Public Financial Disclosure Guide

Print Version

May 2018
Public Financial Disclosure Guide, Table of Contents 2

Version: 5/2018

Table of Contents

Table of Contents...................................................................................................................... 2

Welcome ................................................................................................................................. 10

OGE Form 278e: Overview.................................................................................................... 11

OGE Form 278e: Cover Page ................................................................................................. 14

OGE Form 278e: Part 1 .......................................................................................................... 16

OGE Form 278e: Part 2 .......................................................................................................... 18

Introduction......................................................................................................................... 18

Award or Prize .................................................................................................................... 20

Bonus (cash)........................................................................................................................ 21

Carried Interest.................................................................................................................... 22

Cash Balance Pension Plan................................................................................................. 23

Contingency Fee ................................................................................................................. 24

Deferred Compensation ...................................................................................................... 25

Defined Benefit Plan........................................................................................................... 30

Defined Contribution Plan .................................................................................................. 32

Director Fee ........................................................................................................................ 33

Employee Stock Ownership Plan........................................................................................ 34

Employee Stock Purchase Plan........................................................................................... 35

Executor or Administrator Fee............................................................................................ 36

Farm (operated as a business)............................................................................................. 37

Gambling Winnings............................................................................................................ 38

Government Benefit or Payment ........................................................................................ 39

Honorarium......................................................................................................................... 40

Intellectual Property............................................................................................................ 41

Investment Fund (general).................................................................................................. 43

IRA, Roth IRA, SEP IRA, or Keogh Plan .......................................................................... 46

Law Firm (partnership)....................................................................................................... 47

Legal Practice (solo practice).............................................................................................. 49

Life insurance (split-dollar) ................................................................................................ 50

Money Purchase Pension Plan............................................................................................ 52

Option (incentive stock option plan)................................................................................... 53

Phantom Stock .................................................................................................................... 55

Restricted Stock .................................................................................................................. 56

Restricted Stock Unit (RSU)............................................................................................... 57

Salary .................................................................................................................................. 58

Self-Funded Defined Benefit Plan...................................................................................... 59

Severance Payment (cash) .................................................................................................. 61

Small Business (general)..................................................................................................... 62

Stable Value Fund............................................................................................................... 64

Stock ................................................................................................................................... 65

Stock Appreciation Right.................................................................................................... 66

Third-Party Escrow Agreement .......................................................................................... 67

TIAA-CREF........................................................................................................................ 68

Trustee Fee.......................................................................................................................... 69
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OGE Form 278e: Part 3 .......................................................................................................... 70

Introduction......................................................................................................................... 70

Bonus (anticipated cash payment) ...................................................................................... 71

Carried Interest.................................................................................................................... 72

Cash Balance Pension Plan................................................................................................. 73

Contingency Fee ................................................................................................................. 74

Deferred Compensation ...................................................................................................... 75

Defined Benefit Plan........................................................................................................... 76

Defined Contribution Plan .................................................................................................. 77

Employee Stock Ownership Plan........................................................................................ 78

Employee Stock Purchase Plan........................................................................................... 79

Future Employment Arrangement ...................................................................................... 80

Law Firm (partnership)....................................................................................................... 81

Leave of Absence................................................................................................................ 82

Legal Practice (solo practice).............................................................................................. 83

Phantom Stock Plan ............................................................................................................ 84

Post-Employment Executive Benefits ................................................................................ 85

Restricted Stock Plan .......................................................................................................... 86

Restricted Stock Unit Plan.................................................................................................. 87

Severance (anticipated cash payment)................................................................................ 88

Split-Dollar Life Insurance Arrangement ........................................................................... 89

Stock Appreciation Right Plan............................................................................................ 90

Stock Option Plan ............................................................................................................... 91

Third-Party Escrow Agreement .......................................................................................... 92

TIAA-CREF (held through retirement plan) ...................................................................... 93

OGE Form 278e: Part 4 .......................................................................................................... 94

OGE Form 278e: Part 5 .......................................................................................................... 96

Introduction......................................................................................................................... 96

Bonus (cash)........................................................................................................................ 98

Carried Interest.................................................................................................................... 99

Cash Balance Pension Plan............................................................................................... 100

Deferred Compensation .................................................................................................... 101

Defined Benefit Plan......................................................................................................... 105

Defined Contribution Plan ................................................................................................ 106

Director Fee ...................................................................................................................... 107

Employee Stock Ownership Plan...................................................................................... 108

Employee Stock Purchase Plan......................................................................................... 109

Executor or Administrator Fee.......................................................................................... 110

Farm (operated as a business)........................................................................................... 111

Government Benefit or Payment ...................................................................................... 112

Honorarium....................................................................................................................... 113

Intellectual Property.......................................................................................................... 114

Investment Fund (general)................................................................................................ 115

IRA, Roth IRA, SEP IRA, or Keogh Plan ........................................................................ 118

Law Firm (partnership)..................................................................................................... 119

Legal Practice (solo practice)............................................................................................ 121
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Life insurance (split-dollar) .............................................................................................. 122

Money Purchase Pension Plan.......................................................................................... 124

Option (incentive stock option plan)................................................................................. 125

Phantom Stock .................................................................................................................. 127

Restricted Stock ................................................................................................................ 128

Restricted Stock Unit (RSU)............................................................................................. 129

Salary ................................................................................................................................ 130

Self-Funded Defined Benefit Plan.................................................................................... 131

Severance Payment (cash) ................................................................................................ 133

Small Business (general)................................................................................................... 134

Stable Value Fund............................................................................................................. 136

Stock ................................................................................................................................. 137

Stock Appreciation Right.................................................................................................. 138

Third-Party Escrow Agreement ........................................................................................ 139

TIAA-CREF...................................................................................................................... 140

Trustee Fee........................................................................................................................ 141

OGE Form 278e: Part 6 ........................................................................................................ 142

Introduction....................................................................................................................... 142

American Depositary Receipt........................................................................................... 144

Annuity (fixed).................................................................................................................. 145

Annuity (variable)............................................................................................................. 146

Bond (corporate)............................................................................................................... 148

Bond (municipal) .............................................................................................................. 149

Brokerage Account ........................................................................................................... 150

Cash Account.................................................................................................................... 151

Collectible Item................................................................................................................. 152

College Savings Plan (529 plan)....................................................................................... 153

Common Trust Fund of a Bank ........................................................................................ 154

Equity Index-Linked Note ................................................................................................ 155

Exchange-Traded Fund..................................................................................................... 156

Farm (or farmland)............................................................................................................ 157

Foreign Exchange Position (“forex”)................................................................................ 159

Futures Contract (“future”)............................................................................................... 160

Government Agency or GSE Security.............................................................................. 161

Investment Fund (general)................................................................................................ 162

Life Insurance (term) ........................................................................................................ 164

Life Insurance (variable)................................................................................................... 165

Life insurance (whole or universal).................................................................................. 167

Loan Made to Another Party............................................................................................. 168

Managed Account ............................................................................................................. 169

Money Market Fund ......................................................................................................... 170

Mutual Fund...................................................................................................................... 171

Oil, Gas, or Other Mineral Rights Lease .......................................................................... 172

Option (put or call purchased) .......................................................................................... 173

Option (put or call written) ............................................................................................... 176

Precious Metal .................................................................................................................. 178
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Prepaid Tuition Plan (529 plan)........................................................................................ 179

Real Estate ........................................................................................................................ 180

Real Estate Holding Company (including REITs)............................................................ 182

Short Sale.......................................................................................................................... 185

Stock ................................................................................................................................. 187

Treasury Security.............................................................................................................. 188

Trust (irrevocable) ............................................................................................................ 189

Trust (revocable living)..................................................................................................... 192

UGMA or UTMA Account............................................................................................... 193

Unit Investment Trust ....................................................................................................... 194

Will or Estate .................................................................................................................... 195

OGE Form 278e: Part 7 ........................................................................................................ 197

OGE Form 278e: Part 8 ........................................................................................................ 199

OGE Form 278e: Part 9 ........................................................................................................ 202

OGE Form 278-T.................................................................................................................. 204

For Ethics Officials............................................................................................................... 205

1.01: Officials Required to File ........................................................................................ 205

1.02: Types of Reports and Filing Deadlines.................................................................... 212

1.03: Forms and Methods of Filing................................................................................... 214

1.04: Extensions................................................................................................................ 216

1.05: Late Filing Fees ....................................................................................................... 218

1.06: Failure to File and Falsification Penalties................................................................ 220

1.07: Written Procedures .................................................................................................. 221

2:01: Reporting Periods .................................................................................................... 223

2.02: Spouses and Dependent Children ............................................................................ 225

2.03: Cover Page of the OGE Form 278e ......................................................................... 227

2.04: OGE Form 278e, Part 1 ........................................................................................... 229

2.05: OGE Form 278e, Part 2 ........................................................................................... 231

2.06: OGE Form 278e, Part 3 ........................................................................................... 233

2.07: OGE Form 278e, Part 4 ........................................................................................... 235

2.08: OGE Form 278e, Part 5 ........................................................................................... 237

2.09: OGE Form 278e, Part 6 ........................................................................................... 238

2.10: OGE Form 278e, Part 7 ........................................................................................... 239

2.11: OGE Form 278e, Part 8 ........................................................................................... 241

2.12: OGE Form 278e, Part 9 ........................................................................................... 243

2.13: Differences between OGE Form 278e and OGE Form 278 .................................... 245

3.01: Cover Page of the OGE Form 278-T....................................................................... 246

3.02: Reporting Periodic Transactions.............................................................................. 247

4.01: Certification Requirements...................................................................................... 249

4.02: Review Timeframes................................................................................................. 251

4.03: Tools of Review....................................................................................................... 252

4.04: When to Obtain Additional Information.................................................................. 253

4.05: Report Amendments and Annotations..................................................................... 256

4.06: Supporting Notes ..................................................................................................... 258

4.07: Public Availability of Reports ................................................................................. 259

4.08: Records Management .............................................................................................. 262
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4.09: Forwarding Reports to OGE.................................................................................... 263

Appendix A: Definitions and Other Information.................................................................. 265

American Depositary Receipt........................................................................................... 265

Annuity (fixed).................................................................................................................. 265

Annuity (variable)............................................................................................................. 265

Asset: Definition ............................................................................................................... 265

Asset Related to Employment or Retirement: Examples.................................................. 266

Asset: Valuation................................................................................................................ 266

Boat Loan.......................................................................................................................... 267

Bond (corporate)............................................................................................................... 267

Bond (municipal) .............................................................................................................. 267

Brokerage Account ........................................................................................................... 267

Business Assets and Liabilities......................................................................................... 268

Capital Call ....................................................................................................................... 268

Carried Interest.................................................................................................................. 268

Cash Balance Pension Plan............................................................................................... 269

Collectible Item................................................................................................................. 269

Common Trust Fund of a Bank ........................................................................................ 269

Confidential Clients.......................................................................................................... 269

Contingency Fee ............................................................................................................... 270

Co-Signed Loan ................................................................................................................ 270

Credit Card Debt............................................................................................................... 270

Defined Benefit Plan......................................................................................................... 271

Defined Contribution Plan ................................................................................................ 271

Designated Agency Ethics Official and Alternate Designated Agency Ethics Official ... 271

Employee Stock Ownership Plan...................................................................................... 272

Employee Stock Purchase Plan......................................................................................... 272

Equity Index-Linked Note ................................................................................................ 272

Excepted Investment Fund................................................................................................ 273

Excepted Trust: Definition................................................................................................ 274

Excepted Trust: How to Report ........................................................................................ 274

Exchange........................................................................................................................... 274

Exchange-Traded Fund..................................................................................................... 275

Foreign Exchange Position (“forex”)................................................................................ 275

Futures Contract................................................................................................................ 276

Gambling Winnings.......................................................................................................... 276

General Guidance: OGE Form 278e, Part 2 ..................................................................... 276

General Guidance: OGE Form 278e, Part 3 ..................................................................... 278

General Guidance: OGE Form 278e, Part 5 ..................................................................... 279

General Guidance: OGE Form 278e, Part 6 ..................................................................... 280

General Guidance: OGE Form 278-T............................................................................... 282

Gifts: Waiver for Personal Gifts....................................................................................... 284

Gifts and Travel Reimbursements: Aggregation .............................................................. 285

Government Agency or GSE Security (“agency security”).............................................. 286

Honorarium....................................................................................................................... 286

Income: Measurement....................................................................................................... 286
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Income: Types................................................................................................................... 287

Intellectual Property.......................................................................................................... 288

Investment Fund: Employment with a Company that Manages the Fund........................ 288

Investment Fund: Spouse’s Employment with the Company that Manages the Fund ..... 289

IRA, Roth IRA, SEP IRA, or Keogh Plan ........................................................................ 289

Leave of Absence.............................................................................................................. 290

Life Insurance (split-dollar).............................................................................................. 290

Life Insurance (term) ........................................................................................................ 290

Life Insurance (variable)................................................................................................... 290

Life Insurance (whole or universal).................................................................................. 291

Line of Credit (exercised)................................................................................................. 291

Managed Account ............................................................................................................. 291

Margin Account ................................................................................................................ 292

Money Market Fund (or money market mutual fund)...................................................... 292

Money Purchase Pension Plan.......................................................................................... 292

Mortgage ........................................................................................................................... 293

Mutual Fund...................................................................................................................... 293

Officers and Employees Subject to Public Financial Disclosure (“covered position”).... 293

Option (incentive stock option plan)................................................................................. 294

Option (put or call purchased) .......................................................................................... 294

Option (put or call written) ............................................................................................... 295

Personal Residence ........................................................................................................... 295

Phantom Stock .................................................................................................................. 295

Qualified Trust.................................................................................................................. 296

Qualified Tuition Program................................................................................................ 297

Real Estate Holding Company.......................................................................................... 297

Relative ............................................................................................................................. 297

Reporting Due Dates: OGE Form 278-T.......................................................................... 298

Reporting Periods: Annual Report.................................................................................... 299

Reporting Periods: Candidate Report ............................................................................... 300

Reporting Periods: New Entrant Report ........................................................................... 301

Reporting Periods: Nominee Report................................................................................. 302

Reporting Periods: Termination Report............................................................................ 303

Reporting Periods by Part: Part 1...................................................................................... 303

Reporting Periods by Part: Parts 2, 5, and 6 ..................................................................... 304

Reporting Periods by Part: Part 3...................................................................................... 304

Reporting Periods by Part: Part 7...................................................................................... 305

Reporting Periods by Part: Part 8...................................................................................... 305

Reporting Periods by Part: Part 9...................................................................................... 306

Restricted Stock ................................................................................................................ 306

Restricted Stock Unit (RSU)............................................................................................. 306

Schedule C Employee ....................................................................................................... 307

Securities........................................................................................................................... 307

Self-Funded Defined Benefit Plan (pension).................................................................... 307

Severance Payment ........................................................................................................... 307

Short Sale.......................................................................................................................... 308
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Special Government Employee (SGE) ............................................................................. 308

Stable Value Fund............................................................................................................. 308

Stock ................................................................................................................................. 309

Stock Appreciation Right.................................................................................................. 309

Student Loan ..................................................................................................................... 309

Sweep Account ................................................................................................................. 310

Third-Party Escrow Agreement ........................................................................................ 310

TIAA-CREF: Definition ................................................................................................... 310

TIAA-CREF: How to Report a CREF Account or TIAA Real Estate ............................. 310

TIAA-CREF: How to Report TIAA Traditional .............................................................. 311

Trust (irrevocable) ............................................................................................................ 311

Trust (revocable living)..................................................................................................... 311

UGMA or UTMA Account............................................................................................... 312

Unit Investment Trust ....................................................................................................... 312

Vested Beneficial Interest................................................................................................. 312

Appendix B: Frequently Asked Questions ........................................................................... 313

FAQs: Annuity (fixed)...................................................................................................... 313

FAQs: Award or Prize ...................................................................................................... 313

FAQs: Bond (corporate) ................................................................................................... 313

FAQs: Bond (municipal)................................................................................................... 314

FAQs: Bonus..................................................................................................................... 315

FAQs: Brokerage Account................................................................................................ 315

FAQs: Cash Account ........................................................................................................ 315

FAQs: Collectible Item..................................................................................................... 316

FAQs: Contingency Fee.................................................................................................... 317

FAQs: Deferred Compensation......................................................................................... 317

FAQs: Defined Benefit Plan (including cash balance pension plan)................................ 317

FAQs: Defined Contribution Plan (including a money purchase pension plan) .............. 318

FAQs: Director Fee........................................................................................................... 318

FAQs: Employee Stock Purchase Plan............................................................................. 320

FAQs: Exchange-Traded Fund (ETF) .............................................................................. 320

FAQs: Farm (or farmland)................................................................................................ 320

FAQs: Foreign Exchange Position (“forex”).................................................................... 321

FAQs: Futures Contract .................................................................................................... 322

FAQs: Future Employment Arrangement......................................................................... 323

FAQs: Gambling Winnings .............................................................................................. 323

FAQs: Gifts and Travel Reimbursements......................................................................... 323

FAQs: Honorarium ........................................................................................................... 326

FAQs: Intellectual Property .............................................................................................. 328

FAQs: Investment Fund (general) .................................................................................... 328

FAQs: Law Firm (partnership) ......................................................................................... 330

FAQs: Leave of Absence .................................................................................................. 330

FAQs: Liabilities............................................................................................................... 332

FAQs: Life Insurance (variable)....................................................................................... 334

FAQs: Life Insurance (whole or universal) ...................................................................... 334

FAQs: Loan Made to Another Party................................................................................. 335
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FAQs: Managed Account ................................................................................................. 335

FAQs: Money Market Fund.............................................................................................. 337

FAQs: Mutual Fund .......................................................................................................... 337

FAQs: OGE Form 278-T .................................................................................................. 337

FAQs: Oil, Gas, or Other Mineral Rights Lease............................................................... 338

FAQs: Option (incentive stock option plan)..................................................................... 338

FAQs: Option (put or call purchased)............................................................................... 339

FAQs: Option (put or call written).................................................................................... 339

FAQs: Positions Held Outside U.S. Government............................................................. 340

FAQs: Precious Metal....................................................................................................... 341

FAQs: Real Estate............................................................................................................. 342

FAQs: Real Estate Holding Company .............................................................................. 343

FAQs: Restricted Stock..................................................................................................... 343

FAQs: Restricted Stock Unit (RSU)................................................................................. 343

FAQs: Salary..................................................................................................................... 344

FAQs: Severance Payment ............................................................................................... 345

FAQs: Short Sale .............................................................................................................. 345

FAQs: Sources of Compensation...................................................................................... 346

FAQs: Stock...................................................................................................................... 346

FAQs: Stock Appreciation Right...................................................................................... 347

FAQs: Third-Party Escrow Agreement ............................................................................ 347

FAQs: Transactions .......................................................................................................... 348

FAQs: Treasury Security .................................................................................................. 350

FAQs: Trust (irrevocable)................................................................................................. 351

FAQs: Trust (revocable living)......................................................................................... 352

FAQs: UGMA or UTMA Account................................................................................... 353

FAQs: Unit Investment Trust (UIT) ................................................................................. 353

FAQs: Will or Estate......................................................................................................... 354

Appendix C: Differences between the July 2016 and May 2018 Print Versions ................. 355
Public Financial Disclosure Guide, Welcome 10

Version: 5/2018

Welcome

Welcome to the print version of the Public Financial Disclosure Guide, a web-based set of 

instructions for completing and reviewing the Executive Branch Personnel Public Financial 

Disclosure Report (OGE Form 278e) and the supplemental Periodic Transaction Report 

(OGE Form 278-T).

Transparency is a critical part of government ethics, and Congress has determined that the 

citizens should know their leaders’ financial interests. To facilitate such transparency, 

Congress enacted the financial disclosure provisions of the Ethics in Government Act. The 

Act imposes detailed requirements for public financial disclosure by senior United States 

Government officials. The OGE Form 278e and the OGE Form 278-T are financial 

disclosure reports that request only as much information as the Act requires a filer to 

disclose.

To assist you with completing or reviewing a report, the Public Financial Disclosure Guide 

offers helpful instructions, illustrations of sample language, definitions, and answers to 

frequently asked questions in plain language. We have attempted to keep our instructions 

clear and concise without compromising detail and accuracy.

Feedback

This guide is an evolving document, which we plan to update over time. We encourage 

feedback and invite you to send your comments, suggestions, corrections, or submissions to 

contactOGE@oge.gov.

Additional Questions

If you are a filer and have additional financial disclosure questions that are not answered in 

this guide, please contact an ethics official at your agency. If you are an agency ethics 

official, please direct additional financial disclosure questions to your desk officer.

Disclaimer

Do not rely on statements in this guide for investment advice. This guide is a training tool 

for federal executive branch financial disclosure. This guide supersedes earlier OGE training 

publications, but applicable statutes and regulations are the final authorities.

In addition, although the use of the sample language provided in this guide promotes a degree 

of consistency in reporting common items, OGE recognizes that there may be other ways of 

reporting particular interests.
Public Financial Disclosure Guide, OGE Form 278e: Overview 11

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OGE Form 278e: Overview

Do I Need to File an OGE Form 278e?

You would file an OGE Form 278e if you are required to complete any of the following 

types of executive branch public financial disclosure reports:

• Candidate Report: Required if you are a candidate for nomination or election to 

the office of President or Vice President.

• Nominee Report: Required if you are a Presidential nominee to a position 

requiring the advice and consent of the Senate (PAS), other than an individual 

nominated for judicial office or an individual nominated as a Foreign Service 

Officer or as an officer of the uniformed services.

• New Entrant Report: Required if you assumed the duties of a position for which 

public financial disclosure is required (“covered position”), unless your agency 

expects you to serve no more than 60 days in any calendar year or unless you are 

moving from one covered position to another without a break in service of more 

than 30 days.

• Annual Report (also called an “Incumbent Report”): Required if you served more 

than 60 days in a covered position during the preceding calendar year.

• Termination Report: Required if you terminated from a covered position, unless 

you served no more than 60 days during any calendar year or unless you assume 

employment in another covered position within 30 days.

How Do I File?

• Candidates: Download a copy of the OGE Form 278e from OGE’s website and 

submit your completed copy to the Federal Election Commission.

• Other Filers: In most cases, individuals should file their reports electronically, 

either through Integrity, a web-based system developed and administered by OGE 

for the executive branch, or through another agency-supported electronic financial 

disclosure system. Contact your agency ethics official if you have any questions 

about getting access to the system used by your agency.

When Must I File?

The due date depends on whether you are filing a Candidate, Nominee, New Entrant, 

Annual, or Termination Report.

• Candidate Report: Within 30 days of becoming a candidate for nomination or 

election to the office of President or Vice President, or by May 15 of that calendar 

year, whichever is later, but at least 30 days before the election, and on or before 

May 15 of each succeeding year you continue to be a candidate.

• Nominee Report: The final, signed version of your report is due no later than 

5 days after nomination by the President for the position. However, you should 

submit a draft of your report as soon as practicable.
Public Financial Disclosure Guide, OGE Form 278e: Overview 12

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• New Entrant Report: Due within 30 days of assuming the duties of the position 

covered by the public filing requirements.

• Annual Report: Due annually, no later than May 15 following the covered 

calendar year.

• Termination Report: Due within 30 days of leaving the position covered by the 

public filing requirements.

Your agency may grant an extension of up to 45 days for good cause shown, with the 

possibility of an additional extension of up to 45 days. If your report is filed more than 

30 days after the date the report is required to be filed, or, if an extension was granted, 

more than 30 days after the last day of the filing extension period, you will be subject to a 

$200 late filing fee. A report is considered to be filed when it is received by your agency.

Unless waived by your agency, your agency will collect the fee for deposit with the 

United States Treasury.

Report Contents 

The OGE Form 278e consists of a Cover Page and nine substantive Parts.

Part 1 – Filer’s Positions Held Outside United States Government

Part 2 – Filer’s Employment Assets & Income and Retirement Accounts

Part 3 – Filer’s Employment Agreements and Arrangements

Part 4 – Filer’s Sources of Compensation Exceeding $5,000 in a Year

Part 5 – Spouse’s Employment Assets & Income and Retirement Accounts

Part 6 – Other Assets and Income

Part 7 – Transactions

Part 8 – Liabilities

Part 9 – Gifts and Travel Reimbursements

The type of public financial disclosure report you are filing will determine which areas 

you must complete and the applicable reporting periods covered by those areas. Click the 

link below corresponding to your report type for additional information.

Nominee Report

New Entrant Report

Candidate Report

Annual Report

Termination Report

Disclose Interests of Your Spouse and Dependent Children

Report your spouse’s interests related to employment (including retirement accounts) in 

Part 5. In addition, the reporting requirements of Parts 6 through 9 apply to you, your 

spouse, and your dependent children. The reporting requirements, however, will 

sometimes differ depending on whether the interest belongs to you, your spouse, or your 

dependent child. In this guide, we explain the requirements for you, your spouse, and 

dependent children for each type of reportable interest.
Public Financial Disclosure Guide, OGE Form 278e: Overview 13

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As a limited exception to this rule, you do not need to report the interests of a spouse 

living separate and apart with the intention of terminating the marriage or providing for a 

permanent separation.

Differences between the OGE Form 278e and the OGE Form 278

Both the OGE Form 278e and the old OGE Form 278 collect the same information. The 

information is merely organized differently. The following table cross-references the two 

forms.

OGE Form 278e Sections Corresponding OGE Form 278 Sections

Cover Page Cover Page

Part 1: Filer’s Positions Held Outside 

United States Government

Schedule D, Part I: Positions Held Outside 

U.S. Government

Part 2: Filer’s Employment Assets & 

Income and Retirement Accounts

Schedule A: Assets and Income

Part 3: Filer’s Employment Agreements 

and Arrangements

Schedule C, Part II: Agreements or 

Arrangements

Part 4: Filer’s Sources of Compensation 

Exceeding $5,000 in a Year

Schedule D, Part II: Compensation in 

Excess of $5,000 Paid by One Source

Part 5: Spouse’s Employment Assets & 

Income and Retirement Accounts

Schedule A: Assets and Income

Part 6: Other Assets and Income Schedule A: Assets and Income

Part 7: Transactions Schedule B, Part I: Transactions

Part 8: Liabilities Schedule C, Part I: Liabilities

Part 9: Gifts and Travel Reimbursements Schedule B, Part II: Gifts, 

Reimbursements, and Travel Expenses
Public Financial Disclosure Guide, OGE Form 278e: Cover Page 14

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OGE Form 278e: Cover Page

If you are filing in Integrity, the Cover Page of your report will be populated based on the 

information in your profile, the type of report you are filing, and your electronic 

signature. If you are not filing in Integrity, consult the guidance below.

Hints for the section to above your name:

All Filers: Specify the type of report.

New Entrants: Enter the date on which you were appointed to the position for which you 

are filing a report.

Annual Filers: Enter the report year.

Termination Filers: Enter the date on which you left the position.
Public Financial Disclosure Guide, OGE Form 278e: Cover Page 15

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Hints for the section titled, “Other Federal Government Positions Held 

During the Preceding 12 Months”:

If you have held another position with the United States Government during the 

preceding 12 months, enter the title of the position and the department or agency. Please 

remember to include the dates (month and year) that you held that position.

If you did not hold any position with the United States Government other than your 

current position, write “None.”

Do not enter information about a position as a United States Government contractor. 

Instead, be sure to list your contractor position in Part 1.

Hints for the section titled, “Filer’s Certification”:

When your report is complete, sign and date the report in the fields provided.

By signing the report, you certify that the information provided is true, complete, and 

correct to the best of your knowledge.
Public Financial Disclosure Guide, OGE Form 278e: Part 1 16

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OGE Form 278e: Part 1

Your Positions Held Outside United States Government

Report any positions that you hold outside the United States Government in Part 1. 

Remember to report your position with your current employer.

Reportable positions include those of an officer, director, general partner, limited partner 

with an active role, proprietor, representative, executor, trustee, employee, or consultant 

of any for-profit or non-profit organization. This would include a member with an active 

role in a limited liability company and any managing member.

Organization Name City/State Organization 

Type

Position Held From To

George and Chapman, LLP Washington, 

DC

Law Firm Partner 5/2011 Present

Widgets Unlimited Grand 

Rapids, MI

Corporation Senior Vice President 2/2003 7/2015

Maryland Rivers Association Annapolis, 

MD

Non-profit Director 2/1998 2/2014

Family Trust #1 Scottsdale, 

AZ

Trust Trustee 8/1999 Present

In a section below, we discuss positions that are not reportable. But, first, let’s discuss 

how to address positions that are reportable.

For You

Part 1

Report any compensated or uncompensated position that you held with an organization 

other than the United States Government at any time during the reporting period, unless 

an exception applies.

Organization Name: Provide the name of the organization. For a family trust, you may 

use initials in lieu of a person’s name (e.g., “2003 J.S. Trust”) or simply refer to the entity 

as a family trust (e.g., “family trust #1”).

City/State: Provide the city and state in which the organization is located.

Organization Type: Describe the type of organization. If filing within Integrity, select 

the type from the drop-down list provided.

Position Type (This question is for internal purposes within Integrity and is not displayed 

on the printed OGE Form 278e.): Indicate the general type of position by selecting one 

of the options provided in the drop-down list. The list of options changes based on the 

type of organization. If none of the pre-determined options matches the type of position, 

you may enter your own description. The type of position held determines the types of 
Public Financial Disclosure Guide, OGE Form 278e: Part 1 17

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questions Integrity asks concerning possible assets, income, and arrangements that you 

may have.

Position Held: Provide the title or a brief functional description of the position you hold 

or held. For Integrity users, the information you enter here might match the information 

that you entered for Position Type. For example, if you selected “consultant” for the 

Position Type, you would likely enter “consultant” for the Position Held. However, you 

should provide a more specific description of the position if your selection under Position 

Type covers several different functional roles. For example, if you selected “employee, 

officer, or director” for Position Type, specify in which role you served or provide your 

title.

From: Provide the month and year in which you began in the position.

To: Provide the month and year in which the position ended. If you still hold the 

position, indicate “present.”

Positions That Are Not Reportable 

You do not need to report the following in Part 1:

• Positions held by your spouse or your dependent children.

• Positions held with the United States Government and positions held in an official 

capacity as a representative of the United States Government.

• Positions held in a religious, social, fraternal, or political organization.

• Positions solely of an honorary nature.

• Mere membership in an organization.

• Passive investment interests as a limited partner or non-managing member of a 

limited liability company (i.e., you are just an investor and provide no services).

In addition, you do not need to report service as a member of an advisory board or 

committee if the following criteria are met: (1) your service is unpaid; (2) the board or 

committee is that of a non-profit or governmental organization; (3) you have no fiduciary 

duties of the sort exercised by officers, directors, or trustees; and (4) your role does not 

involve sufficient supervision by the organization to create a common law employeeemployer relationship.

No Positions to Report

If you do not have any positions to report, you need to state this fact. Within Integrity, 

you would make this statement by marking the “I do not have...” checkbox. For hard 

copy reports, write “None.”

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 18

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OGE Form 278e: Part 2

Your Employment Assets and Income (including retirement 

accounts)

Introduction

Report your assets and income related to employment in Part 2. For purposes of this Part, 

“employment-related” is interpreted broadly to cover all of your non-investment activities

as well as your retirement accounts. Learn how to report a particular asset by selecting 

that asset or source of income from the table below.

Award or Prize

Bonus (cash)

Carried Interest

Cash Balance Pension Plan

Contingency Fee

Deferred Compensation

Defined Benefit Plan

Defined Contribution Plan

Director Fee

Employee Stock Ownership Plan

Employee Stock Purchase Plan

Executor or Administrator Fee

Farm (operated as a business)

Gambling Winnings

Government Benefit or Payment

Honorarium

Intellectual Property

Investment Fund (general)

IRA, Roth IRA, SEP IRA, or Keogh Plan

Law Firm (partnership)

Legal Practice (solo practice)

Life Insurance (split-dollar)

Money Purchase Pension Plan

Option (incentive stock option plan)

Phantom Stock

Restricted Stock

Restricted Stock Unit (RSU)

Salary

Self-Funded Defined Benefit Plan

Severance Payment (cash)

Small Business (general)

Stable Value Fund

Stock

Stock Appreciation Right

Third-Party Escrow Agreement
Public Financial Disclosure Guide, OGE Form 278e: Part 2 19

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TIAA-CREF

Trustee Fee

Other Assets and Income Related to Your Employment

If you have other types of assets or income related to employment, not listed above, click 

here for general guidance.

No Assets or Income Related to Your Employment

If you do not have any assets or sources of income to report related to employment, you 

need to state this fact. Within Integrity, you would make this statement by marking the “I 

do not have...” checkbox. For hard copy reports, write “None.”
Public Financial Disclosure Guide, OGE Form 278e: Part 2 20

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Award or Prize

Report the source and amount of your award or prize in Part 2.

Description EIF Value Income Type Income Amount

Alliance for Excellence in 

Achievement: Auditor of the Year

N/A award $700

Dover City Marathon: Race N/A prize $5,000

For You

Part 2

Report an award or prize if you won or received more than $200 from a single source 

during the reporting period.

Description: Provide the name of the source and describe the type of award or prize.

EIF: Select “N/A.”

Income Type: Describe the type of income as “award” or “prize.”

Income Amount: Provide the exact amount of the award or prize that you won or 

received.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 21

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Bonus (cash)

Report a cash bonus that you received or will receive in Part 2. In addition, report an 

arrangement to receive a bonus in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation 

N/A bonus $11,500

Quasar Engineering (ventilation 

systems), anticipated bonus

N/A $1,001 - $15,000 None (or less than 

$201)

For You

Part 2

Reporting a Bonus You Have Already Received

Report the total amount of bonuses received from a single source during the reporting 

period if the amount is more than $200.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “bonus.”

Income Amount: Provide the exact amount of your bonus.

Reporting a Bonus You Have Not Received

Report an anticipated bonus payment if the value of the anticipated bonus was more than 

$1,000 at the end of the reporting period.

Description: Provide the name of the source and write “anticipated bonus.” In addition, 

if the source is a privately held business, provide the source’s line of business.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the anticipated bonus.

Income Amount: Select the “None (or less than $201)” category.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 22

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Carried Interest

Generally, report your carried interests in Part 2. In addition, report carried interest as an 

arrangement in Part 3 (see Part 3 of this guide for details).

The term “carried interest” may have different meanings. Consult our definition of 

“carried interest” to see how we use this term for purposes of executive branch financial 

disclosure. For interests that do not meet this specific definition, your agency’s ethics 

official will need to consult OGE for guidance on the reporting requirements.

Description EIF Value Income Type Income Amount

Crocus Partners II, LP, carried 

interest (value not readily 

ascertainable)

N/A None (or less than 

$201)

For You

Part 2

As a matter of policy, OGE deems a carried interest to have a value that exceeds $1,000. 

Therefore, carried interests must be reported. Also, if you no longer have a carried 

interest but received more than $200 in income related to a carried interest during the 

reporting period, you need to report the income.

Description: Indicate that the asset is a carried interest and provide the name of the entity 

through which you have the carried interest.

EIF: Select “N/A.”

Value: Report the value of the carried interest by marking the appropriate category. If 

you cannot ascertain the value, leave this field blank but write “value not readily 

ascertainable” in the “Description” field.

Income Type: Specify the type of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category that corresponds to the total amount of income 

during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 23

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Cash Balance Pension Plan

Report your cash balance pension plan in Part 2. In addition, report your participation in 

a cash balance pension plan in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Regional Electric, cash balance 

pension plan

N/A $50,001 - $100,000 None (or less than 

$201)

Widgets Unlimited, cash balance 

pension plan

N/A $100,001 - $250,000 retirement 

payments 

(monthly)

$1,500

Xylophone Technologies 

Corporation, cash balance pension 

plan

N/A None (or less than 

$1,001)

lump sum $51,502

For You

Part 2

Report a cash balance pension plan if the value of the plan was more than $1,000 at the 

end of the reporting period or if you received more than $200 in retirement payments 

during the reporting period.

Description: Report the name of the employer providing the plan and write “cash balance 

pension plan.”

EIF: Select “N/A.”

Value: Report the value of the plan by marking the appropriate category. The value is 

the dollar value indicated in the statement that your plan’s administrator has provided to 

you.

Income Type: Specify the type of income if the total amount of income during the 

reporting period exceeded $200. Describe regular payments as “retirement payments” 

and indicate whether you are providing the monthly or annual amount. Describe a lump 

sum distribution as “lump sum.”

Income Amount: The level of detail required for income depends on the amount and 

type(s) of income.

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Regular payments: Provide either the monthly or annual amount that you receive.

(3) Lump sum distribution: Provide the exact amount.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 24

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Contingency Fee

Report your interest in contingency fee cases in Part 2. In addition, report your 

contingency fee interests in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Faraday, Maxwell & Franklin, 

contingency fee cases (value not 

readily ascertainable)

N/A None (or less than 

$201)

For You

Part 2

Report an interest in contingency fee cases if the value of the interest was more than 

$1,000 at the end of the reporting period or if the interest produced more than $200 in 

income during the reporting period.

Description: Provide the name of the law firm through which you acquired your interest 

in the cases and write “contingency fee case” or “contingency fee cases.”

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the interest. If you cannot 

ascertain the value, which will usually be the case if you have not set a cap on your fee, 

leave this field blank and write “value not readily ascertainable” in the “Description” 

field.

Income Type: Write “contingency fees” if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Provide the exact amount of income over $200. Otherwise, select the 

“None (or less than $201)” category.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 25

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Deferred Compensation

Report your deferred compensation in Part 2. In addition, report your participation in a 

deferred compensation plan in Part 3 (see Part 3 of this guide for details).

Deferred compensation can take many forms, and the reporting requirements will vary 

based on the timing of the compensation and its form. The examples below are intended 

to be merely illustrative of the various forms that deferred compensation may take. 

Regardless of the form of your deferred compensation, you should work with an ethics 

official at your agency to ensure complete and accurate disclosure.

Our guidance on deferred compensation is broken into the following sections:

Example 1: Already Received Lump Sum Cash Payment

Example 2: Future Lump Sum Cash Payment That is Fixed

Example 3: Payments in the Form of Assets – Received or Anticipated

Example 4: Deferred Compensation Plan with Underlying Assets

Example 5: Deferred Compensation Plan Linked to an Index or Other Benchmark

Example 1: Already Received Lump Sum Cash Payment 

You may have already received your deferred compensation, and it may have taken the 

form of a lump sum cash payment. In that case, follow the guidance provided in this 

example.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: received

N/A cash payment $97,850

Part 2

Report a lump sum cash payment (or payments) that you received from a source if the 

total amount exceeded $200 during the reporting period.

Description: Report the name of the employer providing the payment and write “deferred 

compensation: received.” In addition, for a privately held business, describe the line of 

business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Income Type: Describe the type of income as “cash payment.”

Income Amount: Provide the exact amount of your lump sum payment.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 26

Version: 5/2018

Example 2: Future Lump Sum Cash Payment That is Fixed 

You may not have received your deferred compensation, but your employer may owe you 

deferred compensation in the future in the form of a lump sum cash payment. That lump 

sum payment may be a fixed, as opposed to variable, amount that has already been 

determined. In that case, this example provides guidance on reporting the fixed amount 

lump sum payment that your employer owes you.

Instead of being fixed, the amount of your future lump sum payment may depend on the 

performance of investments. Alternatively, it may depend on the performance of 

something tracked, such as an index, a mutual fund, or some other benchmark. In either 

of those cases, Example 2 would not apply to your situation. You should refer to either 

Example 4 or 5 below for guidance on a “Deferred Compensation Plan with Underlying 

Assets” or a “Deferred Compensation Plan Linked to an Index or Other Benchmark.”

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: cash receivable

N/A $50,001 - $100,000 None (or less than 

$201)

Part 2

Report an anticipated lump sum cash payment if the fixed amount that you are owed was 

more than $1,000 at the end of the reporting period.

Description: Report the name of the employer providing the payment and write “deferred 

compensation: cash receivable.” In addition, for a privately held business, describe the 

line of business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the fixed lump sum payment 

that you are owed.

Income Amount: Select the category for “None (or less than $201).”

Example 3: Payments in the Form of Assets – Received or Anticipated 

You may have an arrangement for deferred compensation in the form of assets or options, 

rather than cash. If you have not yet received the deferred compensation, provide the 

name of the employer and write “deferred compensation receivable” in the “Description” 

field. Then, report the assets using the guidance appropriate for that type of asset (e.g., 

stock, stock options, restricted stock, stock appreciation right, phantom stock, and 

restricted stock units).
Public Financial Disclosure Guide, OGE Form 278e: Part 2 27

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Example 4: Deferred Compensation Plan with Underlying Assets 

This example addresses the situation of a deferred compensation plan through your 

employer only if you have a plan that holds underlying assets and have determined, in 

consultation with your employer or attorney, that this plan is accurately described as a 

“deferred compensation” plan.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation:

N

- Halley Engineering N/A $50,001 - $100,000 None (or less than 

$201)

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A $50,001 - $100,000 None (or less than 

$201)

Part 2

Report the deferred compensation plan and each underlying asset of the plan that 

individually was worth more than $1,000 at the end of the reporting period or that 

individually produced more than $200 in income during the reporting period.

Description: Provide the name of the employer and write “deferred compensation.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

Next, report each of the underlying assets that individually was worth more than $1,000 

at the end of the reporting period or that individually produced more than $200 in income 

during the reporting period.

EIF: Select “N.” In addition, for each underlying asset, indicate whether the asset 

(1) qualifies as an EIF (“Y”), (2) does not qualify as an EIF (“N”), or (3) is not an 

investment vehicle that holds other assets (“N/A”).

Value: You do not need to provide the overall value for the plan. Instead, provide the 

individual value of each underlying asset by selecting the appropriate category.

Income Type: You do not need to provide the type(s) of income for the plan as a whole. 

Instead, provide the type(s) of income produced by each underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.

Income Amount: Provide the amount of income produced by each underlying asset 

during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 28

Version: 5/2018

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Example 5: Deferred Compensation Plan Linked to an Index or Other 

Benchmark 

You may have an interest in a deferred compensation plan under which your employer 

owes you a future lump sum payment that is not fixed but variable.

The amount of that future lump sum payment may depend on the performance of 

something tracked, such as an index, a mutual fund, or some other benchmark. However, 

you do not, through the deferred compensation plan, own the thing being tracked. (For 

instance, the plan may track the performance of the S&P 500 or the performance of a 

mutual fund that mirrors the S&P 500. However, you do not hold, through the deferred 

compensation plan, shares of the companies listed on the S&P 500 or shares of the 

mutual fund. Instead, your employer owes you a cash payment, and your employer may 

pay more money if the S&P 500 performs well or may pay less money if the S&P 500 

performs poorly.)

This example provides guidance on reporting the variable amount lump sum payment of 

deferred compensation that your employer owes you.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: tracks S&P 500

N/A $50,001 - $100,000 None (or less than 

$201)

Part 2

Report your interest in the plan if the value of your interest was more than $1,000 at the 

end of the reporting period or if your interest produced more than $200 in income during 

the reporting period.

Description: Provide the name of the employer, write “deferred compensation,” and 

specify the index or other benchmark that your future payment tracks. In addition, for a 

privately held business, describe the line of business, unless you have already provided 

this information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of your interest.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 29

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Income Amount: Select the category for “None (or less than $201).”

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 30

Version: 5/2018

Defined Benefit Plan

Report your defined benefit plan in Part 2. In addition, report your participation in a 

defined benefit plan in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Regional Electric, defined benefit 

plan (value not readily 

ascertainable): eligible for 

$3,000/mo. at age 65

N/A None (or less than 

$201)

Widgets Unlimited, defined benefit 

plan (value not readily 

ascertainable)

N/A retirement 

payments (annual)

$20,000

For You

Part 2

Report a defined benefit plan if the value of the plan was more than $1,000 at the end of 

the reporting period or if you received more than $200 in retirement payments during the 

reporting period. Do not report a plan that you obtained through United States 

Government employment.

Description: Report the name of the employer providing the plan and write “defined

benefit plan.”

EIF: Select “N/A.”

Value:

(1) The value of the plan is readily ascertainable: Report the value of the plan by 

marking the appropriate category.

(2) The value of the plan is not readily ascertainable but you received more than $200 in 

income during the reporting period: Leave the “Value” field blank and write “value not 

readily ascertainable” in the “Description” field.

(3) The value of the plan is not readily ascertainable and you did not receive more than 

$200 in income during the reporting period: Leave the “Value” field blank. In the 

“Description” field, write “value not readily ascertainable” and indicate the monthly or 

annual amount that you will be eligible to receive at a certain age (e.g., “eligible for 

$3,000/mo. at age 65”).

Income Type: If the total amount of income during the reporting period exceeded $200, 

write “retirement payments” and indicate whether you are reporting a monthly or annual 

amount. Otherwise, leave the field blank.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 31

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Income Amount: Provide either the monthly or annual amount that you receive over 

$200. Otherwise, select the “None (or less than $201)” category.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 32

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Defined Contribution Plan

Report your defined contribution plan in Part 2. In addition, report your participation in a 

defined contribution plan in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

Tyler Informatics, 401(k) plan: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For You

Part 2

Report each underlying asset of the defined contribution plan that individually was worth 

more than $1,000 at the end of reporting period or that individually produced more than 

$200 in income during the reporting period. Although this information is not required, 

you may specify that the assets are held within a defined contribution plan.

This guide contains specific instructions for common types of assets held within a 

defined contribution plan (e.g., mutual funds, exchange-traded funds, stocks, and 

corporate bonds).

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 33

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Director Fee

Report the source and amount of your director fees in Part 2.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation 

N/A director fees $17,850

DSLK Financial Techniques, Inc.

(financial services)

N/A director fees $5,375

For You

Part 2

Report the total amount of your director fees during the reporting period if the amount is 

more than $200.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “director fees.”

Income Amount: Provide the exact amount of your director fees during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 34

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Employee Stock Ownership Plan

Report your employee stock ownership plan (ESOP) in Part 2. In addition, report your 

participation in an employee stock ownership plan in Part 3 (see Part 3 of this guide for 

details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, ESOP account N/A $1,001 - $15,000 None (or less than 

$201)

For You

Part 2

Report an ESOP account if the value of the account was more than $1,000 at the end of 

the reporting period or if the account produced more than $200 in income during the 

reporting period.

Description: Provide the name of the employer and write “ESOP account” or “employee 

stock ownership plan account.” In addition, for a privately held business, describe the 

line of business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the account by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income. Most 

filers select “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 2 35

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Employee Stock Purchase Plan

Report your employee stock purchase plan (ESPP) in Part 2. In addition, report your 

participation in an employee stock purchase plan in Part 3 (see Part 3 of this guide for 

details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, ESPP account N/A $1,001 - $15,000 None (or less than 

$201)

For You

Part 2

Report an ESPP account if the cash balance of the account was more than $1,000 at the 

end of the reporting period or if the account produced more than $200 in income during 

the reporting period.

Description: Provide the name of the employer and write “ESPP account.” In addition, 

for a privately held business, describe the line of business, unless you have already 

provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the account by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income. Most 

filers select “None (or less than $201).”

Reporting Stock Acquired Through an ESPP Account

Report any stock that you acquired as a separate line item entry, using the standard 

instructions for stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 36

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Executor or Administrator Fee

Report fees for your service as an executor or administrator in Part 2. In addition, report 

the following interests in Part 6: (1) assets distributed from an estate and (2) a beneficial 

interest in an estate that has not yet been distributed. Do not report an interest in the will 

of a living person.

Description EIF Value Income Type Income Amount

Estate of Ms. Eliot N/A executor fees $4,300

Estate of a family member N/A administrator fees $1,900

For You

Part 2

Report the total amount of your fees during the reporting period if the amount is more 

than $200.

Description: Identify the estate. If the estate is that of a relative, you may write “estate 

of a family member.” In other cases, identify the estate by the last name of the party 

(e.g., “Estate of Mr. Doe”).

EIF: Select “N/A.”

Income Type: Write “executor fees” or “administrator fees.”

Income Amount: Provide the exact amount of your fees during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 37

Version: 5/2018

Farm (operated as a business)

Report a farm that you operate as a business in Part 2.

Description EIF Value Income Type Income Amount

Highlands Farm, Papillion, NE, 

general partner (crops)

N/A $500,001 -

$1,000,000

partnership 

income

$130,005

Bailey Horse Farm, Ashburn, VA, 

sole proprietor (livestock)

N/A $250,001 - $500,000 farming income $76,513

For You

Part 2

Report a farm that you operate as a business if its value was more than $1,000 at the end 

of the reporting period or if it produced more than $200 in income during the reporting 

period.

Do not report passive investment interests in a farm in Part 2. Report these interests in 

Part 6 instead.

Description: Provide the name of the farm; the location of the farm (either the city and 

state or the county and state); and the business of the farm, such as crops or livestock. In 

addition, it is helpful if you specify the type of interest that you have in the farm, such as 

“sole proprietor” or “general partner.”

EIF: Select “N/A.”

Value: Select the appropriate category to report the value of the farm, including such 

assets as the land, the crops (standing or in storage), the livestock, the farm equipment, 

the buildings, etc.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: The level of detail required for income depends on the amount and 

type(s) of income.

(1) Income less than $201: Select the category for “None (or less than $201).” 

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 38

Version: 5/2018

Gambling Winnings

Report the source and amount of your gambling winnings in Part 2.

