TRANSITION GUIDE

INTRODUCTION A message from OGE’s Director 6

How OGE can help with the transition 9

PRESIDENTIAL NOMINEES OGE’s role in Presidential nominations 19

Critical milestones 22

Input determines output 24

Nominee response time matters 26

What to tell nominees 27

Pre-clearance 28

Integrity, the electronic filing system 29

ESTABLISHING PROCEDURES Investing in the nominee process 33

Obtaining needed expertise 34

Initiating reports in Integrity 35

Sequence of the process 36

Variations 38

ETHICS IN THE NEW ADMINISTRATION

Setting the tone 43

Concrete steps 45

RESOURCES Key online resources 50

Some relevant OGE issuances 52

PAS position spreadsheets 62

OGE contact information 66

Notes 

TABLE OF CONTENTS

INTRODUCTION
A MESSAGE FROM OGE’S DIRECTOR

Our pledge to you is that together,

OGE and the Presidential Transition Team will get the new 

administration off to a strong ethical start. 
One of the great traditions of our nation is the peaceful transition of 

power. History is made every four or eight years when our government 

turns over the reins of power from one Presidential administration to the 

next.

At the same time, the work of a Presidential transition is a monumental 

undertaking. In just over ten weeks between the election and the 

inauguration, the President-elect must prepare to take control of 

a government comprising more than 130 agencies, hundreds of 

subcomponents, and millions of civilian and uniformed personnel. 

The U.S. Office of Government Ethics (OGE) recognizes that the 

Presidential transition is a critical time when the nation is vulnerable, 

with the potential for manmade, natural, or economic disasters to strike 

while the government’s top leadership positions are vacant. OGE works 

in partnership with the Presidential Transition Team to make sure that 

prospective nominees are free of conflicts of interest, so that top leadership 

positions can be filled quickly.

The demands on the Presidential Transition Team will be extreme, but 

achieving an effective transition is vital to the nation’s interests. Success 

depends largely on investing the resources, time, and effort needed to 

achieve an effective transition. 

The Presidential Transition Team needs to be well-organized and 

knowledgeable about the process. This guide identifies ways OGE can 

help, explains the nominee ethics process, and provides strategies for 

establishing a strong ethical culture in the new Presidential administration. 

At the end of the guide, we also provide useful reference materials.

Our pledge to you is that together, OGE and the Presidential Transition 

Team will get the new administration off to a strong ethical start. The 

President-elect and the American people deserve nothing less.

Walter M. Shaub, Jr. Director

OGE is ready to assist the Presidential 

Transition Team in navigating the 

transition and laying the groundwork 

for a strong ethical culture in the new 

administration. OGE can also assist 

in establishing a strong White House 

ethics program. The following section 

highlights some of the ways OGE can 

help. 

HOW OGE CAN 

HELP WITH THE 

TRANSITION

9
• The Presidential nomination process

• Communications with OGE staff 

• Communications with agency ethics officials

• Financial disclosure requirements

• Electronic filing of financial disclosure reports

• “Blind” review of sensitive financial disclosure reports

• Informal pre-screening of prospective nominees 

• Ethics agreements and how they are used to prevent 

conflicts of interest

• Ethics laws and regulations that will apply to the 

President-elect’s appointees

• OGE’s ability to provide technical assistance on ethics 

initiatives

• Best practices for expediting the ethics review for 

nominees

1BRIEFINGS

BEFORE & AFTER

THE ELECTION

It is important to establish lines of communication with OGE 

before the election. Please contact OGE’s Director in August 

to schedule briefings for campaign officials engaged in planning 

Presidential transition activities. We recommend that you send 

representatives to the initial briefing who are at a high enough level 

in the campaign to be able to agree to procedures for interactions 

with OGE. In the briefings, we can provide detailed information 

on the following:
The financial disclosure vetting 

process for a potential nominee 

can take weeks and sometimes 

months.

2 E T H I C S R E V I E W O F 

NOMINEE FINANCIAL 

DISCLOSURE REPORTS 

The financial disclosure vetting process for a potential nominee 

can take weeks and sometimes months. Nominees often have 

complex financial investments and employment arrangements 

that are difficult to untangle. We will help you work through 

those issues effectively and efficiently. We also recommend that 

you collect draft financial disclosure reports from nominees and 

provide them to OGE as soon as possible, in order to avoid 

delays in the nomination process.

11
3 PRELIMINARY 

CONSULTATIONS ON 

PROSPECTIVE NOMINEES

OGE can provide preliminary consultations regarding a nominee’s 

potential conflicts of interest. These consultations are useful 

when you need to know whether the nominee’s financial interests 

would make nomination for one or more possible positions 

impracticable. For example, one obstacle may be a nominee’s 

unwillingness or inability to divest a specific financial interest. 

Without identifying the individual, you can describe the financial 

interest and the type of position being considered. OGE can then 

provide a tentative assessment as to whether that financial interest 

would likely pose a conflict of interest for a nominee in that 

position. 

These consultations are useful 

when you need to know whether 

the nominee’s financial interests 

would make nomination for 

one or more possible positions 

impracticable.
4 “BLIND” REVIEWS OF 

NOMINEE REPORTS

We recognize that there may be certain circumstances when you 

are not ready to provide a particular nominee’s financial disclosure 

report to OGE. This may happen when you have not made a 

decision as to the specific position to which you will nominate the 

individual or the individual’s identity is sensitive. 

In these instances, you can redact information about the 

individual’s identity or the position and agency. OGE can then 

conduct a “blind” review of the report for technical compliance 

with financial disclosure requirements. OGE will not be able to 

perform a conflicts of interest analysis without knowing what 

position the potential nominee is going to, but resolving technical 

reporting issues will greatly reduce the time needed for the ethics 

review when you later make a decision about the nominee. 

We recommend that you limit requests for these “blind” reviews 

to only nominees receiving serious consideration in order to avoid 

diverting resources that OGE would otherwise devote to your 

other nominees. In addition, OGE will not be able to coordinate 

directly with the anonymous nominee. Therefore, you will need 

to assign someone to serve as an intermediary to communicate 

OGE’s comments and questions regarding the financial disclosure 

report.

13
6

7 TRAINING AND GUIDANCE 

ON GOVERNMENT ETHICS

TECHNICAL ASSISTANCE 

WITH ETHICS INITIATIVES

If the President-elect intends to issue an executive order or other 

instructions regarding government ethics, OGE is available to 

assist in the drafting process. OGE will explain any consequences 

of policy decisions or specific language and can identify a variety 

of options to achieve the President-elect’s objectives.

