  Bequests and other forms of inheritance |

-  [Only annual filers fill out this section, not New Entrants]

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- Part V: Gifts  and Travel Reimbursements

-  [Only annual filers fill out this section, not New Entrants]

| Source | Description |
| --- | --- |
| 1. Law Offices of Jingle, Talley and Williams  | 14 Carat gold electroplate business card carrying case (This costs less than $122 and should not be reported) |
| 2. Law Offices of Jingle, Talley and Williams | Leather Attaché case (Example of a gift totaling more than $305 from one source) |
| 3. Hawaiian Tropic Resort  | Airline ticket $400, hotel rooms $150, and meals $205 incident to employment (travel reimbursement) (The items have to be listed since they total over $305. Dollar amounts are for illustrative purposes - they do not have to be reported.) |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- 2007 Summation of Changes

|  You No Longer Have To Report:
 Part I Assets and Income. 
 Any diversified mutual funds. 
The type of income (e.g., rental, capital gains, dividends, cash, etc...)  you receive or earn, with the exception of any honoraria.
 Part II Liabilities.
 Student loans
 Credit card debts
 Loans from financial institutions which are based on terms generally available to the public
 Part IV Agreements and Arrangements.
The dates on which you entered agreements and arrangements, other than for future employment.   |
| --- |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

- 2007 Summation of Changes

|  You No Longer Have To Report:
 Part V Gifts and Travel Reimbursements. 
 There are new thresholds for reporting gifts that you, your spouse, or dependents receive. 
 You do not need to report any travel related reimbursements for lodging, transportation, food or gifts totaling less than $305 from any one source during the reporting period.
 If you received more than one gift from one source, you only have to report individual items which have a value of greater than $122 and only then if they all total more than $305.
 |
| --- |

## Financial DisclosureNet-Training Conference

- NRCS Ethics Office  □  Financial Disclosure Training for State Ethics Advisors

|  
The End |
| --- |