Description EIF Value Income Type Income Amount

Royal Pond Casino N/A gambling 

winnings

$7,489

For You

Part 2

Report gambling winnings if you won or received more than $200 from a single source 

during the reporting period. This threshold is based on gross winnings, not net winnings.

Description: Provide the name of the source.

EIF: Select “N/A.”

Income Type: Describe the type of income as “gambling winnings.”

Income Amount: Provide the exact amount of your winnings.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 39

Version: 5/2018

Government Benefit or Payment

For You

Do not report:

• Income you received as an employee of the United States Government, including 

military Reserve pay.

• Retirement benefits you received from the United States Government, including 

the Thrift Savings Plan and any other United States Government retirement 

system.

• Your income from the United States Government’s Social Security, veterans’ 

benefits, and other similar United States Government benefits programs.

Report in Part 2:

• Honoraria you received from the United States Government.

• Consulting fees you received as an independent contractor with the United States 

Government.

• Salary you received from state, local, or foreign government employment. 

• Honoraria or consulting fees you received from state, local, or foreign 

government sources.

• Your retirement benefits from a state, local, or foreign government, such as 

participation in a defined benefit plan or a defined contribution plan.

• Your income from state, local, or foreign government benefits programs.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 40

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Honorarium

Report an honorarium that you received or will receive in Part 2.

Description EIF Value Income Type Income Amount

Loomis County University –

8/12/2015

N/A honorarium $220

Loomis County University –

10/20/2015

N/A honorarium $220

East State College, anticipated 

honorarium

N/A $1,001 - $15,000 None (or less than 

$201)

For You

Part 2

Reporting an Honorarium You Have Already Received

If you received honoraria from a single source aggregating more than $200 during the 

reporting period, report each honorarium received from that source.

Description: Provide the name of the source that paid the honorarium and enter the date 

of the services.

EIF: Select “N/A.”

Income Type: Describe the type of income as “honorarium.”

Income Amount: Provide the exact amount of your honorarium.

Reporting an Honorarium You Have Not Received

Report an honorarium that you anticipate receiving if (1) you have provided the service 

for which the honorarium will be paid or have a contractual right to an honorarium after 

providing the service in the future and (2) the value of the anticipated honorarium is more 

than $1,000.

Description: Provide the name of the source and write “anticipated honorarium.” If you 

have already provided the services, enter the date in the space provided.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the anticipated honorarium.

Income Amount: Select the “None (or less than $201)” category.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 41

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Intellectual Property

Report your intellectual property and income from intellectual property in Part 2.

Description EIF Value Income Type Income Amount

“History of Clocks,” Stateburg 

University Press (value not readily 

ascertainable)

N/A rent or royalties $201 - $1,000

“Financial Disclosure,” 4th ed., 

Zorn & Co. (value not readily 

ascertainable)

N/A advance $22,000

“Circular frame and hub system for 

a conveyance,” Patent # 

202,482,924 (value not readily 

ascertainable)

N/A None (or less than 

$201)

For You

Part 2

Report intellectual property if the value of the intellectual property was more than $1,000 

at the end of the reporting period or if your intellectual property produced more than 

$200 in income during the reporting period.

Description: Describe the intellectual property. For a book, provide the name of the 

book and identify the publisher. For a patent, provide the patent number and a very brief 

description of the patent. For other types of intellectual property, provide a similarly 

specific description that is sufficient for the reader to understand the nature of your 

property.

EIF: Select “N/A.”

Value: Report the value of the intellectual property by selecting the appropriate category. 

If you cannot ascertain the value, leave this field blank but write “value not readily 

ascertainable” in the “Description” field. 

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200 (e.g., select “rent or royalties” or write “advance”).

Income Amount: The level of detail required for income depends on the amount and the 

type(s) of income.

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 42

Version: 5/2018

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 43

Version: 5/2018

Investment Fund (general)

If you have an equity interest in an investment fund related to, or acquired through, 

employment, report the fund in Part 2, and report any arrangements related to the fund in

Part 3 (see Part 3 of this guide for details). In addition, report any investment fund held 

through a retirement plan or individual retirement account in Part 2, and report any 

continued participation in the retirement plan in Part 3.

Note that other entries in this guide specifically address mutual funds, exchange-traded 

funds, and money market funds. See those entries for more targeted guidance if 

applicable.

Investment Fund Qualifies as an EIF

Description EIF Value Income Type Income Amount

Positron Investments XI, LP Y $100,001 - $250,000 $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If You Know the Value and Income of the 

Underlying Assets

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A $15,001 - $50,000 None (or less than 

$201)

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A $15,001 - $50,000 None (or less than 

$201)

- WQX Optics (medical devices) N/A $1,001 - $15,000 capital gains $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If the Value and Income of the 

Underlying Assets is Not Readily Ascertainable

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N $50,001 - $100,000 capital gains $5,001 - $15,000

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A

- WQX Optics (medical devices) N/A
Public Financial Disclosure Guide, OGE Form 278e: Part 2 44

Version: 5/2018

For You

Part 2

Report an equity interest in an investment fund if the value was more than $1,000 at the 

end of the reporting period or if the interest produced more than $200 in total income 

during the reporting period.

The reporting requirements will depend on whether the investment fund qualifies as an 

excepted investment fund (EIF).

Investment Fund Qualifies as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category. 

Income Type: Leave this field blank.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Investment Fund Does Not Qualify as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “N.”

Additional Disclosure of Underlying Assets: Because the investment fund does not 

qualify as an EIF, you need to report each underlying asset of the fund that was worth 

more than $1,000 at the end of the reporting period or that produced more than $200 in 

income during the reporting period. For purposes of this calculation, you may use the 

interest that you have in the asset. Report each underlying asset using the guidance 

applicable to that type of asset.

In certain cases, investment funds do not provide information regarding an investor’s 

interest in the value and/or income of the fund’s underlying assets. If you are unable to 

ascertain the value of the underlying assets, you may instead provide value information 

for the total interest that you have in the fund. Similarly, if you are unable to ascertain 

the income of the underlying assets, you may instead provide income information for the 

total interest that you have in the fund.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 45

Version: 5/2018

Other Interests 

Additional requirements may apply if you have ever worked for the company that 

manages the investment fund. Click here for guidance on these additional requirements.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 46

Version: 5/2018

IRA, Roth IRA, SEP IRA, or Keogh Plan

Report the underlying assets of your Individual Retirement Account (IRA), Roth IRA, 

Simplified Employee Pension Individual Retirement Account (SEP IRA), or Keogh plan 

in Part 2.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

IRA #1: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For You

Part 2

Report each underlying asset of your IRA, Roth IRA, SEP IRA, Keogh plan, or other 

individual account that individually was worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period. You may indicate that the assets are held within a retirement account, 

but this information is not required.

This guide contains specific instructions for common types of assets held within a 

retirement account (e.g., mutual funds, exchange-traded funds, stocks, and corporate 

bonds).
Public Financial Disclosure Guide, OGE Form 278e: Part 2 47

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Law Firm (partnership)

Report your law firm partnership in Part 2. In addition, report what will happen to your 

interest in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Faraday, Maxwell & Franklin 

(law firm)

N/A partnership share $287,539

Faraday, Maxwell & Franklin, 

anticipated partnership share

N/A $100,001 - $250,000 None (or less than 

$201)

Faraday, Maxwell & Franklin, 

capital account

N/A $50,001 - $100,000 None (or less than 

$201)

For You

Part 2

Report a law firm partnership interest if its value was more than $1,000 at the end of the 

reporting period or if it produced more than $200 in income during the reporting period.

If You Received a Partnership Share

Description: Provide the name of the law firm. You should also indicate that the entity is 

a law firm, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Income Type: Describe the type of income as “partnership share.”

Income Amount: Provide the exact amount your partnership share, including draw and 

any distributions.

If You Anticipate Payment of an Outstanding Partnership Share

Description: Provide the name of the law firm and write “anticipated partnership share” 

or “partnership share receivable.” You should also indicate that the entity is a law firm, 

unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the anticipated payment, 

including draw, distributions, and any other related components of your compensation.

Income Amount: Select the “None (or less than $201)” category for income.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 48

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Capital Account

Description: Provide the name of the law firm and write “capital account.” You should 

also indicate that the entity is a law firm, unless you have already provided this 

information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the capital account.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200. The type of income is usually “interest” for capital 

accounts.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Other Income and Interests

Business Assets and Liabilities: You need not itemize the assets and liabilities of the law 

firm. Disclosing the law firm itself is normally sufficient. As an exception to this rule, 

you would report any assets or liabilities that are unrelated to the operations of the law 

firm.

Compensation and Other Benefits: In addition to partnership income, report any 

additional compensation and other benefits. Report these as separate line entries using 

the instructions for that type of asset or income. For example, various sections of this 

guide address: severance payments, bonuses, deferred compensation, defined benefit 

plans, defined contribution plans, and other items.

Contingency Fee Interests: If you have any interests in contingency fee cases, report 

these interests in Part 2 and Part 3 using the instructions provided in this guide.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 49

Version: 5/2018

Legal Practice (solo practice)

Report your solo legal practice in Part 2. In addition, report what will happen to your 

solo legal practice in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Law Office of Geoffrey Chaucer 

(solo legal practice)

N/A $100,001 - $250,000 legal fees $157,106

For You

Part 2

Report a solo legal practice if the value of the practice was more than $1,000 at the end of 

the reporting period or if the practice produced more than $200 in income during the 

reporting period.

Description: Indicate that you practice law as a solo practitioner. You may also include 

the name under which you do business; however, it is not required.

EIF: Select “N/A.”

Value: Report the value of the practice by selecting the appropriate category. The value 

of the practice would include all assets held by the practice, unless itemized separately.

Income Type: Describe the type of income as “legal fees.”

Income Amount: Provide the exact amount of income. 

Other Interests

Referral Fees: If you have an arrangement to receive referral fees from another attorney 

after you enter government service, report the arrangement in Part 3.

Contingency Fee Interests: If you have any interests in contingency fee cases, report 

these interests in Part 2 and Part 3 using the instructions provided in this guide. 

Business Assets and Liabilities: You need not itemize the assets and liabilities of your 

legal practice. Disclosing the legal practice itself is normally sufficient. As an exception 

to this rule, you would report any assets or liabilities that are unrelated to the operations 

of the practice.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 50

Version: 5/2018

Life insurance (split-dollar)

Report your coverage by a split-dollar life insurance policy in Part 2. In addition, report 

the arrangement for this coverage in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Mutual of Spokane, split-dollar 

variable life through SendNow Co.:

N

- Liberty Income Securities Fund Y $15,001 - $50,000 None (or less than 

$201)

- American U.S. Large Cap Value Y $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report a split-dollar life insurance policy if the value of the policy was more than $1,000 

at the end of the reporting period or if the policy produced more than $200 in income 

during the reporting period.

Description: Provide the name of the insurance company issuing the policy; write “splitdollar” to describe the payment method; note the type of policy (e.g., whole, universal, or 

variable); and provide the name of the employer through which you hold the policy. In 

addition, for a variable split-dollar policy, provide the name of each underlying asset 

within the policy that individually was worth more than $1,000 at the end of the reporting 

period or that individually produced more than $200 in income during the reporting 

period.

EIF: Select “N/A” for whole or universal life policies. Select “N” for the first line entry 

of a variable life policy because the overall policy is an investment vehicle that does not 

qualify as an excepted investment fund. For each underlying asset of a variable life 

policy, indicate whether the asset (1) qualifies as an EIF (“Y”), (2) does not qualify as an 

EIF (“N”), or (3) is not an investment vehicle that holds other assets (“N/A”).

Value: For whole or universal split-dollar policies, report the value of the policy by 

selecting the appropriate category. For variable split-dollar policies, report the value of 

each underlying asset.

Income Type: For whole or universal split-dollar policies, report the type of income 

produced by the policy during the reporting period. For variable split-dollar policies, 

report the income produced by each of the underlying assets. Do not provide the type of 

income if the amount did not exceed $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 2 51

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(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 52

Version: 5/2018

Money Purchase Pension Plan

Report your money purchase pension plan in Part 2 using the guidance for defined 

contribution plans. In addition, report your participation in a money purchase pension 

plan in Part 3 (see Part 3 of this guide for details).
Public Financial Disclosure Guide, OGE Form 278e: Part 2 53

Version: 5/2018

Option (incentive stock option plan)

Report your incentive stock options and stock acquired through an incentive stock option 

plan in Part 2. In addition, report your participation in an incentive stock option plan in 

Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, stock options N/A $15,001 - $50,000 None (or less than 

$201)

Widgets Unlimited, stock options

(value not readily ascertainable): 

740 vested shares, strike $19, exp. 

1/2018

N/A None (or less than 

$201)

For You

Part 2

Reporting Stock Options

Report a stock option if the value of the option was more than $1,000 at the end of the 

reporting period or if the option produced more than $200 in income during the reporting 

period.

Description: Provide the exact name of the stock for which the option was issued and 

write “stock option.” In addition, for a privately held business, describe the line of 

business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: If you are able to determine the value of your option, report the value by marking 

the appropriate category. Keep in mind that the value of an option is not the same as the 

value of the stock for which it was issued. However, your employer’s human resources 

office may be able to provide you with the value of your stock option. If your employer 

has not provided you with this information, the U.S. Office of Government Ethics will 

accept either of the following methods of valuation: 

(A) If the option is “underwater” or if the value of the option is otherwise difficult to 

determine, write “value not readily ascertainable” in the “Description” field and provide 

the following information: (1) the name of the stock for which the option was issued; 

(2) the number of shares of the stock for which the option was issued; (3) the strike price; 

(4) the expiration date; (5) an indication as to whether the option is vested; and (6) the 

date on which the option will vest, if the option is unvested. 

(B) Alternatively, you may use any commonly accepted formula to calculate the value of 

your options (e.g., the Black-Scholes pricing model).
Public Financial Disclosure Guide, OGE Form 278e: Part 2 54

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Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced. Options obtained through employment (e.g., incentive stock options) normally 

do not produce income, which means that most filers select “None (or less than $201).”

Reporting Stock Acquired by Exercising Stock Options

Report any stock that you acquired as a separate line item entry, using the standard 

instructions for stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 55

Version: 5/2018

Phantom Stock

Report your phantom stock and income from phantom stock in Part 2. In addition, report 

your participation in a phantom stock plan in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, phantom stock N/A $15,001 - $50,000 cash payment $14,025

Xylophone Technologies 

Corporation, phantom stock

N/A $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report phantom stock if the value of the phantom stock was more than $1,000 at the end 

of the reporting period or if the phantom stock produced more than $200 in income 

during the reporting period. 

Description: Provide the name of the employer and write “phantom stock.” In addition, 

for a privately held business, describe the line of business, unless you have already 

provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the phantom stock by selecting the appropriate category.

Income Type: Write “cash payment” for cash income over $200.

Income Amount: Provide the exact amount of cash income over $200 during the 

reporting period. Otherwise, select the “None (or less than $201)” category.

Reporting Stock Acquired Through a Phantom Stock Plan

Report any stock that you acquired as a separate line item entry, using the standard 

instructions for stock.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 56

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Restricted Stock

Report your restricted stock and income from restricted stock in Part 2. In addition, 

report your participation in a restricted stock plan in Part 3 (see Part 3 of this guide for 

details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, restricted stock N/A $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report restricted stock if the value of the stock was more than $1,000 at the end of the 

reporting period or if the restricted stock produced more than $200 in income during the 

reporting period.

Reporting Unvested Restricted Stock

Description: Provide the exact name of the stock and write “restricted stock.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the restricted stock by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Reporting Restricted Stock That Has Vested

Report the stock as you would any other stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 57

Version: 5/2018

Restricted Stock Unit (RSU)

Report your restricted stock units and income from restricted stock units in Part 2. In 

addition, report your participation in a restricted stock unit plan in Part 3 (see Part 3 of 

this guide for details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, restricted stock 

units

N/A $15,001 - $50,000 cash payment $14,025

Xylophone Technologies 

Corporation, restricted stock units

N/A $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report a restricted stock unit if its value was more than $1,000 at the end of the reporting 

period or if the restricted stock unit produced more than $200 in income during the 

reporting period.

Description: Provide the name of the employer and write “restricted stock unit.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the restricted stock unit by selecting the appropriate category.

Income Type: Write “cash payment” for cash income over $200.

Income Amount: Provide the exact amount of cash income over $200 during the 

reporting period. Otherwise, select the “None (or less than $201)” category.

Reporting Stock Acquired Through a Restricted Stock Unit Plan

Report any stock that you acquired as a separate line item entry, using the standard 

instructions for stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 58

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Salary

Report the source and amount of your salary in Part 2.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation

N/A salary $187,489

DSLK Financial Techniques, Inc. 

(financial services)

N/A salary $195,375

For You

Part 2

Report your total income from salary during the reporting period if the amount is more 

than $200, unless the salary was from United States Government employment.

Description: Provide the name of your employer. In addition, if your employer is a 

privately held business, provide your employer’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “salary.”

Income Amount: Provide the exact amount of your salary income during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 59

Version: 5/2018

Self-Funded Defined Benefit Plan

Report your self-funded defined benefit plan and its underlying assets in Part 2.

Description EIF Value Income Type Income Amount

Betsy Jones, self-funded defined 

benefit plan (DSLK Financial 

Techniques, Inc.):

N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For You

Part 2

Report a self-funded defined benefit pension plan if the value of the plan was more than 

$1,000 at the end of the reporting period or if the plan produced more than $200 in 

income during the reporting period. In addition, provide the names of each underlying 

asset within the plan that individually was worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period.

Reporting the Plan

Description: Write your name and describe the type of plan. Provide the name of the 

financial institution through which the plan is held.

EIF: Select “N” because a self-funded defined benefit plan is an investment vehicle that 

does not qualify as an excepted investment fund.

Reporting the Underlying Assets

Description: Provide the name of the underlying asset.

EIF: For each underlying asset, indicate whether the asset (1) qualifies as an EIF (“Y”), 

(2) does not qualify as an EIF (“N”), or (3) is not an investment vehicle that holds other 

assets (“N/A”).

Value: Report the value of the underlying asset by selecting the appropriate category.

Income Type: Specify the type(s) of income produced by the underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 2 60

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(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 61

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Severance Payment (cash)

Report a cash severance payment that you received or will receive in Part 2. In addition, 

report an arrangement to receive severance in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation 

N/A severance $11,508

Quasar Engineering (ventilation 

systems), anticipated severance

N/A $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Reporting a Severance Payment You Have Already Received

Report the total amount of severance payments received during the reporting period if the 

amount is more than $200.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “severance.”

Income Amount: Provide the exact amount of your severance payment.

Reporting a Severance Payment You Have Not Received

Report an anticipated severance payment if its value was more than $1,000 at the end of 

the reporting period.

Description: Provide the name of the source and write “anticipated severance.” In 

addition, if the source is a privately held business, provide the source’s line of business.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the anticipated severance 

payment.

Income Amount: Select the “None (or less than $201)” category.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 62

Version: 5/2018

Small Business (general)

Report a small business that you operate in Part 2.

Note that other entries in this guide specifically address farms, law firms, and corporate 

stock. See those entries for more targeted guidance if applicable.

Description EIF Value Income Type Income Amount

Advanced Systems, LLC (software) N/A $500,001 -

$1,000,000

business income $130,005

ABC Holdings, Inc., S-Corp, d/b/a 

Jones Management Solutions 

(HR consulting) 

N/A $15,001 - $50,000 business income $88,130

Accountant, sole proprietor N/A $1,001 - $15,000 accounting fees $93,153

Piano teacher, sole proprietor N/A $1,001 - $15,000 lesson fees $35,650

For You

Part 2

Report your small business if its value was more than $1,000 at the end of the reporting 

period or if it produced more than $200 in income during the reporting period.

Description: Provide the name of your business and, unless your business is publicly 

traded, the type of business being conducted. In the absence of a specific business name, 

describe the trade practiced. If the legal name of the business differs from the name 

under which the business operates, it is helpful if you provide both names for clarity. In 

addition, unless otherwise specified, reported business interests are generally assumed to 

be structured as C-corporations. Consequently, if your business is otherwise structured, it 

is helpful to describe the type of business interest, such as “LLC” or “sole 

proprietorship.”

EIF: Select “N/A.”

Value: Select the appropriate category to report the value of the business.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: The level of detail required for income depends on the amount and 

type(s) of income.

(1) Income less than $201: Select the category for “None (or less than $201).” 

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 63

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(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Additional Requirements

Business Assets and Liabilities: You need not itemize the assets and liabilities of the 

business. Disclosing the small business itself is normally sufficient. As an exception to 

this rule, you would report any assets or liabilities that are unrelated to the operations of 

that business.

Compensation and Other Benefits: In addition to business income, you may receive other 

compensation and benefits. Report these as separate line entries using the instructions in 

this guide for that type of asset or income. For example, various entries in this guide 

address: severance payments, bonuses, deferred compensation, defined benefit plans, 

defined contribution plans, and other items.

Honoraria: In general, you need to report the source of an honorarium (income for an 

appearance, speech, or article) separately even if you received the income through a 

single-member LLC or a speakers’ bureau. See the honorarium entry in this guide for 

additional information.

Copyright on a Book: In general, you need to report the copyright on a book even if you 

received the income through a single-member LLC. Report your LLC on one line in Part 

2 and then report each book on a separate line.

Interests Arising from a Sale: Report a third-party escrow agreement using the 

instructions in this guide for such agreements.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 64

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Stable Value Fund

Report a stable value fund held in your retirement account or plan in Part 2. In addition, 

report your participation in the retirement account or plan in Part 3 (see Part 3 of this 

guide for details).

Description EIF Value Income Type Income Amount

ING Stable Value Fund Y $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report a stable value fund if the value of the stable value fund was more than $1,000 at 

the end of the reporting period or if the stable value fund produced more than $200 in 

income during the reporting period.

Description: Provide the name of the stable value fund and the institution that manages 

the fund (e.g., Fidelity, Vanguard, T. Rowe Price, etc.), unless the institution is part of the 

fund name. In addition, although not required, you may indicate the type of account or 

plan in which the fund is held (e.g., defined contribution plan, 401(k), 403(b), 457, etc.).

EIF: Stable value funds often qualify as excepted investment funds. In such cases, select 

“Y” for this field.

Value: Report the value of the stable value fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 65

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Stock

Report stock obtained through your business, employment, or other income-generating 

activities in Part 2.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$201 - $1,000

BMSL Propulsion, Inc. (rocket fuel 

research)

N/A $50,001 - $100,000 None (or less than 

$201)

For You

Part 2

Report a stock if the value of the stock was more than $1,000 at the end of the reporting 

period or if the stock produced more than $200 in income during the reporting period.

Description: Provide the exact name of the stock (e.g., “Xylophone Technologies 

Corporation”). In addition, for stock of a privately held company, provide a description 

of the issuer’s trade or business (e.g. grain distributor, supermarket, financial advisory, 

etc.).

EIF: Select “N/A.”

Value: Report the value of the stock by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200. Stocks normally produce dividend income but stocks 

may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Equity Compensation Plans and Other Interests

Stock obtained through employment-related activities often originates from equity 

compensation plans and other interests, such as deferred compensation, employee stock 

ownership plans, employee stock purchase plans, incentive stock options, phantom stock, 

restricted stock, restricted stock units, and stock appreciation rights. Report these 

interests in Part 2 and any related arrangements in Part 3 if applicable.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 66

Version: 5/2018

Stock Appreciation Right

Report your stock appreciation rights and income from stock appreciation rights in Part 2. 

In addition, report your participation in a stock appreciation right plan in Part 3 (see Part 

3 of this guide for details).

Description EIF Value Income Type Income Amount

Widgets Unlimited, stock 

appreciation rights

N/A $15,001 - $50,000 cash payment $14,025

Xylophone Technologies 

Corporation, stock appreciation 

rights

N/A $15,001 - $50,000 None (or less than 

$201)

For You

Part 2

Report a stock appreciation right if the value of the stock appreciation right was more 

than $1,000 at the end of the reporting period or if the stock appreciation right produced 

more than $200 in income during the reporting period.

Description: Provide the name of the employer and write “stock appreciation right.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the stock appreciation right by selecting the appropriate 

category. If the stock appreciation right is “underwater” or if its value is otherwise 

difficult to determine, write “value not readily ascertainable” in the “Description” field 

and provide the following information: (1) grant price; (2) number of shares; 

(3) expiration date; (4) vesting status; and (5) for an unvested stock appreciation right, the 

vesting date.

Income Type: Write “cash payment” for cash income over $200.

Income Amount: Provide the exact amount of cash income over $200 during the 

reporting period. Otherwise, select the “None (or less than $201)” category.

Reporting Stock Acquired Through a Stock Appreciation Right Plan

Report any stock that you acquired as a separate line item entry, using the standard 

instructions for stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 67

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Third-Party Escrow Agreement

Report your interest in an escrow agreement in Part 2. In addition, report the terms of 

your agreement in Part 3 (see Part 3 of this guide for details).

Description EIF Value Income Type Income Amount

Third-party escrow account with 

Tristate Bank (due to sale of WQX 

Systems, LLC to Widgets 

Unlimited)

N/A $1,000,001 -

$5,000,000

None (or less than 

$201)

For You

Part 2

Report your interest in an escrow agreement if the value of the escrow property was more 

than $1,000 at the end of the reporting period or if the escrow property produced more 

than $200 in income during the reporting period.

Description: Provide the name of the account, including the name of the third-party 

escrow holder with whom the escrow property is held in trust, and write a short 

description of the nature of the transaction (e.g., “due to sale of WQX Systems, LLC to 

Widgets Unlimited”).

EIF: Select “N/A.”

Value: Report the value of the escrow property by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 2 68

Version: 5/2018

TIAA-CREF

Report a TIAA-CREF product obtained through your business, employment, or other 

income-generating activities in Part 2. In addition, if you hold this product through a 

retirement plan, report your participation in the plan in Part 3 (see Part 3 of this guide for 

details).

Description EIF Value Income Type Income Amount

TIAA Traditional N/A $50,001 - $100,000 interest $1,001 - $2,500

CREF Stock Y $1,001 - $15,000 None (or less than 

$201)

For You

Part 2

The specific reporting requirements will depend on the type of TIAA-CREF product that 

you hold.

For specific instructions on reporting the TIAA Traditional Annuity, click here.

For specific instructions on reporting CREF accounts and TIAA Real Estate, click here.
Public Financial Disclosure Guide, OGE Form 278e: Part 2 69

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Trustee Fee

Report the source and amount of your trustee fees in Part 2.

Note that you may have to report the underlying holdings of the trust in Part 6 if you, 

your spouse, or dependent child have an interest in or have received income from the 

trust (see the trust entries in this guide for details).

Description EIF Value Income Type Income Amount

Family trust #1 N/A trustee fees $2,300

For You

Part 2

Report the source and amount of fees that you received for services as a trustee during the 

reporting period if the amount is more than $200.

Description: Provide the name of the trust. For a family trust, you may use initials in 

lieu of a person’s name (e.g., “2003 J.S. Trust”) or simply refer to the entity as a family 

trust (e.g., “family trust #1”).

EIF: Select “N/A.”

Income Type: Describe the type of income as “trustee fees.”

Income Amount: Provide the exact amount of your fees during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 70

Version: 5/2018

OGE Form 278e: Part 3

Your Employment Agreements and Arrangements

Introduction

Report your participation in certain financial agreements or arrangements in Part 3. 

Learn how to report a particular agreement or arrangement by selecting that item from the 

table below.

Bonus (anticipated cash payment)

Carried Interest

Cash Balance Pension Plan

Contingency Fee

Deferred Compensation

Defined Benefit Plan

Defined Contribution Plan

Employee Stock Ownership Plan

Employee Stock Purchase Plan

Future Employment Arrangement

Law Firm (partnership)

Leave of Absence

Legal Practice (solo practice)

Phantom Stock Plan

Post-Employment Executive Benefits

Restricted Stock Plan

Restricted Stock Unit Plan

Severance (anticipated cash payment)

Split-Dollar Life Insurance Arrangement

Stock Appreciation Right Plan

Stock Option Plan

Third-Party Escrow Agreement

TIAA-CREF (held through retirement plan)

Other Agreements and Arrangements 

If you have other agreements or arrangements not listed above, click here for general 

guidance.

No Agreements or Arrangements to Report

If you do not have any agreements or arrangements to report, you need to state this fact. 

Within Integrity, you would make the statement by marking the “I do not have...” 

checkbox. For hard copy reports, write “None” for the first line entry.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 71

Version: 5/2018

Bonus (anticipated cash payment)

Report an arrangement to receive a cash bonus payment in Part 3. In addition, report the 

anticipated bonus in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Widgets Unlimited Madison, 

WI

Pursuant to my employment agreement, I will receive a 

performance-based bonus for services rendered in 2014 up to 

the date of my departure from the firm. This bonus will be 

paid prior to my assuming the duties of the position of Under 

Secretary.

3/02

For You

Part 3

Report any arrangement to receive a bonus. In addition, if you are an Annual or 

Termination filer, report any arrangement to receive a bonus that you had at any point 

during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Describe the nature of the bonus (e.g., “annual year-end performance 

bonus”) and the status of the arrangement (e.g., bonus is still pending, some bonus 

payments were received, or all bonus payments were received). In addition, if the 

payment will be (or was) made pursuant to your employment agreement or a standard 

company policy, state this fact in your description. Consult your ethics official for 

additional assistance regarding the language.

Date: Provide the month and year in which you became covered by the policy or 

agreement that provides for the payment of a bonus from your employer.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 72

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Carried Interest

Report an arrangement for carried interest in Part 3. In addition, report carried interest in 

Part 2 (see Part 2 of this guide for details).

The term “carried interest” may have different meanings. Consult our definition of 

“carried interest” to see how we use this term for purposes of executive branch financial 

disclosure.

Employer or Party City/State Status and Terms Date

Crocus Partners II, LP Rochester, 

NY

Pursuant to my contract, I retain carried interest in Crocus 

Partners II, LP, as compensation for services provided in 

2012-2013. The percentage was fixed in March 2012. 

Payment will be made if and when the fund profits from its 

investments.

3/12

For You

Part 3

Report any arrangement to receive carried interest. In addition, if you are an Annual or 

Termination filer, report any arrangement to receive carried interest that you had at any 

point during the reporting period.

Employer or Party: Provide the name of the entity with which you have the carried 

interest.

City/State: Provide the city and state in which the entity is located.

Status and Terms: Describe the arrangement regarding your carried interest, including

whether the percentage interest has been fixed.

Date: Provide the month and year in which you became covered by the arrangement that 

provides for the payment of carried interest.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 73

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Cash Balance Pension Plan

Report your participation in a cash balance pension plan in Part 3. In addition, report the 

cash balance pension plan in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Regional Electric Portland,

ME

I will continue to participate in this cash balance pension 

plan. The plan sponsor will not make further contributions 

after my separation.

2/93

Widgets Unlimited Madison, 

WI

Following my separation, I will receive a lump sum 

distribution of my Widgets Unlimited cash balance pension 

plan. The firm will not make further contributions after my 

separation.

11/02

For You

Part 3

Report your continued participation in a cash balance pension plan. In addition, if you 

are an Annual or Termination filer, report a cash balance pension plan in which you 

participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a cash balance pension plan and indicate whether 

you (1) will continue to participate, (2) will receive a payout, or (3) have already received 

a payout. If you will continue to participate, specify whether the employer will continue 

to make contributions.

Date: Provide the month and year when you began participating in the cash balance 

pension plan. This often is the date you became an employee of the organization.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 74

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Contingency Fee

Report an arrangement for contingency fee interests in Part 3. In addition, report your 

interest in contingency fee cases in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Faraday, Maxwell & 

Franklin

NY, NY Upon confirmation, I will transfer to Faraday, Maxwell & 

Franklin several cases in which I have a contingency fee 

interest. I will retain an interest in those fees, as stated in my 

agreement with that firm.

5/14

For You

Part 3

Report any continuing interests in contingency fee cases. In addition, if you are an 

Annual or Termination filer, report any interests in contingency fee cases that you had at 

any point during the reporting period.

Employer or Party: Provide the name of the firm or attorney with which you have the 

arrangement.

City/State: Provide the city and state in which the firm or attorney is located.

Status and Terms: Describe the arrangement regarding your contingency fee interests, 

including whether the arrangement is still active. Specifically, report such details as 

whether you have an agreement or arrangement with another lawyer or a firm, such as a 

buy-sell or partnership agreement, that covers what happens to your interest in a 

contingency fee case upon your departure from the firm. Indicate whether you will retain 

an interest in any recovery obtained in a contingency fee case.

Date: Provide the month and year in which you made the arrangement regarding your 

case(s).
Public Financial Disclosure Guide, OGE Form 278e: Part 3 75

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Deferred Compensation

Report your participation in a deferred compensation plan in Part 3. In addition, report 

your deferred compensation in Part 2 (see Part 2 of this guide for details).

For You

Part 3

Report your continuing participation in a deferred compensation plan. In addition, if you 

are an Annual or Termination filer, report a deferred compensation plan in which you 

participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a deferred compensation plan and describe its 

terms in detail. Among other details, state what you will receive and when you will 

receive it. In addition, state any deviations from the normal terms of the plan that the 

employer will make for you. This includes any acceleration of payment, any waiving of 

vesting requirements, and any change in the form or timing of payment or eligibility.

Date: Provide the month and year in which you began participating in the plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 76

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Defined Benefit Plan

Report your participation in a defined benefit plan in Part 3. In addition, report the 

defined benefit plan in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Geotronics Corp. Duluth, MN I will continue to participate in this defined benefit plan. 2/81

For You

Part 3

Report your continued participation in a defined benefit plan (excluding a plan with the 

United States Government). In addition, if you are an Annual or Termination filer, report 

a defined benefit plan in which you participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a defined benefit plan and indicate whether you 

will continue to participate.

Date: Provide the month and year when you began participating in the defined benefit 

plan. This often is the date you became an employee of the organization.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 77

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Defined Contribution Plan

Report your participation in a defined contribution plan in Part 3. In addition, report your 

defined contribution plan in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Tyler Informatics Charlotte, 

NC

I will continue to participate in this defined contribution 

plan. The plan sponsor will not make further contributions 

after my separation.

5/94

For You

Part 3

Report your participation in a defined contribution plan (excluding a plan with the United 

States Government). In addition, if you are an Annual or Termination filer, report a 

defined contribution plan in which you participated at any point during the reporting 

period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a defined contribution plan and indicate whether 

you will continue to participate. If you will continue to participate, specify whether the 

employer will continue to make contributions.

Date: Provide the month and year in which you began participating in the defined 

contribution plan. This often is the date you became an employee of the organization.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 78

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Employee Stock Ownership Plan

Report your participation in an employee stock ownership plan (ESOP) in Part 3. In 

addition, report the employee stock ownership plan in Part 2 (see Part 2 of this guide for 

details).

Employer or Party City/State Status and Terms Date

Widgets Unlimited Madison, 

WI

My participation in the employee stock ownership plan will 

cease upon my separation from the firm.

2/10

For You

Part 3

Report your participation in an employee stock ownership plan. In addition, if you are an 

Annual or Termination filer, report an employee stock ownership plan in which you 

participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Report your participation in the employee stock ownership plan and 

indicate whether you will continue to participate.

Date: Provide the month and year in which you began participating in the employee 

stock ownership plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 79

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Employee Stock Purchase Plan

Report your participation in an employee stock purchase plan (ESPP) in Part 3. In 

addition, report the employee stock purchase plan in Part 2 (see Part 2 of this guide for 

details).

Employer or Party City/State Status and Terms Date

Widgets Unlimited Grand 

Rapids, MI

My participation in the employee stock purchase plan will 

cease upon my separation from the firm.

2/10

For You

Part 3

Report your participation in an employee stock purchase plan. In addition, if you are an 

Annual or Termination filer, report an employee stock purchase plan in which you 

participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Report your participation in the employee stock purchase plan and 

indicate whether you will continue to participate.

Date: Provide the month and year in which you began participating in the employee 

stock purchase plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 80

Version: 5/2018

Future Employment Arrangement

Report your arrangement for future employment in Part 3.

Employer or Party City/State Status and Terms Date

Alberts & Barrow, LLP Miami, FL Employment agreement with Alberts & Barrow, LLP, to 

return to former “of counsel” position with the firm upon 

termination of federal appointment.

2/14

For You

Part 3

Report any arrangement for future employment with an entity other than the United 

States Government. In addition, if you are an Annual or Termination filer, report any 

arrangement for future employment with an entity other than the United States 

Government that you had at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Briefly describe the type of arrangement and its terms. In particular, 

indicate when you will begin employment. If you have a re-employment arrangement 

with a current or former employer, indicate whether you will continue to receive any 

benefits or other payments prior to re-employment.

Date: Provide the month and year in which the arrangement began.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 3 81

Version: 5/2018

Law Firm (partnership)

Report what will happen to your interest in a law firm partnership in Part 3. In addition, 

report the partnership interest in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Faraday, Maxwell & 

Franklin

NY, NY Pursuant to the partnership agreement, following my 

withdrawal from the firm, I will receive my final partnership 

share distribution in four quarterly payments. The total 

amount of the payments will be calculated as of the date of 

my withdrawal.

4/93

Faraday, Maxwell & 

Franklin

NY, NY Pursuant to the partnership agreement, following my 

withdrawal from the firm, I will receive a lump sum payment 

of my capital account. This payment will be calculated as of 

the date of my withdrawal.

4/93

For You

Part 3

Report any agreement or arrangement that you have concerning the refund of your capital 

account, the payment of an anticipated partnership share, and, if applicable, the removal 

of your name from the partnership. In addition, if you are an Annual or Termination 

filer, report any such arrangement that you had at any point during the reporting period.

Employer or Party: Provide the name of the firm.

City/State: Provide the city and state in which the firm is located.

Status and Terms: Provide the terms under which the payments will be (or were) paid. If 

the payments are being (or were) made pursuant to an established agreement or firm 

policy, you should note that fact in your description. In addition, if your name will be (or 

was) removed from the partnership, disclose the change (e.g., “partnership was changed 

to ‘Faraday & Maxwell’ upon my withdrawal”).

Date: Provide the month and year in which you entered into the agreement or 

arrangement.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 82

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Leave of Absence

Report your arrangement for a leave of absence in Part 3.

Employer or Party City/State Status and Terms Date

East State University Fresno, CA I will take an unpaid, two-year leave of absence from my

faculty position.

2/16

East State University Fresno, CA I will continue to participate in the East State 403(b) plan. 

The university will not make contributions during my leave.

8/92

For You

Part 3

Report an arrangement that you have for a leave of absence. In addition, if you are an 

Annual or Termination filer, report any arrangement for a leave of absence that you had 

at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Briefly describe the type of arrangement and its terms. In particular, 

indicate whether the leave is paid or unpaid and specify the duration of the leave. Also, 

indicate whether your employer will continue to make contributions to any retirement or 

benefit plans.

Date: Provide the month and year in which the leave of absence began. If the leave has 

not yet begun, you may enter the current month and year.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 3 83

Version: 5/2018

Legal Practice (solo practice)

Report what will happen to your solo legal practice in Part 3. In addition, report the solo 

legal practice in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Geoffrey Chaucer Santa Fe, 

NM

My solo legal practice will be inactive during my 

appointment and all outstanding client fees will be fixed 

before I enter government service.

7/14

For You

Part 3

Report any arrangement concerning what will happen to your legal practice during your 

period of government service. In addition, if you are an Annual or Termination filer, 

report any such arrangement that you had at any point during the reporting period.

Employer or Party: Provide the name of the practice.

City/State: Provide the city and state in which the practice is located.

Status and Terms: Describe the status of your legal practice and how you will handle (or 

handled) any remaining fees owed to you (e.g., amounts of outstanding fees were fixed 

before entering government service). In addition, describe any arrangements you have 

(or had) with respect to referral fees and contingency fee cases.

Date: Provide the month and year in which you entered into an agreement or 

arrangement with any other parties.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 84

Version: 5/2018

Phantom Stock Plan

Report your participation in a phantom stock plan in Part 3. In addition, report the 

phantom stock in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Steamship Taxi Co. St. Louis, 

MO

Upon separation, I will receive a lump sum cash payment 

equal to the value of my vested phantom stock, calculated as 

of the date of my separation. I will forfeit any unvested 

phantom stock interests.

7/98

For You

Part 3

Report your continuing participation in a phantom stock plan. In addition, if you are an 

Annual or Termination filer, report a phantom stock plan in which you participated at any 

point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a phantom stock plan and describe its terms in 

detail. Among other details, state what you will receive and when you will receive it. In 

addition, state any deviations from the normal terms of the plan that the employer will 

make for you. This includes any acceleration of payment, any waiving of vesting 

requirements, and any change in the form or timing of payment or eligibility.

Date: Provide the month and year in which you began participating in the phantom stock 

plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 85

Version: 5/2018

Post-Employment Executive Benefits

Report an agreement or arrangement for post-employment executive benefits in Part 3.

Employer or Party City/State Status and Terms Date

Allied Business 

Computing, Inc.

Reston, VA Pursuant to company policy, as a retired corporate officer, I 

and my spouse will retain health insurance coverage for life.

10/97

For You

Part 3

Report any executive benefits that you will continue to receive after leaving an employer. 

In addition, if you are an Annual or Termination filer, report any arrangement for 

executive benefits from a former employer that you had at any point during the reporting 

period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Briefly describe the type of benefits received under the agreement or 

arrangement and the status of your participation.

Date: Provide the month and year in which you became covered by the agreement or 

arrangement.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 86

Version: 5/2018

Restricted Stock Plan

Report your participation in a restricted stock plan in Part 3. In addition, report the 

restricted stock in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Icebox Repair Company Stowe, VT I will forfeit my unvested restricted stock upon my 

separation.

5/05

For You

Part 3

Report your participation in a restricted stock plan. In addition, if you are an Annual or 

Termination filer, report a restricted stock plan in which you participated at any point 

during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a restricted stock plan and describe what will 

happen (or has happened) to your restricted stock (e.g., retention until vesting, forfeiture 

of unvested restricted stock, acceleration of vesting prior to entering government service, 

etc.). If applicable, specify the timeframe in which these actions will occur.

Date: Provide the month and year in which you began participating in the restricted stock 

plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 87

Version: 5/2018

Restricted Stock Unit Plan

Report your participation in a restricted stock unit (RSU) plan in Part 3. In addition, 

report the restricted stock units in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Mimeograph Supply Co. Nashville, 

TN

Pursuant to the company’s executive compensation plan, my 

unvested restricted stock units will vest upon separation. At 

that time, I will receive a cash payout.

11/02

For You

Part 3

Report your participation in a restricted stock unit plan. In addition, if you are an Annual 

or Termination filer, report a restricted stock unit plan in which you participated at any 

point during the reporting period. 

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a restricted stock unit plan and describe what will 

happen (or has happened) to your restricted stock units (e.g., retention of RSUs, payout of 

vested RSUs, forfeiture of unvested RSUs, or accelerated payout of unvested RSUs prior 

to government appointment, etc.). If applicable, specify the timeframe in which these 

actions will occur and the form that any payout will take (e.g., cash or stock).

Date: Provide the month and year in which you began participating in the restricted stock 

unit plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 88

Version: 5/2018

Severance (anticipated cash payment)

Report an arrangement to receive a cash severance payment in Part 3. In addition, report 

the anticipated severance in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

SendNow Co. Fort Wayne, 

IN

Pursuant to my employment agreement, I will receive a lump 

sum severance payment within 90 days of my separation 

from the firm.

5/07

For You

Part 3

Report any arrangement to receive a severance payment. In addition, if you are an 

Annual or Termination filer, report any arrangement to receive a severance payment that 

you had at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Describe the terms under which the severance will be (or was) paid 

(e.g., “quarterly payments over two years” or “lump sum before entering government 

service”). If the severance is being (or was) paid pursuant to an established agreement or 

company policy, also note that fact in your description. Consult your ethics official for 

additional assistance regarding the language.

Date: Provide the month and year in which you became covered by the policy or 

arrangement that provides for a severance payment.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 89

Version: 5/2018

Split-Dollar Life Insurance Arrangement

Report your arrangement for coverage by a split-dollar life insurance policy in Part 3. In 

addition, report the policy coverage in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

SendNow Co. Fort Wayne, 

IN

After my separation, the firm will continue paying the 

premiums for my split-dollar variable life policy, which the 

firm will recover from the death benefit.

2/09

For You

Part 3

Report your continued participation in a split-dollar life insurance policy arrangement. In 

addition, if you are an Annual or Termination filer, report a split-dollar life insurance 

policy arrangement in which you participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the arrangement as a split-dollar life insurance policy and 

indicate whether you will continue to be covered by the policy. If you will continue to 

participate, specify whether the employer will continue to make contributions. You do 

not need to specify how the premiums will be repaid, but providing this information is 

helpful.

Date: Provide the month and year in which your coverage began.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 90

Version: 5/2018

Stock Appreciation Right Plan

Report your participation in a stock appreciation right plan in Part 3. In addition, report 

the stock appreciation rights in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Steamship Taxi Co. St. Louis, 

MO

All unvested stock appreciation rights will be forfeited upon 

my separation. I will exercise or forfeit my vested rights. 

Payment of any exercised rights will be in the form of a cash 

lump sum.

7/06

For You

Part 3

Report your participation in a stock appreciation right plan. In addition, if you are an 

Annual or Termination filer, report a stock appreciation right plan in which you 

participated at any point during the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a stock appreciation right plan and describe what 

will happen (or has happened) to your stock appreciation rights (e.g., retention of stock 

appreciation rights, exercise of vested rights, forfeiture of unvested rights, or accelerated 

payout of unvested rights). If applicable, specify the timeframe in which these actions 

will occur and the form that any payout will take (e.g., cash or stock).

Date: Provide the month and year in which you began participating in the stock 

appreciation right plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 91

Version: 5/2018

Stock Option Plan

Report your participation in an incentive stock option plan in Part 3. In addition, report 

the incentive stock options in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Mimeograph Supply Co. Nashville, 

TN

I will forfeit my unvested stock options upon separation. I 

will retain my vested stock options.

11/02

For You

Part 3

Report your participation in a stock option plan. In addition, if you are an Annual or 

Termination filer, report a stock option plan in which you participated at any point during 

the reporting period.

Employer or Party: Provide the name of the employer.

City/State: Provide the city and state in which the employer is located.

Status and Terms: Identify the plan as a stock option plan and describe what will happen 

(or has happened) to your stock options (e.g., retention, exercise, forfeiture, accelerated 

vesting, etc.). If applicable, specify the timeframe in which these actions will occur (e.g., 

“upon my separation”).

Date: Provide the month and year in which you began participating in the stock option 

plan.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 92

Version: 5/2018

Third-Party Escrow Agreement

Report your participation in an escrow agreement in Part 3. In addition, report the 

escrow agreement in Part 2 (see Part 2 of this guide for details).

Employer or Party City/State Status and Terms Date

Tristate Bank Philadelphia, PA Escrow account with Tristate Bank is from the sale of 

WQX Systems, LLC. Under the provisions of the 

purchase plan with Widgets Unlimited, $2 million is 

being held in escrow for unforeseen costs and liabilities 

for matters predating the sale. The remainder will be 

distributed to me in December 2016. There have been no 

such costs or liabilities reported thus far.

1/15

Widgets Unlimited Madison, WI See above.

WQX Systems, LLC Denver, CO See above.

For You

Part 3

Report your continued participation in a third-party escrow agreement. In addition, if 

you are an Annual or Termination filer, report a third-party escrow agreement in which 

you participated at any point during the reporting period.

Employer or Party: Provide the names of the grantee, grantor, and escrow agent (or 

depositary).

City/State: Provide the city and state in which each party is located.

Status and Terms: Describe the terms and status of the escrow agreement. Specifically, 

report such details as the purpose of the escrow agreement, including the name of the 

escrow holder or agent; the nature and amount of the underlying business or real estate 

transaction; and the timeframe needed to execute the transaction. In addition, report any 

anticipated conditions affecting the transaction’s completion.

Date: Provide the month and year in which the escrow agreement began.
Public Financial Disclosure Guide, OGE Form 278e: Part 3 93

Version: 5/2018

TIAA-CREF (held through retirement plan)

Report your participation in a retirement plan in Part 3. In addition, report the TIAACREF products in Part 2 (see Part 2 of this guide for details).

Employer or State City/State Status and Terms Date

East State University Charlotte, 

NC

I will continue to participate in this defined contribution 

plan. The plan sponsor will not make further contributions 

after my separation.

5/94

For You

Part 3

If you hold or held a TIAA-CREF product through a retirement plan, report your 

continued participation in the plan. In addition, if you are an Annual or Termination filer, 

report a retirement plan in which you participated at any point during the reporting 

period.

Employer or Party: Provide the name of the employer. (Note: Do not list TIAA-CREF 

as a party. The arrangement that is relevant for financial disclosure purposes is your 

arrangement with the employer-sponsored retirement plan through which you acquired 

the TIAA-CREF product.)

City/State: Provide the city and state in which the employer is located.

Status and Terms: Report the type of plan (e.g., “defined contribution plan” or “401(k)”) 

and indicate whether you will continue to participate. If you will continue to participate, 

specify whether the employer will continue to make contributions.

Date: Provide the month and year in which you began participating in the plan. This 

often is the date you became an employee of the organization.
Public Financial Disclosure Guide, OGE Form 278e: Part 4 94

Version: 5/2018

OGE Form 278e: Part 4

Your Sources of Compensation Exceeding $5,000 in a Year 

(Nominee and New Entrant Reports Only)

Report the source of any non-federal compensation that exceeded $5,000 in any calendar 

year during the reporting period in Part 4.