On January 20, 2017, newly appointed White House staff will 

need to respond immediately to countless urgent matters of 

national importance. The terrain will be fraught with ethical 

landmines that can lead to criminal, civil, and administrative 

penalties for individual appointees and to embarrassment for the 

new administration. 

5 DRAFTING ETHICS 

AGREEMENTS

The ethics agreement outlines specific steps a nominee will take to 

avoid conflicts of interest. OGE’s staff and agency ethics officials 

draft each ethics agreement using standardized language from 

OGE’s ethics agreement guide that will be modified as needed to 

tailor the agreement to the nominee’s unique circumstances.
9

8 TRAINING ON THE 

ELECTRONIC FILING 

SYSTEM, INTEGRITY

COORDINATING CONTACTS 

WITH AGENCIES

During the Presidential transition and in the first days of the 

new administration, it can be hard to know who to call in the 

government. OGE can help you reach the right people. OGE 

oversees a network of over 4,500 agency ethics officials spanning 

every agency in the executive branch. We can leverage this 

network to connect you with the right people to assist you with a 

wide variety of issues.

Nominees file their financial disclosure reports through the 

executive branch’s electronic filing system, which is named 

Integrity. Although Integrity is a “smart” system that guides 

nominees through the process of filing their reports, before any 

of your potential nominees can have access to the system, OGE 

will need to train at least two members of your staff to serve 

important roles in the system.

OGE can help prevent problems by conducting government 

ethics training for new White House officials, either before or 

after January 20, 2017. OGE also stands ready to support the new 

White House Counsel’s Office (WHCO) by providing guidance 

when issues arise. In addition, OGE can assist you in establishing 

an organized and effective ethics program in the Executive Office 

of the President and the Office of the Vice President.

15

PRESIDENTIAL NOMINEES

The law requires OGE to review the 

financial disclosure reports of most 

Presidential nominees for civilian 

positions requiring Senate confirmation. 

OGE reviews these reports for potential 

conflicts of interest and for compliance 

with disclosure requirements. OGE’s 

efforts to resolve potential conflicts help 

ensure that nominees will be able to 

perform the duties of their positions.

OGE’S ROLE IN 

PRESIDENTIAL 

NOMINATIONS

19
OGE’s staff appreciates that the ethics review must 

be, at once, both thorough and expeditious.

OGE’s staff works in concert with agency ethics officials to review 

nominees’ draft financial disclosure reports. Then, agency ethics 

officials work directly with nominees or their representatives to assist 

them in revising their draft reports.

Agency ethics officials also supply knowledge regarding their agency’s 

missions and activities that is crucial to analyzing potential conflicts 

of interest. Together, OGE’s staff and agency ethics officials identify 

potential conflicts of interest and draft ethics agreements in order to 

resolve them. The commitments that nominees make in their ethics 

agreements ensure that they will be able to carry out their duties as 

Presidential appointees effectively and honorably.

OGE brings to this job a wealth of expertise and experience. OGE’s 

staff appreciates that the ethics review must be, at once, both thorough 

and expeditious. The goals are to ensure compliance with ethics and 

disclosure requirements and, whenever possible, to reduce the burden 

on the nominee.

OGE has also developed a number of useful tools and resources, all of 

which are available on OGE’s website. These tools include a nominee 

ethics guide, a comprehensive financial disclosure guide, an ethics 

agreement guide, and numerous legal advisories.
The process requires skillful coordination between the Presidential 

Transition Team, OGE, the agency, the nominee, and in some cases 

the nominee’s representative.

FINANCIAL

DISCLOSURE

REPORT

&

ETHICS

AGREEMENT

TRANSITION

TEAM

OGE

AGENCY

NOMINEE

NOMINEE

REP

21
AUG SEP OCT

CRITICAL MILESTONES

OGE Briefing

In August, send a 

high-level team to 

OGE to receive 

a briefing and to 

make plans for 

the ethics review 

of nominees.

Administrator

In September, 

designate PTT’s 

Administrator 

and staff for 

electronic filing, 

and send them to 

training at OGE.

Set-Up

In September, 

work with OGE 

to complete the 

technical set-up 

of PTT’s e-filing 

process for 

nominees.

This timeline 

illustrates a 

few critical 

milestones for 

the Presidential 

Transition Team 

(PTT) with 

regard to the 

ethics review 

of prospective 

Presidential 

nominees.

Recruit

In October, 

recruit a 

financial 

disclosure 

expert to detail 

from an agency 

or to hire.
NOV DEC JAN

Ethics Lead

By November 9, 

detail or hire a 

financial disclosure 

expert to coordinate 

with OGE.

Nominees

In November, provide 

prospective nominees 

with OGE’s Nominee 

Ethics Guide.

Surge

In early December, 

significantly 

increase the 

volume of financial 

disclosure reports 

submitted to OGE 

and agencies for 

review.

Nominate

On January 20, 

the President 

traditionally 

nominates 

cabinet-level 

officials.

Hearings

In January, 

the Senate 

traditionally 

holds hearings 

for cabinetlevel nominees, 

even though 

they have not 

been formally 

nominated.

Disclosure

Require prospective 

nominees for priority 

positions to complete 

draft financial 

disclosure reports.

Review

Starting as early as possible in 

November, send nominee financial 

disclosure reports to OGE and 

agencies for review.

23
The new President will need to fill nearly 1,100 Senate-confirmed 

civilian positions in the executive branch. This is no small undertaking. 

The average time for the ethics review of a financial disclosure report, 

including development of an ethics agreement, is 43 days. OGE can 

expedite individual reports upon request, but the trade-off is that 

expediting one report may cause another one to take longer.

The graph on the opposite page illustrates the volume of reports that 

OGE reviewed in the last Presidential transition in 2009. The grey line 

represents the number of reports OGE received each month. The green 

line represents the number of reports OGE pre-cleared (i.e., tentatively 

approved for nomination) each month. The key takeaway from the 

graph is that while OGE’s nominee process is highly efficient, OGE 

can’t review financial disclosure reports it hasn’t received. The sooner 

OGE receives reports, the sooner OGE can clear them. 

By all accounts, the 2009 Presidential transition was a highly successful 

one. This upcoming transition, however, can be more successful if the 

Presidential Transition Team releases draft nominee financial disclosure 

reports to OGE sooner. In order to achieve the President-elect’s goals 

for filling leadership positions, we encourage you to invest the resources 

needed to move this graph to the left in late 2016 and 2017. 

INPUT DETERMINES OUTPUT
In order to achieve the President-elect’s goals 

for filling leadership positions, we encourage 

you to invest the resources needed to move this 

graph to the left in late 2016 and 2017.