Source Name City/State Brief Description of Duties

Faraday, Maxwell & Franklin New York, NY Associate attorney at this firm.

Widgets Unlimited Grand Rapids, 

MI

Legal services (client of Faraday, Maxwell & Franklin)

For You

Part 4

Report any source that paid more than $5,000 for your personal services in any calendar 

year during the reporting period, which covers the preceding two calendar years and the 

current calendar year up to the date of filing.

Report such payments both from employers and from any clients to whom you personally 

provided services. You must report a source even if the source made its payment to your 

employer and not to you. As an exception to the requirement to report sources of such 

payments, do not include the United States Government as a source.

Do not report a client’s payment to your employer if you did not provide the services for 

which the client is paying. Because another employee, associate, or partner provided the 

services, the payment is not for services that you personally provided and, therefore, is 

not reportable in Part 4.

Generally, report sources as follows:

Source Name: Provide the name of the source.

City/State: Provide the city and state in which this source is located.

* In certain rare cases, you need not publicly disclose the identity of confidential clients. 

In those cases, specify the reason(s) why confidential clients have not been disclosed. 

For each reason specified, indicate the number of confidential clients that have not been 

disclosed and indicate how many clients are entities and how many are individuals (e.g., 

“2 confidential clients are not disclosed because they are subject to non-public 

investigations = 1 partnership and 1 individual”). For Presidential nominees, the nondisclosure of confidential clients must be approved in advance by OGE.

Brief Description of Duties: Provide a brief description of the type of services rendered.
Public Financial Disclosure Guide, OGE Form 278e: Part 4 95

Version: 5/2018

For Your Spouse or Your Dependent Children

Do not report your spouse’s or dependent children’s sources of compensation in Part 4.

No Sources of Compensation to Report

If you do not have any sources of compensation to report, you need to state this fact. 

Within Integrity, you would make the statement by marking the “I do not have...” 

checkbox. For hard copy reports, write “None” for the first line entry.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 5 96

Version: 5/2018

OGE Form 278e: Part 5

Spouse’s Employment Assets and Income (including retirement 

accounts)

Introduction

Report your spouse’s assets and income related to employment in Part 5. For purposes of 

this Part, “employment-related” is interpreted broadly to cover, with certain exceptions, 

all of your spouse’s non-investment activities as well as your spouse’s retirement 

accounts. Learn how to report a particular asset by selecting that asset or source of 

income from the table below.

Bonus (cash)

Carried Interest

Cash Balance Pension Plan

Deferred Compensation

Defined Benefit Plan

Defined Contribution Plan

Director Fee

Employee Stock Ownership Plan

Employee Stock Purchase Plan

Executor or Administrator Fee

Farm (operated as a business)

Government Benefit or Payment

Honorarium

Intellectual Property

Investment Fund (general)

IRA, Roth IRA, SEP IRA, or Keogh Plan

Law Firm (partnership)

Legal Practice (solo practice)

Life Insurance (split-dollar)

Money Purchase Pension Plan

Option (incentive stock option plan)

Phantom Stock

Restricted Stock

Restricted Stock Unit (RSU)

Salary

Self-Funded Defined Benefit Plan

Severance Payment (cash)

Small Business (general)

Stable Value Fund

Stock

Stock Appreciation Right

Third-Party Escrow Agreement

TIAA-CREF

Trustee Fee
Public Financial Disclosure Guide, OGE Form 278e: Part 5 97

Version: 5/2018

Other Assets and Income Related to Your Spouse’s Employment

If your spouse has other types of assets or income related to employment not listed above, 

click here for general guidance.

No Assets or Income Related to Your Spouse’s Employment

If you do not have any assets or income to report related to your spouse’s employment, 

you need to state this fact. Within Integrity, you would make the statement by marking 

the “I do not have...” checkbox. For hard copy reports, write “None” for the first line 

entry.
Public Financial Disclosure Guide, OGE Form 278e: Part 5 98

Version: 5/2018

Bonus (cash)

Report a cash bonus that your spouse received in Part 5.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A bonus

For Your Spouse

Part 5

Report your spouse’s bonus if your spouse received more than $1,000 during the 

reporting period.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “bonus.”
Public Financial Disclosure Guide, OGE Form 278e: Part 5 99

Version: 5/2018

Carried Interest

Generally, report your spouse’s carried interests in Part 5.

The term “carried interest” may have different meanings. Consult our definition of 

“carried interest” to see how we use this term for internal purposes of executive branch 

financial disclosure. For interests that do not meet this specific definition, your agency’s 

ethics official will need to consult OGE for guidance on the reporting requirements.

Description EIF Value Income Type Income Amount

Crocus Partners II, LP, carried 

interest (value not readily 

ascertainable)

N/A None (or less than 

$201)

For Your Spouse

Part 5

As a matter of policy, OGE deems a carried interest to have a value that exceeds $1,000. 

Therefore, carried interests must be reported. Also, if your spouse no longer has a carried 

interest but received more than $200 in income related to a carried interest during the 

reporting period, you need to report the income.

Description: Indicate that the asset is a carried interest and provide the name of the entity 

through which your spouse has the carried interest.

EIF: Select “N/A.”

Value: Report the value of the carried interest by marking the appropriate category. If 

you cannot ascertain the value, leave this field blank but write “value not readily 

ascertainable” in the “Description” field.

Income Type: Specify the type of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category that corresponds to the total amount of income 

during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 5 100

Version: 5/2018

Cash Balance Pension Plan

Report your spouse’s cash balance pension plan in Part 5.

Description EIF Value Income Type Income Amount

Regional Electric, cash balance 

pension plan

N/A $50,001 - $100,000 None (or less than 

$201)

Widgets Unlimited, cash balance 

pension plan

N/A $100,001 - $250,000 retirement 

payments

For Your Spouse

Part 5

Report a cash balance pension plan if the value of the plan was more than $1,000 at the 

end of the reporting period or if your spouse received more than $1,000 in retirement 

payments during the reporting period.

Description: Report the name of the employer providing the plan and write “cash balance 

pension plan.”

EIF: Select “N/A.”

Value: Report the value of the plan by selecting the appropriate category. The value is 

the dollar value indicated in the statement provided by the plan’s administrator.

Income Type: Write “retirement payments” if your spouse is receiving payments or 

received a lump sum distribution.

Income Amount: Select “None (or less than $201)” if your spouse has not received any 

payments. Do not complete this field if your spouse is receiving or has received 

payments because writing “retirement payments” in the “Income Type” field is sufficient.
Public Financial Disclosure Guide, OGE Form 278e: Part 5 101

Version: 5/2018

Deferred Compensation

Report your spouse’s deferred compensation in Part 5.

Deferred compensation can take many forms, and the reporting requirements will vary 

based on the timing of the compensation and its form. The examples below are intended 

to be merely illustrative of the various forms that deferred compensation may take. 

Regardless of the form of your spouse’s deferred compensation, you should work with an 

ethics official at your agency to ensure complete and accurate disclosure. 

Our guidance on deferred compensation is broken into the following sections:

Example 1: Already Received Lump Sum Cash Payment

Example 2: Future Lump Sum Cash Payment That is Fixed

Example 3: Payments in the Form of Assets – Received or Anticipated

Example 4: Deferred Compensation Plan with Underlying Assets

Example 5: Deferred Compensation Plan Linked to an Index or Other Benchmark

Example 1: Already Received Lump Sum Cash Payment

Your spouse may have already received deferred compensation, and it may have taken 

the form of a lump sum cash payment. In that case, follow the guidance provided in this 

example.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: received

N/A cash payment

Part 5

Report a lump sum cash payment (or payments) that your spouse received from a source 

if the total amount exceeded $1,000 during the reporting period.

Description: Report the name of the employer providing the payment and write “deferred 

compensation: received.” In addition, for a privately held business, describe the line of 

business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Income Type: Describe the type of income as “cash payment.”
Public Financial Disclosure Guide, OGE Form 278e: Part 5 102

Version: 5/2018

Example 2: Future Lump Sum Cash Payment That is Fixed

Your spouse’s employer may owe your spouse deferred compensation in the future in the 

form of a lump sum cash payment. That lump sum payment may be a fixed, as opposed 

to variable, amount that has already been determined. In that case, this example provides 

guidance on reporting the fixed amount lump sum payment that your spouse’s employer 

owes.

Instead of being fixed, the amount of your spouse’s future lump sum payment may 

depend on the performance of investments. Alternatively, it may depend on the 

performance of something tracked, such as an index, a mutual fund, or some other 

benchmark. In either of those cases, Example 2 would not apply to your spouse’s 

situation. You should refer to either Example 4 or 5 below for guidance on a “Deferred 

Compensation Plan with Underlying Assets” or a “Deferred Compensation Plan Linked 

to an Index or Other Benchmark.”

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: cash receivable

N/A $50,001 - $100,000 None (or less than 

$201)

Part 5

Report an anticipated lump sum cash payment if the fixed amount that your spouse is 

owed was more than $1,000 at the end of reporting period.

Description: Report the name of the employer providing the payment and write “deferred 

compensation: cash receivable.” In addition, for a privately held business, describe the 

line of business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the fixed lump sum payment 

that your spouse is owed. 

Income Amount: Select the category for “None (or less than $201).”

Example 3: Payments in the Form of Assets – Received or Anticipated

Your spouse may have an arrangement for deferred compensation in the form of assets or 

options, rather than cash. If your spouse has not yet received the deferred compensation, 

provide the name of the employer and write “deferred compensation receivable” in the 

“Description” field. Then, report the assets using the guidance appropriate for that type 

of asset (e.g., stock, stock options, restricted stock, stock appreciation right, phantom 

stock, and restricted stock units).
Public Financial Disclosure Guide, OGE Form 278e: Part 5 103

Version: 5/2018

Example 4: Deferred Compensation Plan with Underlying Assets

This example addresses the situation of a deferred compensation plan only if your spouse 

has a plan that holds underlying assets and you have determined, in consultation with 

your spouse’s employer or your attorney, that this plan is accurately described as a 

“deferred compensation” plan.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation:

N

- Halley Engineering N/A $50,001 - $100,000 None (or less than 

$201)

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A $50,001 - $100,000 None (or less than 

$201)

Part 5

Report the deferred compensation plan and each underlying asset of the plan that 

individually was worth more than $1,000 at the end of the reporting period or that 

individually produced more than $200 in income during the reporting period.

Description: Provide the name of the employer and write “deferred compensation.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

Next, report each of the underlying assets that individually was worth more than $1,000 

at the end of the reporting period or that individually produced more than $200 in income 

during the reporting period.

EIF: Select “N.” In addition, for each underlying asset, indicate whether the asset 

(1) qualifies as an EIF (“Y”), (2) does not qualify as an EIF (“N”), or (3) is not an 

investment vehicle that holds other assets (“N/A”).

Value: You do not need to provide the overall value for the plan. Instead, provide the 

individual value of each underlying asset by selecting the appropriate category.

Income Type: You do not need to provide the type(s) of income for the plan as a whole. 

Instead, provide the type(s) of income produced by each underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.

Income Amount: Provide the amount of income produced by each underlying asset 

during the reporting period.

(1) Income less than $201: Select the category for “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 5 104

Version: 5/2018

(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Example 5: Deferred Compensation Plan Linked to an Index or Other 

Benchmark

Your spouse may have an interest in a deferred compensation plan under which your 

spouse’s employer owes a future lump sum payment that is not fixed but variable.

The amount of that future lump sum payment may depend on the performance of 

something tracked, such as an index, a mutual fund, or some other benchmark. However, 

your spouse does not, through the deferred compensation plan, own the thing being 

tracked. (For instance, the plan may track the performance of the S&P 500 or the 

performance of a mutual fund that mirrors the S&P 500. However, your spouse does not 

hold, through the deferred compensation plan, shares of the companies listed on the 

S&P 500 or shares of the mutual fund. Instead, the employer owes your spouse a cash 

payment, and the employer may pay more money if the S&P 500 performs well or may 

pay less money if the S&P 500 performs poorly.)

This example provides guidance on reporting the variable amount lump sum payment of 

deferred compensation that an employer owes your spouse.

Description EIF Value Income Type Income Amount

Halley Engineering, deferred 

compensation: tracks S&P 500

N/A $50,001 - $100,000 None (or less than 

$201)

Part 5

Report your spouse’s interest in the plan if the value of your spouse’s interest was more 

than $1,000 at the end of the reporting period or if your spouse’s interest produced more 

than $200 in income during the reporting period.

Description: Provide the name of the employer, write “deferred compensation,” and 

specify the index or other benchmark that your spouse’s future payment tracks. In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of your spouse’s interest.

Income Amount: Select the category for “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 5 105

Version: 5/2018

Defined Benefit Plan

Report your spouse’s defined benefit plan in Part 5.

Description EIF Value Income Type Income Amount

Regional Electric, defined benefit 

plan (value not readily 

ascertainable)

N/A None (or less than 

$201)

Widgets Unlimited, defined benefit 

plan (value not readily 

ascertainable)

N/A retirement 

payments

For Your Spouse

Part 5

Report a defined benefit plan if the value of the plan was more than $1,000 at the end of 

the reporting period or if your spouse received more than $1,000 in retirement payments 

during the reporting period. Do not report a plan that your spouse obtained through 

United States Government employment.

Description: Report the name of the employer providing the plan and write “defined 

benefit plan.”

EIF: Select “N/A.”

Value: Report the value of the plan by selecting the appropriate category. If you cannot 

ascertain the value, leave this field blank and write “value not readily ascertainable” in 

the “Description” field.

Income Type: Write “retirement payments” if your spouse is receiving payments or 

received a lump sum distribution.

Income Amount: Select the “None (or less than $201)” category if your spouse has not 

received any payments. Do not complete this field if your spouse is receiving or has 

received payments because writing “retirement payments” in the “Income Type” field is 

sufficient.
Public Financial Disclosure Guide, OGE Form 278e: Part 5 106

Version: 5/2018

Defined Contribution Plan

Report your spouse’s defined contribution plan in Part 5.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

Tyler Informatics, 401(k) plan: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For Your Spouse

Part 5

Report each underlying asset of the defined contribution plan that individually was worth 

more than $1,000 at the end of reporting period or that individually produced more than 

$200 in income during the reporting period. Although this information is not required, 

you may specify that the assets are held within a defined contribution plan.

This guide contains specific instructions for common types of assets held within a 

defined contribution plan (e.g., mutual funds, exchange-traded funds, stocks, and 

corporate bonds).
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Director Fee

Report the source of your spouse’s director fees in Part 5.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A director fees

For Your Spouse

Part 5

Report the source of your spouse’s director fees during the reporting period if the amount 

is more than $1,000.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “director fees.”
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Employee Stock Ownership Plan

Report your spouse’s employee stock ownership plan (ESOP) in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, ESOP account N/A $1,001 - $15,000 None (or less than 

$201)

For Your Spouse

Part 5

Report an ESOP account if the value of the account was more than $1,000 at the end of 

the reporting period or if the account produced more than $200 in income during the 

reporting period.

Description: Provide the name of the employer and write “ESOP account” or “employee 

stock ownership plan account.” In addition, for a privately held business, describe the

line of business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the account by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income. Most 

filers select “None (or less than $201).”
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Employee Stock Purchase Plan

Report your spouse’s employee stock purchase plan (ESPP) in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, ESPP account N/A $1,001 - $15,000 None (or less than 

$201)

For Your Spouse

Part 5

Report an ESPP account if the cash balance of the account was more than $1,000 at the 

end of the reporting period or if the account produced more than $200 in income during 

the reporting period.

Description: Provide the name of the employer and write “ESPP account” or “employee 

stock purchase plan account.” In addition, for a privately held business, describe the line 

of business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the account by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income. Most 

filers select “None (or less than $201).”

Reporting Stock Acquired Through an ESPP Account

Report any stock that your spouse acquired as a separate line item entry, using the 

standard instructions for stock.
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Executor or Administrator Fee

Report fees for your spouse’s service as an executor or administrator in Part 5. In 

addition, report the following interests in Part 6: (1) assets distributed from an estate and 

(2) a beneficial interest in an estate that has not yet been distributed. Do not report an 

interest in the will of a living person.

Description EIF Value Income Type Income Amount

Estate of Ms. Eliot N/A executor fees

Estate of a family member N/A administrator fees

For Your Spouse

Part 5

Report the source of fees that your spouse received if the amount was more than $1,000 

during the reporting period.

Description: Identify the estate. If the estate is that of a relative, you may write “estate 

of a family member.” In other cases, identify the estate by the last name of the party 

(e.g., “Estate of Mr. Doe”).

EIF: Select “N/A.”

Income Type: Write “executor fees” or “administrator fees.”
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Farm (operated as a business)

Report a farm that your spouse operates as a business in Part 5.

Description EIF Value Income Type Income Amount

Spouse’s farm, Boise, ID, 

sole proprietor (crops)

$250,001 - $500,000 farming income

For Your Spouse

Part 5

Reporting a Farm in Which You Have No Financial Interest

Report a farm that your spouse operates as a business, and in which you have no financial 

interest, if its value was more than $1,000 at the end of the reporting period or if it 

produced more than $1,000 in earned income during the reporting period (or $200 in 

interest, dividends, capital gains, rent, or royalties).

Do not report passive investment interests in a farm in Part 5. Report these interests in 

Part 6 instead.

Description: Provide the name of farm (or write “spouse’s farm” for a sole 

proprietorship); the location of the farm (either the city and state or the county and state); 

and the business of the farm, such as crops or livestock. In addition, it is helpful if you 

specify the type of interest that your spouse has in the farm, such as “sole proprietor” or 

“general partner.”

EIF: Select “N/A.”

Value: Select the appropriate category to report the value of the farm, including such 

assets as the land, the crops (standing or in storage), the livestock, the farm equipment, 

the buildings, etc.

Income Type: Write “farming income” if your spouse’s earned income exceeded $1,000 

during the reporting period. Select the applicable type of income categories for income 

over $200 that can be classified as interest, dividends, capital gains, rent, or royalties.

Income Amount: Select the categories corresponding to the total amount of interest, 

dividends, capital gains, rent, or royalties. Do not provide an amount for earned income.

Reporting a Farm in Which You Have a Financial Interest

If you have only a passive investment interest in a farm that your spouse operates as a 

business, you may use the guidance above for your spouse’s interest in the farm and may 

report your interest in Part 6. If you also have an active role in the business, you would 

report your interest in Part 2.
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Government Benefit or Payment

For Your Spouse 

Do not report:

• Income your spouse received as an employee of the United States Government, 

including military Reserve pay.

• Retirement benefits your spouse received from the United States Government, 

including the Thrift Savings Plan and any other United States Government 

retirement system.

• Your spouse’s income from the United States Government’s Social Security, 

veterans’ benefits, and other similar United States Government benefits programs.

• Your spouse’s income from state, local, or foreign government benefits programs.

Report in Part 5:

• Honoraria your spouse received from the United States Government.

• Consulting fees your spouse received as an independent contractor with the 

United States Government.

• Salary your spouse received from state, local, or foreign government employment.

• Honoraria or consulting fees your spouse received from state, local, or foreign 

government sources.

• Your spouse’s retirement benefits from a state, local, or foreign government, such 

as participation in a defined benefit plan or a defined contribution plan.

• When reporting a payment to your spouse, describe the type but not the amount of 

the payment (unless honoraria).
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Honorarium

Report an honorarium that your spouse received in Part 5.

Description EIF Value Income Type Income Amount

Loomis County University –

8/12/2015

N/A honorarium $220

Loomis County University –

10/20/2015

N/A honorarium $220

For Your Spouse 

Part 5

If your spouse received honoraria from a single source aggregating more than $200 

during the reporting period, report each honorarium received from that source.

Description: Provide the name of the source that paid the honorarium and enter the date 

of the services.

Income Type: Describe the type of income as “honorarium.”

Income Amount: Provide the exact amount of the honorarium.
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Intellectual Property

Report your spouse’s intellectual property and income from intellectual property in 

Part 5.

Description EIF Value Income Type Income Amount

“History of Clocks,” Stateburg 

University Press (value not readily 

ascertainable)

N/A rent or royalties $201 - $1,000

“Financial Disclosure,” 4th ed., 

Zorn & Co. (value not readily 

ascertainable)

N/A advance

“Circular frame and hub system for 

a conveyance,” Patent # 

202,482,924 (value not readily 

ascertainable)

N/A None (or less than 

$201)

For Your Spouse

Part 5

Report your spouse’s intellectual property if any of the following are true: (1) the value 

of the intellectual property was more than $1,000 at the end of the reporting period, 

(2) the intellectual property produced more than $200 in royalties or capital gains during 

the reporting period, or (3) your spouse received an advance of more than $1,000 during 

the reporting period. If your spouse received any other type of income, consult your 

ethics official regarding reporting requirements.

Description: Describe the intellectual property. For a book, provide the name of the 

book and identify the publisher. For a patent, provide the patent number and a very brief 

description of the patent. For other types of intellectual property, provide a similarly 

specific description that is sufficient for the reader to understand the nature of your 

spouse’s property. 

EIF: Select “N/A.”

Value: Report the value of the intellectual property by selecting the appropriate category. 

If you cannot ascertain the value, leave this field blank but write “value not readily 

ascertainable” in the “Description” field.

Income Type: If your spouse earned royalties in excess of $200 during the reporting 

period, select the category labeled “rent or royalties.” If your spouse received an advance 

or other earned income, describe the type of income in the space provided.

Income Amount: Select the category that corresponds to the total amount of royalties 

produced during the reporting period. Do not provide an amount for advances or other 

earned income.
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Investment Fund (general)

If your spouse has an equity interest in an investment fund related to, or acquired 

through, employment, report the fund in Part 5. In addition, report any investment fund 

held through a retirement plan or individual retirement account in Part 5.

Note that other entries in this guide specifically address mutual funds, exchange-traded 

funds, and money market funds. See those entries for more targeted guidance if 

applicable.

Investment Fund Qualifies as an EIF

Description EIF Value Income Type Income Amount

Positron Investments XI, LP Y $100,001 - $250,000 $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If You Know the Value and Income of the 

Underlying Assets

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A $15,001 - $50,000 None (or less than 

$201)

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A $15,001 - $50,000 None (or less than 

$201)

- WQX Optics (medical devices) N/A $1,001 - $15,000 capital gains $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If the Value and Income of the 

Underlying Assets is Not Readily Ascertainable

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N $50,001 - $100,000 capital gains $5,001 - $15,000

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A

- WQX Optics (medical devices) N/A

For Your Spouse 

Part 5

Report an equity interest in an investment fund if the value was more than $1,000 at the 

end of the reporting period or if the interest produced more than $200 in total income 
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during the reporting period. See “Other Interests” below if your spouse manages the 

investment fund.

The reporting requirements will depend on whether the investment fund qualifies as an 

excepted investment fund (EIF).

Investment Fund Qualifies as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category. 

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Investment Fund Does Not Qualify as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “N.”

Additional Disclosure of Underlying Assets: Because the investment fund does not 

qualify as an EIF, you need to report each underlying asset of the fund that was worth 

more than $1,000 at the end of the reporting period or that produced more than $200 in 

income during the reporting period. For purposes of this calculation, you may use the 

interest that your spouse has in the asset. Report each underlying asset using the 

guidance applicable to that type of asset.

In certain cases, investment funds do not provide information regarding an investor’s 

interest in the value and/or income of the fund’s underlying assets. If you are unable to 

ascertain the value of the underlying assets, you may instead provide value information 

for the total interest that your spouse has in the fund. Similarly, if you are unable to 

ascertain the income of the underlying assets, you may instead provide income 

information for the total interest that your spouse has in the fund.

Note that you need only provide a description of your spouse’s earned income under the 

financial disclosure rules. Therefore, if any of the income from the fund constitutes your 

spouse’s earned income, you may provide just a description rather than a description and 

amount of income.
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Other Interests

Additional requirements may apply if your spouse has ever worked for the company that 

manages the investment fund. Click here for guidance on these additional requirements.
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IRA, Roth IRA, SEP IRA, or Keogh Plan

Report the underlying assets of your spouse’s Individual Retirement Account (IRA), Roth 

IRA, Simplified Employee Pension Individual Retirement Account (SEP IRA), or Keogh 

plan in Part 5.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

IRA #1: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For Your Spouse

Part 5

Report each underlying asset of your spouse’s IRA, Roth IRA, SEP IRA, Keogh plan, or 

other individual account that individually was worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period. You may indicate that the assets are held within a retirement account, 

but this information is not required.

This guide contains specific instructions for common types of assets held within a 

retirement account (e.g., mutual funds, exchange-traded funds, stocks, and corporate 

bonds).
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Law Firm (partnership)

Report your spouse’s law firm partnership in Part 5.

Description EIF Value Income Type Income Amount

Faraday, Maxwell & Franklin 

(law firm)

N/A partnership share

Faraday, Maxwell & Franklin, 

capital account

N/A $50,001 - $100,000 None (or less than 

$201)

For Your Spouse

Part 5

Report a law firm partnership interest of your spouse if its value was more than $1,000 at 

the end of the reporting period or if it produced more than $1,000 in earned income 

during the reporting period (or $200 in interest, dividends, capital gains, rent, or 

royalties).

If Your Spouse Has Received a Partnership Share

Description: Provide the name of the law firm. You should also indicate that the entity is 

a law firm, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Income Type: Describe the type of income as “partnership share.”

Capital Account 

Description: Provide the name of the law firm and write “capital account.”

EIF: Select “N/A.”

Value: Select the category that corresponds to the value of the capital account.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200. The type of income is usually “interest” for capital 

accounts.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Other Interests

Business Assets and Liabilities: You need not itemize the assets and liabilities of the law 

firm. Disclosing the law firm itself is normally sufficient. As an exception to this rule, 
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you would report any assets or liabilities that are unrelated to the operations of the law 

firm.

Compensation and Other Benefits: In addition to partnership income, report any 

additional compensation and other benefits. Report these as separate line entries using 

the instructions for that type of asset or income. For example, various sections of this 

guide address: severance payments, bonuses, deferred compensation, defined benefit 

plans, defined contribution plans, and other items.
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Legal Practice (solo practice)

Report your spouse’s solo legal practice in Part 5.

Description EIF Value Income Type Income Amount

Law firm (solo legal practice) N/A $100,001 - $250,000 legal fees

For Your Spouse

Part 5

Report your spouse’s solo legal practice if the value of the practice was more than $1,000 

at the end of the reporting period or if the practice produced more than $1,000 in income 

during the reporting period.

Description: Indicate that your spouse practices law as a solo practitioner.

EIF: Select “N/A.”

Value: Report the value of the practice by selecting the appropriate category. The value 

of the practice would include all assets held by the practice, unless itemized separately.

Income Type: Describe the type of income as “legal fees.”

Other Interests

Business Assets and Liabilities: You need not itemize the assets and liabilities of your 

spouse’s legal practice. Disclosing the legal practice itself is normally sufficient. As an 

exception to this rule, you would report any assets or liabilities that are unrelated to the 

operations of the legal practice.
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Life insurance (split-dollar)

Report your spouse’s coverage by a split-dollar life insurance policy in Part 5.

Description EIF Value Income Type Income Amount

Mutual of Spokane, split-dollar 

variable life through SendNow Co.:

N

- Liberty Income Securities Fund Y $15,001 - $50,000 None (or less than 

$201)

- American U.S. Large Cap Value Y $15,001 - $50,000 None (or less than 

$201)

For Your Spouse

Part 5

Report your spouse’s split-dollar life insurance policy if the value of the policy was more 

than $1,000 at the end of the reporting period or if the policy produced more than $200 in 

income during the reporting period.

Description: Provide the name of the insurance company issuing the policy; write “splitdollar” to describe the payment method; note the type of policy (e.g., whole, universal, or 

variable); and provide the name of the employer through which your spouse holds the 

policy. In addition, for a variable split-dollar policy, provide the name of each 

underlying asset within the policy that individually was worth more than $1,000 at the 

end of the reporting period or that individually produced more than $200 in income 

during the reporting period.

EIF: Select “N/A” for whole or universal life policies. Select “N” for the first line entry 

of a variable life policy because the overall policy is an investment vehicle that does not 

qualify as an excepted investment fund. For each underlying asset of a variable life 

policy, indicate whether the asset (1) qualifies as an EIF (“Y”), (2) does not qualify as an 

EIF (“N”), or (3) is not an investment vehicle that holds other assets (“N/A”).

Value: For whole or universal split-dollar policies, report the value of the policy by 

selecting the appropriate category. For variable split-dollar policies, report the value of 

each underlying asset.

Income Type: For whole or universal split-dollar policies, report the type of income 

produced by the policy during the reporting period. For variable split-dollar policies, 

report the income produced by each of the underlying assets. Leave this field blank if the 

amount of income produced did not exceed $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”
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(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.
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Money Purchase Pension Plan

Report your spouse’s money purchase pension plan in Part 5 using the guidance for 

defined contribution plans.
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Option (incentive stock option plan)

Report your spouse’s incentive stock options and any stock acquired through an incentive 

stock option plan in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, stock options N/A $15,001 - $50,000 None (or less than 

$201)

Widgets Unlimited, stock options

(value not readily ascertainable): 

740 vested shares, strike $19, exp. 

1/2018

N/A None (or less than 

$201)

For Your Spouse

Part 5

Report a stock option if the value of the option was more than $1,000 at the end of the 

reporting period or if the option produced more than $200 in income during the reporting 

period.

Reporting Stock Options

Description: Provide the exact name of the stock for which the option was issued and 

write “stock option.” In addition, for a privately held business, describe the line of 

business, unless you have already provided this information in another entry.

EIF: Select “N/A.”

Value: If you are able to determine the value of your spouse’s option, report the value by 

marking the appropriate category. Keep in mind that the value of an option is not the 

same as the value of the stock for which it was issued. However, your spouse’s human 

resources office may be able to provide the value of your stock option. If the employer 

has not provided this information, the U.S. Office of Government Ethics will accept 

either of the following methods of valuation:

(A) If the option is “underwater” or if the value of the option is otherwise difficult to 

determine, write “value not readily ascertainable” in the “Description” field and provide 

the following information: (1) the name of the stock for which the option was issued; 

(2) the number of shares of the stock for which the option was issued; (3) the strike price;

(4) the expiration date; (5) an indication as to whether the option is vested; and (6) the 

date on which the option will vest, if the option is unvested. 

(B) Alternatively, you may use any commonly accepted formula to calculate the value of 

your options (e.g., the Black-Scholes pricing model).
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Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced. Options obtained through employment (e.g., incentive stock options) normally 

do not produce income, which means that most filers select “None (or less than $201).”

Reporting Stock Acquired by Exercising Stock Options

Report any stock that your spouse acquired as a separate line item entry, using the 

standard instructions for stock.
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Phantom Stock

Report your spouse’s phantom stock and income from phantom stock in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, phantom stock N/A $15,001 - $50,000 cash payment

Xylophone Technologies 

Corporation, phantom stock

N/A $15,001 - $50,000 None (or less than 

$201)

For Your Spouse

Part 5

Report phantom stock if the value of the phantom stock was more than $1,000 at the end 

of the reporting period or if the phantom stock produced more than $1,000 in income 

during the reporting period.

Description: Provide the name of the employer and write “phantom stock.” In addition, 

for a privately held business, describe the line of business, unless you have already 

provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the phantom stock by selecting the appropriate category.

Income Type: Write “cash payment” to describe cash income.

Income Amount: Select the “None (or less than $201)” category if your spouse has not 

received any cash income. Do not complete this field if your spouse has received income 

because writing “cash payment” in the “Income Type” field is sufficient.

Reporting Stock Acquired Through a Phantom Stock Plan

Report any stock that your spouse acquired as a separate line item entry, using the 

standard instructions for stock.
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Restricted Stock

Report your spouse’s restricted stock and income from restricted stock in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, restricted stock N/A $15,001 - $50,000 None (or less than 

$201)

For Your Spouse

Part 5

Report restricted stock if the value of the stock was more than $1,000 at the end of the 

reporting period or if the restricted stock produced more than $200 in income during the 

reporting period.

Reporting Unvested Restricted Stock

Description: Provide the exact name of the stock and write “restricted stock.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the restricted stock by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Reporting Restricted Stock That Has Vested

Report the stock as you would any other stock.
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Restricted Stock Unit (RSU)

Report your spouse’s restricted stock units and income from restricted stock units in 

Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, restricted stock 

units

N/A $15,001 - $50,000 cash payment

Xylophone Technologies 

Corporation, restricted stock units

N/A $15,001 - $50,000 None (or less than 

$201)

For Your Spouse

Part 5

Report a restricted stock unit if its value was more than $1,000 at the end of the reporting 

period or if the restricted stock unit produced more than $1,000 in income during the 

reporting period.

Description: Provide the name of the employer and write “restricted stock unit.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the restricted stock unit by selecting the appropriate category.

Income Type: Write “cash payment” to describe cash income.

Income Amount: Select the “None (or less than $201)” category if your spouse has not 

received any cash income. Do not complete this field if your spouse has received income 

because writing “cash payment” in the “Income Type” field is sufficient.

Reporting Stock Acquired Through a Restricted Stock Unit Plan

Report any stock that your spouse acquired as a separate line item entry, using the 

standard instructions for stock.
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Salary

Report the source of your spouse’s salary in Part 5.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation

N/A salary

DSLK Financial Techniques, Inc. 

(financial services)

N/A salary

For Your Spouse

Part 5

Report the source of your spouse’s salary during the reporting period if the amount is 

more than $1,000, unless the salary was from United States Government employment.

Description: Provide the name of your spouse’s employer. In addition, if your spouse’s 

employer is a privately held business, provide the employer’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “salary.”
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Self-Funded Defined Benefit Plan

Report your spouse’s self-funded defined benefit plan and its underlying assets in Part 5.

Description EIF Value Income Type Income Amount

Self-funded defined benefit plan 

(DSLK Financial Techniques, Inc.):

N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For Your Spouse

Part 5

Report a self-funded defined benefit pension plan if the value of the plan was more than 

$1,000 at the end of the reporting period or if the plan produced more than $200 in 

income during the reporting period. In addition, provide the names of each underlying 

asset within the plan that individually was worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period.

Reporting the Plan

Description: Write “self-funded defined benefit plan.” Provide the name of the financial 

institution through which the plan is held.

EIF: Select “N” because a self-funded defined benefit plan is an investment vehicle that 

does not qualify as an excepted investment fund.

Reporting the Underlying Assets

Description: Provide the name of the underlying asset.

EIF: For each underlying asset, indicate whether the asset (1) qualifies as an EIF (“Y”), 

(2) does not qualify as an EIF (“N”), or (3) is not an investment vehicle that holds other 

assets (“N/A”).

Value: Report the value of the underlying asset by selecting the appropriate category. 

Income Type: Specify the type(s) of income produced by the underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”
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(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

category that corresponds to the total amount of income produced during the reporting 

period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.
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Severance Payment (cash)

Report a cash severance payment that your spouse received in Part 5.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation 

N/A severance

For Your Spouse

Part 5

If you already have reported your spouse’s employment, you do not need to report a cash 

severance payment that your spouse received. However, if your spouse’s employment 

terminated outside the reporting period, you may not have already reported your spouse’s 

employment. In that case, report a cash severance payment of more than $1,000 that your 

spouse received within the reporting period.

Description: Provide the name of the source. In addition, if the source is a privately held 

business, provide the source’s line of business.

EIF: Select “N/A.”

Income Type: Describe the type of income as “severance.”
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Small Business (general)

Report a small business that your spouse operates in Part 5.

Note that other entries in this guide specifically address farms, law firms, and corporate 

stock. See those entries for more targeted guidance if applicable.

Description EIF Value Income Type Income Amount

Advanced Systems, LLC (software) N/A $500,001 -

$1,000,000

business income

ABC Holdings, Inc., S-Corp, d/b/a 

Jones Management Solutions (HR 

consulting) 

N/A $15,001 - $50,000 business income

Accountant, sole proprietor N/A $1,001 - $15,000 accounting fees

Piano teacher, sole proprietor N/A $1,001 - $15,000 lesson fees

For Your Spouse

Part 5

Report your spouse’s small business if its value was more than $1,000 at the end of the 

reporting period, if the business produced more than $200 in dividends, interest, rent, 

royalties, or honoraria during the reporting period, or if the business produced more than 

$1,000 of other income during the reporting period.

Description: Provide the name of the business and, unless the business is publicly traded, 

the type of business being conducted. In the absence of a specific business name, 

describe the trade practiced. If the legal name of the business differs from the name 

under which the business operates, it is helpful if you provide both names for clarity. In 

addition, unless otherwise specified, reported business interests are generally assumed to 

be structured as C-corporations. Consequently, if the business is otherwise structured, it 

is helpful to describe the type of business interest, such as “LLC” or “sole 

proprietorship.”

EIF: Select “N/A.”

Value: Select the appropriate category to report the value of the business.

Income Type and Income Amount: The level of detail required for income depends on 

the amount and type(s) of income.

(1) Dividends, capital gains, interest, rent, or royalties over $200: Specify the categories 

of income for “Income Type” and select the category that corresponds to the total amount 

of income produced during the reporting period.

(2) Honoraria over $200: See “Additional Requirements” below.
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(3) Other income over $1,000: Specify the type of income. (For purposes of financial 

disclosure, income from a business operated by a spouse will be treated as being subject 

to the earned income reporting requirements, unless the income is classified as dividends, 

capital gains, interest, rent, royalties, or honoraria.)

Additional Requirements

Business Assets and Liabilities: You need not itemize the assets and liabilities of the 

business. Disclosing the small business itself is normally sufficient. As an exception to 

this rule, you would report any assets or liabilities that are unrelated to the operations of 

that business.

Compensation and Other Benefits: In addition to business income, your spouse may 

receive other compensation and other benefits. Report these as separate line entries using 

the instructions in this guide for that type of asset or income. For example, various 

entries in this guide address: severance payments, bonuses, deferred compensation, 

defined benefit plans, defined contribution plans, and other items. 

Honoraria: In general, you need to report the source of an honorarium (income for an 

appearance, speech, or article) separately even if your spouse received the income 

through a single-member LLC or a speakers’ bureau. See the honorarium entry in this 

guide for additional information.

Copyright on a Book: In general, you need to report the copyright on a book even if your 

spouse received the income through a single-member LLC. Report the LLC on one line 

in Part 5 and then report each book on a separate line.

Interests Arising from a Sale: Report a third-party escrow agreement using the 

instructions in this guide for such agreements.
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Stable Value Fund

Report a stable value fund held in your spouse’s retirement account or plan in Part 5.

Description EIF Value Income Type Income Amount

ING Stable Value Fund Y $15,001 - $50,000 None (or less than 

$201)

For Your Spouse 

Part 5

Report a stable value fund if the value of the stable value fund was more than $1,000 at 

the end of the reporting period or if the stable value fund produced more than $200 in 

income during the reporting period.

Description: Provide the name of the stable value fund and the institution that manages 

the fund (e.g., Fidelity, Vanguard, T. Rowe Price, etc.), unless the institution is part of the 

fund name. In addition, although not required, you may indicate the type of account or 

plan in which the fund is held (e.g., defined contribution plan, 401(k), 403(b), 457, etc.).

EIF: Stable value funds often qualify as excepted investment funds. In such cases, select 

“Y” for this field.

Value: Report the value of the stable value fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.
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Stock

Report stock obtained through your spouse’s business, employment, or other incomegenerating activities in Part 5.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$201 - $1,000

BMSL Propulsion, Inc. (rocket fuel 

research)

N/A $50,001 - $100,000 None (or less than 

$201)

For Your Spouse

Part 5

Report a stock if the value of the stock was more than $1,000 at the end of the reporting 

period or if the stock produced more than $200 in income during the reporting period.

Description: Provide the exact name of the stock (e.g., “Xylophone Technologies 

Corporation”). In addition, for stock of a privately held company, provide a description 

of the issuer’s trade or business (e.g. grain distributor, supermarket, financial advisory, 

etc.).

EIF: Select “N/A.”

Value: Report the value of the stock by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200. Stocks normally produce dividend income but stocks 

may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Equity Compensation Plans and Other Interests

Stock obtained through employment-related activities often originates from equity 

compensation plans and other interests, such as deferred compensation, employee stock 

ownership plans, employee stock purchase plans, incentive stock options, phantom stock, 

restricted stock, restricted stock units, and stock appreciation rights. Report these 

interests in Part 5 as well.
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Stock Appreciation Right

Report your spouse’s stock appreciation rights and income from stock appreciation rights 

in Part 5.

Description EIF Value Income Type Income Amount

Widgets Unlimited, stock 

appreciation right

$15,001 - $50,000 cash payment

Xylophone Technologies 

Corporation, stock appreciation 

right

$15,001 - $50,000 None (or less than 

$201)

For Your Spouse

Part 5

Report a stock appreciation right if the value of the stock appreciation right was more 

than $1,000 at the end of the reporting period or if the stock appreciation right produced 

more than $1,000 in income during the reporting period.

Description: Provide the name of the employer and write “stock appreciation right.” In 

addition, for a privately held business, describe the line of business, unless you have 

already provided this information in another entry.

EIF: Select “N/A.”

Value: Report the value of the stock appreciation right by selecting the appropriate 

category. If the stock appreciation right is “underwater” or if its value is otherwise 

difficult to determine, write “value not readily ascertainable” in the “Description” field 

and provide the following information: (1) grant price; (2) number of shares; 

(3) expiration date; (4) vesting status; and (5) for an unvested stock appreciation right, the 

vesting date.

Income Type: Write “cash payment” to describe cash income.

Income Amount: Select the “None (or less than $201)” category if your spouse has not 

received any cash income. Do not complete this field if your spouse has received income 

because writing “cash payment” in the “Income Type” field is sufficient.

Reporting Stock Acquired Through a Stock Appreciation Right Plan

Report any stock that your spouse acquired as a separate line item entry, using the 

standard instructions for stock.
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Third-Party Escrow Agreement

Report your spouse’s interest in an escrow agreement in Part 5.

Description EIF Value Income Type Income Amount

Third-party escrow account with 

Tristate Bank (due to sale of WQX 

Systems, LLC to Widgets 

Unlimited)

N/A Over $1,000,000 None (or less than 

$201)

For Your Spouse

Part 5

Report your spouse’s interest in an escrow agreement if the value of the escrow property 

was more than $1,000 at the end of the reporting period or if the escrow property 

produced more than $200 in income during the reporting period.

Description: Provide the name of the account, including the name of the third-party 

escrow holder with whom the escrow property is held in trust, and write a short 

description of the nature of the transaction (e.g., “due to sale of WQX Systems, LLC to 

Widgets Unlimited”).

EIF: Select “N/A.”

Value: Report the value of the escrow property by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.
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TIAA-CREF

Report a TIAA-CREF product obtained through your spouse’s business, employment, or 

other income-generating activities in Part 5.

Description EIF Value Income Type Income Amount

TIAA Traditional N/A $50,001 - $100,000 interest $1,001 - $2,500

CREF Stock Y $1,001 - $15,000 None (or less than 

$201)

For Your Spouse

Part 5

The specific reporting requirements will depend on the type of TIAA-CREF product that 

your spouse holds.

For specific instructions on reporting the TIAA Traditional Annuity, click here.

For specific instructions on reporting CREF accounts and TIAA Real Estate, click here.
Public Financial Disclosure Guide, OGE Form 278e: Part 5 141

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Trustee Fee

Report the source of your spouse’s trustee fees in Part 5.

Note that you may have to report the underlying holdings of the trust in Part 6 if you, 

your spouse, or dependent child have an interest in or have received income from the 

trust (see the trust entries in this guide for details).

Description EIF Value Income Type Income Amount

Family trust #1 N/A trustee fees

For Your Spouse

Part 5

Report the source of your spouse’s trustee fees during the reporting period if the amount 

is more than $1,000.

Description: Provide the name of the trust. For a family trust, you may use initials in 

lieu of a person’s name (e.g., “2003 J.S. Trust”) or simply refer to the entity as a family 

trust (e.g., “family trust #1”).

EIF: Select “N/A.”

Income Type: Describe the type of income as “trustee fees.”
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OGE Form 278e: Part 6

Other Assets and Income

Introduction

Report assets and sources of investment income for you, your spouse, and your 

dependent children in Part 6. Do not include assets or income reported in Parts 2 or Part 

5. Learn how to report a particular asset by selecting that asset from the table below.

American Depositary Receipt

Annuity (fixed)

Annuity (variable)

Bond (corporate)

Bond (municipal)

Brokerage Account

Cash Account

Collectible Item

College Savings Plan (529 plan)

Common Trust Fund of a Bank

Equity Index-Linked Note

Exchange-Traded Fund

Farm (or farmland)

Foreign Exchange Position (“forex”)

Futures Contract (“future”)

Government Agency or GSE Security

Investment Fund (general)

Life Insurance (term)

Life Insurance (variable)

Life Insurance (whole or universal)

Loan Made to Another Party

Managed Account

Money Market Fund

Mutual Fund

Oil, Gas, or Other Mineral Rights Lease

Option (put or call purchased)

Option (put or call written)

Precious Metal

Prepaid Tuition Plan (529 plan)

Real Estate

Real Estate Holding Company (including REITs)

Short Sale

Stock

Treasury Security

Trust (irrevocable)

Trust (revocable living)

UGMA or UTMA Account
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Unit Investment Trust

Will or Estate

Other Assets and Investment Income

If you have types of assets or sources of investment income not listed above, click here

for general guidance.

No Other Assets or Investment Income

If you do not have any other assets or sources of investment income to report, you need to 

state this fact. Within Integrity, you would make the statement by marking the “I do not 

have...” checkbox. For hard copy reports, write “None” for the first line entry.
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American Depositary Receipt

Report an American depositary receipt (ADR) and income produced by the American 

depositary receipt in Part 6.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $15,001 - $50,000 None (or less than 

$201)

Halley Research (pharmaceuticals), 

ADR

N/A $15,001 - $50,000 dividends $201 - $1,000

For You, Your Spouse, and Your Dependent Children 

Part 6

Report an American depositary receipt if the value of the American depositary receipt 

was more than $1,000 at the end of the reporting period or if the American depositary 

receipt produced more than $200 in income during the reporting period.

Description: Provide the exact name of the American depositary receipt. In addition, if 

the security is not publicly traded in the United States, provide a description of the 

issuer’s trade or business and indicate that the security is an ADR. Ticker symbols for 

publicly traded ADRs are helpful but not required.

EIF: Select “N/A.”

Value: Report the value of the American depositary receipt by selecting the appropriate 

category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.
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Annuity (fixed)

Report a fixed annuity and income produced by the annuity in Part 6.

Description EIF Value Income Type Income Amount

Mutual of Aurora, fixed annuity N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a fixed annuity if the value of the annuity was more than $1,000 at the end of the 

reporting period or if the annuity produced more than $200 in income during the

reporting period.

Description: Provide the name of the insurance company issuing the annuity and write 

“fixed annuity.”

EIF: Select “N/A.”

Value: Report the value of the annuity by marking the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. The type of income usually is “interest” 

for fixed annuities.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
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Annuity (variable)

Report a variable annuity and the income produced by the annuity in Part 6.

Description EIF Value Income Type Income Amount

Long Life, Inc., variable annuity: N

- Liberty Income Securities Fund Y $1,001 - $15,000 None (or less than 

$201)

- American U.S. Large Cap Value Y $1,001 - $15,000 None (or less than 

$201)

- Long Life Fixed Account N/A $1,001 - $15,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children 

Part 6

Reporting the Overall Variable Annuity

Report a variable annuity if the total value of the annuity was more than $1,000 at the end 

of the reporting period or if the annuity produced more than $200 in total income during 

the reporting period.

Description: Provide the name of the insurance company issuing the annuity and write 

“variable annuity.”

EIF: Select “N” because a variable annuity is an investment vehicle that does not qualify 

as an excepted investment fund.

Reporting the Underlying Assets

If the overall annuity is reportable, provide the names of each underlying asset within the 

annuity that individually was worth more than $1,000 at the end of the reporting period or 

that individually produced more than $200 in income during the reporting period.

Description: Provide the name of the underlying asset.

EIF: For each underlying asset, indicate whether the asset (1) qualifies as an EIF (“Y”), 

(2) does not qualify as an EIF (“N”), or (3) is not an investment vehicle that holds other 

assets (“N/A”).

Value: Report the value of the underlying asset by selecting the appropriate category.

Income Type: Specify the type(s) of income produced by the underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.
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Income Amount: Provide the amount of income produced by each underlying asset 

during the reporting period.

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

appropriate category of income.

(3) Other income: Provide the exact amount of income produced.
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Bond (corporate)

Report a corporate bond and income produced by the bond in Part 6.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation, bonds

N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a corporate bond if the value of the bond was more than $1,000 at the end of the 

reporting period or if the bond produced more than $200 in income during the reporting 

period.

Description: Provide the name of the corporate issuer (e.g., “Xylophone Technologies 

Corporation”) and identify the asset as a bond. You do not need to include the terms of 

the bond.

EIF: Select “N/A.”

Value: Report the value of the bond by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Bonds normally produce interest income 

but may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
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Bond (municipal)

Report a municipal bond and income produced by the bond in Part 6.

Description EIF Value Income Type Income Amount

Philadelphia, PA, bonds N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a bond if the value of the bond was more than $1,000 at the end of the reporting 

period or if the bond produced more than $200 in income during the reporting period.

Description: Provide the name of the issuing government authority and identify the asset 

as a bond.

EIF: Select “N/A.”

Value: Report the value of the bond by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Municipal bonds normally produce 

interest income but may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
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Brokerage Account

Report the underlying assets of a brokerage account in Part 6.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

Brokerage account: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$2,501 - $5,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report each underlying asset of a brokerage account that individually was worth more 

than $1,000 at the end of the reporting period or that individually produced more than 

$200 in income during the reporting period. You may indicate that the assets are held 

within a brokerage account, but this information is not required.

This guide contains specific instructions for common types of assets held within a 

brokerage account (e.g., mutual funds, exchange-traded funds, stocks, and corporate 

bonds).

Click Here for Frequently Asked Questions
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Cash Account

Report a cash account and income produced by the cash account in Part 6.

Description EIF Value Income Type Income Amount

U.S. bank account #1 (cash) N/A $15,001 - $50,000 interest $201 - $1,000

U.S. bank account #2 (cash) N/A $15,001 - $50,000 interest $201 - $1,000

U.S. brokerage money market 

account (cash)

N/A $50,001 - $100,000 interest $201 - $1,000

1st Bank of France accounts (cash) N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Aggregate all of the cash accounts at a single financial institution that belong to you, your 

spouse, or your dependent children. Report the cash accounts if the total value of the 

accounts was more than $5,000 at the end of the reporting period or if the accounts 

produced more than $200 in total income during the reporting period. Note that the value 

threshold for cash accounts is higher than that of other assets.

Description: For accounts held at a bank, credit union, or other similar financial 

institution in the United States, identify that the account is a cash account held in the 

United States and identify the type of financial institution. For accounts held in U.S. 

financial institutions, you may provide the name of the financial institution but do not 

have to do so. You must have an entry for each U.S. financial institution where there are 

reportable accounts. If you have multiple bank accounts, identify the accounts as “U.S. 

bank account #1 (cash)” and “U.S. bank account #2 (cash)” and so on. For an account 

held at a foreign bank or financial institution, write the name of the bank and indicate that 

it is a cash account. 

Do not provide account numbers for any cash account.

EIF: Select “N/A.”

Value: Report the value of the account(s) by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. The type of income is usually “interest” 

for bank accounts.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
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Collectible Item

Report a collectible item and income from the sales of collectible items in Part 6.

Description EIF Value Income Type Income Amount

Collection of “Star Wars” figures N/A $1,001 - $15,000 capital gains $201 - $1,000

Artwork N/A $500,001 -

$1,000,000

capital gains $50,001 - $100,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a collectible item if (1) the item is held for investment purposes and had a value 

that was more than $1,000 at the end of the reporting period or (2) the item produced 

more than $200 in income during the reporting period.

Description: Describe the nature of the collectible item, such as “rare book” or “classic 

car.” You may aggregate multiple items of a similar nature as a single entry.

EIF: Select “N/A.”

Value: Report the value of the collectible item by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
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College Savings Plan (529 plan)

Report a college savings plan and related income in Part 6.

Description EIF Value Income Type Income Amount

CA (ScholarShare) College Savings 

Plan:

N

- Portfolio 2015 Y $1,001 - $15,000 None (or less than 

$201)

- Conservative Portfolio Y $1,001 - $15,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Reporting the Overall Plan

Report a college savings plan if the total value was more than $1,000 at the end of the 

reporting period or if the plan produced more than $200 in total income during the 

reporting period.

Description: Provide the sponsoring state and the type of plan.

EIF: Select “N” because a college savings plan is an investment vehicle that does not 

qualify as an excepted investment fund.

Reporting the Underlying Assets

If the overall plan is reportable, provide the names of each underlying asset within the 

plan that individually was worth more than $1,000 at the end of the reporting period or 

produced more than $200 in income during the reporting period.

Description: Provide the name of the underlying asset.

EIF: For each underlying asset, indicate whether the asset (1) qualifies as an EIF (“Y”), 

(2) does not qualify as an EIF (“N”), or (3) is not an investment vehicle that holds other 

assets (“N/A”). In most cases, the underlying assets will qualify as EIFs.

Value: Report the value of the underlying asset by selecting the appropriate category.

Income Type: Specify the type(s) of income produced by an underlying asset, unless the 

asset qualifies as an EIF or the income did not exceed $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.
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Common Trust Fund of a Bank

Report a common trust fund of a bank and income produced by the common trust fund in 

Part 6.

Description EIF Value Income Type Income Amount

First District Bank, Long-Term 

Bond Common Trust Fund

Y $15,001 - $50,000 $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a common trust fund if the value of the common trust fund was more than $1,000 

at the end of the reporting period or if the common trust fund produced more than $200 in 

income during the reporting period. 

Normally, a common trust fund of a commercial bank that is open to the public will 

qualify as an excepted investment fund (EIF). In that case, report this item, as follows:

Description: Provide the name of the bank and the common trust fund.

EIF: Select “Y.”

Value: Report the value of the common trust fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.
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Equity Index-Linked Note

Report an equity index-linked note and income produced by the note in Part 6.

Description EIF Value Income Type Income Amount

First District Bank Note Linked to 

S&P500 Index

N/A $1,001 - $15,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report an equity index-linked note if the value of the note was more than $1,000 at the 

end of the reporting period or if the note produced more than $200 in income during the 

reporting period.

Description: Provide the name of the issuer and the name of the index to which the note 

is linked.

EIF: Select “N/A.”

Value: Report the value of the note by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Equity index-linked notes normally 

produce interest income but may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 156

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Exchange-Traded Fund

Report an exchange-traded fund (ETF) and income produced by the fund in Part 6.

Description EIF Value Income Type Income Amount

iShares Dow Jones U.S. Industrial 

Sector Index Fund (IYJ)

Y $15,001 - $50,000 $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report an exchange-traded fund if the value of the fund was more than $1,000 at the end 

of the reporting period or if the fund produced more than $200 in income during the 

reporting period.

Description: Provide the exact name of the fund (e.g., list “iShares S&P500 Index” 

rather than just “iShares”).

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 157

Version: 5/2018

Farm (or farmland)

Report a passive investment interest in a farm or farmland in Part 6.

Do not use these instructions if you have or your spouse has an active management role 

in the farm. Report a farm that you manage as a business in Part 2, and report a farm that 

your spouse manages in Part 5.

Description EIF Value Income Type Income Amount

Bar T Farm, Keller, TX, 

corporate stock holder (livestock)

N/A $1,001 - $15,000 dividends $201 - $1,000

Farmland, Zanesville, OH, leased 

for cash rent

N/A $250,001 - $500,000 rent or royalties $15,001 - $50,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a passive investment interest in a farm or farmland if the value of the interest was 

more than $1,000 at the end of the reporting period or if it produced more than $200 in 

income during the reporting period. 

Description:

(1) Farm: Provide the name of the farm; the location of the farm (either the city and state 

or the county and state); the business of the farm, such as crops or livestock; and, if 

applicable, an indication that the farm has been leased to a third party. In addition, it is 

helpful if you specify the type of interest that you have in the farm, such as “sole 

proprietor” or “general partner.”

(2) Farmland: Identify the interest as farmland and provide its location (either the city 

and state or the county and state). In addition, if applicable, provide the name of the 

partnership or other entity used to hold the farmland and note any leasing arrangements.

EIF: Select “N/A.”

Value: Report the value of your interest by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 158

Version: 5/2018

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 159

Version: 5/2018

Foreign Exchange Position (“forex”)

Report a foreign exchange position and income produced by the foreign exchange 

position in Part 6.

Description EIF Value Income Type Income Amount

Euro-US Dollar (EUR/USD), open 

position

N/A $1,001 -$15,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report a foreign exchange position if the value of the position was more than $1,000 at 

the end of the reporting period or if the position produced more than $200 in income 

during the reporting period.

Description: Provide the name of the foreign exchange position by identifying the 

currency pair (e.g., “US Dollar-Japanese Yen”) and indicate whether the position is open 

or closed.

EIF: Select “N/A.”

Value: Report the value by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 160

Version: 5/2018

Futures Contract (“future”)

Report a futures contract (or “future”) and income produced by the future in Part 6.

Description EIF Value Income Type Income Amount

Crude oil futures, closed position N/A None (or less than 

$1,001)

capital gains $1,001 - $2,500

Pork belly futures, open position N/A $1,001 - $15,000 None (or less than 

$201)

Silver futures, open position (value 

not readily ascertainable): December 

2016, 10 contracts, 32.20/oz. 

N/A None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report futures if the value of the future was more than $1,000 at the end of the reporting 

period or if the future produced more than $200 in income during the reporting period.

Description: Provide the name of the future and indicate whether the position is open or 

closed.

EIF: Select “N/A.”

Value: Report the value by selecting the appropriate category. If the value of the future 

is difficult to determine, write “value not readily ascertainable” in the “Description” field 

and provide the following information: (1) the contract month and year; (2) the number of 

the contracts you control; and (3) the closing price of the future.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 161

Version: 5/2018

Government Agency or GSE Security

Report a Government Agency or Government-Sponsored Enterprise security and income 

produced by the security in Part 6.

Description EIF Value Income Type Income Amount

GNMAs N/A $15,001 - $50,000 interest $201 - $1,000

Fannie Mae N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a Government Agency or Government-Sponsored Enterprise security if the value 

of the security was more than $1,000 at the end of the reporting period or if the security 

produced more than $200 in income during the reporting period.

Description: Provide the name of the issuer. You do not need to include the terms of the 

security.

EIF: Select “N/A.”

Value: Report the value of the security by selecting the appropriate category. 

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 162

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Investment Fund (general)

Report an equity interest in an investment fund and income produced by the interest in 

Part 6.

Note that other entries in this guide specifically address mutual funds, exchange-traded 

funds, and money market funds. See those entries for more targeted guidance if 

applicable.

Investment Fund Qualifies as an EIF

Description EIF Value Income Type Income Amount

Positron Investments XI, LP Y $100,001 - $250,000 $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If You Know the Value and Income of the 

Underlying Assets

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A $15,001 - $50,000 None (or less than 

$201)

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A $15,001 - $50,000 None (or less than 

$201)

- WQX Optics (medical devices) N/A $1,001 - $15,000 capital gains $5,001 - $15,000

Investment Fund Does Not Qualify as an EIF – If the Value and Income of the 

Underlying Assets is Not Readily Ascertainable

Description EIF Value Income Type Income Amount

Jones Capital Ventures, LLC: N $50,001 - $100,000 capital gains $5,001 - $15,000

- Hydroponics Unlimited, LLC 

(agricultural products)

N/A

- BMSL Propulsion, Inc. (rocket 

fuel research)

N/A

- WQX Optics (medical devices) N/A

For You, Your Spouse, and Your Dependent Children

Part 6

Report an equity interest in an investment fund if the value was more than $1,000 at the 

end of the reporting period or if the interest produced more than $200 in total income 

during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 163

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The reporting requirements will depend on whether the investment fund qualifies as an 

excepted investment fund.

Investment Fund Qualifies as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category. 

Income Type: Leave this field blank.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Investment Fund Does Not Qualify as an EIF

Description: Provide the name of the investment fund and, unless clear from the name, 

describe the type of asset.

EIF: Select “N.”

Additional Disclosure of Underlying Assets: Because the investment fund does not 

qualify as an EIF, you need to report each underlying asset of the fund that was worth 

more than $1,000 at the end of the reporting period or that produced more than $200 in 

income during the reporting period. For purposes of this calculation, you may use the 

interest that you, your spouse, and your dependent children have in the asset. Report 

each underlying asset using the guidance applicable to that type of asset.

In certain cases, investment funds do not provide information regarding an investor’s 

interest in the value and/or income of the fund’s underlying assets. If you are unable to 

ascertain the value of the underlying assets, you may instead provide value information 

for the total interest that you, your spouse, and your dependent children have in the fund. 

Similarly, if you are unable to ascertain the income of the underlying assets, you may 

instead provide income information for the total interest that you, your spouse, and your 

dependent children have in the fund.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 164

Version: 5/2018

Life Insurance (term)

Do not report a term life insurance policy that belongs to you, your spouse, or dependent 

child. In addition, do not report proceeds received from a term life insurance policy for 

which you, your spouse, or dependent child is a beneficiary.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 165

Version: 5/2018

Life Insurance (variable)

Report a variable life insurance policy and income from the policy in Part 6.

Description EIF Value Income Type Income Amount

Long Life, Inc., variable life: N

- Liberty Income Securities Fund Y $1,001 - $15,000 None (or less than 

$201)

- American U.S. Large Cap Value Y $1,001 - $15,000 None (or less than 

$201)

- Long Life Fixed Account N/A $1,001 - $15,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Report a variable life insurance policy if the total value of the policy was more than 

$1,000 at the end of the reporting period or if the policy produced more than $200 in total 

income during the reporting period. In addition, provide the names of each underlying 

holding within the policy that individually was worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period.

Part 6

Reporting the Overall Variable Life Insurance Policy

Description: Provide the name of the insurance company issuing the policy and write 

“variable life.”

EIF: Select “N” for the first line entry of a variable life policy because the overall policy 

is an investment vehicle that does not qualify as an excepted investment fund.

Reporting the Underlying Assets

Description: Provide the name of the underlying asset.

EIF: For each underlying asset, indicate whether the asset (1) qualifies as an EIF (“Y”), 

(2) does not qualify as an EIF (“N”), or (3) is not an investment vehicle that holds other 

assets (“N/A”). In most cases, an investment fund held within a variable life insurance 

policy will qualify as an EIF.

Value: Report the value of the underlying asset by selecting the appropriate category.

Income Type: Specify the type(s) of income produced by the underlying asset, unless the 

underlying asset qualifies as an EIF or the income did not exceed $200.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 166

Version: 5/2018

Income Amount: Provide the amount of income produced by each underlying asset 

during the reporting period.

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, royalties, or income from EIFs: Select the 

appropriate category of income.

(3) Other income: Provide the exact amount of income produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 167

Version: 5/2018

Life insurance (whole or universal)

Report a whole or universal life insurance policy and income from the policy in Part 6.

Description EIF Value Income Type Income Amount

Home Life, Inc., whole life N/A $15,001 - $50,000 dividends $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a whole life or universal life insurance policy if the value of the policy was more 

than $1,000 at the end of the reporting period or if the policy produced more than $200 in 

income during the reporting period.

Description: Provide the name of the insurance company issuing the policy and write 

“whole life” or “universal life.”

EIF: Select “N/A.”

Value: Report the value of the policy by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Whole life and universal life policies 

normally produce interest or dividend income.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 168

Version: 5/2018

Loan Made to Another Party

Report a loan that you, your spouse, or your dependent child made and the income 

produced by such a loan in Part 6. However, you do not need to report loans to certain 

members of your immediate family, as discussed below.

Description EIF Value Income Type Income Amount

Personal loan to family member N/A $1,001 - $15,000 None (or less than 

$201)

Personal loan to Brain Imagery 

Consultations, LLC

N/A $15,001 - $50,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

The applicable statute excludes certain loans to family members from the reporting 

requirement. You do not need to report loans made by you or your spouse to each other 

or to a parent, sibling, child, or grandchild.

Report a loan made to another party if the value of the loan was more than $1,000 at the 

end of the reporting period or if the loan produced more than $200 in income during the 

reporting period. The other party may be either a person or an entity.

Description: Identify the party who owes the liability and write “loan” or “note.” If the 

party is a close relative, identify the party as a “family member” (e.g., “personal loan to a 

family member”). If the party is a natural person (i.e., a human) who is not related to 

you, identify the party by last name only (e.g., “personal loan to Mr. Doe”). If the party 

is an entity, identify the party by name (e.g., “personal loan to Wilson Widgets”).

EIF: Select “N/A.”

Value: Report the value of the loan by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Loans normally produce interest income.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 169

Version: 5/2018

Managed Account

Report the underlying assets of a managed account in Part 6.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$2,501 - $5,000

or

Description EIF Value Income Type Income Amount

ANW Wealth Retention Strategy: N

- ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$2,501 - $5,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report each underlying asset of a managed account that individually was worth more 

than $1,000 at the end of the reporting period or that individually produced more than 

$200 in income during the reporting period. Although this information is not required, 

you may provide the name of the managed account.

This guide contains specific instructions for common types of assets held within a 

managed account (e.g., mutual funds, exchange-traded funds, stocks, and corporate 

bonds).

A Managed Account Is Not an “Excepted Investment Fund”

Note that your managed account is not an “excepted investment fund.” Even if you 

selected an established portfolio of investment choices when you established your 

managed account, the managed account is not an “excepted investment fund.” In fact, 

the managed account is not an investment fund at all. You have not “pooled” your 

money with other investors. Although the account manager may have offered you the 

option of selecting a predetermined “portfolio” of assets, you own each of these assets 

individually and directly in your own name. For this reason, as well as other reasons, 

disclose each asset as a separate line item in your financial disclosure report.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 170

Version: 5/2018

Money Market Fund

Report a money market fund and income produced by the fund in Part 6.

Description EIF Value Income Type Income Amount

Vanguard Prime Money Market 

Fund (VMMXX)

Y $15,001 - $50,000 $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a money market fund if the value of the fund was more than $5,000 at the end of 

the reporting period or if the fund produced more than $200 in income during the 

reporting period. Note that the value threshold for money market funds is higher than 

that of other assets.

Description: Provide the exact name of the fund (e.g., write “Vanguard Prime Money 

Market Fund,” do not write only “Vanguard” or “Vanguard money market fund”).

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 171

Version: 5/2018

Mutual Fund

Report a mutual fund and income produced by the fund in Part 6.

Description EIF Value Income Type Income Amount

Janus Balanced Fund (JDBAX) Y $15,001 - $50,000 $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a mutual fund if the value of the fund was more than $1,000 at the end of the 

reporting period or if the fund produced more than $200 in income during the reporting 

period.

Description: Provide the exact name of the fund (e.g., write “Janus Balanced Fund”; 

do not write only “Janus” or “Balanced Fund”).

EIF: Select “Y.”

Value: Report the value of the fund by selecting the appropriate category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 172

Version: 5/2018

Oil, Gas, or Other Mineral Rights Lease

Report leased oil, gas, or other mineral rights and income produced by the lease in Part 6.

Description EIF Value Income Type Income Amount

Oil lease, Fargo, ND –

Humble Oil and Refining Co.

N/A $1,001 - $15,000 rent or royalties $201 - $1,000

Natural gas lease, Dallas, TX –

El Paso Corporation

N/A $50,001 - $100,000 signing bonus $13,700

For You, Your Spouse, and Your Dependent Children

Part 6

Report a lease if the value of the lease was more than $1,000 at the end of the reporting 

period or if the lease produced more than $200 in income during the reporting period.

Description: Indicate that the asset is a lease and provide: (1) the location of the land 

(either city and state or county and state); (2) the resource being extracted under the terms 

of the lease; and (3) the name of the lessee (i.e., company extracting resources and paying 

royalties).

EIF: Select “N/A.”

Value: Report the value of the lease by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Leases normally produce “rent or 

royalties” income, but in some cases they may also produce dividends, interest, or capital 

gains. If the lease produces any other type of income, provide an appropriate description 

(e.g., “signing bonus” or “upfront payment”).

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 173

Version: 5/2018

Option (put or call purchased)

Report a put or a call option that you purchased and income produced by the option in 

Part 6.

Description EIF Value Income Type Income Amount

Growlster, Inc. (GRWL), call option N/A $1,001 - $15,000 None (or less than 

$201)

Growlster, Inc. (GRWL), call option 

(value not readily ascertainable):

100 shares, strike $7, exp. 5/2016

N/A None (or less than 

$201)

Widgets Unlimited (WIG), put 

option

N/A None (or less than 

$1,001)

capital gains $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Reporting a Put or Call Option That You Have Not Exercised

Report a put or call option if its value was more than $1,000 at the end of the reporting 

period or if the option produced more than $200 in income during the reporting period.

Description: Provide the name of the option, which should include the name of the 

underlying security and the type of option (e.g., “Widgets Unlimited (WIG), put option”).

EIF: Select “N/A.”

Value: Report the value of the option by selecting the appropriate category. If the option 

is “underwater” or if the value of the option is otherwise difficult to determine, write 

“value not readily ascertainable” in the “Description” field and provide the following 

information: (1) the number of units of the security for which the option exists; (2) the 

strike price; and (3) the expiration date.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200. Options normally do not produce income 

until they have been exercised or sold. 

Income Amount: Select the category corresponding to the total amount of income 

produced, which is usually “None (or less than $201).”

Reporting a Put Option That You Fully Exercised

If you fully exercised a put option, neither the option nor the underlying security will 

have any reportable value. Report the underlying security if it produced more than $200 

in income during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 174

Version: 5/2018

Description: Provide the name of the underlying security that you sold (e.g., “Widgets 

Unlimited (WIG)”).

EIF: Select “N/A.”

Value: Report the value of the underlying security by selecting the appropriate category, 

which should be “None (or less than $1,001).”

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. In some cases, the underlying security 

may have produced dividends or interest before you sold it. More often, you will have 

capital gains as a result of selling the underlying security.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Reporting a Call Option That You Fully Exercised

If you fully exercised a call option, the option will no longer have a value of its own, but 

the underlying security that you purchased may have reportable value or income. Report 

the underlying security if its value was more than $1,000 at the end of the reporting 

period or if it produced more than $200 in income during the reporting period.

Description: Provide the name of the underlying security that you purchased (e.g., 

“Growlster, Inc. (GRWL)”).

EIF: Select “N/A.”

Value: Report the value of the underlying security by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. The exercise of the call option will not 

itself produce reportable capital gains; however, any subsequent sale of the purchased 

underlying security may produce capital gains. In addition, the purchased underlying 

security may have generated reportable dividend or interest income.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Reporting a Put or Call Option That You Resold

Report a put or call option that you resold if the sale produced more than $200 in income 

during the reporting period.

Description: Provide the name of the option, which should include the name of the 

underlying security and the type of option (e.g., “Widgets Unlimited (WIG), put option”).
Public Financial Disclosure Guide, OGE Form 278e: Part 6 175

Version: 5/2018

EIF: Select “N/A.”

Value: Report the value of the option by selecting the appropriate category, which 

should be “None (or less than $1,001).”

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200. Sales of options ordinarily produce capital 

gains.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 176

Version: 5/2018

Option (put or call written)

Report a put or a call option that you wrote and income produced by the option in Part 6.

Description EIF Value Income Type Income Amount

Widgets Unlimited (WIG), open 

position for written put option:

100 shares, strike $7, exp. 5/2016

N/A None (or less than 

$201)

Xylophone Technology Corporation 

(XYZ), closed position for written 

put option

N/A None (or less than 

$1,001)

capital gains $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Open Position

Report a written put or call option in an open position if the value of the shares was more 

than $1,000 at the time the position was opened.

Description: Provide the name of the underlying security, the type of option, and an 

indication that the position is open. In addition, in lieu of selecting a category of value, 

provide the following information: (1) the number of units of the security for which the 

option exists; (2) the strike price; and (3) the expiration date.

EIF: Select “N/A.”

Value: Leave this field blank.

Income Type and Income Amount: You should not have any income to report, so select 

“None (or less than $201).”

Closed Position

Report a written put or call option in a closed position if the option produced more than 

$200 in income during the reporting period.

Description: Provide the name of the underlying security, the type of option, and an 

indication that the position is closed.

EIF: Select “N/A.”

Value: Report the value of the option by selecting the appropriate category, which 

should be “None (or less than $1,001).”

Income Type: Specify the type of income.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 177

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Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Stock Acquired Through an Exercised Option

Report the stock as you would any other stock.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 178

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Precious Metal

Report a precious metal and income from the sale of precious metal in Part 6.

Description EIF Value Income Type Income Amount

Gold coins N/A $1,001 - $15,000 None (or less than 

$201)

Platinum bars N/A $250,001 - 500,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report precious metal if either of the following is true: (1) the metal is held for 

investment purposes and had a value that was more than $1,000 at the end of the 

reporting period or (2) the metal produced more than $200 in income during the reporting 

period.

Description: Describe the type of metal owned (e.g., gold) and the form in which you 

hold the metal (e.g., ingots, jewelry, coins, or warehouse certificates).

EIF: Select “N/A.”

Value: Report the value of the precious metal by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 179

Version: 5/2018

Prepaid Tuition Plan (529 plan)

Report a prepaid tuition plan and related income in Part 6.

Description EIF Value Income Type Income Amount

Maryland Prepaid College Trust 

(MPCT), University Plan – 4 years

N/A $15,001 - $50,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report a prepaid tuition plan if the value was more than $1,000 at the end of the reporting 

period or if the plan produced more than $200 in total income during the reporting period.

Description: Provide the sponsoring state and the name of the plan.

EIF: Select “N/A.”

Value: Report the value of the plan by selecting the appropriate category. If you do not 

know the current value, you can use the cost of the plan at the time that you purchased it.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200. There usually is no income to report.

Income Amount: Select the category corresponding to the total amount of income 

produced, which is usually “None (or less than $201).”
Public Financial Disclosure Guide, OGE Form 278e: Part 6 180

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Real Estate

Report investment real estate and income produced by real estate in Part 6. Do not report 

your personal residence if it does not produce rental income.

Other requirements may apply (a) if the real estate is a farm, (b) if the real estate is held 

by a trust, (c) if the real estate is held by a limited liability company or other entity, or 

(d) if you have leased mineral rights associated with the property. These requirements 

are addressed below.

Description EIF Value Income Type Income Amount

Residential real estate, 

Des Moines, IA

N/A $100,001 - $250,000 rent or royalties $5,001 - $15,000

Undeveloped land, Rapid City, SD N/A $100,001 - $250,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report real estate if the value of the real estate was more than $1,000 at the end of the 

reporting period or if the real estate produced more than $200 in income during the 

reporting period.

You do not need to report a personal residence if it is not rented out during any portion of 

the reporting period. A personal residence includes a vacation home that is not rented 

out.

Description: Describe the type of real estate (e.g., “residential,” “commercial,” 

“industrial,” or “undeveloped”) and provide the city and state in which it is located. 

Providing the county and state is also acceptable. Do not provide a street address.

EIF: Select “N/A.”

Value: Report the value of the real estate by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200. Usually the type of income will be “rent or 

royalties” or “capital gains.”

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, or royalties: Select the category that 

corresponds to the total amount of income produced during the reporting period.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 181

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(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Mortgages

Report a mortgage that exceeded $10,000 at any point during the reporting period in Part 

8. An exception for mortgages on personal residences may apply. See Part 8 in this 

guide for details.

Other Requirements

Farm: If the real estate is a farm, consult the instructions in this guide for farms.

Holding Company: If the real estate is held through a limited liability company or other 

legal entity, report the entity using the guidance applicable to that type of entity.

Mineral Rights: If you, your spouse, or dependent child earns income based on the 

leasing of mineral rights, consult the instructions in this guide for an oil, gas, or other 

mineral rights lease.

Trust: If the real estate is held in a trust, consult the instructions in this guide for trusts.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 182

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Real Estate Holding Company (including REITs)

Report a real estate holding company (including a REIT) and income produced by the 

company in Part 6.

Do not use this entry to report a mutual fund that holds REITs. See the “Mutual Fund” 

entry instead. In addition, if you operate a trade or business involving real estate, see the 

“Small Business” entry.

Real Estate Holding Company Qualifies as an EIF

Description EIF Value Income Type Income Amount

Blackhawk Commercial Realty

Portfolio

Y $100,001 - $250,000 $5,001 - $15,000

Amalgamated Commercial Realty

Trust (ACR)

Y $50,001 - $100,000 $2,501 - $5,000

Real Estate Holding Company Does Not Qualify as an EIF – If You Know the Value and 

Income of the Underlying Assets

Description EIF Value Income Type Income Amount

Macon Real Estate V, LP: N

- commercial real estate, 

Champaign, IL

N/A $50,001 - $100,000 rent or royalties $2,501 - $5,000

- commercial real estate, 

Terre Haute, IN

N/A $50,001 - $100,000 None (or less than 

$201)

- commercial real estate, 

Louisville, KY

N/A $15,001 - $50,000 capital gains $5,001 - $15,000

Real Estate Holding Company Does Not Qualify as an EIF – If the Value and Income of 

the Underlying Assets is Not Readily Ascertainable

Description EIF Value Income Type Income Amount

Macon Real Estate V, LP: N $100,001 - $250,000 rent or royalties

capital gains

$15,001 - $50,000

- commercial real estate, 

Champaign, IL

N/A

- commercial real estate, 

Terre Haute, IN

N/A

- commercial real estate, 

Louisville, KY

N/A
Public Financial Disclosure Guide, OGE Form 278e: Part 6 183

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For You, Your Spouse, and Your Dependent Children

Part 6

Report an equity interest in a real estate holding company (including a REIT) if the value 

of the interest was more than $1,000 at the end of the reporting period or if the interest 

produced more than $200 in total income during the reporting period.

The reporting requirements will depend on whether the real estate holding company

qualifies as an excepted investment fund. Real estate holding companies that may qualify 

include real estate investment trusts (REITs) as well as private equity and hedge real 

estate funds that are or were publicly available.

Real Estate Holding Company Qualifies as an EIF

Description: Provide the name of the real estate holding company and, unless clear from

the name, describe the type of asset.

EIF: Select “Y.”

Value: Report the value of the real estate holding company by selecting the appropriate 

category.

Income Type: Leave this field blank.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Real Estate Holding Company Does Not Qualify as an EIF

Description: Provide the name of the real estate holding company and, unless clear from

the name, describe the type of asset.

EIF: Select “N.”

Additional Disclosure of Underlying Assets: Because the real estate holding company

does not qualify as an EIF, you need to report each underlying asset of the real estate 

holding company that was worth more than $1,000 at the end of the reporting period or 

that produced more than $200 in income during the reporting period. For purposes of this 

calculation, you may use the interest that you, your spouse, and your dependent children 

have in the asset.

In certain cases, real estate holding companies do not provide information regarding an 

investor’s interest in the value and/or income of the entity’s underlying assets. If you are 

unable to ascertain the value of the underlying assets, you may instead provide value 

information for the total interest that you, your spouse, and your dependent children have 

in the real estate holding company. Similarly, if you are unable to ascertain the income 
Public Financial Disclosure Guide, OGE Form 278e: Part 6 184

Version: 5/2018

of the underlying assets, you may instead provide income information for the total 

interest that you, your spouse, and your dependent children have in the real estate holding 

company.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 185

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Short Sale

Report short sales and income from short sales in Part 6.

Description EIF Value Income Type Income Amount

Widgets Unlimited (WIG), open 

short position: 1,000 shares at $25

N/A None (or less than 

$201)

Xylophone Technology Corporation 

(XYZ), closed short position

N/A None (or less than 

$1,001)

capital gains $5,001 - $15,000

For You, Your Spouse, and Your Dependent Children

Part 6

Open Position

Report a short sale in an open position if the value of the shorted security was more than 

$1,000 at the time the position was opened.

Description: Provide the name of the security you shorted (e.g., “Widgets Unlimited”) 

and indicate the short position is open. In addition, in lieu of selecting a category of 

value, provide the following information: (1) the number of shares shorted and (2) the 

price at which you shorted the shares.

EIF: Select “N/A.”

Value: Leave this field blank.

Income Type and Income Amount: You should not have any income to report, so select 

“None (or less than $201).”

Closed Position

Report a short sale in a closed position if the short sale produced more than $200 in 

income during the reporting period.

Description: Provide the name of the security you shorted (e.g., “Xylophone 

Technologies Corporation”) and indicate the short position is closed.

EIF: Select “N/A.”

Value: Select the “None (or less than $1,001)” category.

Income Type: Specify the type of income.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 186

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Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 187

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Stock

Report stock and income from stock in Part 6.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends 

capital gains

$201 - $1,000

BMSL Propulsion, Inc. (rocket fuel 

research)

N/A $50,001 - $100,000 None (or less than 

$201)

For You, Your Spouse, and Your Dependent Children

Part 6

Report a stock if the value of the stock was more than $1,000 at the end of the reporting 

period or if the stock produced more than $200 in income during the reporting period.

Description: Provide the exact name of the stock (e.g., “Xylophone Technologies 

Corporation”). In addition, for stock of a privately held company, provide a description 

of the issuer’s trade or business (e.g. grain distributor, supermarket, financial advisory, 

etc.).

EIF: Select “N/A.”

Value: Report the value of the stock by selecting the appropriate category. 

Income Type: Specify the type(s) of income if the total amount of income during the 

reporting period exceeded $200. Stocks normally produce dividend income but stocks 

may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 188

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Treasury Security

Report a Treasury security and income produced by the security in Part 6.

Description EIF Value Income Type Income Amount

U.S. savings bonds N/A $15,001 - $50,000 interest $201 - $1,000

Treasury bonds N/A $15,001 - $50,000 interest $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a Treasury security if the value of the security was more than $1,000 at the end of 

the reporting period or if the security produced more than $200 in income during the 

reporting period.

Description: Provide the type of security held. You do not need to include the terms of 

the security.

EIF: Select “N/A.”

Value: Report the value of the security by selecting the appropriate category.

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period exceeded $200. Treasury securities normally produce interest 

income but may also produce capital gains if sold.

Income Amount: Select the category corresponding to the total amount of income 

produced.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 189

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Trust (irrevocable)

Report an irrevocable trust in Part 6 if you, your spouse, or your dependent child has a 

vested beneficial interest or received income.

Vested Beneficial Interest – Proportionate Interest in the Value and Income of the 

Underlying Assets Is Readily Ascertainable

Description EIF Value Income Type Income Amount

Family trust #1: N

- Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends $201- $1,000

- Philadelphia, PA, bonds N/A $1,001 - $15,000 interest $201 - $1,000

- QWERTY Growth Fund 

(QWTYX)

Y $50,001 - $100,000 $2,501 - $5,000

Vested Beneficial Interest – Proportionate Interest in the Value and Income of the 

Underlying Assets Is Not Readily Ascertainable

Example 1

Description EIF Value Income Type Income Amount

Family trust #1: N $50,001 - $100,000 dividends

interest

$5,001 - $15,000

- Xylophone Technologies 

Corporation (XYZ)

N/A

- Philadelphia, PA, bonds N/A

- QWERTY Growth Fund 

(QWTYX)

Y

Example 2

Description EIF Value Income Type Income Amount

Family trust #1*: N $50,001 - $100,000 None (or less than 

$201)

- Xylophone Technologies 

Corporation (XYZ)

N/A

- Philadelphia, PA, bonds N/A

- QWERTY Growth Fund 

(QWTYX)

Y

* I have a 1/3 remainder interest in the trust. The current value of the trust is reported.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 190

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For You, Your Spouse, and Your Dependent Children

Part 6

Vested Beneficial Interest

Report the trust interest if the interest was worth more than $1,000 at the end of the 

reporting period or if the interest produced more than $200 in income during the 

reporting period.

Description: Use initials (“J.S. 2003 Trust”) or a general description (“Family trust #1”) 

in lieu of a full name.

EIF: Select “N.”

Leave the remaining fields blank.

Additional Disclosure of Underlying Assets: In addition to the information specified 

above, you need to report each underlying asset of the trust that was worth more than 

$1,000 at the end of the reporting period or that produced more than $200 in income 

during the reporting period. For purposes of this calculation, you may use the 

proportionate interest that you, your spouse, and your dependent children have in the 

asset. Report each underlying asset using the guidance applicable to that type of asset.

In certain cases, beneficiaries cannot ascertain the proportionate interest that they have in 

the value and/or income of the trust’s underlying assets. If you are unable to ascertain the 

proportionate interest in the value of the underlying assets, you may instead provide a 

good faith estimate of the value of the total interest that you, your spouse, and your 

dependent children have in the trust. Similarly, if you are unable to ascertain the 

proportionate interest in the income of the underlying assets, you may instead provide 

income information for the total interest that you, your spouse, and your dependent 

children have in the trust.

Excepted Trusts: If you do not have a right to receive information regarding the 

underlying assets of a trust that someone else established for your benefit, you might be 

able to rely on a partial exception for “excepted trusts.”

Click here for more information on reporting an excepted trust.

Income from Discretionary Trusts

Report a discretionary trust as a source of income and the exact amount of income if 

distributions from the trust totaled more than $200 during the reporting period. Do not 

use the rule for discretionary trusts unless you have first consulted OGE DAEOgram DO08-024 (August 6, 2008) and OGE Legal Advisory LA-13-04 (April 9, 2013) and are sure 

that the trust is a discretionary trust within the meaning of those documents.
Public Financial Disclosure Guide, OGE Form 278e: Part 6 191

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Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 192

Version: 5/2018

Trust (revocable living)

Report assets and income from a revocable living trust in Part 6 if (1) you, your spouse, 

or your dependent child is the grantor or (2) you, your spouse, or your dependent child 

receives mandatory distributions.

See OGE DAEOgram DO-02-015 (June 11, 2002) for a detailed discussion of revocable 

living trusts.

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends $201 - $1,000

QWERTY Growth Fund (QWTYX) Y $50,001 - $100,000 $1,001 - $2,500

For You, Your Spouse, and Your Dependent Children

Part 6

Report each underlying asset of the trust that individually was worth more than $1,000 at 

the end of the reporting period or that individually produced more than $200 in income 

during the reporting period. Use the instructions specific to each type of asset (e.g., 

mutual funds, exchange-traded funds, stocks, corporate bonds, and cash accounts, such as 

certificates of deposit). You may identify that the assets are held in a revocable living 

trust, but this information is not required. If you choose to identify the trust, use initials 

(“J.S. 2003 Trust”) or a general description (“Family trust”) in lieu of a full name.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 193

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UGMA or UTMA Account

Report the underlying assets of your dependent child’s Uniform Gifts to Minors Act 

(UGMA) account or Uniform Transfers to Minors Act (UTMA) account in Part 6.

Description EIF Value Income Type Income Amount

ABC Diversified Bond Fund Y $50,001 - $100,000 $1,001 - $2,500

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends

capital gains

$2,501 - $5,000

For Your Dependent Children

Part 6

Report each underlying asset of a Uniform Gifts to Minors Act (UGMA) account or 

Uniform Transfers to Minors Act (UTMA) account that individually was worth more 

than $1,000 at the end of the reporting period or that individually produced more than 

$200 in income during the reporting period. You may indicate that the assets are held 

within a UGMA or UTMA account, but this information is not required.

This guide contains specific instructions for common types of assets held within such an 

account (e.g., mutual funds, exchange-traded funds, stocks, and corporate bonds).

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 194

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Unit Investment Trust

Report a unit investment trust (UIT) and income produced by the unit investment trust in 

Part 6.

Description EIF Value Income Type Income Amount

First Trust International High 

Dividend Equity Portfolio 

(FGRWNX)

Y $15,001 - $50,000 $201 - $1,000

For You, Your Spouse, and Your Dependent Children

Part 6

Report a unit investment trust if the value of the unit investment trust was more than 

$1,000 at the end of the reporting period or if the unit investment trust produced more 

than $200 in income during the reporting period.

Description: Provide the exact name of the unit investment trust (e.g., list “Invesco Van 

Kampen Intermediate Corporate Investment Grade Trust” rather than just “Invesco Van 

Kampen”).

EIF: Select “Y.”

Value: Report the value of the unit investment trust by selecting the appropriate 

category.

Income Type: Do not complete this field for EIFs.

Income Amount: Select the category that corresponds to the total amount of income 

produced during the reporting period.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 6 195

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Will or Estate

Generally, report the following interests in Part 6: (1) assets distributed from an estate 

and (2) a beneficial interest in an estate that has not yet been distributed. In addition, 

report any fees you received as an executor or administrator in Part 2 and any fees your 

spouse received in Part 5. Do not report an interest in the will of a living person.

Assets Distributed from an Estate

Description EIF Value Income Type Income Amount

Xylophone Technologies 

Corporation (XYZ)

N/A $1,001 - $15,000 dividends $201 - $1,000

QWERTY Growth Fund (QWYXX) Y $50,001 - $100,000 $1,001 - $2,500

Beneficial Interest in an Estate (assets not yet distributed)

Description EIF Value Income Type Income Amount

Estate of a family member (value 

and income not readily 

ascertainable)

N/A

There are many types of wills, and wills are established and interpreted under state law. 

The guidance provided here and in other sections of this guide addresses the most 

common situations. It is recommended that you work with an ethics official at your 

agency to determine whether and how to disclose information about a will or an estate.

Note that the wills and estates discussed in this section do not involve trusts. Consult an 

ethics official at your agency if the will or estate involves a trust.

For You, Your Spouse, and Your Dependent Children

Part 6

Reporting Assets Distributed from an Estate

Report each distributed asset that individually was worth more than $1,000 at the end of 

the reporting period or that individually produced more than $200 in income during the 

reporting period. Count income produced by the asset only after it was distributed to 

you, your spouse, or your dependent children. 

This guide contains specific instructions for common types of assets that you may hold 

(e.g., mutual funds, exchange-traded funds, stocks, and corporate bonds).
Public Financial Disclosure Guide, OGE Form 278e: Part 6 196

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Reporting a Beneficial Interest in an Estate That Has Not Been Distributed

Report a beneficial interest if the interest was worth more than $1,000 at the end of the 

reporting period or if the interest produced more than $200 in income during the 

reporting period.

Description: Identify the estate. If the estate is that of a relative, you may write “estate 

of a family member.” In other cases, identify the estate by the last name of the party 

(e.g., “Estate of Mr. Doe”). If you cannot ascertain the value of the interest or the income 

produced, leave the other fields blank and write “value and income not readily 

ascertainable” in the “Description” field.

EIF: Select “N/A.”

Value, Income Type and Income Amount: If known, report the value of the interest and 

the income it produced by selecting the appropriate categories. However, in the case of 

an undistributed share of an estate, you normally would not complete these fields.

Wills of Living Persons

You do not need to report any interest in the will of a living person. Note, however, that 

other reporting requirements may apply if the person has established a trust. 

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 7 197

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OGE Form 278e: Part 7

Transactions (Annual and Termination Reports Only)

Note: These instructions do not apply to Periodic Transaction reports.

Report purchases, sales, or exchanges in Part 7. You do not need to report transactions 

previously disclosed in a Periodic Transaction report (OGE Form 278-T), unless your 

agency requires such reporting.

Description Type Date Amount

Janus Balanced Fund (JDBAX) sale 6/12/15 $15,001 - $50,000

Residential real estate, 

Seattle, WA

purchase 6/12/15 $250,001 - $500,000

For You, Your Spouse, and Your Dependent Children

Part 7

Report a purchase, sale, or exchange of real property or securities that occurred during 

the reporting period if the amount of the transaction was more than $1,000.

Description: Provide a description sufficient to identify the asset being reported (or both 

assets in the case of an exchange). The amount of information needed for a sufficient 

description will depend on the type of asset being reported. In general, the following 

rules apply.

(1) Stock: Provide the name of the issuing company.

(2) Other securities with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.

(3) Real estate: Describe the type of real estate (e.g., “residential,” “commercial,” 

“industrial,” or “undeveloped”) and provide the city and state in which it is located. 

Providing the county and state is also acceptable. Do not provide a street address.

If the asset is an underlying holding of some other investment vehicle (e.g., held within a 

fund that does not qualify as an excepted investment fund), it is helpful if you identify the 

investment vehicle (e.g., Positron Investments, LLC: Chevron Corp.).

Type: Specify the type of transaction as a purchase, sale, or exchange.

Date: Provide the month, day, and year of the transaction.

Amount: Report the amount of the transaction by selecting the appropriate category.
Public Financial Disclosure Guide, OGE Form 278e: Part 7 198

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Transactions That Are Not Reportable

You do not need to report transactions that concern the following:

• A personal residence, unless the personal residence was rented out at any point 

during the reporting period.

• Cash accounts (e.g., checking, savings, certificates of deposit, money market 

accounts) and money market mutual funds.

• Treasury bills, bonds, notes, and savings bonds.

• Holdings within a Thrift Savings Plan account or other retirement account for 

United States Government employees.

• An underlying asset held within an excepted investment fund, an excepted trust, 

or a qualified trust.

• Assets of a trade or business, unless the assets are unrelated to the operations of 

that trade or business.

In addition, you do not need to report:

• Transactions previously disclosed in a Periodic Transaction report (OGE Form 

278-T), unless your agency requires such reporting.

• Transactions that occurred when you were not an employee of the United States 

Government.

• Actions that do not constitute purchases, sales, or exchanges (e.g., gifts given or 

received, stock splits, bond calls or maturity, and expiration of options).

• Transactions that occurred solely by and between you, your spouse, or your 

dependent children.

• Transactions involving the interests of a spouse living separate and apart from you 

with the intention of terminating the marriage or providing for a permanent 

separation.

• Transactions involving the interests of a former spouse or a spouse from whom 

you are permanently separated.

No Transactions to Report

If you do not have any transactions to report, you need to state this fact. Within Integrity, 

you would make the statement by marking the “I do not have...” checkbox. For hard 

copy reports, write “None” for the first line entry.

Click Here for Frequently Asked Questions
Public Financial Disclosure Guide, OGE Form 278e: Part 8 199

Version: 5/2018

OGE Form 278e: Part 8

Liabilities

Report liabilities in Part 8. You must report your own liabilities and those of your spouse 

and dependent children.

Although there are many different types of reportable liabilities, all are reported in a 

similar manner. Common types of reportable liabilities include: Boat loans, capital calls, 

credit card debt, exercised lines of credit, margin accounts, mortgage debt, student loans, 

loans from non-commercial sources (e.g., loan from a friend), and liabilities for which 

you co-signed and have a current legal obligation to repay.

Creditor Name Type Amount Year 

Incurred

Rate Term

First District Bank mortgage $100,001 - $250,000 2007 4.7% 30 years

XYZ National Visa credit card $10,001 - $15,000 2011 variable revolving

John Jones personal loan $15,001 - $50,000 2012 prime 

+1%

on 

demand

For You, Your Spouse, and Your Dependent Children

Part 8

Report liabilities owed to any creditor that exceeded $10,000 at any time during the 

reporting period.

A general description of the requirements for all reportable liabilities is included below. 

For more detailed guidance on a particular liability, please consult the Frequently Asked 

Questions.

Creditor Name: Provide the name of the creditor/lending institution.

Type: Describe the type of liability.

Amount: Mark the appropriate category of amount or value. For revolving charge 

accounts, use the value of the liability at the end of the reporting period. For all other 

liabilities, mark the category that corresponds to the highest value of the liability during 

the reporting period.

Year Incurred: Provide the year that the liability was incurred.

Rate: Provide the interest rate. Describing the rate in reference to a prime rate, such as 

“prime + 1,” is also sufficient.
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Term: Specify, in years or months, the time that the loan allows for repayment. 

Describing the term as “on demand,” “open-ended,” “revolving” (credit cards) or 

something similar is also sufficient if applicable.

Certain Mortgages Are Not Reportable

If you are not a nominee or appointee to a Presidentially-appointed, Senate-confirmed 

(PAS) position, you do not need to report a mortgage or home equity loan secured by 

your personal residence, unless you rented out the personal residence during the reporting 

period. However, you must report mortgages or home equity loans on properties that do 

not qualify as personal residences.

If you are a nominee or appointee to one of the three types of PAS positions listed below, 

you do not need to report a mortgage or home equity loan secured by your personal 

residence, unless you rented out the personal residence during the reporting period. 

However, you must report mortgages or home equity loans on properties that do not 

qualify as personal residences. The three types of PAS positions are: 

• a position in which you will serve as a special Government employee (SGE); 

• a position as a Foreign Service Officer below the rank of ambassador; or 

• a position in the uniformed services for which the pay grade prescribed by section 

201 of title 37, United States Code is O-6 or below.

If you are a nominee or appointee to any other type of PAS position, you must report a 

mortgage or home equity loan secured by your personal residence as you would a 

mortgage on any other property.

Other Liabilities That Are Not Reportable

You do not need to report the following liabilities in Part 8:

• Loans secured by a personal motor vehicle, household furniture, or appliances, if 

the loan does not exceed the item’s purchase price.

• Revolving charge accounts, such as credit card balances, if the outstanding 

liability did not exceed $10,000 at the close of the reporting period. This method 

of calculating the threshold differs from the method for all other entries in Part 8.

• Liabilities of a trade or business, unless the liabilities are unrelated to the 

operations of that trade or business.

• Personal liabilities owed to a spouse, parent, sibling, or child of yours, your 

spouse, or your dependent child.

• Liabilities of a spouse living separate and apart with the intention of terminating 

the marriage or providing for a permanent separation.

• Obligations arising from divorce or permanent separation.
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No Liabilities to Report

If you do not have any liabilities to report, you need to state this fact. Within Integrity, 

you would make the statement by marking the “I do not have...” checkbox. For hard 

copy reports, write “None” for the first line entry.

Click Here for Frequently Asked Questions
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OGE Form 278e: Part 9

Gifts and Travel Reimbursements (Annual and Termination 

Reports Only)

Report gifts and travel reimbursements in Part 9.

Source Name City/State Brief Description Value

Mary Smith Louisville, 

KY

Electronic organizer (birthday present) $415

Rock Collectors Association Los Angeles, 

CA

Airline ticket, hotel room, and meals incident to 

speech at convention in St. Louis, MO, (August 3-4, 

2017). Personal activity unrelated to official duties.

$820

For You, Your Spouse, and Your Dependent Children

Part 9

Gifts: Report gifts totaling more than $390 that were received from a single source 

during the reporting period. When determining whether the total value of gifts from a 

single source exceeds $390, you do not need to include any gifts that had a value of $156 

or less. Click here for an example.