25
The single biggest factor affecting the time it takes to review a 

nominee’s financial disclosure report is the responsiveness of the 

nominee. Multiple rounds of questions and revisions are usually needed 

before a report can be finalized—the financial disclosure requirements 

in the Ethics in Government Act are just that complex. 

Delays can occur whenever a nominee is slow in:

• Gathering documents needed to complete the financial 

disclosure report;

• Responding to questions from OGE or agency ethics officials;

• Contacting a source of needed information, such as a brokerage 

firm, a financial advisor, an employer’s human resources office, a 

partner, etc.; or

• Wrapping up negotiations to plan for things like the dissolution 

of a partnership, the sale of a company, the termination of an 

employment relationship, etc.

Delays can also occur whenever a nominee is reluctant to agree to the 

steps legally required to resolve conflicts of interest, such as resignation, 

divestiture, or recusal.

Here are three simple ways you can reduce nominee response time:

• Provide nominees with OGE’s Nominee Ethics Guide, 

• Emphasize the importance of nominees responding when OGE or 

agency ethics officials request additional information or corrections 

to the financial disclosure report, and 

• Warn nominees in advance that ethics laws and regulations may 

require them to make changes to their financial holdings.

NOMINEE RESPONSE TIME 

MATTERS
Nominees should respond promptly to questions from ethics 

officials in order to avoid delays. They also need to be aware 

that ethics laws and regulations will require them to take 

certain actions to avoid conflicts of interest. Below is some 

suggested language that you can email to nominees: 

1. It is imperative that 

you respond promptly to 

questions from agency 

ethics officials.

4. Be prepared for the 

possibility that conflict 

of interest laws may 

necessitate changes in 

your personal finances, 

potentially including 

the divestiture of assets 

and resignation from 

business or volunteer 

positions.

6. Be sure to review 

OGE’s Nominee 

Ethics Guide at the 

beginning of the ethics 

process. Let us know if 

you have not received a 

copy of the guide.

5. Be aware that 

conflict of interest 

laws also apply to the 

financial interests of 

your spouse and minor 

child. For this reason, 

they too may need to 

divest assets.

2. When directed to 

revise your financial 

disclosure report, revise 

the report and notify 

agency ethics officials as 

quickly as possible.

3. Be prepared for the 

unfortunate reality that 

the vetting and Senate 

confirmation processes 

can be burdensome and 

intrusive.

WHAT TO TELL NOMINEES 

27
This process protects the President 

in exercising the constitutional 

authority to nominate individuals 

to senior leadership positions in the 

government.

PRE-CLEARANCE

Pre-clearance is the pivotal point in the nominee process when the 

Presidential Transition Team receives staff-level assurance from OGE 

that the nominee report is ready to be certified. OGE developed the 

pre-clearance process decades ago to ensure that ethics issues are 

resolved before a Presidential nomination is announced. This process 

protects the President in exercising the constitutional authority to 

nominate individuals to senior leadership positions in the government. 

It also protects the privacy of private citizens who may choose to 

withdraw from consideration before being nominated publicly.

While pre-clearance is not a final commitment by OGE to certify a 

nominee’s report as is, OGE will expedite efforts to work with the 

nominee to resolve any issues if the final report is later determined not 

to be ready for certification. In high profile cases or ones that raise 

unusual issues, OGE’s Director and General Counsel will be involved at 

the pre-clearance stage to prevent future delays.
As mentioned previously, Presidential nominees in the executive branch 

file public financial disclosure reports through Integrity, the executive 

branch electronic financial disclosure system. Integrity is a secure webbased system accessed through www.integrity.gov. Integrity employs 

a combination of smart data-entry tables and context-dependent 

questions to guide nominees through the complex financial disclosure 

requirements. 

Integrity is hosted in a secure government cloud and has successfully 

undergone a full, independent security assessment. It leverages the 

advanced authentication system of the Office of Management and 

Budget’s Budget Formulation and Execution Line of Business. Both 

Integrity’s authentication provider and host are authorized under GSA’s 

Federal Risk and Authorization Management Program (FedRAMP). 

In developing Integrity, OGE was aware that the Presidential Transition 

Team would need a firewall separating the outgoing President’s 

nominees from the President-elect’s nominees. For that reason, the 

current White House will be unable to access any data entered by the 

Presidential Transition Team. In fact, even OGE and the nominee’s 

agency will be unable to access that data until the Presidential Transition 

Team releases it to OGE. 

INTEGRITY, THE 

ELECTRONIC FILING 

SYSTEM

29

ESTABLISHING PROCEDURES

The Presidential Transition Team’s 

nominee program is a high stakes 

operation. An ineffective nomination 

process can cause delays in getting 

the President’s leadership team in 

place. Unresolved conflicts of interest 

can derail a nomination or ultimately 

expose Presidential appointees 

to potential criminal, civil, or 

administrative penalties for inadvertent 

violations of law. More broadly, 

these problems can spell trouble for 

a new Presidential administration. 

This section provides some relatively 

detailed information to assist in 

establishing effective procedures. The 

information in this section is intended 

primarily for Presidential Transition 

Team members who are directly 

involved in nominations. 

INVESTING IN 

THE NOMINEE 

PROCESS

33
It is important to have a government ethics expert on the Presidential 

Transition Team. In the past, transition teams have detailed senior 

ethics officials from the executive branch. If needed, OGE can either 

provide a detailee or recommend ethics officials from other agencies. 

Alternatively, you can secure the services of an expert from outside the 

government. 

In either case, this individual can coordinate with OGE, manage the 

release of nominee reports to OGE, and relay OGE’s comments on 

nominees’ drafts in connection with an initial “blind” review of reports. 

In this regard, it would help if the individual has previously used the 

electronic filing system, Integrity. 

OGE recommends that you send at least two—and preferably more— 

individuals to OGE for training on the use of Integrity. By sending 

additional individuals to OGE for training, you can ensure that you 

have consistent coverage of functions. At least one individual will need 

to serve as the Presidential Transition Team’s Integrity Administrator. 

Another individual will need to release financial disclosure reports 

to OGE through Integrity. (Due to security protocols, the Integrity

Administrator cannot release reports to OGE.) 

OBTAINING NEEDED EXPERTISE

The Presidential Transition Team’s nominee 

program is a high stakes operation.
As discussed in the previous section, nominee reports are processed 

through Integrity, the executive branch electronic filing system. Integrity 

is configured for a seamless handoff from the Presidential Transition 

Team to the new White House. In order to accomplish this handoff, the 

Presidential Transition Team needs to establish procedures that parallel 

the procedures the new White House will use after the inauguration. 