Travel reimbursements: Report travel reimbursements totaling more than $390 that were 

received from a single source during the reporting period. When determining whether the 

total value of reimbursements from a single source exceeds $390, you do not need to 

include any reimbursements that had a value of $156 or less.

* Note: The reporting and aggregation thresholds increased from $375/$150 to 

$390/$156 for any gifts or travel reimbursements received on or after January 1, 2017. 

Source Name: Provide the identity of the source.

City/State: Provide the source’s city and state of business or residence.

Brief Description: Describe the nature of the item or reimbursement received. For travel 

gifts and reimbursements, this description would include a travel itinerary, the dates of 

travel, and the nature of the expenses. Although not required, it is helpful to specify your 

relationship to the source or note the basis on which you accepted the gift or 

reimbursement.

Value: Provide the fair market value of the gift(s) or travel reimbursement(s).

Gifts and Travel Reimbursements That Are Not Reportable

You need not report the following gifts and travel reimbursements:
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• Anything given to your spouse or dependent child totally independent of their 

relationship to you (e.g., your spouse’s business-related travel reimbursements).

• Anything for which you paid fair market value.

• Anything accepted by the United States Government under a statute or contract 

(e.g., travel payments accepted under 31 U.S.C. § 1353).

• Anything received when you were not an employee of the United States 

Government.

• Anything received from a “relative.”

• Bequests and other forms of inheritance.

• Suitable mementos of a function honoring you (e.g., retirement party).

• Communications to your office, including subscriptions to newspapers and 

periodicals.

• Nonbusiness gifts of personal hospitality (food, lodging, and entertainment, but 

not transportation) at the donor’s personal residence or family property.

• Food, lodging, transportation, entertainment, or reimbursements provided by a 

foreign government within a foreign country or by the United States Government, 

the District of Columbia, or a state or local government.

• Food and beverages that are not consumed in connection with a gift of overnight 

lodging.

• Reimbursements required to be reported under the Foreign Gifts and Decorations 

Act.

• Reimbursements received for political trips that must be reported under § 304 of 

the Federal Election Campaign Act of 1971.

Also, in certain unusual cases, the Director of OGE may grant a waiver of the public 

disclosure requirements for gifts. This authority is ordinarily used when a filer receives a 

large number of personal gifts, such as at an engagement or wedding. However, you 

must still report the items that you received to your agency and OGE, and the fact that 

you obtained a waiver will be publicly available. Click here for more details.

No Gifts or Travel Reimbursements to Report

If you do not have any gifts or travel reimbursements to report, you need to state this fact. 

Within Integrity, you would make the statement by marking the “I do not have...” 

checkbox. For hard copy reports, write “None” for the first line entry.

Click Here for Frequently Asked Questions
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OGE Form 278-T

Do I Need to File an OGE Form 278-T (Periodic Transaction Report)?

You must file a Periodic Transaction report if:

• you are in a position subject to the public financial disclosure requirements 

(“covered position”);

• you served or are expected to serve in a covered position for more than 60 days; 

and

• you have a reportable transaction as discussed below.

You are not required to file a negative report if you have no reportable transactions.

How Do I File?

In most cases, individuals should file their reports electronically, either through Integrity, 

a web-based system developed and administered by OGE for executive-branch-wide use, 

or through another agency-supported electronic financial disclosure system. Contact 

your agency ethics official if you have any questions about getting access to the system 

used by your agency.

When Must I File?

Periodic transaction reporting is subject to two different due dates. Under the Ethics in 

Government Act, you need to file a report:

• within 30 days of receiving notification of a transaction, but

• not later than 45 days after the transaction.

Click here for additional information on these due dates.

Report Contents 

The OGE Form 278-T consists of a general information section and a section for 

reporting transactions. Click here for instructions on how to report transactions.
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For Ethics Officials

1.01: Officials Required to File

Basic Filing Requirement

5 U.S.C. app. § 101; 5 C.F.R. § 2634.202

The following individuals are required to file an Executive Branch Personnel Public 

Financial Disclosure Report:

• Candidates: A candidate for nomination or election to the office of President or 

Vice President. A report filed to satisfy the Candidate reporting requirements is 

called a “Candidate Report.”

• Nominees: A Presidential nominee to a position requiring the advice and consent 

of the Senate (PAS), other than an individual nominated for judicial office or an 

individual nominated as a Foreign Service Officer or as an officer of the 

uniformed services. A report filed to satisfy the Nominee reporting requirements 

is called a “Nominee Report.”

• New Entrant Filers: An individual who has assumed the duties of a position for 

which public financial disclosure is required (“covered position”), unless the 

individual is expected to serve no more than 60 days in any single calendar year 

or unless the individual is transferring from one covered position to another 

without a break in service of more than 30 days. A report filed to satisfy the New 

Entrant reporting requirements is called a “New Entrant Report.”

• Annual (or Incumbent) Filers: An individual who served more than 60 days in a 

covered position during the preceding calendar year. A report filed to satisfy the 

Annual reporting requirements is called an “Annual Report” or an “Incumbent 

Report.”

• Termination Filers: An individual who terminated service in a covered position, 

unless the individual served no more than 60 days during any single calendar year 

or unless the individual assumed employment in another covered position within 

30 days of termination. A report filed to satisfy the Termination reporting 

requirements is called a “Termination Report.”

Equal Classification Determinations

5 U.S.C. app. § 101(f)(3); 5 C.F.R. § 2634.202(c)

The Director of OGE may designate additional positions for filing public financial 

disclosure reports if OGE determines that those positions are equivalent to others that 

normally require filing. OGE uses this authority to account for employees with unusual 

status. Although salary levels usually define the class of filers, the level of an 

employee’s responsibility, not pay, actually determines who must file. Only the Director 

of OGE may determine whether a particular position has responsibilities equal to that of 
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other public filing positions. An agency that wishes the Director to designate a position 

for public filing must submit a written request providing a basis for this determination.

For additional information, see OGE DAEOgram DO-07-029 (August 20, 2007).

Exclusion for Individuals Serving 60 Days or Less

5 U.S.C. app. §§ 101(d) & (h); 5 C.F.R. § 2634.201(a) & § 2634.204

A filing exclusion exists for individuals who served or will serve no more than 60 days in 

a covered position. The application of the exclusion depends on the type of public report 

that the individual would otherwise be required to file.

New Entrant and Nominee Reports

A New Entrant report is not required if the agency at which the position is located 

determines that the employee is not reasonably expected to perform the duties of the 

position for more than 60 days in any calendar year. Agencies need not inform OGE of 

such decisions but must record them in their own files. The Director of OGE will 

exclude a nominee to a PAS position from the filing requirement if the Director 

determines that the individual is not reasonably expected to perform the duties of the 

position for more than 60 days in any calendar year. The Director makes this 

determination based on information from the employee’s agency. Some Senate 

committees, however, might require a confidential OGE Form 278e under their own 

statutory authority to require information as a condition of confirmation.

If an employee has initially been excluded from public filing but does work more than 60 

days in a calendar year, then the employee must file a New Entrant report within 15 days 

after the 60th day. The employee should also file any subsequent Annual and 

Termination reports.

Annual Reports

An employee who performed the duties of the position for no more than 60 days in a 

calendar year does not need to file an Annual report covering that calendar year. 

However, the employee may still be subject to other reporting requirements. For 

example, an employee who assumes the duties of a covered position in December 2014 

does not have to file an Annual report for calendar year 2014. However, the employee 

will need to complete a New Entrant report, unless the DAEO determines that the 

employee is not reasonably expected to perform the duties of the position for more than 

60 days in any calendar year.

Termination Report

An employee need not file a public Termination report if he or she performed the duties 

of the position for no more than 60 days in any calendar year.
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Day-Counting Rules for Purposes of the Exclusion

For part-time employees and special Government employees, agencies should count the 

days on which the employees actually worked (excluding certain de minimis activities). 

If a part-time employee works a part of a day, or on a Saturday, a Sunday, or a holiday, 

then that day counts as one day in determining the number of days worked. See OGE 

DAEOgram DO-07-005 (February 22, 2007) and OGE DAEOgram DO-07-002 (January 

19, 2007) for additional guidance.

For full-time employees, agencies should count consecutive calendar days of assignment 

to the position, including weekends and holidays.

Confidential Financial Disclosure

Special Government employees exempted from the public filing requirement must file a 

New Entrant confidential financial disclosure report, regardless of the number of days 

served, unless they are exempted from filing by agency determination.

Optional Procedures If the Number of Days to Be Worked Is Unclear

In certain cases, agency ethics officials do not expect an employee to serve more than 60 

days but know there is a real possibility that the employee could do so. In such cases, 

agency ethics officials may permit, but not require, an employee to file a modified OGE 

Form 278e in lieu of a confidential financial disclosure form. The modified OGE Form 

278e would include only the information required by the confidential financial disclosure 

requirements. For example, in Parts 2, 5, and 6, the filer would report the assets that meet 

either the value or income reporting thresholds, but would not complete the value and 

income fields. Similarly, the filer would complete only the Creditor Name and Type 

fields in Part 8. The modified OGE Form 278e would be treated as confidential and 

marked “not for public release” (or “confidential”), unless and until the employee works 

more than 60 days in that calendar year. If the employee does work more than 60 days, 

the employee must update the report within 15 days of the 60th day, including all of the 

information required for a public OGE Form 278e. See OGE DAEOgram DO-03-021 

(October 23, 2003) for additional guidance.

Alternatively, an employee may voluntarily complete all of the information required for a 

public OGE Form 278e at the time he or she files confidentially. For example, unlike the 

procedure discussed above, the employee may complete the value and income fields for 

each entry in Parts 2, 5, and 6. The OGE Form 278e would be treated as confidential and 

marked “not for public release” (or “confidential”), unless and until the employee works 

more than 60 days in that calendar year. In the event that the employee does serve more 

than 60 days, the agency could use the existing confidential OGE Form 278e to satisfy 

the public reporting requirement, provided that the information is no more than 6 months 

old. The agency would simply remove the confidential designation from the report 

within 15 days after the 60th day worked.
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Exclusion for Non-policy-making Schedule C Positions

5 U.S.C. app. § 101(f)(5); 5 C.F.R. § 2634.203

At the request of agencies, the Director of OGE may exclude politically-appointed 

administrative support positions from public filing. The authority extends to Schedule C

and other civilian positions that: 

• are excepted from the competitive service because of their confidential character 

and 

• are classified at or below GS-15 or for which the rate of basic pay outside the 

General Schedule (lowest step) is below 120% of the rate of pay for GS-15-01.

OGE excludes a position if it determines that the exclusion would not adversely affect the 

integrity of the Government or the public’s confidence in the integrity of the Government 

because the position has no policy-making role with respect to agency programs. OGE 

distinguishes between positions with programmatic policy-making roles and positions 

whose incumbents have only administrative roles based on the duties specified in the 

incumbent’s position description. Policy-making roles include, but are not limited to the 

following: making substantive decisions and advising officials on courses of action or the 

possible outcomes of policy decisions. Policy-making roles do not include administrative 

tasks such as scheduling meetings, compiling information for policy-makers, or making 

decisions about workflow and office management procedures. Once an exclusion is 

granted, the exclusion applies to all employees who fill that position, unless and until the 

duties of that position change.

Agencies that wish to exclude a position must submit a written request to the Director of 

OGE that includes the position title and a copy of the position description. The exclusion 

of a position is effective upon the agency’s written request to OGE; however, that request 

should be submitted before the due date for the report the employee would otherwise file. 

If OGE denies a request, OGE will set a due date for filing the OGE Form 278e, which 

will normally be 45 days from the date of the denial. An agency may request 

reconsideration of a denial by submitting an amended position description or other 

additional materials.

Special Waiver of Public Reporting Requirements for a Special Government 

Employee (SGE)

5 U.S.C. app. § 101(i); 5 C.F.R. § 2634.205

In certain unusual circumstances, the Director of OGE may waive the public availability 

requirement for an SGE’s financial disclosure report. This waiver may be granted only if 

the SGE is reasonably expected to perform or has performed the duties of an office or 

position for fewer than 130 days in a calendar year. The waiver does not exempt a person 

from the requirement to file a financial disclosure report; rather, it merely exempts the 

report from release to the public. Once a waiver has been granted under the Ethics in 
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Government Act, the report will also be exempt from release under the Freedom of 

Information Act.

The Director may grant a waiver if all of the following four criteria are met:

• the individual is a special Government employee; 

• the individual is able to provide services specially needed; 

• it is unlikely that the individual’s outside employment or financial interests will 

create a conflict of interest; and 

• public disclosure is not necessary under the circumstances. 

If an SGE desires a waiver, the SGE must submit a written request to OGE via the SGE’s 

agency within 10 days after (1) the SGE learns that the position requires public disclosure 

and will involve more than 60 days of service or (2) the SGE works more than 60 days in 

a covered position despite plans to work no more than 60 days, whichever is earlier. The 

request must include a cover letter as well as a statement justifying the request and the 

SGE’s completed OGE Form 278e.

Elements of a Waiver Request

Each request for a waiver from filing a public financial disclosure report must include the 

following: 

1. A cover letter that: 

• provides the employee’s name and position; 

• states the approximate number of days in a calendar year which the employee 

expects to serve in that position; and 

• requests a waiver of public filing under 5 C.F.R. § 2634.205.

2. A separate statement that provides the reasons for an individual’s belief that the four 

criteria listed above are met.

3. A completed OGE Form 278e, which provides the factual basis for determining that 

no conflict of interest is likely. The agency must ensure that the OGE Form 278e has 

been identified as a confidential report.

The agency should forward the request to OGE with its opinion as to whether OGE 

should grant a waiver. If OGE grants the request, the cover letter described above would 

be publicly available in lieu of the OGE Form 278e. If OGE denies the waiver, the 

agency would make the report publicly available in accordance with the release 

provisions of the Ethics in Government Act. The cover letter, however, would not be 

releasable to the public in this case.
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Federal Advisory Committees

Generally, only Government employees are subject to the federal ethics requirements, 

including financial disclosure, the conflict of interest laws, and the standards of ethical 

conduct. Members of federal advisory committees frequently are appointed as special 

Government employees, and these special Government employees are subject to the 

federal ethics requirements, with certain exceptions and modifications. Sometimes, 

however, members are instead selected to serve as “representatives” of interest groups 

that have a stake in the work of the advisory committee. These representative members 

are not Government employees and, therefore, are not subject to the federal ethics 

requirements. OGE has provided specific guidance (OGE 82 x 22; OGE 00 x 1; DO-04-

022; and DO-05-012) to help agencies determine whether particular advisory committee 

members should be designated as special Government employees or as representatives.

Detailees / Acting in a Position

5 C.F.R. §§ 2634.201(a), 2634.602(a) & 2634.605(b)

The position, not the individual in the position, controls the public financial disclosure 

filing requirements. Accordingly, individuals detailed to or acting in a “covered” 

position for more than 60 days must file a public financial disclosure report. The detailed 

employee files the report with the employee’s home agency. The agency to which the 

employee is detailed should perform an intermediate review. See OGE 81 x 3.

An agency should make a prospective determination whether a person entering a position 

will work more than 60 days when deciding whether the person should file a New Entrant 

report. If an agency is uncertain about this estimate, the agency may offer the employee 

the option of filing a modified OGE Form 278e. See the discussion provided above 

under “Exclusion for Individuals Serving 60 Days or Less.”

Intergovernmental Personnel Act (IPA) Detailees

An IPA detailee to a federal position is a federal employee for purposes of the Ethics in 

Government Act. Consequently, an IPA detailee must file an OGE Form 278e if the 

detailee is assigned to an established public filing position and is reasonably expected to 

perform the duties of that position for more than 60 days in a calendar year. An IPA 

detailee who is given a set of ad hoc, unclassified duties, relevant only to the specific 

assignment project is not required to file an OGE Form 278e. Such IPA detailees do not 

have clearly defined positions and many of them retain their non-federal salaries, which 

may not reflect the level of responsibility of their Government duties and often may be 

higher than the salaries paid to other Government employees for similar work. However, 

in unusual cases, an agency may request an equal classification request from OGE.

Any IPA detailee who is not required to file an OGE Form 278e may be required to file a 

confidential financial disclosure report (OGE Form 450) if the employee’s duties and 

responsibilities meet the criteria set forth at 5 C.F.R. § 2634.904(a)(1).
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For additional information, see OGE DAEOgram DO-02-029 (December 9, 2002).

Changes in Position or Duties

Individuals do not file a New Entrant report if they transfer between covered positions 

without a break of service in excess of 30 days. In these cases, the agency should instead 

review the individual’s most recent OGE Form 278e for potential conflicts in the new 

position. This review would not constitute a full, formal review leading to certification; 

however, the agency should document that such conflicts review occurred.

Similarly, if a current filer temporarily assumes the duties of another position, the 

individual would not file a new report. The agency, however, should review the 

individual’s most recent OGE Form 278e for potential conflicts with the new position. 

See OGE DAEOgram DO-08-040 (December 16, 2008).

Master List of Filers

Agencies must compile and maintain a list or database of public filers.

In addition to a basic identification list of names, titles, addresses, and phone numbers, 

agencies may wish to include other information to assist in program management. These 

other elements may include:

• dates of position entrance, filing, review, extensions, late filing fees, and 

certification;

• number of days worked in that calendar year (for SGEs);

• number and type of requests for the public release of a report; and

• ethics agreements and their status.
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1.02: Types of Reports and Filing Deadlines

When a Covered Individual Must File a Report

5 U.S.C. app. § 101; 5 C.F.R. § 2634.201

Individuals covered by the public filing requirements must complete a public financial 

disclosure report in several different situations:

• Candidate Report: Due within 30 days of becoming a candidate for nomination or 

election to the office of President or Vice President, or by May 15 of that calendar 

year, whichever is later, but at least 30 days before the election, and on or before 

May 15 of each succeeding year the individual continues to be a candidate.

• Nominee Report: Due no later than 5 days after nomination by the President for 

the position.

• New Entrant Report: Due within 30 days of assuming the duties of the position 

covered by the public filing requirements. A report is not required if service is 

expected to last no more than 60 days in a calendar year or if the individual is 

transferring from one covered position to another without a break in service of 

more than 30 days. See “Officials Required to File” for more information.

• Annual Report: Due annually, no later than May 15th following the covered 

calendar year. A report is not required if the filer served no more than 60 days in 

the calendar year. See “Officials Required to File” for more information.

• Termination Report: Due within 30 days of leaving a position covered by the 

public filing requirements. A report is not required if the filer served no more 

than 60 days in a calendar year or if the individual is transferring from one 

covered position to another without a break in service of more than 30 days. See 

“Officials Required to File” for more information.

• Periodic Transaction Report: Due within 30 days of receiving notification of a 

transaction, but not later than 45 days after the transaction.

Calculating Due Dates

Start Date

For cases in which a filer has a certain number of days to file a report, the filing period 

starts on the day after the triggering event. 

Example: A filer assumes the duties of a public filing position October 1. The 30-day 

period for the filer’s New Entrant report starts on October 2.

End Date

The filing period ends at the end of the last day of the period. 
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Example 1: A filer assumes the duties of a public filing position October 1. The 30-day 

period for the filer’s New Entrant report ends at the end of the day on October 31. The 

filer’s New Entrant report will be late if received on November 1.

Example 2: A filer’s Annual report needs to be received by the end of the day on May 15.

Effect of Weekends and Federal Holidays

If a due date falls on a weekend or federal holiday, the report is due the next normal 

workday.

Combination Reports

Filer Terminates Prior to Filing of a Required Annual Report

Employees who anticipate leaving a covered position on or within 90 days after the May 

15 annual deadline may file a combined Annual/Termination report if they request and 

receive an agency extension of the annual filing deadline.

An employee leaving before May 15 who has not yet filed an Annual report would file a 

Termination report, not a combined report.

Filer Terminates Prior to Filing of a Required New Entrant Report

A person could also file a combination New Entrant/Termination report. This situation 

would arise when an employee leaves a covered position shortly after entering the 

position. With extensions, the due date for the New Entrant report could fall after the 

employee’s termination, making a combined New Entrant/Termination report possible.

Note that Integrity does not provide an option to assign a New Entrant/Termination 

report. Agencies may have the filer complete the combined New Entrant/Termination 

report in hard copy or they may have the filer complete both a New Entrant report and a 

Termination report within Integrity. If completing two reports, the filer could use the 

same reporting period for both reports so long as the agency makes a public annotation 

explaining the reporting period used.

Moving between Covered Positions

Filer Moves between Covered Positions at Different Agencies

If a filer moves between covered positions at different agencies, the individual should file 

the next Annual report with his or her new agency. The new agency should provide a 

copy of the report to the filer’s former agency so that the former agency may review the 

report for any issues related to the filer’s service with that agency. This review by the 

former agency is not a full review within the meaning of this guide and no intermediate 

or final certification is required.
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1.03: Forms and Methods of Filing

Forms

OGE currently provides three forms for public financial disclosures.

• OGE Form 278e: Used to file Candidate, Nominee, New Entrant, Annual, and 

Termination reports. In certain cases, filers may need to complete multiple 

reports and are permitted to use a single form (e.g., a combined Annual and 

Termination report).

• OGE Form 278: Legacy format used to file Candidate, Nominee, New Entrant, 

Annual, and Termination reports. As of January 1, 2016, individuals may not file 

reports using the OGE Form 278, unless the filer’s agency has received a 

temporary waiver related to the retrofitting of the agency’s electronic financial 

disclosure system. See Program Advisory PA-15-01 (March 2, 2015).

• OGE Form 278-T: Used to file Periodic Transaction reports.

This guide assumes you are reviewing the OGE Form 278e or the OGE Form 278-T. If 

you are reviewing the OGE Form 278 instead, you should consult OGE’s guide for that 

form entitled “Public Financial Disclosure: A Reviewer’s Reference” (2004).

Use of Attachments for PAS Filers

Nominees to positions requiring Presidential appointment and Senate confirmation (PAS) 

may not attach brokerage statements or other materials in lieu of entering required 

financial disclosure information into the OGE Form 278e. In certain circumstances, OGE 

may permit a PAS filer to provide clarifying notes to the OGE Form 278e; however, such 

material is used to supplement, not to substitute for, required information.

Use of Attachments for Other Public Filers

All filers must complete the Cover Page of the OGE Form 278e and the equivalent fields 

of the OGE Form 278-T. If approved by the agency reviewing officials, filers may 

supply some or all of the information for the substantive Parts by attaching a statement 

from a financial institution, brokerage report, or other material.

These attachments must: 

• include all of the information that the OGE Form 278e or OGE Form 278-T 

requires, 

• cover the appropriate time periods completely, and 

• readily disclose the information in a clear and concise manner.

A public financial disclosure report must be a complete document in itself. Although the 

OGE Form 278e or OGE Form 278-T can incorporate material from other sources, the 

material must be made part of the form by attaching it and referencing it in the relevant 

Parts.
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For additional information, see OGE DAEOgram DO-00-007 (February 22, 2000).

Methods of Filing

Individuals filing as Candidates should download a copy of the OGE Form 278e from 

OGE’s website and submit a completed copy to the Federal Election Commission.

In most other cases, individuals should file their reports electronically, either through 

Integrity, the web-based system developed and administered by OGE for the executive 

branch, or through another agency-supported electronic financial disclosure system. If 

necessary, however, agencies may permit filers to submit a copy of the OGE Form 278e 

or OGE Form 278-T downloaded from OGE’s website.
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1.04: Extensions

5 U.S.C. app. § 101(g)(1); 5 C.F.R. § 2634.201(f)

An agency may grant any filer or class of filers an extension of the time available to file a 

report for “good cause shown,” provided such extensions do not exceed 90 days. 

Extensions of more than 45 days are subject to stricter documentation requirements.

Form of the Request and Approval

OGE recommends that all extension requests and approvals be in writing. However, oral 

extensions are permissible, provided that the extension does not extend the total time to 

file more than 45 days past the original due date. An extension that extends the total time 

for filing by 46 to 90 days requires a written request by the filer and written approval by 

the agency.

For example, a filer may orally request a single 45-day extension but can only request 

(and receive agency approval of) a 90-day extension in writing. Similarly, a filer may 

orally request a 15-day extension on three separate occasions; however, the filer may not 

orally request (and the agency may not orally approve) a fourth such extension because 

that extension, when aggregated with prior extensions, would total more than 45 days.

“Good Cause”

Examples of “good cause shown” include:

• an agency’s failure to notify an individual in a timely manner of the obligation to 

file;

• a New Entrant filer’s inability to collect value and income information for 

complex holdings within 30 days of entering the position;

• an Annual filer’s inability to provide value and income information until certain 

investment statements are received;

• long periods of official travel by the filer prior to the due date; 

• significant illness or family emergency; 

• extremely pressing duty assignments; 

• convenience of filing combined reports (e.g., combined Annual/Termination 

report); and

• administrative or technical difficulties in filing a report (e.g., the electronic 

financial disclosure system used by the agency was unavailable in the days 

leading up to the filing deadline).

Agencies may grant extensions in other situations not covered by these examples; 

however, an agency should be able to articulate why an extension meets the criteria for 

“good cause.”
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Timing of Extension Requests and Approvals

Filers should request an extension before the due date. Likewise, agencies should act on 

the request prior to the due date.

Documenting Extensions

The Cover Page of the filer’s financial disclosure report must reflect the total number of 

days by which the due date was extended. For reports filed in Integrity, the reviewer 

should record the extension in the applicable field of the General Information page. Once 

entered, the extension information will appear next to the filer’s signature on the printed 

Cover Page.

Special Extension for Service in a Combat Zone

5 U.S.C. app. § 101(g)(2)

An individual serving with or in support of the Armed Forces automatically receives an 

extension if serving in a combat zone on the applicable due date. When applicable, this 

extension replaces all other extensions.

This extension runs until 180 days after the later of the following two dates:

• the last day of the individual’s service in the combat zone or

• the last day of the individual’s hospitalization resulting from that service.

Agencies must document the combat zone extension in the Cover Page to the filer’s OGE 

Form 278e. Writing “combat zone extension” is sufficient.

Extensions Do Not Change the Reporting Period

The reporting period is tied to a report’s original due date and is unaffected by any 

extensions. For example, a New Entrant report was originally due December 14, 2015. 

The filer received a 30-day extension and filed January 8, 2016. The Part 2 reporting 

period would start on January 1, 2014 and end on December 14, 2015.
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1.05: Late Filing Fees

5 U.S.C. app. § 104(d); 5 C.F.R. § 2634.704

An official who files any public financial disclosure report more than 30 days after the 

due date or more than 30 days after the last day of an extension, whichever occurs later, 

must pay the United States a $200 late filing fee. The “date of filing” is the date that the 

agency receives the report. The fee becomes due only when the report is actually filed. 

If the employee refuses to file, see the “Failure to File and Falsification Penalties” 

section.

Delegation of Collection Responsibilities

OGE has delegated to agencies the responsibility to collect late filing fees.

Notice of Late Filing Fee

For reports that are more than 30 days overdue, an agency must provide the delinquent 

filer with written notice that the filer:

• will owe the United States a $200 late filing fee upon filing that is subject to 

agency debt collection procedures if not paid; and

• must remit the full fee to the agency, payable to the “United States Treasury;” but

• may submit a written request to the agency that the fee be waived due to 

“extraordinary circumstances.”

Collection of the Late Filing Fee

If successful in collecting a late filing fee, the agency must forward it to the United States 

Treasury for deposit as miscellaneous receipts. Ethics officials should defer to their 

agency finance office for appropriate handling of fees collected.

If unsuccessful in collecting the late filing fee, the agency should institute debt collection 

procedures, such as salary or administrative offset. In addition, an agency may take 

appropriate disciplinary action.

Waiver of the Late Filing Fee

OGE has delegated its authority to waive the late filing fee to agencies. The fee may be 

waived if the delay in filing was caused by extraordinary circumstances.

Extraordinary circumstances may include the agency’s failure to notify a New Entrant 

filer, first-time Annual filer or Termination filer of the requirement to file the public 

financial disclosure report. Other circumstances that OGE views as extraordinary are:

• a family emergency, such as a fire, an illness or a death; 

• transfer of position causing confusion over filing; 
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• agency errors (other than notification errors); and 

• the duties of a filer’s office (only agency emergencies). 

In determining whether circumstances are extraordinary, other factors to consider 

include: 

• the position of the filer (a filer might be held to a higher standard because the filer 

is an agency head or in a similar position); 

• whether the filer requested any extensions, indicating a good-faith effort to file; 

and 

• the timeliness of the filer’s previous reports. 

Employees who have previously filed Annual public reports should be aware of the next 

year’s annual filing requirement. In the absence of other extraordinary circumstances, an 

agency should not waive the late filing fee based on failure of an ethics official to remind 

an experienced filer to submit the OGE Form 278e. Nor should the agency waive the late 

fee for any employee who was mistaken about the due date, unless the agency 

contributed to that misunderstanding.

Since the statute allows a 30-day grace period after the filing due date before late filing 

fees apply, filers should ensure that the agency receives their reports by the end of that 

period. Accordingly, administrative or postal delays at the end of the grace period alone 

do not constitute an extraordinary circumstance.
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1.06: Failure to File and Falsification Penalties

In addition to the fee discussed in “Late Filing Fees” section, individuals who fail to file a 

report, file a false report, or fail to report required information risk serious consequences. 

Both the agency and the Department of Justice may take action against the employee. 

This possibility emphasizes the importance of documenting contacts with filers, 

especially when there are concerns regarding timely or accurate filing. If it appears that 

penalties may need to be applied, OGE recommends that all contacts be in writing. 

Ethics officials should also make notes about telephone and in-person conversations.

Agency Disciplinary Action

5 U.S.C. app. § 104(c); 5 C.F.R. § 2634.701(d)

An agency may take any appropriate action against employees who have not filed or who 

have filed a false, incomplete, or late report, in accordance with applicable personnel 

laws and regulations. Agency action does not, however, preclude action by the 

Department of Justice.

Actions that the Department of Justice May Take

Civil Action

5 U.S.C. app. § 104(a)(1)

The Attorney General may bring a civil action in any appropriate United States district 

court against any individual who knowingly and willfully falsifies or who knowingly and 

willfully fails to file or report any information that such individual is required to report 

pursuant to 5 U.S.C. app. § 102. The court in which such action is brought may assess a 

civil penalty of up to $50,000.

Criminal Action

5 U.S.C. app. § 104(a)(2); 18 U.S.C. § 1001

The Attorney General may bring a criminal action against any individual who: 

• knowingly and willfully falsifies information required to be reported or 

• knowingly and willfully fails to file or report any information that such individual 

is required to report.
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1.07: Written Procedures

5 U.S.C. app. § 402(d)(1); 5 C.F.R. § 2634.103(a) Note

Requirements

Each agency is required by Section 402(d)(1) of the Ethics in Government Act to have 

written procedures for both the public and confidential financial disclosure systems 

regarding the collection, review, and evaluation of reports, as well as their public 

availability, as appropriate. An agency may issue separate written procedures for the 

confidential disclosure system or combine such guidance with its procedures for the 

public system.

In developing procedures, agencies should follow the guidance set forth in OGE 

DAEOgram DA-09-03-92 (September 3, 1992). Pursuant to that guidance, agency 

procedures for public financial disclosure should address the following topics:

• Identifying New Entrant, Annual, and Termination report filers, including a 

determination of who will be responsible for identifying filers and maintaining 

and updating master listings of filers.

• Distributing blank report forms (or, if applicable for the agency, providing access 

to an electronic filing system).

• Filing instructions (i.e., where and when to file reports, including any internal 

agency due dates).

• Identifying who filers should contact for assistance in completing the reports.

• Granting filing extensions.

• Granting exclusions from the filing requirements, including how to obtain 

approval from OGE for exclusions from the public financial disclosure 

requirements.

• Designating officials authorized to review and certify reports.

• Performing a technical and conflicts of interest review.

• Levels of review and approval.

• Obtaining additional information from the filer when the report is incomplete, 

ambiguous, or raises conflict of interest issues and establishing an allowable 

timeframe within which the filer must provide the additional information.

• Amending and revising reports based on additional information obtained from the 

filer.

• Maintaining custody of reports.

• Providing for public access to public financial disclosure reports.

• Requiring remedial actions to resolve conflicts of interest or violations of laws, 

regulations or executive orders.

• Pursuing administrative or disciplinary actions where appropriate.

• Following up on delinquent reports. 

• Collecting the $200 late filing fee and granting waivers of the $200 late filing fee.
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In addition to these requirements, agency procedures must address how the agency 

handles Periodic Transaction reports and complies with the other requirements of the 

STOCK Act (Public Law 112-105).
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2:01: Reporting Periods

5 U.S.C. app. §§ 101(d), 101(e), & 102(b); 5 C.F.R. § 2634.308

The Reporting Periods for the OGE Form 278e vary depending on the type of report 

being filed.

Part

Report Information for the Following Period...

Nominee,

New Entrant, 

and Candidate

Annual Termination Annual / 

Termination

1. Filer’s Positions Preceding Two 

Calendar Years to 

Filing Date

Preceding 

Calendar Year to 

Filing Date

End of Period 

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

2. Filer’s 

Employment Assets 

& Income and 

Retirement 

Accounts

Preceding 

Calendar Year to 

Filing Date1

Preceding 

Calendar Year

End of Period 

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

3. Filer’s 

Employment 

Agreements and 

Arrangements

As of Filing Date Preceding 

Calendar Year to 

Filing Date

End of Period 

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

4. Filer’s Sources of 

Compensation 

Exceeding $5,000 

in a Year

Preceding Two 

Calendar Years to 

Filing Date (N/A

for Candidates)

N/A – Leave this 

Part blank

N/A – Leave this 

Part blank

N/A – Leave this 

Part blank

5. Spouse’s 

Employment Assets 

& Income and 

Retirement 

Accounts

Preceding 

Calendar Year to 

Filing Date1

Preceding 

Calendar Year

End of Period 

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

6. Other Assets and 

Income

Preceding 

Calendar Year to 

Filing Date1

Preceding 

Calendar Year

End of Period

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

7. Transactions N/A – Leave this 

Part blank

Preceding 

Calendar Year2

End of Period 

Covered by Last 

Report to Term 

Date2

Preceding 

Calendar Year to 

Term Date2
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8. Liabilities Preceding 

Calendar Year to 

Filing Date1

Preceding 

Calendar Year

End of Period 

Covered by Last 

Report to Term 

Date

Preceding 

Calendar Year to 

Term Date

9. Gifts and Travel 

Reimbursements

N/A – Leave this 

Part blank

Preceding 

Calendar Year2

End of Period 

Covered by Last 

Report to Term 

Date2

Preceding 

Calendar Year to 

Term Date2

1 For example, if today is March 3, 2016, the reporting period would run from January 1, 

2015 to March 3, 2016. The filer may end the reporting period for assets and liabilities 

on any day within 31 days of the filing date.

2 Filers do not need to include any period when they were not an officer or employee of 

the United States Government.
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2.02: Spouses and Dependent Children

Reporting Requirements

5 U.S.C. app. § 102(e); 5 C.F.R. § 2634.309

Interests of a filer’s spouse and dependent children are reportable in the following Parts:

• Part 5: Spouse’s Employment Assets & Income and Retirement Accounts 

• Part 6: Other Assets and Income

• Part 7: Transactions

• Part 8: Liabilities

• Part 9: Gifts and Travel Reimbursements (unless received for reasons 

independent of their relationship to the filer)

Definitions

Spouse

For purposes of financial disclosure and other federal ethics rules, “spouse” means an 

individual to whom the filer has been legally married, including a same-sex marriage, 

regardless of the filer’s state of residence. The term “spouse” does not include an 

individual with whom the filer is in a civil union, domestic partnership, or other 

relationship other than marriage. See OGE Legal Advisory LA-13-10 (August 19, 2013).

Dependent Child v. Minor Child

5 U.S.C. app. § 109(2); 5 C.F.R. § 2634.105(d)

The criminal statute on conflict of interest (18 U.S.C. § 208) uses the term “minor child,” 

but the financial disclosure requirements (and the Standards of Conduct provisions on 

impartiality) refer more broadly to “dependent children.”

For purposes of financial disclosure, “dependent” means an individual who is:

1. a son, daughter, stepson or stepdaughter of the filer; and

2. unmarried, under age 21 and living in the filer’s house or considered dependent by tax 

code standards.

“Minor child” is a class of children defined by state law, usually as under age 18.
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Tests for Separateness

5 U.S.C. app. § 102(e)(1)(E); 5 C.F.R. § 2634.309(a)(3)

A filer need not report assets, investment income, or liabilities of a spouse or dependent 

child if the interests strictly meet all the tests for separateness. These tests, however, are 

very rarely met. For example, an asset which is reported on a joint tax return or held in a 

trust for a child’s education is a benefit to the filer. Thus, the asset should be reported. A 

practical effect of these tests is that filers who complete joint tax returns, cohabitate, 

share expenses, or have not been disinherited by their spouses must report the spouse’s 

interests.

Changes in Status

Marriage during a Filing Period

When a filer gets married during the reporting period, the filer reports:

• In Parts 5 and 6: A spouse’s assets and sources of income for the period after the 

date of the marriage.

• In Part 7: A spouse’s transactions that took place for the period after the date of 

the marriage.

• In Part 8: A spouse’s liabilities that exceeded the reporting threshold during the 

period after the date of the marriage.

• In Part 9: A spouse’s gifts and travel reimbursements that were received after the 

date of the marriage.

Divorce or Separation

5 U.S.C. app. § 102(e)(2); 5 C.F.R. § 2634.309(c)

A filer who is divorced or permanently separated need not report a spouse’s interests for 

the period before or after the divorce or permanent separation. However, note that even 

in situations where there is no reporting requirement, 18 U.S.C. § 208 will still apply to 

particular matters in which an employee knows his or her separated spouse has a financial 

interest.

No Longer a Dependent

The filer need not report the sole interests of any child who was not a dependent as of the 

date of filing. The filer, however, must still report any interests which are (or were) also 

those of the filer or the filer’s spouse (e.g., a child’s loan for which the filer co-signed).
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2.03: Cover Page of the OGE Form 278e

The Cover Page of the OGE Form 278e contains the following information:

1. Filer’s Name

2. Report Type: The type of report must be specified. Based on the type of report, one 

or more of the following fields may be required:

• Date of Appointment (for New Entrant Reports)

• Year (for Annual Reports)

• Date of Termination (for Termination Reports)

• Name of Congressional Committee(s) Considering Nomination (for Nominee 

Reports)

3. Position: This field refers to the title of the position for which a report is being filed.

4. Agency: This field refers to the agency in which the position is located.

5. Other Federal Positions Held During the Preceding 12 Months: Filers should list any 

positions (other than the one for which they are filing) that they held with the United 

States Government during the twelve months prior to the date of filing, including any 

positions in the legislative and judicial branches. Filers should also provide the month 

and year in which they started and ended their service in the positions. Ongoing service 

should be reflected as “to Present.”

6. Filer’s Certification: Individuals filing hard copies of the OGE Form 278e must sign 

and date their reports in ink. By signing the report, the filer certifies that the information 

contained in the report is true, complete, and correct to the filer’s knowledge. The 

original signature should appear on the copy of the form that agency reviewers certify. 

Reviewers may certify photocopies, but OGE does not recommend this practice. 

Individuals filing within Integrity or other electronic filing system will certify their 

reports through an electronic signature.

7. For Reviewer’s Use Only:

• Extension: Reviewers must specify the number of days of any extension granted. 

For hard copy reports, reviewers may enter the information in the “Comments of 

Reviewing Officials” section.

• Receipt Date: Reviewers of hard copy reports must enter the date of agency 

receipt in the “Comments of Reviewing Officials” section. The filer’s electronic 

signature date constitutes the receipt date for reports filed using Integrity or 

another electronic filing system.

• Comments of Reviewing Officials: Reviewers of hard copy reports should use 

the “Comments of Reviewing Officials” section for annotations to the report. 

Reviewers using Integrity would make annotations through the “public 
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annotation” feature. See “Report Amendments and Annotations” for additional 

information.

• Agency Ethics Official Opinion: The signer certifies “on the basis of the 

information contained in this report, I conclude that the filer is in compliance with 

applicable laws and regulations,” subject to any annotations in the “Comments of 

Reviewing Officials” section. Before signing, the official should be aware of 

certification requirements (see “Certification Requirements”). Certification ends 

the review process.

• Other Review: The preliminary reviewing official should sign and date here if the 

agency requires an intermediate review. Individuals who are not examining the 

report for both technical sufficiency and potential conflicts of interest should not 

sign the Cover Page. For example, a supervisor who is only checking a filer’s 

disclosed interests for potential conflicts would not sign here. Integrity records 

such reviews internally within the system. For hard copy reports, a limited review 

may be noted in the “Comments of Reviewing Officials” section or in the 

agency’s background notes to the report. If a limited review is recorded in the 

“Other Review” field, the limited nature of the review should be noted. 

• U.S. Office of Government Ethics Certification: The Director of OGE, or a 

designee, certifies those reports subject to OGE review after the reports have been 

certified at the agency level.
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2.04: OGE Form 278e, Part 1

Filer’s Positions Held Outside United States Government

What to Report

5 U.S.C. app. § 102(a)(6)(A); 5 C.F.R. § 2634.307

Filers report in Part 1 any compensated or uncompensated position held with an 

organization other than the United States Government at any time during the reporting 

period, unless an exception applies.

Organization Name: Filers provide the name of the organization. For a family trust, 

filers may use initials in lieu of a person’s name (e.g., “2003 J.S. Trust”) or simply refer 

to the entity as a family trust (e.g., “family trust #1”).

City/State: Filers provide the city and state in which the organization is located.

Organization Type: Filers describe the type of organization.

Position Type (This question is for internal purposes within Integrity and is not displayed 

on the printed OGE Form 278e.): Filers indicate the general type of organization by 

selecting one of the options provided in the drop-down list. The list of options changes 

based on the type of organization. If none of the pre-determined options matches the type 

of position, filers may enter their own description. The type of position held determines 

the types of questions Integrity asks concerning possible assets, income, and 

arrangements.

Position Held: Filers provide the title or a brief functional description of the position.

From: Filers provide the month and year in which service in the position began.

To: Filers provide the month and year in which the position ended. If a filer still holds 

the position, the filer should indicate “present.”

Positions That Are Not Reportable

Filers do not need to report the following in Part 1:

• Positions held by a spouse or dependent children.

• Positions held with the United States Government and positions held in an official 

capacity as a representative of the United States Government.

• Positions held in a religious, social, fraternal, or political organization.

• Positions solely of an honorary nature.

• Mere membership in an organization.
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• Passive investment interests as a limited partner or non-managing member of a 

limited liability company (i.e., the filer is just an investor and provides no 

services).

In addition, filers do not need to report service as a member of an advisory board or 

committee if the following criteria are met: (1) the filer’s service is unpaid; (2) the board 

or committee is that of a non-profit or governmental organization; (3) the filer does not 

have fiduciary duties of the sort exercised by officers, directors, or trustees; and (4) the 

filer’s role does not involve sufficient supervision by the organization to create a 

common law employee-employer relationship.

No Positions to Report

The filer must affirmatively state that he or she does not have any positions to report. 

Within Integrity, the filer would make this statement by marking the “I do not have...” 

checkbox. For hard copy reports, the filer would write “None.”
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2.05: OGE Form 278e, Part 2

Filer’s Employment Assets & Income and Retirement Accounts

What to Report

5 U.S.C. app. §§ 102(a)(1) & (a)(3); 5 C.F.R. § 2634.301-302

Filers report an asset related to employment in Part 2 if the value of the asset was more 

than $1,000 at the end of the reporting period or if the asset produced more than $200 in 

income during the reporting period. For purposes of this Part, “employment-related” is 

interpreted broadly to cover all of the filer’s non-investment activities as well as the 

filer’s retirement accounts.

In addition, filers report each source, whether a natural person or an entity, that provided 

the filer more than $200 of earned income and other non-investment income during the 

reporting period.

How to Report

Generally, filers report employment-related assets and sources of non-investment income 

as follows:

Description: Filers must provide a description sufficient to identify the asset or source 

being reported. The amount of information needed for a sufficient description will 

depend on the type of asset or income being reported. In general, the following rules 

apply.

(1) Stock: Provide the name of issuing company. For stock in a privately held company, 

describe the issuer’s business.

(2) Other assets with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.

(3) Assets without specific names: Describe the type of asset, including the city/state (or 

county and state) for real estate.

(4) Sources of earned or other non-investment income: Provide the name of the source 

and, for privately held companies, the nature of the business. In addition, for honoraria, 

include the date that the services were provided.

EIF: If a filer is reporting an investment vehicle that invests in assets of its own, the filer 

would report each underlying asset that was individually worth more than $1,000 at the 

end of the reporting period or that individually produced more than $200 in income 

during the reporting period. As an exception to this requirement, however, a filer does 

not need to report the underlying assets of an investment vehicle that qualifies as an 

excepted investment fund (EIF). A filer marks the “EIF” field to indicate whether an 
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entry qualifies as an excepted investment fund. Click here for the definition of “excepted 

investment fund” provided to filers.

Value: Filers report the value of an asset by selecting the appropriate category. Filers of 

New Entrant, Nominee, and Candidate reports may determine the value of an asset by 

choosing its value on any date that is within 31 days of the date of filing. Filers of 

Annual and Termination reports should value assets as of the end of the reporting period.

Income Type: Filers skip this section if the amount of income during the reporting period 

was less than $201 or if the filer is reporting an investment vehicle that qualifies as an 

excepted investment fund. In all other cases, filers specify the type(s) of income (e.g., 

salary, consulting fees, dividends, interest, capital gains, rent, royalties, etc.) 

Income Amount:

(1) Income less than $201: Filers select the “None (or less than $201)” amount category.

(2) Dividends, capital gains, interest, rent, royalties, or income from excepted investment 

funds: Filers select the category that corresponds to the total amount of income produced 

during the reporting period.

(3) Other income: Filers provide the exact amount of income produced during the 

reporting period.

Assets and Income That Are Not Reportable

Assets or income from United States Government employment are not reportable in the 

OGE Form 278e. In addition, filers should not report in Part 2 assets that were acquired 

separately from business, employment, or other income-generating activities (e.g., assets 

purchased through a brokerage account). Filers should instead report such assets in Part 

6; nonetheless, reviewers need not treat the reporting of such assets in Part 2 as an error 

requiring follow-up. Reviewers may wish to notify the filer of the appropriate placement 

of such assets if the misplacement can cause confusion on the part of the reader.

No Assets or Income to Report

The filer must affirmatively state that he or she does not have any assets or sources of 

non-investment income to report. Within Integrity, the filer would make this statement 

by marking the “I do not have...” checkbox. For hard copy reports, the filer would write 

“None.”
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2.06: OGE Form 278e, Part 3

Filer’s Employment Agreements and Arrangements

What to Report

5 U.S.C. app. §§ 102(a)(7); 5 C.F.R. § 2634.306

Filers report their participation in the following agreements or arrangements during the 

reporting period:

• Future employment.

• Leaves of absence.

• Continuing payments from an employer, including severance and payments not 

yet received for previous work. (This does not include ordinary salary from a 

current employer.)

• Continuing participation in an employee welfare, retirement, or other benefit plan, 

such as pensions or a deferred compensation plan.

• Retention or disposition of employer-awarded equity, sharing in profits or carried 

interests (e.g., vested and unvested stock options, restricted stock, future share of 

a company’s profits, etc.).

How to Report

Filers complete Part 3 by providing the following information and any other pertinent 

details of the agreement or arrangement:

Employer or Party: Filers provide the other parties to the agreement or arrangement. In 

most cases, the other party will be the filer’s employer.

City/State: Filers provide the city and state of the other parties. 

Status and Terms: Filers briefly describe the type of agreement or arrangement, its terms 

(in particular, the timing and form of any payments), and its current status. 

Date: Filers provide the month and year in which the agreement or arrangement began. 

In many cases, this will be when the filer joined the employer or otherwise became 

eligible for coverage under the agreement.

Agreements and Arrangements That Are Not Reportable

Filers do not need to report the following as agreements and arrangements in Part 3: 

(1) agreements and arrangements of a spouse or dependent child; (2) agreements and 

arrangements with the United States Government, such as participation in the Federal 

Employees Retirement System or the Civil Service Retirement System; and (3) if the filer 

is a Nominee, New Entrant, or Candidate, any agreement or arrangement that will end 

before the individual files the report.
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No Agreements or Arrangements to Report

The filer must affirmatively state that he or she does not have any agreements or 

arrangements to report. Within Integrity, the filer would make this statement by marking 

the “I do not have...” checkbox. For hard copy reports, the filer would write “None.”
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2.07: OGE Form 278e, Part 4

Filer’s Sources of Compensation Exceeding $5,000 in a Year 

(Nominee and New Entrant Reports Only)

What to Report

5 U.S.C. app. § 102(a)(6)(B); 5 C.F.R. § 2634.308(b)(6)

Filers report any source that paid more than $5,000 for the filer’s personal services in any 

calendar year during the reporting period, which covers the preceding two calendar years 

and the current calendar year up to the date of filing.

Filers report such payments both from employers and from any clients to whom the filer 

personally provided services. Filers report a source even if the source made its payment 

to an employer and not to the filer directly. As an exception to the requirement to report 

sources of such payments, filers do not include the United States Government as a source.

Filers do not report a client’s payment to an employer if the filer did not provide the 

services for which the client is paying. Because another employee, associate or partner 

provided the services, the payment is not for services the filer personally provided and, 

therefore, is not reportable in Part 4.

How to Report

Generally, filers report sources as follows:

Source Name: Filers provide the name of the source.

City/State: Filers provide the city and state in which the source is located.

* In certain rare cases, filers need not provide the identity of confidential clients. In those 

cases, filers need to specify the reason(s) why confidential clients have not been 

disclosed. For each reason specified, filers would indicate the number of confidential 

clients that have not been disclosed and indicate how many clients are entities and how 

many are individuals (e.g., “2 confidential clients are not disclosed because they are 

subject to non-public investigations = 1 partnership and 1 individual”). For Presidential 

nominees, the non-disclosure of confidential clients must be approved in advance by 

OGE. See the guidance on this topic provided to filers by clicking here.

Brief Description of Duties: Filers provide a brief description of the type of services 

rendered.

Sources That Are Not Reportable

Filers do not report the United States Government as a source or any source of a spouse 

or dependent child.
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No Sources to Report

The filer must affirmatively state that he or she does not have any sources of 

compensation to report. Within Integrity, the filer would make this statement by marking 

the “I do not have...” checkbox. For hard copy reports, the filer would write “None.”
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2.08: OGE Form 278e, Part 5

Spouse’s Employment Assets & Income and Retirement 

Accounts

What to Report

5 U.S.C. app. § 102(e)(1); 5 C.F.R. § 2634.309

Filers report an asset related to a spouse’s employment in Part 5 if the value of the asset

was more than $1,000 at the end of the reporting period, or if the asset produced more 

than $200 in income during the reporting period. For purposes of this Part, 

“employment-related” is interpreted broadly to cover, with certain exceptions, all of a 

spouse’s non-investment activities as well as the spouse’s retirement accounts.

In addition, filers report each source, whether a natural person or an entity, that provided 

the filer’s spouse more than $1,000 of earned income during the reporting period. Note 

that filers report their sources of non-investment income in Part 2, regardless of whether 

the income can be characterized as “earned.” For their spouses, however, filers report 

only sources of earned income.

How to Report

Filers report their spouses’ employment-related assets and sources of earned income in 

the same manner as their own employment-related interests, with two exceptions. First, 

filers leave the “Income Amount” field blank when reporting a spouse’s earned income 

other than honoraria. The exact amount of honoraria is required. Second, the “Value” 

and “Income Amount” fields include a category labeled “Over $1,000,000.” A filer may 

use this category or may use the higher value and amount categories.

Assets and Income That Are Not Reportable

The reporting exceptions for filers also apply to spouses. In addition, filers report only 

sources of earned income for spouses, not all sources of non-investment income.

No Assets or Income to Report

The filer must affirmatively state that he or she does not have any assets or sources of 

earned income to report. Within Integrity, the filer would make this statement by 

marking the “I do not have...” checkbox. For hard copy reports, the filer would write 

“None.”
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2.09: OGE Form 278e, Part 6

Other Assets and Income

What to Report

5 U.S.C. app. §§ 102(a)(1), (a)(3), & (e)(1); 5 C.F.R. §§ 2634.301-302 & 309

Filers report each asset, not already reported in Part 2 or Part 5, that ended the reporting 

period with a value greater than $1,000 or produced more than $200 in income during the 

reporting period. For purposes of the value and income thresholds, filers aggregate their 

interests with those of their spouses and dependent children.

How to Report

Filers report assets in the same manner as their employment-related assets with one 

exception. The “Value” and “Income Amount” fields include a category labeled “Over 

$1,000,000.” A filer may use this category for assets owned by the filer’s spouse or 

dependent children, but not for those assets owned individually or jointly by the filer.

Assets and Income That Are Not Reportable

Filers do not report any of the following: (1) a personal residence (including a vacation 

home used as a second residence or a vacation home used as a timeshare) that the filer 

did not rent out during the reporting period; (2) retirement benefits from the United States 

Government, including the Thrift Savings Plan; (3) income from Social Security, 

veterans’ benefits, and other similar United States Government benefits; (4) cash 

accounts (e.g., money market accounts, certificates of deposit, savings accounts, checking 

accounts) in a single financial institution aggregating $5,000 or less; (5) shares in a single 

money market fund aggregating $5,000 or less; (6) term life insurance; (7) insurance 

claims and reimbursements, unless they are subject to federal income tax; (8) assets of a 

trade or business, unless the assets are unrelated to the operations of that trade or 

business; (9) loans made by the filer or the filer’s spouse to each other or to a parent, 

sibling, child, or grandchild; (10) interests of a spouse living separate and apart with the 

intention of terminating the marriage or providing for a permanent separation; 

(11) interests of a former spouse or a spouse from whom the filer is permanently 

separated; and (12) payments from a spouse or former spouse associated with a divorce 

or permanent separation.

No Assets to Report

The filer must affirmatively state that he or she does not have any assets to report. 

Within Integrity, the filer would make this statement by marking the “I do not have...” 

checkbox. For hard copy reports, the filer would write “None.”
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2.10: OGE Form 278e, Part 7

Transactions (Annual and Termination Reports Only)

What to Report

5 U.S.C. app. §§ 102(a)(5) & (e)(1); 5 C.F.R. §§ 2634.303 & 309

Filers report a purchase, sale, or exchange of real property or securities that occurred 

during the reporting period if the amount of the transaction was more than $1,000.

How to Report

Generally, filers report transactions as follows:

Description: Filers provide a description sufficient to identify the asset being reported (or 

both assets in the case of an exchange). The amount of information needed for a 

sufficient description will depend on the type of asset being reported. In general, the 

following rules apply.

(1) Stock: Provide the name of the issuing company.

(2) Other securities with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.

(3) Real estate: Describe the type of real estate (e.g., “residential,” “commercial,” 

“industrial,” or “undeveloped”) and provide the city and state in which it is located. 

Providing the county and state is also acceptable. Do not provide a street address.

If the asset is an underlying holding of some other investment vehicle (e.g., held within a 

fund that does not qualify as an excepted investment fund), it is helpful if the filer 

identifies the investment vehicle (e.g., Positron Investments, LLC: Chevron Corp.).

Type: Filers specify the type of transaction as a purchase, sale, or exchange.

Date: Filers provide the month, day, and year of the transaction.

Amount: Filers report the amount of the transaction by selecting the appropriate 

category.

Transactions That Are Not Reportable

Filers do not need to report transactions that concern the following: (1) a personal 

residence, unless the personal residence was rented out at any point during the reporting 

period; (2) cash accounts (e.g., checking, savings, certificates of deposit, money market 

accounts) and money market mutual funds; (3) Treasury bills, bonds, notes, and savings 

bonds; (4) holdings within a Thrift Savings Plan account or other retirement account for 

United States Government employees; (5) an underlying asset of an excepted investment 
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fund, an excepted trust, or a qualified trust; and (6) assets of a trade or business, unless 

the assets are unrelated to the operations of that trade or business.

In addition, filers do not need to report: (1) transactions that occurred when the filer was 

not an employee of the United States Government; (2) actions that do not constitute 

purchases, sales, or exchanges (e.g., gifts given or received, stock splits, bond calls or 

maturity, or expiration of options); (3) transactions that occurred solely by and between 

the filer, the filer’s spouse, or the filer’s dependent children; (4) transactions involving 

the interests of a spouse living separate and apart with the intention of terminating the 

marriage or providing for a permanent separation; and (5) transactions involving the 

interests of a former spouse or a spouse from whom the filer is permanently separated.

Relationship to Periodic Transaction Reports

Filers do not need to report a transaction in an Annual or Termination report (OGE Form 

278e) if the transaction has already been reported in a Periodic Transaction report (OGE 

Form 278-T), unless the filer’s agency requires duplicate reporting. Filers using Integrity

can import transactions disclosed on prior Periodic Transaction reports without additional 

data entry. Other electronic filing systems may offer similar functionality. Agencies 

using such systems may determine that the benefits of aggregating all transactions within 

a reporting period in a single report outweigh the minimal burden imposed on the filer. If 

an agency does not require duplicate reporting, the agency may still require filers to 

incorporate their Periodic Transaction reports by reference or attach prior Periodic 

Transaction reports to their Annual or Termination report. See Legal Advisory LA-12-04 

(June 20, 2012).

No Transactions to Report

The filer must affirmatively state that he or she does not have any transactions to report. 

Within Integrity, the filer would make this statement by marking the “I do not have...” 

checkbox. For hard copy reports, the filer would write “None.”
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2.11: OGE Form 278e, Part 8

Liabilities

What to Report

5 U.S.C. app. §§ 102(a)(4) & (e)(1); 5 C.F.R. §§ 2634.305 & 309

Filers report liabilities owed to any creditor that exceeded $10,000 at any time during the 

reporting period. The reporting requirement covers liabilities of the filer and any 

liabilities of the filer’s spouse and dependent children.

How to Report

Generally, filers report liabilities as follows:

Creditors: Filers provide the name of the creditor. Reviewers may request the city and 

state if that information is needed for the conflicts analysis.

Type: Filers describe the type of liability.

Amount: Filers mark the appropriate category of amount or value. For revolving charge 

accounts, filers use the value of the liability at the end of the reporting period. For all 

other liabilities, filers mark the category that corresponds to the highest value of the 

liability during the reporting period.

Year Incurred: Filers provide the year that the liability was incurred.

Rate: Filers provide the interest rate. Describing the rate in reference to a prime rate, 

such as “prime + 1,” is also sufficient.

Term: Filers specify, in years or months, the time that the loan allows for repayment. 

Describing the term as “on demand,” “open-ended,” “revolving” (credit cards) or 

something similar is also sufficient, if applicable.

Certain Mortgages Are Not Reportable

• If the filer is not a nominee or appointee to a Presidentially-appointed, Senateconfirmed (PAS) position, the filer does not need to report a mortgage or home equity 

loan secured by a personal residence, unless the personal residence was rented out 

during the reporting period. However, the filer must report mortgages or home equity 

loans on properties that do not qualify as personal residences.

• If the filer is a nominee or appointee to one of the three types of PAS positions listed 

below, the filer does not need to report a mortgage or home equity loan secured by a 

personal residence, unless the personal residence was rented out during the reporting 

period. However, the filer must report mortgages or home equity loans on properties 

that do not qualify as personal residences. The three types of PAS positions are:

o a position in which the filer will serve as a special Government employee (SGE);
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o a position as a Foreign Service Officer below the rank of ambassador; or

o a position in the uniformed services for which the pay grade prescribed by section 

201 of title 37, United States Code is O-6 or below.

• If the filer is a nominee or appointee to any other type of PAS position, the filer must 

report a mortgage or home equity loan secured by a personal residence in the same 

manner that the filer would a mortgage on any other property.

Other Liabilities That Are Not Reportable

Filers do not need to report the following liabilities in Part 8: (1) loans secured by a 

personal motor vehicle, household furniture, or appliances, if the loan does not exceed the 

item’s purchase price; (2) revolving charge accounts, such as credit card balances, if the 

outstanding liability did not exceed $10,000 at the close of the reporting period; 

(3) liabilities of a trade or business, unless the liabilities are unrelated to the operations of 

that trade or business; (4) personal liabilities owed to a spouse, parent, sibling, or child of 

the filer, the filer’s spouse, or the filer’s dependent child; (5) liabilities of a spouse living 

separate and apart with the intention of terminating the marriage or providing for a 

permanent separation; and (6) obligations arising from divorce or permanent separation.

No Liabilities to Report

The filer must affirmatively state that he or she does not have any liabilities to report. 

Within Integrity, the filer would make this statement by marking the “I do not have...” 

checkbox. For hard copy reports, the filer would write “None.”
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2.12: OGE Form 278e, Part 9

Gifts and Travel Reimbursements (Annual and Termination 

Reports Only)

What to Report

5 U.S.C. app. §§ 102(a)(2) & (e)(1); 5 C.F.R. §§ 2634.304 & 309

Separate reporting thresholds apply to gifts and travel reimbursements.

Gifts: Filers report gifts totaling more than $390 that were received from a single source 

during the reporting period. When determining whether the total value of gifts from a 

single source exceeds $390, filers do not need to include any gifts that had a value of 

$156 or less. Click here for an example.

Travel reimbursements: Filers report travel reimbursements totaling more than $390 that 

were received from a single source during the reporting period. When determining 

whether the total value of reimbursements from a single source exceeds $390, filers do 

not need to include any reimbursements that had a value of $156 or less.

The $390 and $156 thresholds are tied to the definition of minimal value under the 

Foreign Gifts and Decorations Act and are updated at three-year intervals. The most 

recent update occurred in 2017 and affects gifts and travel reimbursements received on or 

after January 1, 2017.

How to Report

Generally, filers report gifts and travel reimbursements as follows:

Source Name: Filers provide the identity of the source.

City/State: Filers provide the source’s city and state of business or residence.

Brief Description: Filers describe the nature of the item or reimbursement received. For 

travel gifts and reimbursements, this description would include a travel itinerary, the 

dates of travel, and the nature of the expenses. Although not required, it is helpful if the 

filer specifies his or her relationship to the source or notes the basis on which the gift or 

reimbursement was accepted.4

Value: Filers provide the fair market value of the gift(s) or travel reimbursement(s).
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Gifts and Travel Reimbursements That Are Not Reportable

5 U.S.C. app. §§ 102(a)(2), 109(5), & 109(15); 5 C.F.R.§§ 2634.105(h, k, n) & 

2634.304(c)

Filers do not need to report the following: (1) anything given to the filer’s spouse or 

dependent child totally independent of their relationship to the filer (e.g., the spouse’s 

business-related travel reimbursements); (2) anything for which the filer paid fair market 

value; (3) anything accepted by the United States Government under a statute or contract 

(e.g., travel payments accepted under 31 U.S.C. § 1353); (4) anything received when the 

filer was not an employee of the United States Government; (5) anything received from a 

“relative”; (6) bequests and other forms of inheritance; (7) suitable mementos of a 

function honoring the filer (e.g., retirement party); (8) communications to the filer’s 

office, including subscriptions to newspapers and periodicals; (9) nonbusiness gifts of 

personal hospitality (food, lodging, and entertainment, but not transportation) at the 

donor’s personal residence or family property; (10) food, lodging, transportation, 

entertainment, or reimbursements provided by a foreign government within a foreign 

country or by the United States Government, the District of Columbia, or a state or local 

government; (11) food and beverages that are not consumed in connection with a gift of 

overnight lodging; (12) reimbursements required to be reported under the Foreign Gifts 

and Decorations Act; and (13) reimbursements received for political trips that must be 

reported under § 304 of the Federal Election Campaign Act of 1971.

Waiver

5 U.S.C. app. § 102(a)(2)(C); 5 C.F.R. § 2634.304(f)

In certain unusual cases, the Director of OGE may grant a waiver of the public disclosure 

requirements for gifts. However, the filer must still report the items received to the 

agency and OGE, and the fact that the filer obtained a waiver will be publicly available. 

Click the following link to see more detailed guidance on this topic: Gift Reporting 

Waiver.

No Gifts or Travel Reimbursements to Report

The filer must affirmatively state that he or she does not have any gifts or travel 

reimbursements to report. Within Integrity, the filer would make this statement by 

marking the “I do not have...” checkbox. For hard copy reports, the filer would write 

“None.”
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2.13: Differences between OGE Form 278e and OGE Form 278

OGE redesigned the Executive Branch Personnel Public Financial Disclosure Report to 

support the two fundamental goals of the public financial disclosure system: preventing 

conflicts of interest and promoting transparency. The new report form, the OGE Form 

278e, replaces the old report form, the OGE Form 278.

Both the OGE Form 278e and the old OGE Form 278 collect the same information. The 

information is merely organized differently. The following table cross-references the two 

forms.

OGE Form 278e Sections Corresponding OGE Form 278 Sections

Cover Page Cover Page

Part 1: Filer’s Positions Held Outside 

United States Government

Schedule D, Part I: Positions Held Outside 

U.S. Government

Part 2: Filer’s Employment Assets & 

Income and Retirement Accounts

Schedule A: Assets and Income

Part 3: Filer’s Employment Agreements 

and Arrangements

Schedule C, Part II: Agreements or 

Arrangements

Part 4: Filer’s Sources of Compensation 

Exceeding $5,000 in a Year

Schedule D, Part II: Compensation in 

Excess of $5,000 Paid by One Source

Part 5: Spouse’s Employment Assets & 

Income and Retirement Accounts

Schedule A: Assets and Income

Part 6: Other Assets and Income Schedule A: Assets and Income

Part 7: Transactions Schedule B, Part I: Transactions

Part 8: Liabilities Schedule C, Part I: Liabilities

Part 9: Gifts and Travel Reimbursements Schedule B, Part II: Gifts, 

Reimbursements, and Travel Expenses

OGE reorganized the disclosure of information based on its experience that filers, 

particularly filers entering government service for the first time, occasionally forget to 

report financial interests related to employment. It is not uncommon for agency ethics 

officials to have to instruct filers to add these items to their reports. By segregating 

financial interests related to employment, the OGE Form 278e reduces the risk of 

inadvertent omission. This structure also promotes transparency by highlighting 

information of significant interest to the public. (Note that, for purposes of Parts 2 and 5, 

“employment-related” is interpreted broadly to cover all non-investment activities as well 

as retirement accounts.)

In addition to the reorganization of disclosures, the OGE Form 278e eliminates the 

antiquated grid format, which was developed long before modern computer technology 

was widely available. For example, where a filer would previously have entered an “X” 

in a column to signify that the value of an asset is in the range of $50,001 to $100,000, 

the new OGE Form 278e produces the following text: “$50,001-$100,000.” As a result, 

the OGE Form 278e promotes transparency by being easier to read than the old OGE 

Form 278.
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3.01: Cover Page of the OGE Form 278-T

The Cover Page of the OGE Form 278-T contains the following information:

1. Filer’s Name

2. Position: This field refers to the title of the position for which a report is being filed.

3. Agency: This field refers to the agency in which the position is located.

4. Filer’s Certification: Individuals filing hard copies of the OGE Form 278-T must sign 

and date their reports in ink. By signing the report, the filer certifies that the information 

contained in the report is true, complete, and correct to the filer’s knowledge. The 

original signature should appear on the copy of the form that agency reviewers certify. 

Reviewers may certify photocopies, but OGE does not recommend this practice. 

Individuals filing within Integrity or other electronic filing system will certify their 

reports through an electronic signature.

5. For Reviewer’s Use Only:

• Extension: Reviewers must specify the number of days of any extension granted.

• Receipt Date: Reviewers of hard copy reports must enter the date of agency receipt 

in the “Agency Use Only” box. The filer’s electronic signature date constitutes the 

receipt date for reports filed using Integrity or another electronic filing system.

• Comments of Reviewing Officials: Reviewers of hard copy reports should use the 

“Comments of Reviewing Officials” section for annotations of the report. Reviewers 

using Integrity would make annotations through the “public annotation” feature. See 

“Report Amendments and Annotations” for additional information.

• Agency Ethics Official Opinion: The agency’s final reviewing official certifies “on 

the basis of the information contained in this report, I conclude that the filer is in 

compliance with applicable laws and regulations,” subject to any annotations in the 

“Comments of Reviewing Officials” section. Before signing, the official should be 

aware of certification requirements (see “Certification Requirements”). Certification 

ends the review process.

• Other Review: The intermediate reviewing official should sign and date here if the 

agency requires an intermediate review. Individuals who are not examining the 

report for both technical sufficiency and potential conflicts of interest should not sign 

the Cover Page. For example, a supervisor who is only checking a filer’s disclosed 

interests for potential conflicts would not sign here. Integrity records such reviews 

internally within the system. For hard copy reports, a limited review may be noted in 

the “Comments of Reviewing Officials” section or in the agency’s background notes 

to the report. If a limited review is recorded in the “Other Review” field, the limited 

nature of the review should be noted. 

• U.S. Office of Government Ethics Certification: The Director of OGE, or a designee, 

certifies those reports subject to OGE review after the reports have been certified at 

the agency level.
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3.02: Reporting Periodic Transactions

What to Report

5 U.S.C. app. § 103(l)

Filers report any purchase, sale, or exchange by the filer, the filer’s spouse, or dependent 

child of stocks, bonds, commodity futures, and other securities if the amount of the 

transaction exceeded $1,000.

How to Report

Generally, filers report transactions as follows:

Description: Filers provide a description sufficient to identify the asset being reported (or 

both assets in the case of an exchange). The amount of information needed for a 

sufficient description will depend on the type of asset being reported. In general, the 

following rules apply.

(1) Stock: Provide the name of the issuing company.

(2) Other securities with specific names (e.g., bonds): Provide the full name of the asset 

and, unless clear from the name, describe the type of asset.

If the asset is an underlying holding of some other investment vehicle (e.g., held within a 

fund that does not qualify as an excepted investment fund), it is helpful if the filer 

identifies the investment vehicle (e.g., Positron Investments, LLC: Chevron Corp.).

Type: Filers specify the type of transaction as a purchase, sale, or exchange.

Date: Filers provide the month, day, and year of the transaction.

Notification Over 30 Days Ago: Filers select this field only if notice of the transaction 

was received more than 30 days ago. Absent an extension, filers would likely not select 

this field because filers are required to report transactions within 30 days of notification.

Amount: Filers report the amount of the transaction by selecting the appropriate 

category.

Transactions That Are Not Reportable

Filers do not need to report transactions that concern the following: (1) real property 

(e.g., apartment building or farmland); (2) cash accounts (e.g., checking, savings, 

certificates of deposit, money market accounts) and money market mutual funds; 

(3) Treasury bills, bonds, notes, and savings bonds; (4) an excepted investment fund, 

such as a mutual fund; (5) holdings within a Thrift Savings Plan account or other 

retirement account for United States Government employees; (6) underlying holdings of 
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an excepted trust or a qualified trust; and (7) assets of a trade or business, unless the 

assets are unrelated to the operations of that trade or business.

In addition, filers do not need to report: (1) transactions that occurred when the filer was 

not an employee of the United States Government; (2) actions that do not constitute 

purchases, sales, or exchanges (e.g., gifts given or received, stock splits, bond calls or 

maturity, or expiration of options); (3) transactions that occurred solely by and between 

the filer, the filer’s spouse, or the filer’s dependent children; (4) transactions involving 

the interests of a spouse living separate and apart with the intention of terminating the 

marriage or providing for a permanent separation; and (5) transactions involving the 

interests of a former spouse or a spouse from whom the filer is permanently separated.

Voluntary Reporting of Annual and Termination Information

Filers do not need to report a transaction in an Annual or Termination report (OGE Form 

278e) if the transaction has already been reported in a Periodic Transaction report (OGE 

Form 278-T), unless the filer’s agency requires duplicate reporting. Annual and 

Termination reports, however, also require filers to report purchases, sales, or exchanges 

of: (1) mutual funds and other excepted investment funds and (2) real property (excluding 

a personal residence). If filers prefer to report such transactions in Periodic Transaction 

reports, filers may do so.

* Note that Integrity allows filers to import Periodic Transaction reports into Annual or 

Termination reports without additional data entry. Other electronic filing systems may 

offer similar functionality.
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4.01: Certification Requirements

What Certification Means

5 U.S.C. app. § 106(b); 5 C.F.R. § 2634.605(b)

In order to certify a report, a reviewer must determine, to his or her satisfaction, that: 

1. Each required item on the report is completed, and

2. No interest or position disclosed on the report violates or appears to violate:

• Any applicable provision of chapter 11 of title 18, United States Code (i.e., criminal 

conflict of interest statutes);

• The Ethics in Government Act of 1978, as amended, and the implementing 

regulations;

• Executive Order 12674, as modified by Executive Order 12731, and the 

implementing regulations (i.e., Standards of Conduct); or

• Any other agency-specific statute or regulation which governs the filer.

Who Certifies

5 U.S.C. app. § 106(b); 5 C.F.R. § 2634.605(a)

Reports can be certified by:

• the Designated Agency Ethics Official (DAEO); 

• the Alternate Designated Agency Ethics Official (ADAEO); or 

• a delegate of the DAEO, such as a deputy ethics official, deputy ethics counselor, 

deputy standards of conduct counselor, or the equivalent. 

Only the DAEO (or ADAEO in the DAEO’s absence) may certify reports of nominees to 

positions requiring Presidential appointment and Senate confirmation (PAS). For the 

DAEO’s own report, the agency head or a delegate of the agency head should certify the 

report.

Where to Certify

A reviewer certifies a printed, hard copy of the OGE Form 278e by signing and dating 

the Cover Page in the fields reserved for “Agency Ethics Official’s Opinion.”

A reviewer certifies an OGE Form 278e filed within Integrity or another electronic 

financial disclosure system by taking the appropriate action within the system. See your 

system’s user guide for assistance. Once certified, the reviewer’s electronic signature 

will display in the “Agency Ethics Official’s Opinion” field of the report.
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Intermediate Reviews

Although not required, some agencies find it useful to have one or more individuals 

conduct intermediate reviews prior to the final review by the certifying official. These 

intermediate reviews may entail a full review for technical sufficiency and potential 

conflicts or a limited review for only certain issues.

Limited Intermediate Reviews

An individual conducting a limited intermediate review does not check whether the report 

meets all the prerequisites for certification. For example, an agency may require the 

supervisor to examine disclosed entries for any apparent conflicts with the filer’s duty 

assignments without requiring the supervisor to check for technical errors. Similarly, the 

agency may require an individual to check a report for technical errors without having to 

consider potential conflicts. 

Given the limited nature of such reviews, Integrity does not display the completion of 

these activities on the publicly releasable version of the report but rather records the 

activities within an internal log of review events. For hard copy reports, a limited review 

may be noted in the “Comments of Reviewing Officials” section or in the agency’s 

background notes to the report. If a limited review is recorded in the “Other Review” 

field, the limited nature of the review should be noted. 

Agencies must ensure that limited intermediate reviewers have sufficient training to 

perform the tasks within their purview. For example, a supervisor tasked with 

conducting a review for potential conflicts needs to be familiar with the federal conflict 

of interest laws.

Full Intermediate Reviews

An individual conducting a full intermediate review checks whether the report meets all 

the prerequisites for certification. Such intermediate reviewers follow the same review 

standards applicable to certifying officials that have been set forth in this section of the 

guide. Upon completing a full intermediate review, the reviewer signs and dates the 

report, which is displayed in the “Other Review” field of the Cover Page.

Agencies must ensure that full intermediate reviewers:

• are familiar with the technical reporting requirements; 

• are familiar with the federal conflict of interest laws; and 

• can evaluate available conflict of interest remedies in light of the filer’s duties.
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4.02: Review Timeframes

5 U.S.C. app. § 106(a); 5 C.F.R. § 2634.605(a)

An agency needs to perform a technical review and conflict of interest analysis within 60 

days of receiving a report. If no additional information or remedy is required, agencies 

should also certify the report before the 60-day period expires. If additional information 

or a remedy is required, agencies should contact the filer for the information or begin the 

process of implementing a remedy before the 60-day period expires. Agencies should 

then make reasonable efforts to complete the review process as soon as practicable 

following the expiration of the 60-day period. Such efforts would include actively 

following up with filers and escalating instances of non-responsiveness as appropriate. 

Filers who do not respond to requests for information in a timely manner may be subject 

to the provisions of 5 C.F.R. § 2634.701.

Special expedited procedures apply to reports filed by nominees to positions requiring 

Presidential appointment and Senate confirmation (PAS Nominee reports). See 5 C.F.R. 

§ 2634.605(c) for additional information regarding these procedures.
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4.03: Tools of Review

A variety of resources exist that can help you in the review of a filer’s report. Some of 

these resources include:

• the filer’s prior reports and any supporting materials, if applicable; 

• the notes of an individual who performed an earlier review of the report;

• the instructions accompanying the OGE Form 278e or OGE Form 278-T;

• federal ethics laws and regulations;

• your agency’s prohibited holdings list (if applicable); 

• a list of your agency’s grantees, contractors, licensees, etc.; 

• OGE legal and program management advisories; and

• financial reference materials and/or access to the internet to conduct research.
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4.04: When to Obtain Additional Information

Standard of Scrutiny

5 C.F.R. § 2634.605(b) provides: 

(b) Responsibilities of reviewing officials—(1) Initial review. The reviewing official may 

request an intermediate review by the filer’s supervisor. In the case of a filer who is 

detailed to another agency for more than 60 days during the reporting period, the 

reviewing official shall obtain an intermediate review by the agency where the filer 

served as a detailee. After obtaining any intermediate review or determining that such 

review is not required, the reviewing official shall examine the report to determine, to his 

satisfaction that:

(i) Each required item is completed; and

(ii) No interest or position disclosed on the form violates or appears to violate:

(A) Any applicable provision of chapter 11 of title 18, United States Code;

(B) The Act, as amended, and the implementing regulations;

(C) Executive Order 12674, as modified by Executive Order 12731, and the implementing 

regulations; or

(D) Any other agency-specific statute or regulation which governs the filer.

(2) Signature by reviewing official. If the reviewing official determines that the report 

meets the requirements of paragraph (b)(1) of this section, he shall certify it by signature 

and date. The reviewing official need not audit the report to ascertain whether the 

disclosures are correct. Disclosures shall be taken at “face value” as correct, unless 

there is a patent omission or ambiguity or the official has independent knowledge of 

matters outside the report. However, a report which is signed by a reviewing official 

certifies that the filer’s agency has reviewed the report, and that the reviewing official 

has concluded that each required item has been completed and that on the basis of 

information contained in such report the filer is in compliance with applicable laws and 

regulations noted in paragraph (b)(1)(ii) of this section. 

Additional Considerations

All OGE Form 278e Reports

Parts 2, 5, and 6 of the OGE Form 278e address many of the same types of information. 

Prior to the issuance of the OGE Form 278e, these Parts were combined in a single 

section (“Schedule A”). OGE separated the reporting of filers’ employment assets and 

income, spouses’ employment assets and income, and other assets and income in order to 
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simplify the presentation of the different reporting thresholds as well as to group all 

information related to the filers’ employment activities (i.e., Parts 1 – 4).

Nonetheless, agencies are not expected to be rigid in distinguishing “Employment Assets 

and Income” from “Other Assets and Income.” OGE has established this distinction with 

the goals of increasing accuracy and highlighting relevant assets for the interested public. 

Although these goals are important, rigid enforcement is not required in every case. 

Thus, if an individual filer inadvertently reports an employment-related asset, such as an 

incentive stock option, in Part 6 (“Other Assets and Income”), an agency has discretion to 

either accept the entry or require that the asset be moved to Part 2 or Part 5. Even if the 

agency accepts the entry, the reviewer may still wish to notify the filer of the appropriate 

placement of such assets for future reference.

For reports that will be sent to the Senate, OGE may require reporting on the proper Part 

for the sake of consistent presentation to the Senate Committees.

New Entrant and Nominee Reports

With New Entrant reports, reviewers should approach the report as if it were the story of 

that person’s finances. Look for obvious gaps in that story, such as long-term 

employment with no retirement plan reported or a New Entrant with significant stock 

holdings and no employment. If gaps appear, reviewers should help filers to understand 

the disclosure requirements better. In all cases, however, reviewers need to ensure that 

the filer has reported entries for each Part or affirmatively stated that there are no 

interests to report for that Part. Within Integrity, the filer would make this statement by 

marking the “I do not have...” checkbox. For hard copy reports, the filer would write 

“None.”

The highest level of scrutiny applies when reviewing a report filed by a nominee to a 

position requiring Presidential appointment and Senate confirmation (PAS). Therefore, 

reviewers should err on the side of seeking clarification or additional information from a 

PAS nominee if there is any doubt about the adequacy of a report. See OGE DAEOgram 

DO-08-002 (January 25, 2008).

Annual Reports

Reviewers are not required to perform a line-by-line comparison between a filer’s current 

Annual report and the filer’s most recent prior report, and reviewers need not reconcile 

all of the differences that may exist. Reviewers should familiarize themselves with the 

prior report and follow up on any apparent inconsistencies that raise reasonable concerns 

as to whether the filer understands the reporting requirements (e.g., significant changes in 

the number of assets without corresponding transactions in either the Annual report or 

Periodic Transaction reports). Reviewers should also follow up on inconsistencies 

relevant to the reviewer’s conflict of interest analysis. In all cases, however, reviewers 

need to ensure that the filer has reported entries for each Part or affirmatively stated that 

there are no interests to report for that Part. Within Integrity, the filer would make this 
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statement by marking the “I do not have...” checkbox. For hard copy reports, the filer 

would write “None.”

Termination Reports

As noted above with respect to Annual reports, reviewers do not need to perform a lineby-line comparison between a filer’s Termination report and the filer’s most recent prior 

report; however, reviewers should follow up on inconsistencies that raise reasonable 

concerns as to whether the filer understands the reporting requirements and any 

inconsistencies that are relevant for the reviewer’s conflict of interest analysis.

In addition, it may be reasonable not to seek additional information regarding reporting 

issues that do not affect the reviewer’s conflict of interest analysis. In all cases, however, 

reviewers need to ensure that the filer has reported entries for each Part or affirmatively 

stated that there are no interests to report for that Part. Within Integrity, the filer would 

make this statement by marking the “I do not have...” checkbox. For hard copy reports, 

the filer would write “None.”

Over-Reporting

If the filer discloses interests that are not reportable or provides more detail than is 

required, the reviewer should notify the filer. In some cases, no change to the report is 

necessary; however, the filer should understand that such information can be excluded 

from future reports and be given the option of requesting a redaction.
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4.05: Report Amendments and Annotations

Reports, at times, require additional information, clarification, or redaction. In some 

cases, a filer may initiate an amendment to a report. In other cases, a reviewer may make 

the amendment directly, either based on additional information from the filer or 

independent knowledge (e.g., indicating that a publicly traded mutual fund qualifies as an 

excepted investment fund). The method of making changes to a report will depend on 

agency procedures as well as whether the report is being reviewed in hard copy or 

through an electronic filing system.

Guidelines for Reviewer-Initiated Amendments and Annotations

Reviewers should inform filers of any additions, clarifications, or redactions made to the 

report. Generally speaking, reviewers should also take care not to include more 

information than is required to be publicly disclosed by statute and regulation. However, 

in certain cases, providing more information than is required may prove helpful in 

understanding a required entry. In such cases, the reviewer may provide the information 

so long as the filer consents to its inclusion.

How to Amend

Hard Copy Reports

Amendments to a hard copy report can be made through reviewer annotations to existing 

pages or by the filer providing replacement pages. Reviewers should annotate reports 

using ink, initialing and dating the changes. If replacing pages, the reviewer should add 

an annotation itemizing each replacement page in the “Comments of Reviewing 

Officials” section of the Cover Page. It is also recommended, as a best practice, that 

filers initial and date each replacement page or provide a cover letter itemizing the 

replacement pages.

As appropriate, reviewers should include a brief explanation of the amendments on the

affected page or in the “Comments of Reviewing Officials” section (e.g., “revisions per 

filer”).

Integrity

Integrity permits reviewers to add, change, or delete entries or to return the report to the 

filer for the necessary revisions. Integrity records which user made the amendment 

within an audit trail. The audit trail is not part of the public report; however, Integrity

adds a revision date to the public version of the report.

As appropriate, reviewers should include a brief explanation of the amendments using the 

“public annotation” feature, which displays text in the “Comments of Reviewing 

Officials” section of the Cover Page.
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Other Electronic Filing Systems

Agencies using other electronic filing systems should consult any relevant system 

documentation for assistance in making amendments.
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4.06: Supporting Notes

Depending on the report and the procedures at your agency, reviewers may create a set of 

internal, supporting notes that record additional background information, discuss 

technical reporting issues and the conflict of interest analysis, and document significant 

interactions with the filer. Such notes can be especially helpful when reviewing the 

filer’s subsequent reports. These supporting notes may be stored with the report (e.g., 

uploaded to the “Documents” tab of a report within Integrity or filed in the folder that 

holds the hard copy of the report); however, these notes are not part of the report itself, 

should not be attached to the report, and would not be publicly available using the request 

procedures applicable to the report. See “Public Availability of Reports” and “Records 

Management” for additional information.
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4.07: Public Availability of Reports

5 U.S.C. app. § 105; 5 C.F.R. § 2634.603

Almost all OGE Form 278e and OGE Form 278-T reports are available to the public 

under the Ethics in Government Act of 1978, as amended.

Period of Public Availability

Start of Public Availability Period

Candidate, New Entrant, Nominee, Termination, and Periodic Transaction reports must 

be made available to the public within 30 days of receipt. Annual reports must be made 

available to the public within 30 days of receipt or May 15 of the filing year, whichever is 

later.

A report must be made available by the date specified above regardless of whether the 

agency has reviewed or certified the report.

End of Public Availability Period

Reports are publicly available for six years after receipt. As an exception to this rule, the 

Nominee reports of individuals whom the Senate did not confirm are releasable for only 

one year after the individual is no longer under Senate consideration. In addition, a 

Periodic Transaction report (OGE Form 278-T) is releasable until the related subsequent 

Annual or Termination report (OGE Form 278e) has passed its period of availability.

Reports may not be released after the period of public availability has passed even if the 

agency has not yet destroyed the report. See the “Records Management” section for 

information concerning the disposition schedule for reports and supporting materials.

Requesting a Report

Requirements

Any person or entity that wishes to inspect or obtain a copy of a public financial 

disclosure report must submit a written request to the relevant agency stating:

• the requestor’s name, occupation, and address; 

• the name and address of any other person or organization on whose behalf the 

inspection or copy is requested; and 

• that the requestor is aware of the prohibitions on obtaining or using the report 

(listed below).
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These requirements do not apply for reports filed by the President, Vice President, and 

any officer occupying a position listed in section 5312 or section 5313 of title 5, 

United States Code, having been nominated by the President and confirmed by the Senate 

to that position.

Request Form

OGE has developed a standardized application form, the OGE Form 201, for use by those 

requesting to inspect or obtain a copy of an OGE Form 278e or OGE Form 278-T.

Request Process - OGE

To inspect or obtain a copy of a report that is reviewed by OGE, interested persons 

should access the electronic request system on OGE’s website.

Request Process - Agencies

To inspect or obtain a copy of a report that is not reviewed by OGE, interested persons 

should submit a written application to the filer’s agency’s ethics office.

Restrictions on Public Availability

Reports filed by certain persons engaged in intelligence activities are exempt from 

release. Also, in certain unusual circumstances, the Director of OGE may exempt an

SGE’s public financial disclosure report from release. See “Official Required to File” for 

additional information.

Restrictions on the Use of the OGE Form 278e and OGE Form 278-T

No OGE Form 278e or OGE Form 278-T may be used for:

• any unlawful purpose; 

• any commercial purpose, except by news and communications media for 

dissemination to the general public; 

• determining or establishing a credit rating; or 

• direct or indirect use in the solicitation of money for any purpose, including 

political and charitable purposes.

Agencies must require those who wish to examine or obtain a copy of a report to sign a 

statement that the agency has informed the requestor of these restrictions. The Attorney 

General may bring a civil action against anyone who uses or obtains a report for these 

prohibited purposes.

Other Releasable Documents

In addition to OGE Form 278e and OGE Form 278-T reports, members of the public may 

request certain other documents by means of the OGE Form 201 or other written 

application. These records are: (1) certificates of divestiture; (2) Ethics Act qualified 
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blind trust and qualified diversified trust instruments (other than those provisions which 

relate to the testamentary disposition of the trust assets), the list of assets transferred to 

such trusts (and of assets sold in the case of a qualified blind trust), as well as, in the case 

of trust dissolution, the report thereon and the list of trust assets at that time, and the 

certificates of independence and compliance with respect to qualified trusts; 

(3) 18 U.S.C. § 208(b)(1) & (b)(3) waivers granted by the recipient agency (after deletion 

of any material withholdable pursuant to the Freedom of Information Act, 5 U.S.C. § 552 

(see 18 U.S.C. § 208(d)(1)); (4) other OGE Form 201s; (5) cover letters for approved 

gifts reporting waiver requests; and (6) cover letters for approved public reporting waiver 

requests for certain less than 130-day special Government employees.

Requests for other documents would be made under the Freedom of Information Act.

Notifying Filers of Requests for their Reports

No law or OGE regulation requires agencies to inform filers of requests for access to 

their OGE Form 278e and OGE Form 278-T reports. Filers desiring to know whether a 

member of the public has requested their OGE Form 278e or OGE Form 278-T may, the 

same as any member of the public, request a copy of all applications to inspect their 

reports. All applications to inspect an OGE Form 278e or OGE Form 278-T are available 

to the public for the period when the OGE Form 278e or OGE Form 278-T itself is 

available to the public.

Intra-Governmental Access to Reports

Certain Government officials may access reports in their official capacities without 

formal application:

• Agency ethics officials and support staff who maintain the files for such reports if 

the report was filed with (1) their own agency, (2) at another agency if the filer is 

transferring from one covered position to another, or (3) at another agency if the 

filer served at the ethics official’s agency during the reporting period and the 

ethics official is conducting an intermediate review;

• OGE staff; and

• Special Agents of the FBI and U.S. Attorneys conducting a criminal investigation 

into possible conflict of interest violations.

Additional disclosures that may be made are listed in the Privacy Act notice in the 

instructions to the OGE Form 278e and the OGE Form 278-T.
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4.08: Records Management

OGE/GOVT-1 (Privacy Act); General Records Schedule 2.8 (Federal Records 

Act)

Privacy Act System of Records

The OGE Form 278e and OGE Form 278-T reports are covered under the OGE/GOVT-1 

Governmentwide Privacy Act System of Records. This Privacy Act system of records 

provides information about the public financial disclosure system, including the 

location(s) of the records, individuals covered, categories of records, legal authorities, 

purposes for collecting and storing the information contained in the records, routine uses, 

certain legal notice and procedural provisions, access procedures, and policies on storage, 

retrievability, security, retention, and disposal of the records.

Retention Schedule

Public financial disclosure reports are retained according to the following schedule:

• OGE Form 278e reports (excluding PAS nominees): 6 years after receipt.

• OGE Form 278e reports filed by PAS nominees who have been confirmed: 6 

years after receipt.

• OGE Form 278e reports filed by PAS nominees who have not been confirmed: 1 

year after the nominee is no longer under consideration for the position.

• OGE Form 278-T reports: 7 years after receipt (or when the related subsequent 

OGE Form 278e is ready for destruction 6 years later).

A report is destroyed/deleted once it reaches the end of its retention schedule, unless the 

report is needed in an ongoing investigation.
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4.09: Forwarding Reports to OGE

Reports Reviewed by OGE

5 U.S.C. app. § 103; 5 C.F.R. § 2634.602

After certification, agencies forward public financial disclosure reports filed by certain 

individuals to OGE for final certification. These individuals include:

• the Designated Agency Ethics Official (DAEO); 

• nominees and appointees to positions requiring Presidential appointment and 

Senate confirmation (PAS), other than members of the uniformed services; 

• employees of the Executive Office of the President who are appointed under 

3 U.S.C. § 105(a)(2)(A) or (B) or 3 U.S.C. § 107(a)(1)(A) or (b)(1)(A)(i) and 

employees of the Office of the Vice President appointed under 3 U.S.C. 

§ 106(a)(1)(A) or (B). 

Limitations

Acting Officials

Agencies do not forward the reports of acting DAEOs or employees who serve in PAS 

positions in an acting capacity, because those filers do not go through Senate 

confirmation. OGE, however, does review reports filed by recess appointees to PAS 

positions. See OGE DAEOgram DO-07-022 (July 19, 2007).

Days in Position Subject to OGE Review

Agencies forward an Annual or Termination report only if the filer served in one of the 

position(s) listed above for more than 60 days during the reporting period. 

Example: An employee serves in an SES position for more than 60 days in 2015. The 

employee is nominated and confirmed in a PAS position in December 2015. The 

employee files an Annual report in May 2016 because the employee served more than 

60 days during 2015 in a position for which public financial disclosure is required. This 

Annual report, however, need not be forwarded to OGE because the employee did not 

serve more than 60 days in the PAS position during the reporting period.

Status at Time Report Was Required

The filer’s status in a position subject to OGE review has the following effects:

• Annual report: Forward only if the filer was in a position subject to OGE review 

at the end of the calendar year covered by that report.

• Termination report: Forward only if the filer was in a position subject to OGE 

review at the time the filer left public filing status.
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• Periodic Transaction report: Forward only if the filer was in a position subject to 

OGE review at the time of filing.

Example: An employee served in a PAS position for more than 60 days in 2015. The 

employee moves to an SES position in December 2015. The employee files an Annual 

report in May 2016 because the employee served more than 60 days during 2015 in a 

position for which public financial disclosure is required. This Annual report, however, 

need not be forwarded to OGE because the employee did not serve in a position at the 

end of 2015.

PAS SGEs Serving More than 60 Days

A PAS appointee who filed a confidential report as a nominee is required to file a public 

New Entrant report if that appointee does, in fact, serve more than 60 days during a 

calendar. See “Officials Required to File.” Agencies do not forward the New Entrant 

report to OGE; however, the agencies would forward any public Annual, Termination, or 

Periodic Transaction report that the appointee subsequently files in the position. 

Senate Requests

5 U.S.C. app. § 101(b)(1)

Senate committees considering Presidential nominees may request that OGE review the 

reports of nominees who would not normally be required to file during the confirmation 

process. For example, Presidential nominees to boards and commissions who are not 

expected to serve more than 60 days in any calendar year do not meet the statutory 

requirement for filing a Nominee report. Nonetheless, the Senate confirmation 

committee may require a report from a nominee as part of the confirmation process and 

may ask that OGE review the report.

Agency Retention of Forwarded Reports

In most cases, reports will be forwarded to OGE through Integrity. In cases in which a 

report is forwarded in hard copy, agencies should forward a copy and retain the original 

for their records.
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Appendix A: Definitions and Other Information

American Depositary Receipt

An American depositary receipt is a certificate representing shares of foreign securities. 

It is a form of indirect ownership of the foreign securities that are not traded directly on a 

national exchange in the United States. Financial institutions purchase the underlying 

securities on foreign exchanges through their foreign branches, and these foreign 

branches remain the custodians of the securities. Through these foreign branches, the 

financial institutions hold legal title to the underlying stock.

Many American depositary receipts are registered with the U.S. Securities and Exchange 

Commission and traded on national exchanges; however, some American depositary 

receipts are not registered and traded on national exchanges. Investors have to purchase 

these non-registered American depositary receipts directly from their issuers or through 

other private trades (i.e., “over the counter”).

An “American depositary share” corresponds to a single share of the underlying security. 

An American depositary receipt may confer ownership rights to a specified number of 

American depositary shares, representing the investor’s indirect interest in the underlying 

foreign security that the issuing institution holds in its foreign branch.

Annuity (fixed)

A fixed annuity is a contract with an insurance company offering a guaranteed, specified 

rate of return.

Annuity (variable)

A variable annuity is a contract with a life insurance company in which the rate of return 

is based on the performance of investment options chosen by the investor. The 

investment options are typically mutual funds. Some variable annuities, however, also 

provide a fixed account option which pays a set rate of interest.

Asset: Definition

For purposes of financial disclosure, an “asset” refers to an interest in property held in a 

trade or business or for investment or the production of income.

Examples of reportable assets include, but are not limited to:

• stocks, bonds, mutual funds, and other securities;

• real estate;
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• personal bank accounts;

• retirement interests (e.g., defined benefit or defined contribution plan);

• fixed and variable annuities;

• whole, universal, and variable life insurance;

• vested beneficial interests in trusts and estates;

• collectible items held for resale or investment;

• commercial crops;

• accounts or other funds receivable; 

• income receivables, such as anticipated bonuses, severance, and honoraria; and

• capital accounts or other asset ownership in a business.

Asset Related to Employment or Retirement: Examples

The types of assets disclosed in Part 2 and Part 5 of the report include:

• deferred compensation

• defined benefit pension plan

• defined contribution plan (e.g., 401(k) plan, 403(b) plan, 457 plan, TIAA-CREF 

account)

• employee stock ownership plan

• employee stock purchase plan

• employer stock obtained through employment (e.g., by exercising a stock option)

• farm operated as a business (i.e., not a passive investment)

• incentive stock option

• individual retirement account (IRA)

• intellectual property

• investment fund created by an employer solely for employees

• phantom stock

• restricted stock

• restricted stock unit

• self-funded defined benefit plan

• split-dollar life insurance

• stock appreciation right

Asset: Valuation

You may use any of the methods below in determining the fair market value of an asset:

• a good faith estimate of fair market value; 

• the purchase price (if the purchase date is noted);

• a recent appraisal;

• the market value of the property as assessed for tax purposes;
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• the year-end book value of non-publicly traded stock, the year-end exchange 

value of corporate stock, or the face value of corporate bonds or comparable 

securities;

• the net worth of a business partnership;

• the equity value of an individually owned business; or

• any other recognized indication of value (such as the last sale on a stock 

exchange).

Boat Loan

A boat loan is a loan secured by a boat. A loan secured by a boat for personal use is 

generally reportable.

Bond (corporate)

Corporations issue bonds to raise money. Bonds constitute a debt owed by the corporate 

issuer to the bondholder, usually with the promise to pay a specified rate of interest over 

a fixed period of time. Alternatively, bonds may be issued at a discount, with interest 

income being the difference between the discount (purchase) price and redemption value. 

Some bonds are secured by collateral, while others, such as debentures, are backed only 

by the company’s good faith and credit standing.