After the inauguration, the White House’s Presidential Personnel Office 

(PPO) will manage the nominee process. The White House PPO will 

collect and release a nominee’s financial disclosure report to the White 

House Counsel’s Office (WHCO). Then, WHCO will be responsible for 

releasing the nominee’s report to OGE and the nominee’s agency. 

Integrity is configured to accommodate this White House process, with 

separate user roles for PPO and WHCO. For this reason, prior to the 

inauguration the Presidential Transition Team needs to assign members 

of its staff to serve temporarily in the Integrity roles of PPO and 

WHCO.

INITIATING REPORTS IN 

INTEGRITY 

35
The nominee process prior to inauguration flows in this sequence:

Transition Team: The transition team provides the nominee with a copy 

of OGE’s Nominee Ethics Guide.

Transition Team: A transition team member assigned to the “PPO” role 

in Integrity registers the nominee in Integrity and initiates a financial 

disclosure report. Integrity automatically emails the nominee a notice 

with instructions.

Nominee: The nominee completes a draft financial disclosure report in 

Integrity and submits it to the transition team by clicking the “submit” 

button. 

Transition Team: The transition team member assigned to the “PPO” 

role in Integrity releases the report to the transition team member 

assigned to the “WHCO” role in Integrity. 

Transition Team: The transition team member assigned to the “WHCO” 

role in Integrity releases the report through Integrity to OGE and the 

nominee’s agency.

OGE/Agency/Nominee: OGE and agency ethics officials work with 

the nominee to perfect the report and prepare an ethics agreement. 

This work takes multiple rounds. OGE then “preclears” the report in 

Integrity.

Transition Team: The transition team reviews the ethics package, the 

FBI’s background investigation report, and other vetting materials. If a 

favorable decision is made, the name of the intended nominee is released 

publicly.

SEQUENCE OF THE PROCESS
The remainder of this sequence assumes that the Senate will hold a 

hearing in advance of the inauguration. The Senate will likely hold 

advance hearings for nominees to several cabinet-level positions before 

January 20, 2017. For other nominees, the following steps will occur 

when the President makes formal nominations only after having been 

sworn into office.

Agency/Nominee: The agency instructs the nominee to formally file the 

report in Integrity and to sign the ethics agreement. After the nominee 

takes these actions, the agency certifies the report and sends the ethics 

agreement to OGE.

OGE: OGE’s Director certifies the report in Integrity and then 

transmits both the report and the ethics agreement to the appropriate 

Senate committee.

Agency/Nominee: Within 5 days of the Senate hearing, the nominee 

provides the agency with a letter containing updated information about 

earned income. The agency sends copies of the letter to OGE and the 

Senate.

Senate/President: Committee staffers meet with the nominee. Then, 

the committee holds a hearing. After being sworn into office, the 

President makes the formal nomination. The Senate then votes on the 

nomination. 

President: If the Senate confirms the nominee, the President can 

appoint the nominee.

37
There are three types of positions in the executive branch for which the 

process varies slightly: 

1. Ambassadors who are career Foreign Service Officers 

2. U.S. Attorneys

3. U.S. Marshals

The Department of State traditionally initiates the process in Integrity

for Ambassadors who are career Foreign Service Officers. The 

Department of Justice traditionally initiates the process in Integrity for 

both U.S. Attorneys and U.S. Marshals. 

During the transition, both of these departments serve in the “PPO” 

role in Integrity, while the Presidential Transition Team serves only in 

the “WHCO” role in Integrity. Accordingly, the Presidential Transition 

Team will be unable to view these financial disclosure reports until the 

departments release them through Integrity. After the departments 

release these reports, the Presidential Transition Team will then release 

the reports to OGE.

VARIATIONS
39

ETHICS IN THE NEW

ADMINISTRATION

The Presidential Transition Team 

plays an essential role in setting 

the tone for the early days of the 

new administration. (The same 

will be true for the White House’s 

Presidential Personnel Office after 

the inauguration.) The message 

that ethics matters should be 

communicated right from the 

beginning of the nominee process 

and repeated throughout an 

appointee’s public service. 

SETTING THE 

TONE

43
At the heart of the executive 

branch ethics program is the 

principle that public service is a 

public trust. Government officials 

must put the public’s interests 

before their own interests.

At the heart of the executive branch ethics program is the principle 

that public service is a public trust. Government officials must put the 

public’s interests before their own interests. This bedrock principle is an 

easy one to appreciate, but the complex ethics requirements that flow 

from it are not necessarily intuitive. They represent numerous policy 

choices by Congress, Presidents, and federal agencies over the years. 

Presidential appointees will need to build a working knowledge of these 

requirements, so they can spot potential issues and seek help from their 

agency’s ethics officials when they need it. 

You can emphasize to nominees and appointees that serving as a 

federal leader comes with responsibilities. Let them know that they 

must carry out their obligations under the ethics laws and regulations, 

as well as under their individual ethics agreements. Beyond these legal 

requirements, you can charge them with building ethical organizational 

cultures to make ethics a priority in their agencies.
1

2

NOMINEE ETHICS GUIDE

ETHICS AGREEMENTS

You can distribute OGE’s Nominee Ethics Guide to 

nominees early in the process. In addition to guidance 

on the nominee process, the guide provides a valuable 

introduction to key requirements of government ethics laws 

and regulations. You can reinforce this message by directing 

nominees to read the section of the guide addressing 

substantive ethics requirements. 

Government ethics laws and regulations apply to 

Presidential appointees as soon as they begin their federal 

service. For that reason, the ethics agreements that OGE 

and agency ethics officials draft are designed to prevent 

problems from arising. A good ethics agreement is 

meaningless, however, if the appointee does not follow 

through on the commitments made in that agreement. You 

can emphasize to nominees the importance of complying 

with ethics agreements once appointed, and you can let 

them know that OGE and their agencies’ ethics offices will 

be tracking their compliance. 

The five items below describe concrete steps you can take to 

communicate this important message and get the new administration 

off to a strong ethical start.

CONCRETE STEPS

45
3

4

INITIAL ETHICS BRIEFING 

ETHICS TRAINING AND 

ONGOING FINANCIAL 

DISCLOSURE

Nominees will be well-served if you emphasize the importance of 

scheduling ethics briefings with their agency’s ethics officials. Ideally, 

every nominee should receive an ethics briefing on the first day or 

first week in government. Adopting a policy of requiring early ethics 

briefings for Presidential appointees could go a long way toward 

preventing the types of ethics issues that can embarrass a new 

Presidential administration.