Bond (municipal)

Municipal bonds, often called munis, are debt obligations of states, cities, counties, or 

other political subdivisions of states in the United States. The two primary types of 

municipal bonds are general obligation and revenue.

• A general obligation bond is used for general expenditures and is backed by the 

issuer’s full faith and credit (taxing and borrowing power).

• A revenue bond is used to finance a specific public service project and is backed 

by the cash flow from that project. Examples are bonds to finance bridges, 

turnpikes, tunnels, water and sewer systems, schools, power plants, prisons, 

transportation systems, hospitals, sports complexes, and airports.

Brokerage Account

A brokerage account (also called an “asset management account”) is an account through 

which individual investors can make investments. The account may hold cash, money 

market funds, mutual funds, stocks, and bonds. The individual who establishes the 

account owns the investments in that account.
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Business Assets and Liabilities

You are not required to report assets and liabilities of a trade or business, unless those 

interests are unrelated to the operations of the business.

What constitutes “unrelated” will vary based on the specific circumstances; however, the 

following general guidelines apply:

Publicly traded corporations: Assets and liabilities of a publicly traded corporation are 

deemed to be related to the operations of the business for purposes of financial 

disclosure. Consequently, one need not perform any further test with respect to such 

interests.

Businesses that are not publicly traded: One needs to consider factors such as the type of 

asset or liability and its relationship to the economic activity conducted by the business. 

No one factor is necessarily dispositive; however, in many cases, the type of asset itself 

will demonstrate a nexus between the asset and operations of the business, which 

removes the need for further analysis. For example, in OGE’s experience, a filer would 

not need to itemize office furniture, equipment, supplies, inventory, accounts receivable, 

accounts payable, working capital funds, real estate used in the operations of the 

business, or any mortgages on such real estate.

Capital Call

A capital call is a legal right stemming from a contract which allows an investment firm 

to demand money that an investor has agreed to contribute. For example, when an 

investor buys into an investment fund, the investor may not have to contribute all of the 

money that he or she has pledged to give the firm that manages the investment fund. The 

fund’s managers in the firm may wait before collecting money from their investors to 

purchase the fund’s investments, or they may collect money in installments on an as 

needed basis. When the investment fund is ready to purchase investments, the firm will 

issue a capital call to its investors in order to raise money for the investment fund’s 

purchases, at which time the investors will need to contribute their promised funds to the 

firm.

Carried Interest

Carried interests are also known as “profit interests” and “incentive fees.”

For purposes of financial disclosure, a carried interest is an arrangement that stipulates 

the right to future payments based on the performance of an investment fund or business.

Carried interests are generally given to managers and advisors/consultants in private 

equity partnerships, real estate, venture capital, oil and gas, and small business.
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Cash Balance Pension Plan

A cash balance pension plan is a type of defined benefit plan in which the employer 

makes contributions to the employee’s account and guarantees a specific rate of return, 

regardless of the profitability of the plan’s investments. The employer generally makes 

investment decisions concerning the holdings of the plan and bears the risks of 

investment.

Each year, the employee receives a pay credit that is proportional to a percentage of the 

employee’s salary and an income credit that is a fixed rate of return. The employer 

defines this retirement benefit as an account balance, and a cash balance pension plan 

will often allow an employee to choose between an annuity and a lump sum payment.

Collectible Item

For purposes of financial disclosure, a “collectible item” refers to personal property that 

is unique, limited in quantity, antique, or holds special quality or financial value. 

Examples of such items include art work, vintage automobiles, antique furniture, and rare 

stamps or coins.

Common Trust Fund of a Bank

A common trust fund of a bank is a trust that a bank manages on behalf of a group of 

participating customers, in order to invest and reinvest their contributions to the trust 

collectively. A bank customer purchases units of the common trust fund. This 

arrangement allows the trustee to manage the customer’s contributions in a pool of 

contributions from a number of customers. These customers are the beneficiaries of the 

common trust fund.

Acting as a fiduciary, the bank commingles the contributions of participating customers 

in the common trust fund and invests in a variety of underlying holdings. Typically, a 

preprinted trust agreement will name the trustee, specify the investments, and establish 

other terms of participation in the common trust fund.

Confidential Clients

In rare cases, a filer may rely on an exception to the reporting requirements for 

information related to certain clients if the filer is in a privileged relationship, established 

by law, with the client and is able to demonstrate persuasively that the client is a 

“confidential client.” It is rare for a filer to rely on this exception, and it is extremely rare 

for a filer to rely on this exception for more than a few clients.
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In those uncommon circumstances in which the exception applies, you do not need to 

report the identity of a client if:

1. the client’s identity is protected by a statute or court order or the client’s identity 

is under seal;

2. the client is the subject of a pending grand jury proceeding or other non-public 

investigation in which there are no public filings, statements, appearances, or 

reports that identify him or her;

3. disclosure is prohibited by a rule of professional conduct that can be enforced by a 

professional licensing body; or

4. a written confidentiality agreement, entered into at the time that your services 

were retained, expressly prohibits disclosure of the client’s identity.

A client will not be deemed confidential merely based on the filer’s belief that the client 

would prefer not to be disclosed or based on the fame or social standing of the client. 

Similarly, the mere existence of a privileged relationship is not enough to preclude 

disclosure, absent one or more additional conditions explained above.

Additional information concerning the treatment of confidential clients is available in 

OGE DAEOgram DO-06-011 (April 7, 2006).

Contingency Fee

The term “contingency fee” refers to a type of fee arrangement in a case in which an 

attorney or firm agrees that the payment of legal fees will be contingent upon the 

successful outcome of the case. Frequently, a contingency fee will be a portion of the 

proceeds obtained by the client due to the litigation or settlement, or it may be the amount 

of attorney fees accrued but not billed to the client until the successful conclusion of the 

case. The specific arrangements for a contingency fee case should be set forth in a fee 

agreement, which is a contract between the lawyer (or law firm) and the client that 

explains the terms and conditions of the representation.

Co-Signed Loan

Co-signed loans are loans where a legal obligation to pay has resulted from co-signing a 

promissory note with another.

Credit Card Debt

Credit card debt is unsecured consumer debt accumulated through purchases made with a 

credit card.
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Defined Benefit Plan

A defined benefit pension plan usually is a type of retirement plan that an employer 

establishes for its employees. Upon retirement, the employee receives a fixed annuity. 

The annuity typically makes biweekly or monthly payments to the employee for life. The 

annuity may also pay a survivor benefit to the employee’s spouse after the employee’s 

death.

Defined Contribution Plan

A defined contribution plan usually is a type of retirement plan that an employer 

establishes for its employees. In this plan, an employee selects various investments (e.g., 

mutual funds and other investments) and makes pre-tax contributions to those 

investments with deductions from the employee’s salary. Often the employer will make 

contributions to the employee’s investments, too. Examples of defined contribution plans 

include 401(k) plans, 403(b) plans, 457 plans, etc.

Designated Agency Ethics Official and

Alternate Designated Agency Ethics Official

“Designated Agency Ethics Official” (DAEO) 

5 C.F.R. Part 2638, Subpart B

The DAEO is the officer or employee who is designated by the head of an agency to 

administer the provisions of Title I of the Ethics in Government Act of 1978, as amended, 

and 5 C.F.R. Part 2634 within an agency. Subpart B of 5 C.F.R. Part 2638 provides 

additional information regarding the appointment and responsibilities of the DAEO. 

Within this guide, the term “DAEO” will also include any delegate of the DAEO, unless 

otherwise indicated.

“Alternate Designated Agency Ethics Official” (ADAEO)

5 C.F.R. § 2638.202(b)

The ADAEO is the official selected by the agency head to act in the capacity of the 

Designated Agency Ethics Official in the event of that official’s absence.
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Employee Stock Ownership Plan

An employee stock ownership plan is a type of defined contribution plan to which the 

employer contributes shares of company stock. 

Note that employee stock ownership plans should not be confused with employee stock 

purchase plans. An employee stock purchase plan is an employer-sponsored incentive 

plan that allows employees to purchase company stock.

Employee Stock Purchase Plan

An employee stock purchase plan is an employer-sponsored incentive plan that allows 

employees to purchase company stock. Under such a plan, the employer offers its 

employees the option to purchase company stock at the end of an “offering period,” 

which typically ranges between 3 months and 27 months.

When an employee exercises such an option, the employer typically withholds the cost of 

purchasing the stock from the employee’s pay in installments during the offering period. 

The employer holds this money in an account for the employee during the offering 

period. At the end of the offering period, the employee uses the money withheld to 

purchase company stock at the specified purchase price. Most employers offer the stock 

at discounts below fair market value.

Note that employee stock purchase plans should not be confused with employee stock 

ownership plans. An employee stock ownership plan is a type of defined contribution

plan to which the employer contributes shares of company stock

Equity Index-Linked Note

An equity index-linked note is a debt instrument that affords the owner interest payments 

based on the performance of an equity index and, sometimes, a guaranteed return. The 

terms of such notes vary, but interest payments are typically based on any increase in the 

value of a specified equity index (e.g., Standard & Poor’s 500 Index). A note may also 

guarantee the return of the investor’s principal, insulating the investor against decreases 

in the value of the equity index to which the note is linked. In exchange for such 

protection against risk, a note usually will offer an investor a return that is less than 100% 

of the value of any increase in the equity index to which it is linked, or a note may 

establish a maximum return.
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Excepted Investment Fund

Definition

An excepted investment fund is an investment fund that is:

1. independently managed,

2. “widely held,” and

3. either “publicly traded or available” or “widely diversified.”

Normally, you have to disclose all of the underlying holdings of an investment fund, but 

you do not have to list any of the underlying holdings of an excepted investment fund. 

Instead of listing the underlying holdings, select “Y” for the “EIF” field.

Additional Information about Key Terms

• “independently managed”: For purposes of the excepted investment fund 

definition, an investment fund is independently managed if you lack the ability to 

control the fund.

• “widely held”: An investment fund is widely held if the fund has at least 100 

natural persons as direct or indirect investors.

• “publicly traded or available”: An investment fund is publicly traded if it is listed 

on a national exchange (NYSE or NASDAQ) or a regional exchange in the

United States. An investment fund is publicly available if it is, or was, open to 

anyone who wants to become an investor. A fund is not disqualified solely 

because it has net worth or income requirements or if an investor must be an 

“accredited investor.”

• “widely diversified”: If your investment fund is “publicly traded or available,” 

the investment fund does not need to be “widely diversified” in order to qualify as 

an excepted investment fund. For example, mutual funds on the market are 

“publicly traded or available,” which means that you do not have to determine 

whether such a mutual fund is “widely diversified.” If you have some other type 

of investment fund that is not “publicly traded or available,” you will need to 

determine whether that fund is “widely diversified.” An investment fund is 

widely diversified if it (1) holds no more than 5% of the value of its portfolio in 

the securities of any issuer (other than the United States Government) and 

(2) holds no more than 20% of the value of its portfolio in any particular 

economic or geographic sector. For purposes of this rule, a portfolio of U.S. 

securities, absent further limitations, would not be viewed as concentrating in any 

particular “geographic sector.”
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Excepted Trust: Definition

A trust qualifies as an excepted trust if it has both of the following characteristics:

1. The trust was not created by you, your spouse, or dependent children.

AND

2. You, your spouse, or dependent children have no specific knowledge of the trust’s 

holdings or sources of income through a report, disclosure, or constructive receipt, 

whether intended or inadvertent. Filers may not blind themselves from trusts by 

simply avoiding information that is available to them.

The application of the “specific knowledge” standard can be context-dependent. Filers 

are strongly encouraged to consult with an ethics official before designating a trust as an 

excepted trust.

Excepted Trust: How to Report

Part 6

For excepted trusts, report a vested beneficial interest and/or income as follows:

Description: Identify the trust interest, using initials or a general description (e.g., “J.S.

2003 Trust” or “family trust #1”), and indicate the general nature of its holdings to the 

extent known. In addition, write “excepted trust.”

EIF: Select “N/A.”

Income Amount: Select the category that corresponds to the amount of your income 

during the reporting period.

Part 7

Do not report transactions involving excepted trusts in Part 7.

Exchange

An exchange generally occurs when one company acquires another. The shareholders of 

the acquired company are often given the option to sell their shares to the acquiring 

company or exchange their existing stock for stock of the acquiring company.

Example: ABC Corporation recently acquired XYZ Corporation. ABC gave its shares to 

the shareholders of XYZ in exchange for their XYZ shares. A filer would report this 

transaction as an exchange.
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Changing the investment options held in a brokerage or retirement account are not 

exchanges. In these cases, you are selling one fund or stock and buying another. Since 

exchanges are very rare, you may wish to consult your agency ethics official before 

designating a transaction as an exchange.

Exchange-Traded Fund

An exchange-traded fund (ETF) is a fund that pools investors’ money in a variety of 

investments. Unlike traditional mutual funds, most investors buy and sell shares of ETFs 

from other investors on an exchange rather than directly from the issuer. In addition, 

ETFs cannot market themselves to consumers as “mutual funds” because they are not 

necessarily subject to all the requirements applicable to traditional mutual funds. 

Nevertheless, ETFs are usually registered with the U.S. Securities and Exchange 

Commission under the same statutory authorities as traditional mutual funds and unit 

investment trusts.

Foreign Exchange Position (“forex”)

For purposes of financial disclosure, “foreign currency” is the official currency of a 

country other than the United States. It is possible to hold a foreign currency through a 

“foreign exchange” transaction.

A foreign exchange transaction results in the purchase of one currency for investment 

purposes and the simultaneous sale of another. This constitutes an open position that is 

later offset to terminate the position. Both the short and the long position must be offset 

to close out the holding. One may take a position in a foreign currency for speculation or 

for hedging purposes. The increase or decrease in the exchange rate between the two 

currencies may result in a profit or loss.

A foreign exchange transaction always involves a currency pair of which the first listed is 

the “base currency” and second is the “quoted currency.” For example, in the US DollarJapanese Yen pair, the US Dollar is the base currency and the Yen is the quoted currency.

The nature of a foreign exchange transaction requires that you are always long one 

currency of the pair and short the other. This process happens through a foreign 

exchange broker, who bankrolls the entire transaction by supplying all the currencies in 

the exchange. So, for example, if you anticipated that the Dollar was going to appreciate 

versus the Yen, you could buy the Dollar and short the Yen. You borrow the Yen from 

your broker and then sell short the Yen and simultaneously buy the Dollar. In this 

example, the broker would charge you interest on the Yen that the broker lent you, and 

the broker would pay you interest on the Dollar, which you own but which is held by the 

broker.
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Futures Contract

A futures contract (“future”) is an agreement to buy or sell an underlying commodity 

(such as an agricultural product or a financial instrument) at a specified time, price, and 

quantity. A futures contract is identified by its underlying commodity/instrument and the 

month and year of its expiration date. Futures are used to speculate in or hedge against 

the future price of the underlying commodity/instrument.

Gambling Winnings

For purposes of financial disclosure, the term “gambling winnings” includes, but is not

limited to, winnings from lotteries, raffles, horse races, and casinos. It includes cash 

winnings and also the fair market value of prizes such as cars and trips.

General Guidance: OGE Form 278e, Part 2

For You

Part 2

Report an asset related to your employment (which includes any non-investment 

activities and retirement accounts) if the value of the asset was more than $1,000 at the 

end of the reporting period or if the asset produced more than $200 in income during the 

reporting period.

In addition, report each source, whether a natural person or an organization or entity, that 

provided you more than $200 of earned income and other non-investment income during 

the reporting period. There are additional requirements for honoraria payments, as 

discussed in the honorarium entry of this guide.

Generally, you need to report assets and sources of non-investment income as follows:

Description: Provide a description sufficient to identify the asset or source of income 

being reported. The amount of information needed for a sufficient description will 

depend on the type of asset or source of income being reported. In general, the following 

rules apply.

(1) Stock and other equity in a business: Provide the name of the business. For a 

privately held business, describe the line of business as well, unless you have already 

provided this information in another entry.

(2) Other assets with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.
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(3) Assets without specific names: Describe the type of asset, including the city and state 

(or county and state) for real estate.

(4) Sources of earned or other non-investment income: Provide the name of the source 

and, for privately held companies, the nature of the business. In addition, for honoraria, 

include the date that the services were provided.

EIF: If you are reporting an investment vehicle that invests in assets of its own, you need 

to report each underlying asset that was individually worth more than $1,000 at the end of 

the reporting period or that individually produced more than $200 in income during the 

reporting period. As an exception to this requirement, however, you do not need to report 

the underlying assets of an investment vehicle that qualifies as an excepted investment 

fund (EIF). Indicate whether your entry (1) qualifies as an EIF (“Y”), (2) does not 

qualify as an EIF (“N”), or (3) is not an investment vehicle at all (“N/A”).

Value: Report the value of an asset by selecting the appropriate category.

Income Type: Specify the type(s) of income, unless the asset qualifies as an EIF or the 

income did not exceed $200.

Income Amount:

(1) Income less than $201: Select the category for “None (or less than $201).”

(2) Dividends, capital gains, interest, rent, royalties, or income from excepted investment 

funds: Select the category that corresponds to the total amount of income produced 

during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Assets and Income That Are Not Reportable

• Do not include assets or income from United States Government employment 

(e.g., salary, FERS, and Thrift Savings Plan account).

• Assets that were acquired separately from your business, employment, or other 

income-generating activities (e.g., assets purchased through a brokerage account). 

Report these assets in Part 6 instead.
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General Guidance: OGE Form 278e, Part 3

For You

Part 3

Report your participation in any of the following agreements or arrangements during the 

reporting period:

• Future employment.

• Leaves of absence.

• Continuing payments from an employer, including severance and payments not 

yet received for previous work. (This does not include ordinary salary from a 

current employer.)

• Continuing participation in an employee welfare, retirement, or other benefit plan, 

such as pensions or a deferred compensation plan.

• Retention or disposition of employer-awarded equity, sharing in profits, or carried 

interests (e.g., vested and unvested stock options, restricted stock, future share of 

a company’s profits, etc.)

Employer or Party: Provide the parties to the agreement or arrangement, other than 

yourself. In most cases, the other party will be your employer.

City/State: Provide the city and state of the other parties. 

Status and Terms: Briefly describe the type of agreement or arrangement, its terms (in 

particular, the timing and form of any payments), and its current status. 

Date: Provide the month and year in which the agreement or arrangement began. In 

many cases, this will be when you joined the employer or otherwise became eligible for 

coverage under the agreement or arrangement.

Agreements and Arrangements That Are Not Reportable

You do not need to report the following as agreements and arrangements in Part 3:

• Agreements and arrangements of your spouse or your dependent children.

• Agreements and arrangements with the United States Government, such as your 

participation in the Federal Employees Retirement System or the Civil Service 

Retirement System.

• If you are filing a Nominee, New Entrant, or Candidate report, any agreement or 

arrangement that will end before you file your report.
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General Guidance: OGE Form 278e, Part 5

For Your Spouse

Part 5

Report an asset related to your spouse’s employment (which includes any non-investment 

activities and retirement accounts) if the value of the asset was more than $1,000 at the 

end of the reporting period or if the asset produced more than $200 in income during the 

reporting period.

In addition, report each source, whether a natural person or an organization or entity, that 

provided your spouse more than $1,000 of earned income during the reporting period. 

There are additional requirements for honoraria payments, as discussed in the honorarium 

entry of this guide.

Generally, you would report assets and sources of earned income as follows:

Description: Provide a description sufficient to identify the asset or source of income 

being reported. The amount of information needed for a sufficient description will 

depend on the type of asset or source of income being reported. In general, the following 

rules apply.

(1) Stock and other equity in a business: Provide the name of the business. For a 

privately held business, describe the line of business as well, unless you have already 

provided this information in another entry.

(2) Other assets with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.

(3) Assets without specific names: Describe the type of asset, including the city and state 

(or county and state) for real estate.

(4) Sources of earned income: Provide the name of the source and, for privately held 

companies, the nature of the business. In addition, for honoraria, include the date that the 

services were provided.

EIF: If you are reporting an investment vehicle that invests in assets of its own, report 

each underlying asset that was individually worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period. As an exception to this requirement, however, you do not need to report 

the underlying assets of an investment vehicle that qualifies as an excepted investment 

fund (EIF). Indicate whether your entry (1) qualifies as an EIF (“Y”); (2) does not 

qualify as an EIF (“N”), or (3) is not an investment vehicle at all (“N/A”).

Value: Report the value of an asset by selecting the appropriate category.
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Income Type: Specify the type(s) of income unless the asset qualifies as an EIF or the 

income did not exceed $200.

Income Amount:

(1) Income less than $201: Select the “None (or less than $201)” category.

(2) Dividends, capital gains, interest, rent, royalties, or income from excepted investment 

funds: Select the category that corresponds to the total amount of income produced 

during the reporting period.

(3) Other investment income: Provide the exact amount of income produced during the 

reporting period.

(4) Earned Income (other than honoraria): Leave this field blank.

(5) Honorarium: Provide the exact amount of the honorarium.

Assets and Income That Are Not Reportable

• Assets or income from United States Government employment (e.g., salary, 

FERS, Thrift Savings Plan account).

• Assets that were acquired separately from your spouse’s business, employment, or 

other income-generating activities (e.g., assets purchased through a brokerage 

account). Report these assets in Part 6 instead.

• Interests of a spouse living separate and apart with the intention of terminating the 

marriage or providing for a permanent separation.

• Interests of a former spouse or a spouse from whom you are permanently 

separated.

General Guidance: OGE Form 278e, Part 6

Report assets and income from assets in Part 6, unless already reported in Parts 2 or 5 as 

being related to employment.

For You, Your Spouse, and Your Dependent Children

Part 6

Report an asset if the value of the asset was more than $1,000 at the end of the reporting 

period or if the asset produced more than $200 in income during the reporting period. 

For purposes of the value and income thresholds, aggregate your interests with those of 

your spouse and your dependent children.

Generally, report assets as follows, though you should note that specific requirements and 

exceptions for certain types of assets are discussed in this guide:
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Description: Provide a description sufficient to identify the asset being reported. The 

amount of information needed for a sufficient description will depend on the type of asset 

or source of income being reported. In general, the following rules apply.

(1) Stock and other equity in a business: Provide the name of the business. For a 

privately held business, describe the line of business as well, unless you have already 

provided this information in another entry.

(2) Other assets with specific names (e.g., bonds and mutual funds): Provide the full 

name of the asset and, unless clear from the name, describe the type of asset.

(3) Assets without specific names: Describe the type of asset, including the city and state 

(or county and state) for real estate.

EIF: If you are reporting an investment vehicle that invests in assets of its own, report 

each underlying asset that was individually worth more than $1,000 at the end of the 

reporting period or that individually produced more than $200 in income during the 

reporting period. As an exception to this requirement, however, you do not need to report 

the underlying assets of an investment vehicle that qualifies as an excepted investment 

fund (EIF). Indicate whether your entry (1) qualifies as an EIF (“Y”), (2) does not 

qualify as an EIF (“N”), or (3) is not an investment vehicle at all (“N/A”).

Value: Report the value of an asset by selecting the appropriate category.

Income Type: Specify the type(s) of income, unless the asset qualifies as an EIF or the 

income did not exceed $200.

Income Amount:

(1) Income less than $201: Select the “None (or less than $201)” category.

(2) Dividends, capital gains, interest, rent, royalties, or income from excepted investment 

funds: Select the category that corresponds to the total amount of income produced 

during the reporting period.

(3) Other income: Provide the exact amount of income produced during the reporting 

period.

Assets and Income That Are Not Reportable

• A personal residence (including a vacation home used as a second residence or a 

vacation home used as a timeshare) that you did not rent out during the reporting 

period.

• Retirement benefits from the United States Government, including the Thrift 

Savings Plan.

• Income from Social Security, veterans’ benefits, and other similar United States 

Government benefit programs.
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• Cash accounts (e.g., money market accounts, certificates of deposit, savings 

accounts, checking accounts) in a single financial institution aggregating $5,000 

or less.

• Shares in a single money market fund aggregating $5,000 or less.

• Term life insurance.

• Insurance claims and reimbursements, unless they are subject to federal income 

tax.

• Assets of a trade or business, unless the assets are unrelated to the operations of 

that trade or business.

• Loans made by you or your spouse to each other or to a parent, sibling, child, or 

grandchild.

• Interests of a spouse living separate and apart from you with the intention of 

terminating the marriage or providing for a permanent separation.

• Interests of a former spouse or a spouse from whom you are permanently 

separated.

• Payments from a spouse or former spouse associated with a divorce or permanent 

separation.

General Guidance: OGE Form 278-T

Report purchases, sales, or exchanges by the applicable due date.

Description Type Date

Notification 

Over 30 Days 

Ago

Amount

Chevron Corp. (CVX) sale 6/12/15 $15,001 - $50,000

Exxon Mobil Corp. (XOM) purchase 6/12/15 Yes $15,001 - $50,000

For You, Your Spouse, and Your Dependent Children

Report any purchase, sale, or exchange by you, your spouse, or dependent child of stocks, 

bonds, commodity futures, and other securities if the amount of the transaction exceeded 

$1,000.

Description: Provide a description sufficient to identify the asset being reported (or both 

assets in the case of an exchange). The amount of information needed for a sufficient 

description will depend on the type of asset being reported. In general, the following 

rules apply.

(1) Stock: Provide the name of the issuing company.

(2) Other securities with specific names (e.g., bonds): Provide the full name of the asset 

and, unless clear from the name, describe the type of asset.
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If the asset is an underlying holding of some other investment vehicle (e.g., held within a 

fund that does not qualify as an excepted investment fund), it is helpful if you identify the 

investment vehicle (e.g., Positron Investments, LLC: Chevron Corp.).

Type: Specify the type of transaction as a purchase, sale, or exchange.

Date: Provide the month, day, and year of the transaction.

Notification Over 30 Days Ago: Select this field only if you received notice of the 

transaction more than 30 days ago. Absent an extension, you would likely not select this 

field because you are required to report transactions within 30 days of notification.

Amount: Report the amount of the transaction by selecting the appropriate category.

Transactions That Are Not Reportable in an OGE Form 278-T

You do not need to report transactions that concern the following:

• Real property (e.g., apartment building or farmland).

• Cash accounts (e.g., checking, savings, certificates of deposit, money market 

accounts) and money market mutual funds.

• Treasury bills, bonds, notes, and savings bonds.

• An excepted investment fund, such as a mutual fund.

• Holdings of a Thrift Savings Plan account or other retirement account for United 

States Government employees.

• Underlying assets held within an excepted trust or a qualified trust.

• Assets of a trade or business, unless the assets are unrelated to the operations of 

that trade or business.

In addition, you do not need to report:

• Transactions that occurred when you were not an employee of the United States 

Government.

• Transactions that occurred solely by and between you, your spouse, or your 

dependent children.

• Actions that do not constitute purchases, sales, or exchanges (e.g., gifts given or 

received, stock splits, bond calls or maturity, or expiration of options).

• Transactions involving the interests of a spouse living separate and apart from you 

with the intention of terminating the marriage or providing for a permanent 

separation.

• Transactions involving the interests of a former spouse or a spouse from whom 

you are permanently separated.
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Voluntary Reporting of Annual and Termination Information

You do not need to report a transaction in an Annual or Termination report (OGE Form 

278e) if you have already reported the transaction in a Periodic Transaction report (OGE 

Form 278-T), unless your agency requires duplicate reporting. Annual and Termination 

reports, however, also require you to report purchases, sales, or exchanges of: (1) mutual 

funds and other excepted investment funds and (2) real property (excluding your personal 

residence). If you prefer to report such transactions in your Periodic Transaction 

report(s), you may do so.

* Note that Integrity allows filers to import Periodic Transaction reports into Annual or 

Termination reports without additional data entry. Other electronic filing systems may 

offer similar functionality.

No Transactions to Report

Do not file an OGE Form 278-T. Filing is required only if you have reportable 

transactions.

Click Here for Frequently Asked Questions

Gifts: Waiver for Personal Gifts

In unusual cases, the Director of OGE may waive the reporting of gifts if:

• your relationship to the donor and the donor’s motivation for the gifts are personal 

and

• no separate public purpose requires disclosure of the nature, source, and value of 

the gift.

This authority is ordinarily used when a filer receives a large number of personal gifts, 

such as at an engagement or wedding.

Elements of a Request

Requests for a waiver are made in writing to OGE but are first routed through your 

agency’s ethics office. The request should contain a cover letter and an enclosure.

Provide the following in your cover letter:

• your name and your position and

• a request for a waiver under 5 C.F.R. § 2634.304(f).
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Provide the following in your enclosure:

• the identity and occupation of each donor;

• a brief description of each gift and the value of the gift;

• a statement that the relationship between you and the donor is personal; and

• a statement that neither the donor nor any person or organization who employs the 

donor, or whom the donor represents:

o conducts or seeks business with,

o engages in activities regulated by, or

o is directly affected by action taken by your agency.

If you cannot make the above described statement, explain why you cannot. You must 

also be able to state that you have no role in official action directly affecting the donor or 

organizations served by the donor.

If OGE grants a waiver, your cover letter, but not the enclosure, will be available to the 

public as an attachment to your financial disclosure report.

Gifts and Travel Reimbursements: Aggregation

Example

Let’s say you received the following gifts from the same source during the reporting 

period:

• Painting ($290 value)

• Pen set ($185)

• Letter opener ($25)

Step 1: Eliminate those gifts with a value of $156 or less.

• Painting ($290 value)

• Pen set ($185)

• Letter opener ($25)

Step 2: Add the values of the remaining gifts.

• Painting ($290 value)

• Pen set ($185)

$290 + $185 = $475

Step 3: Compare the total value from Step 2 to the $390 threshold. If the value 

is more than $390, report the gifts worth more than $156.
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Report the painting and the pen set. Do not report the letter opener.

Remember

Gifts and travel reimbursements count toward separate $390 thresholds. Let’s say that in 

the example above you received a $290 travel reimbursement instead of a $290 painting. 

If that were the case, the pen set is the only gift that you received with value of more than 

$156. However, the value of the pen set does not individually exceed the $390 threshold, 

so you would have no gifts to report.

Government Agency or GSE Security (“agency security”)

Agency securities are debt obligations issued by U.S. Government agencies and 

U.S. Government-sponsored enterprises (“GSE”). In addition to issuing debt obligations, 

U.S. Government-sponsored enterprises, such as the Federal National Mortgage 

Association, may also sell equity shares.

Examples of U. S. Government Agencies include:

• Government National Mortgage Association (GNMA or Ginnie Mae)

• Export-Import Bank of the United States (ExImBank)

• Tennessee Valley Authority (TVA)

Examples of U.S. Government-Sponsored Enterprises (GSE) include:

• Federal National Mortgage Association (FNMA or Fannie Mae)

• Federal Home Loan Mortgage Corporation (FHLMC or Freddie Mac)

• Federal Agricultural Mortgage Corporation (Farmer Mac)

Honorarium

An honorarium is a payment of money or anything of value for an appearance, speech, or 

article, less any necessary travel expenses.

Income: Measurement

Several rules govern how you measure the amount of income produced by an asset for 

purposes of financial disclosure.

• The definition of investment income is not tied to the IRS definition of income for 

tax purposes. Report accrued income, even if deferred or exempt for tax 

purposes. If you do not receive a report of the amount accruing, you may make a 

good faith estimate.

• You must generally report gross income for any income you directly receive, such 

as salary, proceeds from a sole proprietorship, or rental payments from real estate. 
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You may note your net income from a business or real estate as well if you wish 

to show a loss.

• You may report net distributive share for any partnerships, limited liability 

companies, or S-corporations in which you have an interest.

• You must aggregate all types of income from a particular source in determining 

whether the income meets the reporting threshold. For example, if an asset 

produced $150 in dividends and $150 in capital gains, the total income of $300 

meets the income reporting threshold. You may, however, subtract capital losses 

from any gains and other income when calculating the total amount of income 

produced. For example, if an asset produced $300 in dividends but was sold at a 

loss of $200, the total income of $100 falls below the income reporting threshold.

• When applicable, you must aggregate the income from your assets with those of 

your spouse and dependent children in determining whether the income meets the 

reporting threshold.

Income: Types

Investment Income: “Investment income” includes interest, rents, royalties, dividends, 

capital gains, and other income derived from an asset. Examples of investment income 

include, but are not limited to, income derived from: stocks, bonds, investment funds, and 

other securities; real estate; retirement investment accounts; annuities; the investment 

portion of life insurance contracts; interests in trusts and estates; collectible items; 

commercial crops; accounts or other funds receivable; and businesses.

The definition of investment income for purposes of financial disclosure is not tied to the

Internal Revenue Service’s definition of income for tax purposes. Report accrued 

income, even if deferred or exempt for tax purposes. For example, tax-deferred income 

in a retirement account is reportable in your financial disclosure report. Where you do 

not receive a report of the amount accruing, such as with United States savings bonds, 

you may make a good faith estimate.

Earned Income: “Earned income” includes fees, salaries, commissions, honoraria, and 

any other compensation received for personal services but excludes United States 

Government salary and other federal benefits, including retirement and veterans’ benefits. 

If personal services (provided by you or your spouse or dependent children) are a 

material factor in the production of income from an asset or business, it is considered 

“earned income” for purposes of financial disclosure rather than “investment income.” 

However, your dependent child’s sources of earned income are not reportable.

Other Non-Investment Income: A remainder category exists for income that does not fit 

into the investment income or earned income categories. Examples include prizes, 

scholarships, awards, and gambling winnings. Report only your own sources of other 

non-investment income. Other non-investment income received by your spouse or 

dependent child is not reportable.
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Intellectual Property

“Intellectual property” includes all of the following: patents, inventions, novels, plays, 

movie scripts, other literary works, artistic works, symbols, names, images, designs, 

trademarks, copyrights, films, and musical works.

Investment Fund: Employment with a Company that Manages 

the Fund

If you have ever worked for the company that manages the investment fund, additional 

reporting requirements may apply to you.

• Equity Interest in Actively Managed Fund: If you actively manage an investment 

fund, you should generally follow the ordinary instructions for investment funds; 

however, the fund will not qualify as an excepted investment fund.

• Compensation and Other Benefits: If you provide services to the investment fund 

(e.g., fund manager), you may receive compensation for those services. This 

compensation may take the form of salary, severance, bonus, deferred 

compensation, defined benefit plan, defined contribution plan, or other financial 

interests. Report each such financial interest as a separate line entry in your 

financial disclosure report, using the instructions appropriate for that type of asset 

or income in this guide.

• Co-Investment Interest: In Part 2, report any co-investment interest that you have 

in the investment fund. If you are unable to calculate a value of this interest, write 

“value not readily ascertainable” in the “Description” field. Provide a brief 

explanation of your interest. In Part 3, report any arrangement with your 

employer related to this co-investment interest that will continue after you enter 

government service.

• Carried Interest: See the entry for “Carried Interest” in this guide for assistance.

• Exit Arrangements: In Part 3, report any agreement or arrangement that you have 

concerning your exit from the fund (e.g., buy-back agreement). For further 

information, see the general guidance for reporting agreements or arrangements.

If you have any other type of financial interest in the investment fund, report the interest 

as consistently as possible with the instructions in this guide for similar types of interests. 

Then, talk to an ethics official at your agency for guidance on how to ensure proper 

reporting of that financial interest.
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Investment Fund: Spouse’s Employment with the Company that 

Manages the Fund

If your spouse has ever worked for the company that manages the investment fund, 

additional reporting requirements may apply.

• Equity Interest in Actively Managed Fund: If your spouse actively manages an 

investment fund, you should generally follow the general instructions for 

investment funds; however, any partnership or LLC income would be treated as 

earned income.

• Compensation and Other Benefits: If your spouse provides services to the 

investment fund (e.g., fund manager), your spouse may receive compensation for 

those services. This compensation may take the form of salary, severance, bonus, 

deferred compensation, defined benefit plan, defined contribution plan, or other 

financial interests. Report each such financial interest as a separate line entry in 

your financial disclosure report, using the instructions appropriate for that type of 

asset or income in this guide.

• Co-Investment Interest: In Part 5, report any co-investment interest that your 

spouse has in the investment fund. If you are unable to calculate a value of this 

interest, write “value not readily ascertainable” in the “Description” field. 

Provide a brief explanation of your spouse’s interest.

• Carried Interest: See the entry for carried interest in this guide for assistance.

If your spouse has any other type of financial interest in the investment fund, report the 

interest as consistently as possible with the instructions in this guide for similar types of 

interests. Then, talk to an ethics official at your agency for guidance on how to ensure 

proper reporting of that financial interest.

IRA, Roth IRA, SEP IRA, or Keogh Plan

Individual Retirement Account (IRA) – Traditional and Roth: An Individual Retirement

Account (IRA) is typically a bank, brokerage, or mutual fund account that a person has 

designated as a tax-deferred retirement account. All IRAs are “self-directed” because 

investors choose where to invest their retirement funds. Although investors may place 

these funds in bank accounts, they may also buy stocks and other securities. The main 

difference between a Traditional IRA and a Roth IRA is the tax treatment of 

contributions and withdrawals.

Simplified Employee Pension Individual Retirement Account (SEP IRA): Some small 

employers offer employees the opportunity to participate in a tax-deferred Simplified 

Employee Pension (SEP) plan. Under a Simplified Employee Pension plan, the employer 

and employee make contributions to individual retirement accounts (called a SEP IRA) 

set up by or for each eligible employee. Employees own and control their accounts. For 

purposes of financial disclosure, SEP IRAs are treated like IRAs.
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Keogh Plan: A Keogh plan (also called a “HR-10 plan”) is a tax-deferred pension 

account for self-employed persons and employees of unincorporated businesses. Like 

IRAs, an employee may put almost any available investment into a Keogh, and the 

investment earnings grow on a tax-deferred basis.

Leave of Absence

When entering the executive branch, some employees choose to take a leave of absence 

rather than resign from their employer. For example, a tenured faculty professor might 

take a leave of absence to retain her university position. If you are taking a leave of 

absence, you should discuss the leave of absence with your ethics official, who will 

provide you with guidance on the applicable ethics rules.

Life Insurance (split-dollar)

The term “split-dollar” describes the method of paying for life insurance (whether whole, 

universal, or variable) by splitting the premiums and proceeds between an employer and 

an employee.

Split-dollar payment arrangements generally may take two forms:

• The employer pays the premiums and owns the contract. The employer receives 

reimbursement of the premiums upon the employee’s death, and the employee’s 

beneficiary then receives the balance of the insurance proceeds.

• The employer pays the premiums, but the employee owns the contract. The 

premiums are then repaid to the employer out of the insurance proceeds.

The primary differences between these two arrangements are differing tax consequences 

based on the ownership of the contract.

Life Insurance (term)

Term insurance pays beneficiaries a death benefit if the insured person dies during the 

term of the policy. When the policy expires, no value remains. This type of insurance 

policy is pure insurance with no investment component.

Life Insurance (variable)

A variable life insurance policy is part insurance and part investment. Part of the 

policyholder’s premiums pay for expenses and the insurance part of the policy. The 

remainder goes into a tax-deferred cash reserve which is invested and builds the policy’s 

cash value.
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Unlike whole life and universal life policies, variable life policies provide the 

policyholder a range of investment options, and the rate of return is based on the 

performance of the options chosen by the investor. The investment options are typically 

mutual funds. Some variable life policies, however, also provide a fixed account option 

which pays a set rate of interest.

Life Insurance (whole or universal)

Whole life and universal life policies are part insurance and part investment. Part of the 

policyholder’s premiums pay for expenses and the insurance part of the policy. The 

remainder goes into a tax-deferred cash reserve which is invested and builds the policy’s 

cash value.

• Whole life: The policyholder pays fixed premiums and has no control over 

investments, which are left to the insuring company.

• Universal life: The policyholder can vary premiums by paying them with some of 

the accumulated cash value of the policy, and the policyholder normally receives 

a minimum guaranteed rate of return at money market rates. As with whole life, 

the universal life insurance policyholder generally does not have control over the 

investments. However, if the policy does permit the selection of specific 

investments, please report the policy as a variable life insurance policy.

Line of Credit (exercised)

A line of credit is an arrangement under which liabilities may be created. As a general 

matter, the mere fact that you have a line of credit arrangement (e.g., a plan or 

arrangement permitting you to borrow a certain amount of money) does not necessarily 

require the “line of credit” plan or arrangement to be reported. You have a reportable 

liability when you have actually borrowed money or exercised the borrowing authority 

under the line of credit arrangement.

Managed Account

A managed account (also called a “separately managed account” or “controlled account”) 

is an account that is owned by the investor but managed for a fee by a financial advisor. 

The investor gives the financial advisor the discretion to buy, sell, and trade investments 

on behalf of the investor.

An investor usually chooses among predetermined portfolios, which financial institutions 

sometimes package in categories such as high yield, balanced, large cap, global small 

cap, strategic fixed income, and other similar descriptors. The investor can usually 

customize the portfolio to some extent, although this is not necessarily the case with all 

managed accounts.
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A managed account is not an “excepted investment fund.” Even if the investor may 

select an established portfolio of investment choices, the managed account is not an 

excepted investment fund. In fact, the managed account is not an investment fund at all. 

The investor has not “pooled” the investor’s money with other investors. Although the 

account manager may have offered the option of selecting a predetermined “portfolio” of 

assets, the investor owns each of these assets individually and directly in the investor’s 

own name. For this reason, as well as other reasons, each asset is disclosed as a separate 

line item on the financial disclosure report.

Although some managed accounts may appear similar to mutual funds, they are not 

mutual funds and do not qualify for the same treatment as mutual funds under conflicts of 

interest laws.

Margin Account

A margin account is an account that an investor maintains with the investor’s broker, 

from which the investor can borrow funds to purchase securities.

Money Market Fund (or money market mutual fund)

A money market fund is a type of mutual fund that holds financial interests in certain 

low-risk investments (e.g., government securities, certificates of deposit, and high quality 

bank or corporate obligations). Its rate of return is responsive to fluctuations in the 

market for these investments.

A money market fund is distinguished from a money market account in that a money 

market fund is an investment fund that holds underlying investments, whereas a money 

market account is a cash deposit account. A money market fund is not FDIC insured.

The reporting threshold for both a money market fund and a money market account is a 

value of more than $5,000 (or income more than $200).

Money Purchase Pension Plan

A money purchase pension plan is a type of defined contribution plan in which an 

employer makes fixed contributions to a tax-deferred retirement account. Unlike profitsharing plans in which employer contributions are discretionary, employer contributions 

to a money purchase pension plan are fixed in advance. Each year, the employer makes 

fixed contributions based on an employee’s annual compensation. Like other defined 

contribution plans, money purchase pension plans contain underlying assets in which a 

filer has invested.
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Mortgage

For purposes of financial disclosure, mortgage debt is debt by which the borrower gives 

the lender a lien on real estate as security for repayment of the loan.

Mutual Fund

A mutual fund is a company that is created and managed to hold a portfolio of securities 

as an investment company registered with the U.S. Securities and Exchange Commission 

under the Investment Company Act of 1940, as amended.

Investors purchase shares of the mutual fund, and the value of those shares typically rises 

and falls based on the performance of the mutual fund’s underlying investments. The 

underlying investments of a mutual fund may include shares of companies in a variety of 

business sectors, bonds, cash equivalents, etc.

The mutual fund uses the money it raises from selling its shares to fund its purchases of 

underlying investments. A mutual fund may pay dividends to its investors. It also 

charges management fees.

Officers and Employees Subject to Public Financial Disclosure

(“covered position”)

The following individuals serve in positions covered by the disclosure requirements 

(“covered positions”).

• The President and the Vice President;

• Officers and employees (including special Government employees, as defined in 

18 U.S.C. § 202) in positions that (1) are paid under a system other than the 

General Schedule (e.g., Senior Executive Service) and (2) have a rate of basic pay 

equal to or greater than 120% of the minimum rate of basic pay for GS-15 of the 

General Schedule; members of the uniformed services whose pay grade is O-7 or 

above; and officers or employees in any other positions determined by the 

Director of the Office of Government Ethics to be of equal classification; 

• Administrative law judges;

• Employees in positions which are excepted from the competitive service because 

of their confidential or policy-making character, unless the position has been 

excluded from the public financial disclosure requirements by the Director of the 

Office of Government Ethics;

• The Postmaster General, the Deputy Postmaster General, each Governor of the 

Board of Governors of the U.S. Postal Service, and officers or employees of the 

U.S. Postal Service or Postal Regulatory Commission in positions for which the 

rate of basic pay is equal to or greater than 120% of the minimum rate of basic 

pay for GS-15 of the General Schedule;
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• The Director of the Office of Government Ethics and each designated agency 

ethics official; and

• Civilian employees in the Executive Office of the President (other than special 

Government employees) who hold commissions of appointment from the 

President.

* Note: For purposes of calculating the reporting threshold, the “minimum rate of basic 

pay” for GS-15 is the base pay, excluding locality pay, for GS-15, step 1.

Option (incentive stock option plan)

An incentive stock option is a type of compensation, in the form of an agreement between 

an employer and an employee, that allows the employee to purchase shares of the 

employer’s stock at a specified price (i.e., the “strike price”). A stock option typically 

has a vesting requirement, meaning that the employee may exercise the stock option (i.e., 

purchase the employer’s stock at the strike price) only after a specified period of time has 

passed. If the employee’s employment terminates before the stock option has vested, the 

employee typically forfeits the unvested stock option upon termination. After the stock 

option vests, the employee may exercise the stock option until the stock option expires. 

Once the stock option has expired, the employee no longer has the right to purchase the 

stock at the specified price (i.e., strike price).

An incentive stock option is a type of “call option” because it provides the right to 

purchase stock. Unlike some other types of call options, however, an incentive stock 

option is not traded on the open market.

Option (put or call purchased)

Put option: A put option is a contract that provides an investor the option to sell a 

security.

Call Option: A call option is a contract that provides an investor the option to purchase a 

security.

With regard to each of these types of contracts, the investor has the right, but not the 

obligation, to exercise the option at a specified price (i.e., the “strike price”) until the 

contract’s expiration date.

Some put and call options may be purchased on the open market. As an alternative to 

exercising put and call options, investors can resell these options on the open market 

before their expiration.

Employee incentive stock options are call options. However, they may not be purchased 

or sold on the open market.
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Option (put or call written)

Put option: A put option is a contract that provides the buyer the option to sell a security. 

The writer of a put option has an obligation to buy the security at a specified price (i.e., 

the “strike price”) from the buyer if the buyer exercises the option before the contract’s 

expiration date.

Call Option: A call option is a contract that provides the buyer the option to purchase a 

security. The writer of a call option has an obligation to sell the security at a specified 

price (i.e., the “strike price”) to the buyer if the buyer exercises the option before the 

contract’s expiration date.

Caution: This entry applies to put and call options written on the market. It does not 

apply to:

• Call options acquired through an employment relationship, such as through an 

employee stock purchase plan or an incentive stock option plan. See the 

“Employee Stock Purchase Plan” or “Option (incentive stock option plan)” entries 

for additional information about these types of employment-related options.

• Put or call options that have been purchased rather than written. An option buyer 

does not have an obligation to exercise an option but rather may choose to let the 

option expire, unexercised. For this case, see “Option (put or call purchased)” 

entry.

Personal Residence

For purposes of financial disclosure, a “personal residence” includes any real property 

used exclusively as a private dwelling by you or your spouse, provided the property was 

not rented out during any portion of the reporting period. The term is not limited to your 

domicile, so you may have more than one property that qualifies as a personal residence 

(e.g., your vacation home).

Note that this definition would include a residential property in which you permit a 

family member to live rent free.

Phantom Stock

Phantom stock is a contract between an employer and an employee that grants the 

employee the right to receive a payment based on the value of the employer’s stock. 

When granting phantom stock, the employer does not grant the employee any shares of 

the employer’s stock. Instead, the employer grants the employee a right that tracks the 

value of a specified number of shares of the stock.
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The employee will have a right to receive a payout equivalent to the value of these 

tracked shares. Depending on the terms of the employer’s phantom stock plan regarding 

the vesting of phantom stock, the payout may occur on a specified date or upon the 

occurrence of a certain event, such as retirement, disability, or death. If the employee’s 

employment is terminated before the phantom stock vests, the employee normally forfeits 

the phantom stock.

The plan may provide for a single payment, or it may provide for installment payments 

over a period of time after the phantom stock vests. In some cases, the employer may let 

the employee elect to receive the payout in the form of an equivalent amount of stock. In 

addition to the final payout, under some phantom stock plans, the employee may receive 

payments equivalent to any dividends that the employer pays to stockholders.

It may help to understand some of the key similarities and differences between phantom 

stock and other types of financial interests in an employer. Phantom stock differs from 

an employer’s stock in that phantom stock does not give the employee an ownership 

interest in the employer. Unlike stock, phantom stock also might not convey a right to 

payments based on dividends. Phantom stock differs from a stock appreciation right in 

that its payout is based on the full value of the stock, while the payout of a stock 

appreciation right is based only on any increase in the value of the stock over a specified 

period of time. Phantom stock differs from a stock option because the employee does not 

need to purchase anything.

Qualified Trust

Before discussing qualified trusts, we want to give an important word of caution: Do not 

attempt to establish a federal executive branch qualified trust without first consulting 

OGE.

The Ethics in Government Act of 1978 established a uniform system of qualifying trusts 

that emphasizes independent trustees and limited communication with the employee 

involved.

There are two different types of qualified trusts:

• A qualified blind trust requires you to relinquish control of your assets to an 

independent trustee, who manages the assets in the trust without your knowledge. 