You can explain to nominees that, once in their government 

positions, they will have to comply with ongoing requirements 

that include: (a) participating in new employee ethics training; 

(b) participating in annual ethics training; (c) promptly reporting 

certain financial transactions, such as stock purchases and sales; 

and (d) filing annual financial disclosure reports. It is important 

to set the tone that compliance with these requirements is an 

obligation of public service and important to ensuring public 

confidence in government decision-making.
5 ETHICAL LEADERSHIP 

You can emphasize to nominees that as senior leaders they will play 

key roles in their agency’s ethical culture. Here are a few ways you 

can suggest that they go about making ethics a priority:

• Start off on the right foot by scheduling an initial ethics briefing 

from the agency’s ethics office in the first week—or first day—in 

the job

• Comply with ethics agreements on time

• File financial disclosure reports on time

• Complete new employee and annual ethics training on time

• Continuously monitor financial interests, and remain vigilant for 

possible conflicts of interest in all official activities

• Ensure that the agency’s ethics office has the leadership support 

and the staffing resources it needs

• Invite ethics officials to present on government ethics—even 

if only for 5 minutes—at the beginning of each senior staff 

meeting

• Hold subordinates accountable for knowing and following the 

ethics rules, and take decisive action if ethics rules are violated

• Prevent retaliation against employees who report wrongdoing

• Communicate the agency’s core values and work to sustain an 

ethical culture in which employees put the interests of the public 

first

• Model the importance of ethics training by attending the 

training in person and with subordinates

47

RESOURCES
Several key resources are available to Presidential Transition Team 

members involved in the ethics component of the nominee process:

Public Financial Disclosure Guide

OGE’s online Public Financial Disclosure Guide, found under the 

“Public Financial Disclosure” section of OGE’s website, offers helpful 

instructions, illustrations of sample language, definitions, and answers 

to frequently asked questions in plain language.

Integrity User Manual

The online user manual for the executive branch electronic filing 

system, Integrity, provides useful explanations of the system’s features. 

A user name and password is required to access both Integrity and its 

user manual.

Nominee Checklists

The appendix to OGE’s Nominee Ethics Guide contains detailed 

checklists for: (1) nominees generally; (2) nominees who are attorneys; 

(3) nominees who are corporate officers, employees, or directors; 

(4) nominees who are university professors or deans; and (5) nominees 

who are investment fund managers.

KEY ONLINE RESOURCES

www.oge.gov

OGE’s official website has a wealth of resources 

that will be useful to PTT staff members.
Ethics Agreement Guide

The drafting of ethics agreements for nominees in the executive branch 

necessarily begins with the standardized language provided in OGE’s 

PAS Nominee Ethics Agreement Guide, which is available on OGE’s 

website.

Government Ethics Statutes and Regulations

PTT staff can access relevant government ethics statutes and 

regulations applicable to Presidential nominees and appointees through 

the “Laws and Regulations” section on OGE’s website.

Forms

The OGE Form 278e is available in Excel format under the “Forms” 

section on OGE’s website. A section 508-compliant version of that 

form is available in PDF format. The OGE Form 450 is also available.

Online Presidential Transition Compilations

GSA maintains the federal government’s official Presidential Transition 

Directory at https://presidentialtransition.usa.gov. 

The Partnership for Public Service has published its own helpful 

compilation at http://presidentialtransition.org.

51
Presidential Transition Team members involved in the ethics 

component of the nominee process may also find a number of OGE 

issuances helpful. OGE documents listed below can be obtained by 

entering the document number in the “search” field of OGE’s website 

at www.oge.gov. 

Temporary appointment pending nomination 

This document (Ethical Requirements Applicable to Potential PAS 

Appointees Employed as “Advisors” or “Counselors”) explains that 

potential Senate-confirmed Presidential appointees hired as advisors or 

counselors prior to confirmation are employees of the United States and 

are subject to federal ethics laws and regulations. (Search “DO-01-009”)

Videos on the transition 

OGE has posted online recordings of 3 panel sessions from its 2016 

National Government Ethics Summit on the OGE YouTube Channel:

 o Presidential Transition – OGE Director Walter M. Shaub, Jr. speaks 

with a panel of experts about experiences with Presidential transitions.

Former high-level government officials in the transition 

This document (Statutory Exception for Representation of Candidates 

and Specified Political Entities by Former Senior and Very Senior 

Employees) explains that 18 U.S.C. § 207(j)(7) provides an exception to 

the 1-year no-contact ban for former senior employees and the 2-year 

no-contact ban for very senior employees. In limited circumstances, 

these categories of former employees do not violate the statute if a 

communication or appearance is on behalf of a candidate or one of the 

specified political entities. (Search “DO-08-011”)

SOME RELEVANT OGE 

ISSUANCES

TRANSITION ISSUES
–

Panel members include Lisa Brown (former Co-Chair of Agency 

Review for the Obama-Biden Transition Project), Clay Johnson 

(former Executive Director, Bush-Cheney Transition), and Max Stier 

(President and CEO, Partnership for Public Service). 

o Transition is Coming: Preparing for Success – OGE Chief 

of Staff Shelley Finlayson speaks with a panel of transition service 

providers about the work underway to prepare for a successful 

Presidential transition. Panel members include Mary Gibert (GSA 

Director of Presidential Transition), Martha Kumar (Director of the 

White House Transition Project), Lee Lofthus (Assistant Attorney 

General for Administration, Department of Justice), Kristine 

Simmons (Vice President of Government Affairs, Partnership for 

Public Service), and Gary Stern (General Counsel, National Archives 

and Records Administration).

o Ethics Recommendations for a New Administration – OGE 

Director Walter M. Shaub, Jr. speaks with a panel of experts 

about their diverging recommendations to the next Presidential 

administration regarding government ethics. Panel members include 

Norman L. Eisen, Ambassador (Ret.) (Brookings Institution, Former 

Special Counsel to President Barack Obama), Craig Holman, Ph.D 

(Government Affairs Lobbyist, Public Citizen), Sean Moulton (Open 

Government Program Manager, Project On Government Oversight), 

Richard W. Painter, Professor (University of Minnesota School of 

Law, Reporter for the ALI Project on Government Ethics, Former 

Associate Counsel to President George W. Bush), Gregory S. Walden 

(Senior Counsel, Akin Gump Strauss Hauer & Feld LLP; Former 

Associate Counsel to President George H. W. Bush).

o Proposed Regulatory Amendments & Issues for the Transition

In this session, OGE’s General Counsel David Apol and Assistant 

Counsel Chris Swartz discuss OGE’s proposed amendments to 

Subpart B of the Standards of Conduct and consider various gift 

issues related to the transition. This session focuses on the proposed 

regulations, published at 80 FR 74004 (Nov. 27, 2015), and updates 

on the status of the regulations going forward. Mr. Apol and 

53
Reviewing financial disclosure reports 

This document (Seeking Additional Information from Nominee Filers)

discusses the need to seek additional information when a financial 

disclosure report is incomplete. (Search “DO-08-002”)

Determining when an appointee becomes subject to criminal 

conflicts of interest laws 

This document (Commencement of Officer or Employee Status for 

Purposes of Conflict of Interest Requirements) provides a link to an 

opinion issued by the Department of Justice’s Office of Legal Counsel 

concerning timing of when an individual becomes subject to the federal 

conflict of interest laws and regulations. (Search “DO-02-014”)

Mortgages 

This document (Mortgage Reporting Requirements) explains changes to 

the reporting exception for mortgages with respect to certain filers who 

are nominees to or appointees in Senate-confirmed positions. 

(Search “LA-12-02”)

FINANCIAL DISCLOSURE REQUIREMENTS

CONFLICT OF INTEREST LAWS

Mr. Swartz also discuss gifts issues that are unique to Presidential 

Transitions, such as: the extent to which employees may accept gifts 

given during the inauguration; how to analyze gifts given by members 

of the transition team; and, when the exemption at 5 C.F.R. 2635.204(f), 

for gifts permitted by the Hatch Act, is available.
Exemption for non-profit positions under 18 U.S.C. § 208 

This document (18 U.S.C. § 208(b)(2) Exemption for Official 

Participation in Nonprofit Organizations) discusses the history 

and scope of the exemption for official participation in nonprofit 

organizations at 5 C.F.R. § 2640.203(m). (Search “LA-13-05”)

Types of matters covered by 18 U.S.C. § 208

This document (“Particular Matter Involving Specific Parties,” 

“Particular Matter,” and “Matter”) provides guidance on the meaning 

of 3 terms used in the criminal conflict of interest statutes and OGE’s 

implementing regulations to describe the types of matters covered by 

18 U.S.C. § 208. (Search “DO-06-029”)

Summary of 18 U.S.C. § 209 

This document (18 U.S.C. § 209 Guidance) summarizes 18 U.S.C. § 209, 

which prohibits the supplementation of government salary by outside 

sources. (Search “DO-02-016”)

Waivers under 18 U.S.C. § 208 

This document (Waivers under 18 U.S.C. §§ 208(b)(1) and (b)(3))

provides guidance on issues that should be considered when deciding 

whether to grant a waiver under 18 U.S.C. §§ 208(b)(1) or (b)(3). 

(Search “DO-07-006”)

55
Determining whether a mutual fund is a sector fund 

o 2000 issuance: This OGE document (Diversified and Sector 

Mutual Funds) provides guidance concerning the distinction between 

diversified and sector mutual funds for purposes of certain regulatory 

exemptions under 5 C.F.R. part 2640. (Search “DO-00-030”) 

o 2015 issuance: This OGE document (Diversified and Sector Real 

Estate Funds (Exemption under 5 C.F.R. § 2640.201)) provides guidance 

as to which real estate mutual funds qualify as diversified funds and 

which qualify as sector funds for the purposes of certain regulatory 

exemptions under 5 C.F.R. part 2640. (Search “LA-15-09”)

What to do if a filer cannot disclose the underlying holdings of a 

private investment fund 

o 2008 issuance: This OGE document (Financial Disclosure 

Requirements for Pooled Investment Funds) requires divestiture in 

certain circumstances when a filer cannot disclose the underlying 

holdings of an investment fund. (Search “DO-08-022”) 

o 2014 issuance: This OGE document (Financial Disclosure 

Requirements for Pooled Investment Funds) clarifies the 2008 issuance 

by distinguishing circumstances in which divestiture is required from 

circumstances in which divestiture is not required. (Search “LA-14-05”)

INVESTMENT FUNDS

Defined benefit pension plans 

This OGE document (18 U.S.C. § 208 and Defined Benefit Pension 

Plans) updates and refines previous guidance on the circumstances in 

which an employee has a conflict of interest in matters affecting the 

sponsor of the employee’s defined benefit plan. (Search “DO-99-015”) 

PENSION PLANS
Financial disclosure issues involving trustees and estate executors 

This OGE document (Financial Disclosure Issues Concerning Trustees, 

Executors, and Administrators) provides guidance on reporting trusts 

and estates when an employee is serving as a trustee or executor. 

(Search “DO-02-008”) 

Applicability of the conflicts of interest law to trustees

This OGE document (Office of Legal Counsel (OLC) Opinion 

Concerning Status of Trustees of a Private Trust under 18 U.S.C. § 

provides a link to an opinion issued by the Department of Justice’s 

Office of Legal Counsel concerning the application of 18 U.S.C. § 208 

to individuals serving as trustees of private trusts. 

(Search “DO-01-029”)

Revocable living trusts 

This OGE document (Revocable Living Trusts) explains OGE’s 

approach to revocable living trusts for purposes of both 18 U.S.C. § 208 

and financial disclosure. (Search “DO-02-015”)

Discretionary trusts (sprinkling trusts)

o 2008 issuance: This OGE document (Discretionary Trusts)

explains OGE’s approach to certain interests in discretionary trusts for 

purposes of both 18 U.S.C. § 208 and financial disclosure. 

(Search “DO-08-024”)

o 2013 issuance: This OGE document (Reporting Requirements for 

Discretionary Trusts) modifies the analysis previously announced in the 

2008 issuance regarding financial disclosure requirements for certain 

interests in discretionary trusts. (Search “LA-13-04”)

TRUSTS & TRUSTEES, ESTATES & EXECUTORS

208)

57
Contingency Fees

This OGE document (Contingency Fees and 18 U.S.C. § 203) discusses 

the implications of 18 U.S.C. § 203 for a prospective government 

employee, such as an attorney or other representative, who has an 

interest in a pending contingency fee case. (Search “DO-99-042”)

Compensation in matters affecting the government 

This OGE document (Clarification of Interpretation of 18 U.S.C. § 203) 

explains that 18 U.S.C. § 203 is applicable only in situations involving 

compensation in exchange for the provision of representational services 

to a third party, rendered either by the employee or another. 

(Search “DO-99-049”) 

Confidential clients 

This OGE document (Scope of Public Financial Disclosure Reporting 

Exception for Compensation from an Individual with Whom the Filer is 

in a Privileged Relationship) clarifies that the scope of the nondisclosure 

exception for confidential clients is narrowly construed. Attorneys 

generally must disclose clients. (Search “DO-06-011”; also refer to 

the section on confidential clients in OGE’s online Public Financial 

Disclosure Guide) 

ATTORNEYS & OTHER REPRESENTATIVES

Summary 

This OGE document (Summary of Ethical Requirements Applicable 

to Special Government Employees) summarizes the government ethics 

requirements applicable to special government employees. 

(Search “00x1”) 

SPECIAL GOVERNMENT EMPLOYEES (SGE)
Requirements for book deals 

This OGE document (Book Deals Involving Government Employees)

discusses the ethics rules that pertain to book deals involving 

government employees. (Search “DO-08-006”)

Financial disclosure 

This OGE document (Financial Disclosure Reporting Requirements for 

Special Government Employees) explains the financial disclosure filing 

criteria for special government employees and uses scenarios to illustrate 

how the criteria should be implemented. (Search “DO-03-021”; also 

refer to the section on special government employees in OGE’s online 

Public Financial Disclosure Guide)

60-Day Thresholds

This OGE document (60-Day Thresholds for SGEs) explains that a 

special government employee is always prohibited from representing 

others in connection with particular matters involving specific parties in 

which the SGE has participated personally and substantially. The 60-day 

standard is a threshold for the stricter prohibition in relation to matters 

pending at the employee’s agency in which the SGE has not participated 

personally and substantially. (Search “03x7”)

Day counting 

This OGE document (Opinion of Office of Legal Counsel on SGE 

Day-Counting) discusses an opinion from the Department of Justice’s 

Office of Legal Counsel regarding the counting of days of service for 

special government employees. (Search “07x3”)

BOOK DEALS

59
Summary 

This OGE document (Certificate of Divestiture Reference Guide) 

discusses requirements for requesting Certificates of Divestiture. This 

issuance is intended to be shared with nominees and employees who are 

considering requesting Certificates of Divestiture. (Search “PA-16-04”)

Procedures

This OGE document (Procedures for Requesting a Certificate of 

Divestiture) outlines the information and documents that an agency 

must include in a request for a Certificate of Divestiture. 

(Search “DO-06-030”)

Format of request 

This OGE document (Suggested Format for Requesting a Certificate 

of Divestiture) provides a suggested format for agencies to use when 

requesting Certificates of Divestiture. This format is intended to be 

used only by agency ethics officials. (Search “DO-07-035”)

CERTIFICATES OF DIVESTITURE 
OGE documents can be obtained 

by entering the document number 

in the “search” field of OGE’s 

website at www.oge.gov.

61
The official source for identifying political positions in the executive 

branch is the publication titled, “United States Government Policy and 

Supporting Positions.” This publication, commonly known as the Plum 

Book, is published alternately by the Senate and the House committees 

after each Presidential election. An online version of the 2012 Plum 

Book is available at https://m.gpo.gov/plumbook. 

As explained earlier in this guide, however, the Presidential Transition 

Team will need to begin identifying possible nominees well before the 

election. To assist you in this process, OGE has compiled an unofficial 

Excel workbook listing the civilian Presidentially appointed, Senateconfirmed (PAS) positions traditionally subject to OGE’s review in the 

nomination process. OGE can provide this Excel workbook to you 

upon request. The workbook contains a separate table for each of the 

four categories of civilian PAS nominees described below.

The first table lists PAS positions that are: 

(a) Not subject to term limitations,

(b) Not in the uniformed services, and

(c) Not special government employee positions.

The second table lists PAS positions that are:

(a) Term appointments (e.g., 5 years, 14 years, etc.),

(b) Not in the uniformed services, and

(c) Not special government employee positions.

PAS POSITION SPREADSHEETS

REGULAR PAS POSITIONS

TERM REGULAR PAS POSITIONS

1

2
Appointees in term regular PAS positions carry over from one 

Presidential administration to the next, expiring at the end of a term 

of years. The expiration of a term can, depending on the position 

or the status of the individual in the position, have three different 

consequences:

(a) Carry-over appointment – In some cases the agency’s organic 

statute provides for a carry-over period of a specified length. For 

example, the Special Counsel who leads the Office of Special Counsel 

can continue to serve in that position for up to one year after expiration 

of the term.

(b) Option to appoint to acting status (career Senior Executive 

Service members) – In rare cases, the agency’s organic statute does 

not provide a carry-over period, but the individual in the position 

happens to be a career federal employee. If that career federal employee 

served in the Senior Executive Service, the law requires the Office 

of Personnel Management to place the individual in a career position 

upon expiration of the term. In such cases, the Presidential Personnel 

Office can designate that individual to serve in an acting capacity in 

the PAS position for a period of time until the President reappoints 

that individual or appoints another individual to the PAS position. The 

Vacancies Reform Act of 1998 imposes limits on the length of time an 

individual can serve in an acting capacity.

(c) Termination – In some cases, the agency’s organic statute does 

not provide a carry-over period. If the individual in the position is 

not a career federal employee and does not have placement rights, the 

individual’s government service ceases at the end of the term.

To assist the Presidential Transition Team with its planning, OGE has 

attempted in the term regular PAS table to identify the date on which 

the individual currently in the position was confirmed. The following 

limitations apply to the information provided:

(a) Overtaken by events – If the individual was reappointed or a new 

individual was appointed after the date of publication of this guide, the 

information may be out of date.

63
The third table lists PAS positions in which appointees are special 

government employees. The following criteria apply to these positions:

(a) At the time of appointment, (i) the agency anticipates that the 

appointee will serve in the position for not more than 130 days during 

any period of 365 consecutive days or (ii) the position is specifically 

designated by statute as a special government employee position; and

(b) The position is not in the uniformed services.

Nominees for these positions are subject to varying financial 

disclosure requirements:

(a) The Ethics in Government Act excludes from public financial 

disclosure requirements individuals who serve in their government 

positions for 60 days or less in a calendar year. Most PAS-level special 

government employees serve for 60 days or less each year. 

SPECIAL GOVERNMENT EMPLOYEE PAS 

POSITIONS

3

(b) Appointment date unknown – We have provided the 

confirmation date because that date is readily available in many 

instances. The individual’s term runs, however, from the date 

of appointment, not the date of confirmation. Therefore, when 

calculating the expiration of the term, you should be aware that 

using the confirmation date will provide only an approximate 

expiration date.

(c) Staggered terms – In the case of some boards and 

commissions terms are staggered. If an individual resigns before 

the end of a staggered term, another individual may be appointed 

to serve out the end of that staggered term. In such cases, it is not 

possible to determine when the individual’s term ends based on the 

length of the term, the confirmation date, or the appointment date. 

It is also necessary to know the timing of the specific staggered 

term the individual is serving. To obtain this information, you will 

need to contact officials at the board or commission.
The fourth table lists PAS positions in which appointees are not 

employees of the federal government. Nominees for Non-Federal 

PAS positions file confidential financial disclosure reports, using the 

OGE Form 450.

As a result, nominees for many of these positions are not required 

to file public financial disclosure reports. By regulation, they are 

required to file confidential financial disclosure reports (OGE Form 

450). These financial disclosure reports are not available to the 

public.

(b) The Senate Foreign Relations Committee has determined that 

it would like to receive more information than the OGE Form 

450 collects. For this reason, the committee requires nominees 

to complete the same form that OGE uses for public financial 

disclosure reports, the OGE Form 278e. Although these SGE 

nominees must complete the OGE Form 278e, their reports remain 

confidential and are not available to the public. 

(c) In rare cases, nominees for PAS-level special government 

employee positions may typically serve in their positions for more 

than 60 days in a calendar year. The Ethics in Government Act 

requires them to complete public financial disclosure reports (OGE 

Form 278e). Their financial disclosure reports are available to the 

public upon request.

(d) There is an additional variation in the case of nominees to 

the Internal Revenue Service Oversight Board. The board’s organic 

statute expressly requires members and nominees to file public 

financial disclosure reports, even though they normally serve for 60 

days or less in a calendar year. Their financial disclosure reports are 

available to the public upon request.

4 NON-FEDERAL PAS POSITIONS

65
OGE CONTACT INFORMATION

KEY POINTS OF CONTACT FOR NOMINEE 

FINANCIAL DISCLOSURE

1

Director Walter M. Shaub, Jr.

202.482.9292 walter.shaub@oge.gov

General Counsel David J. Apol

202.482.9205 david.apol@oge.gov

Chief, Presidential Nominations 

Branch (PNB)

Deborah J. Bortot

202.482.9227 deborah.bortot@oge.gov

Senior Counsel for Financial 

Disclosure

Heather A. Jones

202.482.9316 heather.jones@oge.gov

Chief, Ethics Law & Policy 

Branch (ELPB)

Seth H. Jaffe

202.482.9303 seth.jaffe@oge.gov

Nominee Coordinator, Presidential 

Nominations Branch

Teresa L. Williamson

202.482.9283 teresa.williamson@oge.gov

Integrity Program Manager George L. Hancock

202.482. 9309 george.hancock@oge.gov

Integrity Help Desk integrity@oge.gov
The preferred method for transmitting documents to OGE 

electronically is by scanned attachment via email. If you need 

to send documents by fax, however, you may use the following 

fax number: 202.482.9237. Please note that the fax machine is in a 

common area in OGE’s office suite and is accessible to all members 

of OGE’s staff.

A current staff directory is available on OGE’s website at 

www.oge.gov. To access the directory, click on the “ABOUT” tab at 

the top of the home page, then click on “Contact Us.”

U.S. Office of Government Ethics

1201 New York Avenue, NW, Suite 500

Washington, DC 20005-3917

STREET ADDRESS AND FAX NUMBER

STAFF DIRECTORY 

2

3

67
The following list provides contact information for all OGE staff 

available to support OGE’s Presidential nominee review team as 

needed. All phone numbers are in the 202 area code.

CONTACT INFORMATION FOR NOMINEE 

TEAM 

4

Apol, David 482-9205 david.apol@oge.gov

Ashar, Monica 482-9282 monica.ashar@oge.gov

Bortot, Deborah 482-9227 deborah.bortot@oge.gov

Bunderson, Brandon 482-9307 brandon.bunderson@oge.gov

Chapman, Doug 482-9222 doug.chapman@oge.gov

Corbally, Steven 482-9253 steven.corbally@oge.gov

Dowell, Rachel 482-9267 rachel.dowell@oge.gov

Francis, Leigh 482-9313 leigh.francis@oge.gov

Guzman, Ciara 482-9241 ciara.guzman@oge.gov

Horton, Elizabeth 482-9211 elizabeth.horton@oge.gov

Jaffe, Seth 482-9303 seth.jaffe@oge.gov

Jones, Heather 482-9316 heather.jones@oge.gov

Kane-Piasecki, Cheryl 482-9252 cheryl.kane-piasecki@oge.gov

Kaplan, Kimberly 482-9269 kimberly.kaplan@oge.gov

Khaner, Megan 482-9204 megan.khaner@oge.gov

Labedz, Keith 482-9218 keith.labedz@oge.gov

Lightfoot, Patrick 482-9271 patrick.lightfoot@oge.gov

Mabry, Sandra 482-9258 sandra.mabry@oge.gov

MacDonald, Jack 482-9310 jack.macdonald@oge.gov
Marinec, Matthew 482-9286 matthew.marinec@oge.gov

Mathai, Jaideep 482-9308 jaideep.mathai@oge.gov

Matis, Jennifer 482-9216 jennifer.matis@oge.gov

Meyers, David 482-9263 david.meyers@oge.gov

Newton, Elaine 482-9265 newton.elaine@oge.gov

Nonluecha, Stephanie 482-9243 stephanie.nonluecha@oge.gov

Pond, Wendy 482-9285 wendy.pond@oge.gov

Robertson, James 482-9268 james.robertson@oge.gov

Rounds, Emory 482-9232 emory.rounds@oge.gov

Salamone, Vincent 482-9274 vincent.salamone@oge.gov

Shaub, Walter 482-9292 walter.shaub@oge.gov

Shepherd, Patrick 482-9206 patrick.shepherd@oge.gov

Sikora Panza, Kimberly 482-9214 kimberly.sikorapanza@oge.gov

Skalla, Daniel 482-9222 daniel.skalla@oge.gov

Stein, Nicole 482-9255 nicole.stein@oge.gov

Swartz, Chris 482-9266 christopher.swartz@oge.gov

Syme, Lorna 482-9277 lorna.syme@oge.gov

Veilleux, Diana 482-9203 diana.veilleux@oge.gov

Williamson, Teresa 482-9283 teresa.williamson@oge.gov

69
NOTES

NOTES


Walter M. Shaub, Jr.

Director

202.482.9292

walter.shaub@oge.gov

Shelley K. Finlayson

Chief of Staff

202.482.9314

shelley.finlayson@oge.gov

David J. Apol

General Counsel

202.482.9205

david.apol@oge.gov

Deborah J. Bortot, Chief

Presidential Nominations Branch

202.482.9227

deborah.bortot@oge.gov

Heather A. Jones

Sr. Associate Counsel for Nominees

202.482.9316

heather.jones@oge.gov

Seth H. Jaffe, Chief

Ethics Law & Policy Branch

202.482.9302

seth.jaffe@oge.gov

1201 New York Avenue, NW, Suite 500

Washington, DC 20005

WWW.OGE.GOV