Any asset initially placed in the trust continues to pose a potential conflict of 

interest until it has been sold or reduced to a value less than $1,000. The new 

assets purchased by the trustee will not be disclosed to you, so they will not pose 

a conflict.

• A qualified diversified trust holds a portfolio of marketable securities that is so 

diversified that it does not pose a conflict of interest because no specific action 

can significantly impact the overall value of the portfolio. No single asset in the 

trust may be more than 5% of the total portfolio, and no more than 20% of the 
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portfolio may be concentrated in any particular economic, geographic, or 

industrial sector. An asset that poses a significant conflict with your duties also 

cannot be put in the initial trust portfolio.

A “qualified trust” must be certified as such by the Director of OGE. Interested parties 

should contact OGE or an ethics official to coordinate efforts to create an appropriate 

type of trust. OGE has several model qualified trusts available on our website.

Qualified Tuition Program

There are two types of qualified tuition programs:

1. College savings plans: A college savings plan is an investment account in which 

an individual chooses among various investment options, often consisting of 

mutual funds. The amount available for future tuition depends on the amount that 

the individual contributes and the performance of the investments that the 

individual has chosen.

2. Prepaid tuition plans: A prepaid tuition plan is a contract between an individual 

and the plan’s sponsor that allows the individual to prepay future tuition expenses 

at current tuition rates. The sponsor can either be a state or the Tuition Plan 

Consortium, LLC, for private institutions (also known as the Independent 529 

Plan). 

In either case, the qualified tuition program is essentially a program that offers investors 

tax-advantaged accounts for the purpose of saving money to cover educational expenses. 

Qualified tuition programs are often called “529 plans” because they are recognized in 

the tax code at 26 U.S.C. § 529.

Real Estate Holding Company

A real estate holding company is a business that is principally engaged in owning, 

holding, selling, or leasing real estate. These companies derive most of their income 

from dividends, interest, royalties, and rent collection. Real estate holding companies 

may be organized as limited partnerships, limited liability companies, or as corporations. 

A real estate investment trust (REIT) is a specific type of real estate holding company 

that manages a diversified portfolio of real estate and mortgages.

Relative

For purposes of financial disclosure, the term “relative” means an individual who is 

related to you as your father, mother, son, daughter, brother, sister, uncle, aunt, great 

uncle, great aunt, first cousin, nephew, niece, husband, wife, grandfather, grandmother, 
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grandson, granddaughter, father-in-law, mother-in-law, son-in-law, daughter-in-law, 

brother-in-law, sister-in-law, stepfather, stepmother, stepson, stepdaughter, stepbrother, 

stepsister, half brother, half sister, or who is the grandfather or grandmother of your 

spouse. “Relative” also includes your fiancé or fiancée.

Reporting Due Dates: OGE Form 278-T

Periodic transaction reporting is subject to two different deadlines. Under the Ethics in 

Government Act, you need to file a report within 30 days of receiving notification of a 

transaction, but not later than 45 days after the transaction.

Which due date applies depends on when you receive notification of the transaction. 

Normally, you need to disclose a transaction within 30 days of receiving the notification. 

For example, if you receive online confirmation of a transaction that you ordered earlier 

today, you will file your report within 30 days.

Sometimes, you might not receive notification right away. In that case, the 45-day 

deadline can shorten the period for filing your report. For example, if today you receive 

notification of a transaction that occurred early last month, you will need to be sure to file 

your report no later than 45 days after the transaction occurred. The 45-day period might 

end sooner than 30 days from today.

Example 1: You purchase a stock on July 1 and receive notification the same day. You 

need to report the purchase on or before July 31.

Example 2: You receive a statement on August 10 regarding a purchase that occurred on 

July 31. You need to report the purchase on or before September 9 because September 9 

is 30 days after you received notification of the transaction.

Example 3: You receive a statement on August 10 regarding a purchase that occurred on 

July 1. You need to report the purchase on or before August 15. Although the 30-day 

period from notification ends September 9, the 45-day period from the date of the 

transaction ends earlier.

Note: These deadlines do not apply to any voluntary disclosures of Annual and 

Termination report information that you choose to make.

Your agency may grant an extension of up to 45 days for good cause shown with the 

possibility of an additional extension of up to 45 days. If your report is filed more than 

30 days after the date the report is required to be filed, or, if an extension was granted, 

more than 30 days after the last day of the filing extension period, you shall be subject to 

a $200 late filing fee. A report is considered to be filed when it is received by your 

agency. Unless waived by your agency, your agency will collect the fee for deposit with 

the United States Treasury.
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Reporting Periods: Annual Report

Part Report Information for the 

Following Period...

Report Information for the 

Following Individuals...

1. Filer’s Positions Held 

Outside United States 

Government

Preceding Calendar Year to 

Filing Date

You

2. Filer’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year You

3. Filer’s Employment 

Agreements and 

Arrangements

Preceding Calendar Year to 

Filing Date

You

4. Filer’s Sources of 

Compensation Exceeding 

$5,000 in a Year

N/A – Leave this Part blank N/A – Leave this Part blank

5. Spouse’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year Your Spouse

6. Other Assets and 

Income

Preceding Calendar Year You, Your Spouse, and 

Dependent Children

7. Transactions Preceding Calendar Year* You, Your Spouse, and 

Dependent Children

8. Liabilities Preceding Calendar Year You, Your Spouse, and 

Dependent Children

9. Gifts and Travel 

Reimbursements

Preceding Calendar Year* You, Your Spouse, and 

Dependent Children

* Do not include any period when you were not an officer or employee of the United 

States Government.
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Reporting Periods: Candidate Report

Part Report Information for the 

Following Period...

Report Information for the 

Following Individuals...

1. Filer’s Positions Held 

Outside United States 

Government

Preceding Two Calendar 

Years to Filing Date

You

2. Filer’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

You

3. Filer’s Employment 

Agreements and 

Arrangements

As of Filing Date You

4. Filer’s Sources of 

Compensation Exceeding 

$5,000 in a Year

N/A – Leave this Part blank N/A – Leave this Part blank

5. Spouse’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

Your Spouse

6. Other Assets and 

Income

Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

7. Transactions N/A – Leave this Part blank N/A – Leave this Part blank

8. Liabilities Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

9. Gifts and Travel 

Reimbursements

N/A – Leave this Part blank N/A – Leave this Part blank

* For example, if today is March 3, 2016, the reporting period would run from 

January 1, 2015 to March 3, 2016. You may end the reporting period for valuing assets 

and liabilities on any day within 31 days of the filing date.
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Reporting Periods: New Entrant Report

Part Report Information for the 

Following Period...

Report Information for the 

Following Individuals...

1. Filer’s Positions Held 

Outside United States 

Government

Preceding Two Calendar 

Years to Filing Date

You

2. Filer’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

You

3. Filer’s Employment 

Agreements and 

Arrangements

As of Filing Date You

4. Filer’s Sources of 

Compensation Exceeding 

$5,000 in a Year

Preceding Two Calendar 

Years to Filing Date

You

5. Spouse’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

Your Spouse

6. Other Assets and 

Income

Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

7. Transactions N/A – Leave this Part blank N/A – Leave this Part blank

8. Liabilities Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

9. Gifts and Travel 

Reimbursements

N/A – Leave this Part blank N/A – Leave this Part blank

* For example, if today is March 3, 2016, the reporting period would run from 

January 1, 2015 to March 3, 2016. You may end the reporting period for valuing assets 

and liabilities on any day within 31 days of the filing date.
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Reporting Periods: Nominee Report

Part Report Information for the 

Following Period...

Report Information for the 

Following Individuals...

1. Filer’s Positions Held 

Outside United States 

Government

Preceding Two Calendar 

Years to Filing Date

You

2. Filer’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

You

3. Filer’s Employment 

Agreements and 

Arrangements

As of Filing Date You

4. Filer’s Sources of 

Compensation Exceeding 

$5,000 in a Year

Preceding Two Calendar 

Years to Filing Date

You

5. Spouse’s Employment 

Assets & Income and 

Retirement Accounts

Preceding Calendar Year to 

Filing Date*

Your Spouse

6. Other Assets and 

Income

Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

7. Transactions N/A – Leave this Part blank N/A – Leave this Part blank

8. Liabilities Preceding Calendar Year to 

Filing Date*

You, Your Spouse, and 

Dependent Children

9. Gifts and Travel 

Reimbursements

N/A – Leave this Part blank N/A – Leave this Part blank

* For example, if today is March 3, 2016, the reporting period would run from 

January 1, 2015 to March 3, 2016. You may end the reporting period for valuing assets 

and liabilities on any day within 31 days of the filing date. 
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Reporting Periods: Termination Report

Part Report Information for the 

Following Period...

Report Information for the 

Following Individuals...

1. Filer’s Positions Held 

Outside United States 

Government

End of Period Covered by 

Last Report to Term Date

You

2. Filer’s Employment 

Assets & Income and 

Retirement Accounts

End of Period Covered by 

Last Report to Term Date

You

3. Filer’s Employment 

Agreements and 

Arrangements

End of Period Covered by 

Last Report to Term Date

You

4. Filer’s Sources of 

Compensation Exceeding 

$5,000 in a Year

N/A – Leave this Part blank N/A – Leave this Part blank

5. Spouse’s Employment 

Assets & Income and 

Retirement Accounts

End of Period Covered by 

Last Report to Term Date

Your Spouse

6. Other Assets and 

Income

End of Period Covered by 

Last Report to Term Date

You, Your Spouse, and 

Dependent Children

7. Transactions End of Period Covered by 

Last Report to Term Date*

You, Your Spouse, and 

Dependent Children

8. Liabilities End of Period Covered by 

Last Report to Term Date

You, Your Spouse, and 

Dependent Children

9. Gifts and Travel 

Reimbursements

End of Period Covered by 

Last Report to Term Date*

You, Your Spouse, and 

Dependent Children

* Do not include any period when you were not an officer or employee of the United 

States Government.

Reporting Periods by Part: Part 1

New Entrant, Nominee, or Candidate Report

The reporting period for a New Entrant, Nominee, or Candidate report is the current 

calendar year and the preceding two calendar years.

For example, if today is October 15, 2015, the reporting period is January 1, 2013, 

through October 15, 2015.

Annual Report

The reporting period for an Annual report is the preceding calendar year and the current 

calendar year up to the date of filing.
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Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current year up to your date of termination.

Reporting Periods by Part: Parts 2, 5, and 6

New Entrant, Nominee, or Candidate Report

The reporting period for a New Entrant, Nominee, or Candidate report is the current 

calendar year and the previous calendar year.

For example, if today is October 15, 2015, the reporting period is January 1, 2014 

through October 15, 2015.

When valuing an asset for these Parts, you may pick any date that is within 31 days of the 

end of the reporting period.

Annual Report

The reporting period for an Annual report is the preceding calendar year.

Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current calendar year up to the date of your termination.

Reporting Periods by Part: Part 3

New Entrant, Nominee, or Candidate Report

If you are filing a New Entrant, Nominee, or Candidate report, report only agreements or 

arrangements in which you continue to participate as of the date of filing.
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Annual Report

The reporting period for an Annual report is the preceding calendar year and the current 

calendar year up to the date of filing.

Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current year up to your date of termination.

Reporting Periods by Part: Part 7

Annual Report

The reporting period for an Annual report is the preceding calendar year.

Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current year up to your date of termination.

Reporting Periods by Part: Part 8

New Entrant, Nominee, or Candidate Report

The reporting period for a New Entrant, Nominee, or Candidate report is the current 

calendar year and the previous calendar year.

For example, if today is October 15, 2015, the reporting period is January 1, 2014 

through October 15, 2015.

When valuing a liability for this Part, you may pick any date that is within 31 days of the 

end of the reporting period.
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Annual Report

The reporting period for an Annual report is the preceding calendar year.

Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current year up to your date of termination.

Reporting Periods by Part: Part 9

Annual Report

The reporting period for an Annual report is the preceding calendar year.

Termination Report

The reporting period starts after the last day covered by your most recent financial 

disclosure report and ends on the date of your termination.

Annual/Termination Report

The reporting period for a combined Annual/Termination report is the preceding calendar 

year and the current calendar year up to the date of your termination.

Restricted Stock

Restricted stock is a grant to an employee of company stock that is subject to limitations 

on the employee’s ownership rights, such as the right to sell the stock, until the restricted 

stock vests. Specific terms, such as the vesting period and whether the employee will be 

paid dividends before vesting, are spelled out in an agreement between the employee and 

employer. Once the employee’s shares of restricted stock vest, the employee owns the 

stock without limitations and can sell it at any time. Generally, if an employee leaves the 

company before the restricted stock vests, the employee forfeits the unvested restricted 

stock.

Restricted Stock Unit (RSU)

A restricted stock unit (RSU) is a grant to an employee valued in terms of company 

stock. No actual stock is issued at the time of the grant. Instead, the grant of stock or its 
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cash equivalent is deferred until the restricted stock units vest, which is based upon a set 

date or an occurrence described in a restricted stock unit plan or agreement. Once the 

vesting requirement is satisfied, the company ordinarily distributes the shares or cash 

equivalent of the number of shares to the employee; however, the distribution may be 

deferred in some plans.

Generally, if an employee’s employment terminates before the employee has satisfied the 

vesting requirement, the restricted stock units are forfeited.

Schedule C Employee

An employee in a position that is excepted from the competitive service because of its 

policy-determining nature or because it involves a close and confidential working 

relationship with the agency head or other top appointed official. Persons with this type 

of appointment range from secretaries and chauffeurs to policy advisors.

Securities

For purposes of financial disclosure, the term “securities” would include such items as 

stock, corporate or municipal bonds, government agency securities, options, futures, 

mutual funds, exchange-traded funds, unit investment trusts, limited partnership interests, 

and other investment funds. It does not include cash accounts, life insurance policies, or 

annuities.

Self-Funded Defined Benefit Plan (pension)

Self-funded defined benefit pension plans are funded by individuals instead of employers. 

The individual invests money to meet a certain benefit amount in the future. The returns 

on the investments will fund the future benefits to be paid to the individual. If the 

investments do not perform as well as expected, the required contribution amounts will 

increase.

At retirement, participants often roll their balances into IRAs or purchase annuities; 

however, continued participation in the plan is possible as well.

Severance Payment

A severance payment is a payment for past services that is paid by an employer upon the 

departure of an employee. Severance payments may be pursuant to the employer’s 

standard policy or pursuant to an employment agreement with a specific employee.
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Short Sale

A short sale is the sale of securities that an investor has borrowed from a broker. The 

investor must eventually purchase an equal number of the same securities and return 

them to the broker.

• Open Position: When the investor acquires and subsequently sells the initial 

borrowed securities from the broker, but has not yet purchased the replacement 

securities, the investor is in an “open short position.”

• Closed Position: When the investor purchases the replacement securities and 

returns them to the broker, the investor is in a “closed position.”

Generally the investor’s goal is to purchase replacement securities at a price lower than 

the price at which the investor initially sold them. The investor will realize a profit as a 

result of this price discrepancy if the value of the securities decreases. However, the 

investor will lose money if the value of the securities increases before the investor 

purchases them. In either case, the investor pays interest on the loan.

Special Government Employee (SGE)

A special Government employee is defined at 18 U.S.C. § 202(a) as including an officer 

or employee of the executive branch, of any independent agency of the United States, or 

of the District of Columbia, who is retained, designated, appointed or employed by the 

Government to perform, with or without compensation, for not more than 130 days 

during any period of 365 consecutive days, temporary duties either on a full-time or 

intermittent basis. The term also includes a Reserve officer of the Armed Forces or an 

officer of the National Guard while on active duty solely for training, or if serving 

involuntarily.

The definition of SGE focuses on whether the employee was appointed to serve no more 

than 130 days of any consecutive 365-day period. At the time of appointment, the 

appointing official must determine whether the employee will be reasonably expected to 

work more than 130 days in the 365 days after the appointment date. Even if, contrary to 

expectations, the employee subsequently works more than 130 days in the 365-day 

period, the employee remains an SGE for the remainder of that 365-day period.

For additional information, see the memorandum issued by OGE DAEOgram DO-00-003 

and DO-00-003A (February 15, 2000).

Stable Value Fund

A stable value fund is an investment vehicle that is generally offered as an investment 

option in an employee benefit or retirement plan. Stable value funds typically invest in 

bonds and interest-bearing contracts. Some stable value funds are mutual funds that have 
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registered with the U.S. Securities and Exchange Commission, but not all stable value 

funds are registered mutual funds.

Stock

Stock shares represent an equity (ownership) interest in a corporation and entitle the 

holder to a claim on corporate assets and earnings.

Corporations issue two basic types of stock: common and preferred. Differences between 

the two types involve shareholder voting rights, dividend variability, price sensitivity, and 

the priority for payment of dividends and liquidation claims. For purposes of financial 

disclosure, these differences are ordinarily not significant, and there is no requirement to 

specify the type of stock on a disclosure report.

Stock Appreciation Right

A stock appreciation right is a contract between an employer and an employee that grants 

the employee the right to receive a payment tied to any increase in the value of the 

employer’s stock. When granting a stock appreciation right, the employer does not grant 

the employee any shares of the employer’s stock. Instead, the employer grants the 

employee a right that tracks the value of a specified number of shares over a specified 

period of time. The employer designates a “grant price,” and the employee will have a 

right in the future to receive a payout equivalent to the difference between the market 

price of the stock and the grant price.

If the value of the shares increases, the employee can exercise the stock appreciation right 

by requesting a payment equivalent to the increase in value of the shares. For example, if 

the employee has a stock appreciation right tied to 100 shares and the value of the shares 

increases by 50 cents per share, the employee may request a payment of $50. In some 

cases, the employer may let the employee elect to receive the payment in the form of $50 

worth of the employer’s stock at current market value.

Like stock options, a stock appreciation right typically has a vesting requirement and an 

expiration date. The employee may not exercise the stock appreciation right before it 

vests or after it expires. If the employee’s employment is terminated before the stock 

appreciation right vests, the employee normally forfeits the right.

Student Loan

A student loan is a loan given by a lender to a borrower for the purpose of paying 

education-related expenses.
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Sweep Account

For purposes of financial disclosure, a sweep account is a type of account in which funds 

over a predetermined average balance are automatically transferred (or “swept”) from the 

primary cash account into secondary investment accounts (often money market mutual 

funds). This allows the account owner to earn a higher interest on the excess cash with 

minimum personal intervention.

Often, public financial disclosure filers have sweep accounts within brokerage accounts 

that they use primarily for investing in stocks and other securities. Cash from sales of the 

stocks and other securities can be moved into the sweep account pending reinvestment.

Third-Party Escrow Agreement

For purposes of financial disclosure, we are referring to an escrow agreement that is 

designed to make funds available for the purchaser of a business that the filer has sold. 

The purpose of such an agreement would be to protect the purchaser against unforeseen 

liabilities or expenses that arise after the sale but stem from matters predating the sale. 

At the end of a specified period of time, any unused funds will be returned to the seller. 

The agreement is a purely negotiated (i.e., non-standard) item in connection with the sale 

of a business and, as such, will vary from case to case.

TIAA-CREF: Definition

TIAA-CREF (Teachers Insurance and Annuity Association of America – College 

Retirement Equities Fund) is a non-profit entity that provides a variety of financial 

services, including retirement plans.

TIAA-CREF holdings may consist of annuities, various forms of insurance, cash 

accounts, and mutual funds.

TIAA-CREF: How to Report a CREF Account or TIAA Real Estate

CREF accounts (e.g., “CREF Stock” or “CREF Money Market”) and TIAA Real Estate 

are variable annuity accounts that are offered as part of retirement plans.

Part 2 (for you) or Part 5 (for your spouse)

Report a CREF account or TIAA Real Estate if its value was more than $1,000 at the end 

of the reporting period or if it produced more than $200 in income during the reporting 

period.

Description: Provide the exact name of the asset held (e.g., “CREF Inflation-Linked 

Bond” rather than “CREF Fixed Income”).
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EIF: CREF accounts and TIAA Real Estate qualify as excepted investment funds (EIF).

Value: Select the category that corresponds to its value.

Income Amount: Select the category in the “Income Amount” column that corresponds 

to the amount of income produced during the reporting period. Do not include unrealized 

gains as income. If you are unable to ascertain the amount of income, you may write 

“income not readily ascertainable” in the “Description” field.

TIAA-CREF: How to Report TIAA Traditional

TIAA Traditional Annuity is a fixed annuity.

Part 2 (for you) or Part 5 ( for your spouse)

Report a TIAA Traditional Annuity if its value was more than $1,000 at the end of the 

reporting period or if it produced more than $200 in income during the reporting period.

Description: Write “TIAA Traditional Annuity.”

EIF: Select “N/A.”

Value: Select the category that corresponds to its value.

Income Type and Income Amount: Select the category in the “Income Amount” field 

that corresponds to the amount of income produced during the reporting period. If the 

income produced is more than $200, select “interest” for the type of income.

Trust (irrevocable)

An irrevocable trust is a trust from which assets cannot be removed, except as described 

in the trust document.

Trust (revocable living)

In a typical revocable living trust (sometimes called a “revocable inter vivos trust” or a 

“living trust”), the person who created the trust – often called the grantor, settler, or donor 

– transfers ownership of assets into a trust, which is managed by the trustee for the 

benefit of the trust’s beneficiaries. The grantor, who often serves as trustee, can revoke 

the trust and make other changes, such as substituting beneficiaries or taking assets out of 

the trust, at any time. The trust becomes irrevocable upon the grantor’s death. A 

revocable living trust is widely recognized as a will substitute.
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UGMA or UTMA Account

A Uniform Gifts to Minors Act (UGMA) or Uniform Transfers to Minors Act (UTMA) 

account is an account into which property is set aside for a minor’s benefit. Whether a 

UGMA or UTMA account is used depends on the state in which the account is 

established.

Transfers made to a UGMA or UTMA account are irrevocable and belong to the child in 

whose name the account is registered; however, the account is controlled by the custodian 

until the child reaches a certain age, which varies by state (usually 18 or 21).

Unit Investment Trust

A unit investment trust (UIT) is a type of investment company regulated under the 

Investment Company Act of 1940. A UIT buys a relatively fixed portfolio of securities 

and holds them with little or no change until the UIT’s termination date.

Vested Beneficial Interest

A “vested beneficial interest” is a legal concept. In a general way, saying that you have a 

vested beneficial interest in a trust means essentially that you are receiving or have a 

legal right to receive something from the trust. 

Ordinarily, an interest in an irrevocable trust that is “vested” under controlling state law 

will be “vested” for purposes of executive branch financial disclosure as defined in 

5 C.F.R. § 2634.310(a)(2). You may, therefore, wish to consult with the trustee or a 

personal attorney to determine whether your interest is vested under controlling state law 

when deciding whether to report such an interest. If you are still unsure as to whether an 

interest is reportable, you should consult with your agency ethics official.

You should note that OGE has issued specific guidance with respect to interests in 

discretionary trusts and revocable living trusts. If your interest is in what you believe to 

be a discretionary trust, see the “Income from Discretionary Trusts” section within the 

“Trust (irrevocable)” entry for further information. If your interest is in what you believe 

to be a revocable living trust, see the “Trust (revocable living)” entry.
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Appendix B: Frequently Asked Questions

FAQs: Annuity (fixed)

1. What do I select for the “Excepted Investment Fund” field?

A fixed annuity is not an investment fund and has no underlying holdings. Instead, a 

fixed annuity is a debt obligation of the issuing company. For this reason, select “N/A.”

2. How do I value a fixed annuity?

You may use the annuity’s face value, the company’s estimate of the current value, or the 

value of premiums paid plus accrued income.

FAQs: Award or Prize

1. I own a frog that won the prize in a jumping contest in Calaveras County. 

Do I report the winnings?

Yes.

2. I won a prize for public service. Do I report the winnings?

Yes.

FAQs: Bond (corporate)

1. If the bond matured and was redeemed during the reporting period, 

should I still report the bond?

In that event, the bond is reportable if it produced more than $200 in income (usually 

interest income) during the reporting period. If the bond has already matured, the value 

will be “None (or less than $1,001).” (Note that, if you sold the bond before its maturity 

date, you may have both interest and capital gains to report.)

2. I’m not sure how to calculate the income from a corporate bond. Do you

have a suggestion?

Filers are required to make a good faith effort to calculate the amount of interest 

produced. You may find the information in an IRS Form 1099 or in a brokerage account 

statement. Otherwise, you may be able to estimate the amount of interest during a 

reporting period by apportioning the difference between purchase price and maturity 

value over the bond’s term. (It is not sufficient to state a bond’s series or interest rate.)
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FAQs: Bond (municipal)

1. What are municipal bonds?

Municipal bonds, often called munis, are debt obligations of states, cities, counties, or 

other political subdivisions of states in the United States.

Two common types are:

• General obligations (GOs), used for general expenditures and backed by the 

issuer’s full faith and credit (taxing and borrowing power); and

• Revenue bonds (REVs), used to finance specific public service projects and 

backed by cash flow from those projects. Examples are bonds to finance bridges, 

turnpikes, tunnels, water and sewer systems, schools, power plants, prisons, 

transportation systems, hospitals, sports complexes, and airports.

Like other debt obligations, municipal bonds may be issued at a discount as zero 

coupons. They may also be stripped like Treasuries and sold and backed by investment 

brokers.

2. What are some other varieties of municipal securities?

Other varieties of municipal securities include tax bonds, tax anticipation notes (TANs), 

and revenue anticipation notes (RANs), which are obligations sold in anticipation of 

general or specific tax receipts or other income that the issuing government entity expects 

to collect.

3. How are industrial development bonds different from other types of 

municipal bonds?

As a means of attracting business to a community, a local government may issue a type 

of revenue bond called an industrial development bond (IDB), to finance construction of 

facilities for lease to a private corporation. The private company backs these securities, 

so the bond holder has a financial tie to that company, as well as to the issuing 

government authority.

4. How do I value a municipal bond?

You may use any one of the following options:

• the bond’s maturity value;

• the value as shown on an account statement at the end of the reporting period;

• the current market value as reported in daily newspapers; or

• a good faith estimate if the exact value is unknown or not easily determined.
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FAQs: Bonus

1. I received salary and a cash bonus from the same source. Can I combine 

these?

Yes. Write the phrase “salary and bonus” in the “Income Type” field. Be sure to provide 

the combined amount of your salary and bonus. However, you may not combine salary 

and a bonus receivable (i.e., a bonus you have not yet received). Also, do not combine 

salary and a bonus in the form of stock options, restricted stock or other equity. Do not 

combine salary and deferred compensation.

2. I received my bonus in the form of stock options. How should I report 

this?

Follow the instructions for an incentive stock option.

3. I have an outstanding bonus that I have not yet received. Do I have to 

receive this bonus prior to beginning government service?

A non-discretionary bonus may pose no issue. In some cases, however, the answer to this 

question may depend on an analysis of a criminal statute, 18 U.S.C. § 209. The payment 

also may implicate 5 C.F.R. § 2635.503. If you have an outstanding bonus that you have 

not received, you should be sure to discuss this issue with your ethics official before you 

receive the payment.

FAQs: Brokerage Account

1. Why doesn’t my brokerage account qualify as an excepted investment 

fund?

A brokerage account is not an investment fund, which means that the account can never 

be an excepted investment fund. In addition, most brokerage accounts would not satisfy 

the various elements of the excepted investment fund test, even if they were investment 

funds.

FAQs: Cash Account

1. I have several cash accounts at a local bank. How should they be listed 

in my report?

Aggregate any cash accounts you have in a single financial institution and report them in 

Part 6 if they exceed $5,000. For example, if you have $2,000 in a money market 

account, $3,500 in a savings account, and a $5,000 certificate of deposit in Commerce 

Bank, identify the assets as “U.S. bank accounts (cash)” in Part 6. Select a category of 

value for the aggregate value of the accounts. In the example above, the aggregate value 
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is $10,500, so you would select the “$1,001 - $15,000” category. You would also select 

a category of value for the amount of income earned as interest by the accounts during 

the reporting period.

2. What is the difference between a money market account and a money 

market fund?

A money market account is treated as a cash account for filing purposes. A money 

market fund is a type of mutual fund (see the “Money Market Fund” entry).

3. How do I report a sweep account?

Report the sweep account as “U.S. brokerage account (cash).”

4. Do I need to report my checking account?

You need to report an interest-bearing checking account in the same manner that you 

would report other cash accounts.

5. I have physical holdings of cash in a safe deposit box. Do I report that?

You do not have to report currency held in the form of paper currency or coins, unless the 

currency constitutes a collectible held for investment or the production of income.

FAQs: Collectible Item

1. How do I know whether a collectible item is “held for investment 

purposes”?

Household furnishings and paintings displayed for decorative or artistic purposes would 

not normally be considered collectible items held for investment. However, periodic 

sales from a collection of artwork would indicate that the collection is held for investment 

purposes.

If you are unsure whether a collectible item is held for investment purposes, consult your 

ethics official.

2. How do I value a collectible item?

You may use the purchase price, a recent appraisal for insurance purposes, a published 

price guide, the recent sale price of similar items, or a good faith estimate.
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FAQs: Contingency Fee

1. Can I enter into an agreement with my law firm to receive a portion of 

contingency fees in a case in which the United States is a party or has a 

direct and substantial interest?

No. Government employees are precluded by federal criminal law from keeping an 

interest in such cases.

FAQs: Deferred Compensation

1. Am I permitted to receive a payment of deferred compensation after I 

enter government service?

The answer to this question depends on your personal circumstances. However, the one 

answer that applies to all filers is that you should seek advice from an agency ethics 

official before receiving the payment.

2. What if the terms of my separation have not been finalized and will affect 

what I receive under the deferred compensation plan?

In most cases, you will need to finalize these terms before completing your financial 

disclosure report and before entering government service. You also should obtain advice 

from your agency ethics official. It is important that you contact your agency ethics 

official as soon as possible to learn about any ethics laws that will be applicable to your 

deferred compensation payment after you enter government service.

3. What if my agency decides that I must exit a deferred compensation plan 

to resolve a conflict of interest under the government’s ethics laws, but my 

employer raises concerns about compliance with 26 U.S.C. § 409A 

(sometimes referred to as “409A”)? 

Neither the U.S. Office of Government Ethics nor your agency’s ethics officials can 

provide you (or your employer) with tax advice. You may want to consult with your tax 

advisor. In that case, you may want to ask your tax advisor whether 26 C.F.R. § 1.409A3(j)(4)(iii) is relevant to your situation. (This answer was drafted in 2011.)

FAQs: Defined Benefit Plan (including cash balance pension 

plan)

1. Do I report my defined benefit plan with the United States Government?

No. You do not need to report participation in a United States Government retirement 

plan (e.g., CSRS).
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FAQs: Defined Contribution Plan (including a money purchase 

pension plan)

1. Do I report my federal Thrift Saving Plan (TSP) account?

No. Do not report participation in a United States Government retirement plan.

2. I was not required to report my defined contribution plan in Part 2 

because all of the underlying assets were below the value ($1,000) and 

income reporting thresholds ($200). Do I still report my defined 

contribution plan in Part 3?

Yes. Part 2 and Part 3 have different and independent reporting thresholds. Continued 

participation in a defined contribution plan is reportable in Part 3 regardless of the value 

of the underlying assets.

3. All of the underlying assets of my defined contribution plan are below 

the value and income reporting thresholds; however, I still want to report 

the plan in Part 2. How would I do that?

This over reporting is not necessary. However, you would report this plan, as follows:

Description: Provide the name of the employer. Write “defined contribution plan” or 

specify the type of defined contribution plan, such as “401(k)” or “403(b).” Following 

that general description, write “underlying assets below reporting thresholds.”

Value: Select the category that corresponds to the value of your interest in the overall 

plan.

Income Type: If the total amount of income produced during the reporting period is 

more than $200, specify the type(s) of income. Otherwise, leave this field blank.

Income Amount: Select the category corresponding to the total amount of income 

produced.

FAQs: Director Fee

1. Do I report my annual director fees or the total amount of income from 

director fees received during the reporting period?

Report the total amount of income from director fees that you received during the entire 

reporting period, not just the amount that you received in a calendar year.
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2. What if I am paid in equity or an equity-related interest, rather than in 

cash?

Report the equity or equity-related interest that you hold. In the “Description” field, 

indicate that the asset was paid to you as compensation for your board service:

Wilson Widgets stock 

(compensation for board service)

In the “Value” field, report the value of this asset. In the “Income Type” and “Income 

Amount” fields, report any dividends or capital gains accrued or received as a result of 

your ownership of this asset.

Normally, you do not need to report the value of the asset a second time in the “Income 

Amount” field, even if you paid “ordinary income” tax upon receipt or vesting of the 

asset. However, if you have already sold, forfeited or otherwise disposed of the asset, 

report the director fees as income by reporting the value of the payment of this asset in 

the “Income Amount” field and by identifying the payment as “director fees” in the 

“Income Type” field. This will ensure that the form captures your receipt of the asset, 

even if you no longer hold it.

3. What if my director fees are deferred?

Report your financial interest in these deferred fees as a receivable. In the “Description” 

field, describe the nature of your financial interest as “deferred director fees” and 

specifically identify the form that the fees will take (e.g., “receivable: Wilson Widgets 

stock,” “cash receivable,” etc.). In the “Value” field, report the value of this financial 

interest. Leave the “Income Type” field blank and select “None (or less than $201)” in 

the “Income Amount” field because you have not yet received this payment, unless you 

have received dividends or similar payments (e.g., dividend equivalent units).

Wilson Widgets, deferred director fees:

stock equivalent units

Normally, you do not need to report the value of the asset a second time in the “Income 

Amount” field. However, if you have already sold, forfeited or otherwise disposed of 

this financial interest, report the director fees as income by reporting the value of the 

payment of this asset in the “Income Amount” field and by identifying the payment as 

“director fees” in the “Income Type” field.

4. What if my director fees take a different form than those discussed in 

Questions 2 and 3, above?

If you have questions about how to report a complex financial arrangement such as this, 

contact your agency’s ethics official for guidance. Also, you may be able to extrapolate 

the proper reporting method from the answers to Questions 3 and 4. The most important 

thing is to be sure the financial interest or the director fee is captured in some way on the 
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report. Later, your ethics official can work with you to ensure proper reporting before 

you finalize your report.

FAQs: Employee Stock Purchase Plan

1. The sale of stock that I purchased under my company’s employee stock 

purchase plan produced ordinary income. How do I report that income?

Generally, the sale of stock would produce a capital gain or loss. However, in some 

situations, the sale of stock acquired through an employee stock purchase plan may 

produce ordinary income as well.

In these cases, report the exact amount of ordinary income in the “Income Amount” field. 

Describe the income in the “Income Type” field as “option exercise, ordinary income” 

and identify the stock by name.

FAQs: Exchange-Traded Fund (ETF)

1. What is an excepted investment fund (EIF)?

The following link will take you to a definition for “excepted investment fund”: click 

here.

2. Am I required to provide a ticker symbol?

Providing a ticker symbol will expedite the approval of your report, but a ticker symbol is 

not required if you are unable to find the ticker symbol. Do not forget to provide the fund 

family name (e.g., Vanguard, Fidelity, iShares, etc.).

FAQs: Farm (or farmland)

1. Should I report the exact number of acres, average bushels of a 

particular crop, or the number (head) of livestock?

No, you do not need to report that information.

2. Should I report loans to me or the farm that are directly related to 

farming activities?

No, you do not need to report the liabilities of a farm, unless the liabilities are unrelated 

to the operations of the farm.
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3. Should I report a mortgage on farmland?

If you are receiving rent from farmland that you hold directly, report any mortgage that 

you owe on the farmland in Part 8. By contrast, you do not need to report a mortgage 

that you owe on farmland used as part of your farming business.

FAQs: Foreign Exchange Position (“forex”)

1. I traded currency futures as well. Should I report those positions as 

foreign currency?

If you traded currency futures, you should refer to the “Futures Contract” entry for 

examples and instructions on how to report a futures position. Similarly, see the 

“Option” entries for instructions on how to report currency options.

2. If I have income from a profitable currency trade and I have received 

interest income on the position, how do I report this income?

Aggregate the profit and the interest income and, if the total is greater than $200, select 

the appropriate “Income Amount” category. Also, select the “Income Type” categories 

corresponding to capital gains and interest income.

3. If I engaged in a series of trades involving the same currency pair, can I 

aggregate them in a single entry in my financial disclosure report for that 

currency pair?

Yes. You may aggregate all positions for the same currency pair and treat them as a 

single entry in your financial disclosure report. If you have a series of closed positions 

and still maintain open positions, remember to select the category of value that 

corresponds to the value of the open positions.

4. I have a foreign bank account (i.e., deposit account denominated in a 

foreign currency). How do I report that account?

Follow the instructions for cash accounts in this guide.

5. I have physical holdings of foreign currency in a safe deposit box. How 

do I report that?

You do not have to report foreign currency held in the form of paper currency or coins, 

unless the currency constitutes a collectible held for investment or the production of 

income (e.g., rare coins).

6. I have an interest in a currency swap. How do I report this?

The reporting requirements will depend on the exact nature of the interest. Please consult 

your agency ethics official for additional guidance.
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7. Do I report transactions for my foreign exchange positions?

Yes, if you are filing an Annual or Termination report. Report a transaction involving a 

foreign exchange position in Part 7. In the interests of clarity, OGE recommends that you 

leave the “Type” field blank and instead specify the type of transaction by writing 

“opened position” or “closed position” in the “Description” field.

FAQs: Futures Contract

1. How should I value my futures contracts?

You could value your futures position as the fair market value of the underlying 

commodities. This would equate to the closing price of the future multiplied by units of 

the underlying commodity multiplied by the number of contracts you control.

If fair market value information is not readily available, you may choose to provide the 

following information in the “Description” field: (1) the contract month and year; (2) the 

number of contracts you control; (3) the closing price of the future; and (4) the notation 

“(value not readily ascertainable).” For example, you could write, “Silver futures (value 

not readily ascertainable): December 2013, 10 contracts, 32.20/oz.”

2. What do I report for income?

Income from futures will take the form of capital gains and should be reported by 

selecting “capital gains” in the “Income Type” field. Although you will realize your 

actual gains or losses only upon exiting your futures position, our understanding is that 

the income gain or loss associated with a position is calculated daily by your brokerage 

firm for tax purposes. Use the capital gains value amount provided by your broker to 

determine the applicable income amount category in the “Income Amount” field.

3. I have an interest in several forward contracts. How do I report this 

interest?

Although similar to futures contracts, forward contracts are not exchange-traded and do 

not have standard terms. The reporting requirements, therefore, will depend on the exact 

nature of the forward contracts. Please consult your agency ethics official for additional 

guidance on how to report your forward contracts.

4. Do I report transactions for my futures trading?

Yes, if you are filing an Annual or Termination report. Report a futures transaction in 

Part 7. In the interest of clarity, OGE recommends that you leave the “Type” field blank 

and instead specify the type of transaction by writing “opened position” or “closed 

position” in the “Description” field.
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FAQs: Future Employment Arrangement

1. What if my arrangement is not a formal agreement?

If you have any sort of arrangement for prospective future employment, formal or 

otherwise, it is very important that you discuss this arrangement with your agency’s 

ethics officials because such an arrangement is likely covered by the primary federal 

criminal conflict of interest statute, which means you may need to take certain steps to 

avoid conflicts of interest that are subject to criminal penalties. You also would report 

any such arrangement in Part 3 of your financial disclosure report.

FAQs: Gambling Winnings

1. In valuing my winnings or in determining whether the winnings meet the 

reporting threshold, may I subtract amounts that I lost?

No. Report the exact gross amount of any winnings over $200 that you received 

regardless of the amount you lost.

2. I won a car in a raffle. How do I report that?

In the “Income Type” field, write “raffle winnings” and provide the fair market value of 

the new car in the “Income Amount” field. You may elect to identify the item won as a 

car in the “Description” field, but you need not do so.

FAQs: Gifts and Travel Reimbursements

1. How do I value a gift?

Report the fair market value of the gift. For financial disclosure purposes, this is the 

retail cost to buy the gift in the metropolitan area nearest your office. If you cannot find 

the market value of the same item, you may estimate its value by referencing the retail 

cost of similar items of like quality. If items of like quality are not readily available in 

the market, you may make a good faith estimate.

2. Why are the reporting thresholds set at $156 and $390?

The Ethics in Government Act ties the reporting thresholds for gifts and travel 

reimbursements to the definition of “minimal value” for purposes of gifts under the 

Foreign Gifts and Decorations Act (5 U.S.C. § 7342(a)(5)). The General Services 

Administration redefines “minimal value” under the Foreign Gifts and Decorations Act 

every three years.
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3. How do I value a gift of free attendance at an event?

If the event is ticketed, use the face value of the ticket. You may exclude the value of 

food and beverages so long as free attendance was not given in connection with a gift of 

overnight lodging.

If the event was not ticketed, use the per-person cost of the event. The U.S. Office of 

Government Ethics issued a memorandum in 2007 that specifically addressed the 

valuation of free attendance in a skybox or private suite. See OGE DAEOgram DO-07-

003 (February 9, 2007).

You may wish to consult an ethics official at your agency for additional guidance.

4. Do I report travel reimbursements for official travel?

No. However, report any travel payments received under the Government Employees 

Training Act (5 U.S.C. § 4111).

5. Three people contributed to a single gift worth $400. Do I have to report 

that gift?

Yes. A gift from a group of individuals is considered a gift from a single source for 

purposes of the $390 and $156 thresholds. You, therefore, cannot apportion the value of 

the gift among the three donors and use the $156 exception. List each person in the 

“Source Name” column and report the total value of the gift.

6. I received four tickets to an event. Each ticket has a face value of $100. 

Do I have to report the tickets as a single gift worth $400 or can I exclude 

the tickets from reporting because each ticket is worth less than $156?

Report the tickets as a single gift.

7. Gifts from relatives are not reportable. Who counts as a “relative”?

The Ethics in Government Act defines the term “relative” for purposes of financial 

disclosure (5 U.S.C. app. § 109(16)). The term includes people related to you as: father, 

mother, son, daughter, brother, sister, uncle, aunt, great uncle, great aunt, first cousin, 

nephew, niece, husband, wife, grandfather, grandmother, grandson, granddaughter, 

father-in-law, mother-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, 

stepfather, stepmother, stepson, stepdaughter, stepbrother, stepsister, half brother, half 

sister, or who is the grandfather or grandmother of your spouse. The term also includes a 

fiancé or fiancée.

8. What qualifies as a “suitable memento” of a function honoring me?

The reporting exclusion for “suitable mementos of a function honoring the reporting 

individual” covers items that serve to remind you of the event, whether a mere souvenir 

or something with utilitarian purpose. It is not limited to items of nominal intrinsic value 
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because the basic gift reporting threshold already excludes items worth no more than 

$156, or $390 in the aggregate from a single source. An “honoring function” might 

include a retirement party, personal achievement dinner, or other similar event.

Despite its apparently broad scope, however, this reporting exclusion for mementos is 

limited by the term “suitable.” Whether a memento is “suitable” to a particular function 

depends on the circumstances surrounding the event, such as the types of gifts 

traditionally given or considered appropriate on such occasions, your position and 

relationship to the donors, the number of donors, and the gift’s significance to the 

occasion.

Because the applicability of this exclusion depends on the particular circumstances, you 

may wish to consult with your agency ethics official for additional guidance.

9. My spouse has been invited to a work-related event, and I will attend as 

my spouse’s guest. Do I have to report this gift?

Gifts given to your spouse because of your spouse’s employment or other activities may 

sometimes benefit you. This might occur, for example, when your spouse’s employer 

sponsors an event to which its employees may bring a spouse or other guest. You do not 

need to report these gifts so long as the donor did not target the gift to you specifically or 

to you as a United States Government employee.

10. A prospective employer has paid for my travel to an interview. Do I 

have to report the travel arrangements as a gift or reimbursement?

Yes, if the travel arrangements meet the disclosure requirements of the general rules for 

gifts and travel reimbursements. There is no specific reporting exclusion for items 

received from a prospective employer.

11. Do I report gifts received by a legal defense fund established for my 

benefit?

Yes. Report gifts to a legal defense fund totaling more than $390 from a single source 

that were received during the reporting period for a fund established for your benefit. 

Aggregate all reportable donations from the same source and report if the total exceeds 

$390.

Source Name City/State Brief Description Value

Matthew Jones Encinitas, 

CA

Cash donation to the Audrey Duke Legal Defense Fund $400

Source Name: Provide the identity of the source of the gift to the legal defense fund.

City/State: Provide the source’s city and state of business or residence.
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Brief Description: Describe the nature of the gift and specify the fund to which the 

donation was made. 

Value: Provide the fair market value of the gift(s). If the gift is a cash donation, provide 

the exact amount. 

12. Do I report gifts distributed to me by a legal defense fund that was 

established for a small class of recipients?

Yes. Report gifts totaling more than $390 that were distributed to you during the 

reporting period by a legal defense fund that was established for a small class of 

recipients. The gift may be reported in such a manner provided that there is independent, 

public reporting by the fund of donations to the fund totaling more than $390, including 

donor names, the city/state of the donors, and the value of the donations.

Source Name City/State Brief Description Value

Washington Legal 

Defense Fund 

Washington, 

DC

Cash distribution from the Washington Legal Defense Fund.

Individual donors to this fund are listed at [website address]

$800

Source Name: Provide the name of the legal defense fund.

City/State: Provide the source’s city and state of business or residence.

Brief Description: Describe the nature of the gift and provide a description of where to 

locate additional reporting information. 

Value: Provide the fair market value of the gift(s). If the gift is a cash distribution, 

provide the exact amount.

FAQs: Honorarium

1. I received a $150 honorarium from a university in June of this year and a 

$100 honorarium from the same university in August of this year. Are 

these honoraria reportable?

Yes. The honoraria are reportable because the aggregate amount is greater than $200 

from the same source during the reporting period. 

2. How do I treat travel expenses that were paid for by a source?

In calculating the amount of an honorarium, subtract any actual and necessary travel 

expenses incurred by you and one relative. For example, if the expenses were paid for or 

reimbursed by the source, do not count the payment/reimbursement as part of the 

honorarium that you are reporting in Part 2.
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If you paid the expenses without reimbursement, subtract these expenses from the 

amount of the honorarium that you are reporting in Part 2.

For purposes of this rule, “travel expenses” means the cost of transportation and the cost 

of lodging and meals.

3. Do I count my agent’s fees when calculating my honorarium?

No. You may subtract agent’s fees.

4. Do I report payments that I donated or directed to charity?

Yes. If you wish, you may note that the payment was donated or directed to charity in 

Part 2.

5. How do I report honoraria that I received through a speakers’ bureau?

Report each source of honoraria in excess of $200 as a separate line entry in Part 2. For 

example, if you gave $500-speeches at three universities through ABC Speakers’ Bureau, 

report all three sources in Part 2.

6. How do I report honoraria that I received through my limited liability 

company?

Report each source of honoraria in excess of $200 as a separate line entry in Part 2. For 

example, if you gave $500-speeches at three universities through Smith Appearances, 

LLC, report Smith Appearances, LLC, and all three sources in Part 2.

7. I am an employee of an organization. I gave a speech at an event on 

behalf of the organization, and the organization was paid for providing a 

speaker. The payment was income of the organization and not my 

personal income. Accordingly, I did not pay taxes or take a deduction 

related to this payment. Do I need to report this payment in Part 2 of my 

financial disclosure report, as an honorarium or as any other form of 

income?

Under these specific circumstances, you do not need to report the payment as an 

honorarium or as any other form of income in Part 2. As you explained, this payment 

was income of the organization and not your personal income.

If you are a Nominee or New Entrant filer, you report this payment in Part 4, which 

collects information about payments made to your employer for your personal services, if 

the total amount received by the employer exceeded $5,000 in a calendar year during the 

reporting period. (Note: Annual and Termination filers do not complete Part 4.)

Note, however, that the answer is different if the organization is a flow-through entity, 

such that you eventually receive the payment indirectly through the entity. In that case, 

you would be required to report the payment in Part 2 and Part 4. Likewise, in the case 
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of a speakers’ bureau that accepts the payment and later pays you all or substantially all 

of the payment, you are required to report the payment in Part 2 and Part 4.

FAQs: Intellectual Property

1. I created a LLC to hold all of the copyrights on my books. Do I just 

report the LLC or do I need to itemize each book? 

Report your LLC on one line in Part 2 and then report each book on a separate line 

underneath the LLC.

FAQs: Investment Fund (general)

1. The investment fund is not an excepted investment fund, but all of its 

underlying assets are below the dollar thresholds for reporting (i.e., $1,000 

in value or $200 in income). How should I report this investment fund?

Description: Provide the name of the fund and, unless clear from the name, describe the 

type of asset (e.g., “hedge fund,” “stable value fund,” “venture capital fund,” etc.).

After the description of the investment fund, write “underlying assets below reporting 

thresholds.”

EIF: Select “N.”

Value: Select the category that corresponds to the total value of your interest in the 

investment fund.

Report the income in the “Income Type” and “Income Amount” fields. See Question #2 

for more information on reporting income.

2. Do I provide the exact amount of income or do I select a category of 

income in the “Income Amount” field?

In the “Income Type” and “Income Amount” fields, you generally would report all 

income produced during the reporting period. But what you enter depends on several 

factors:

• Income less than $201: Select the “None (or less than $201)” category in the 

“Income Amount” field. You do not need to specify the type of income.

• Excepted investment fund: If the asset qualifies as an excepted investment fund, 

select the “Income Amount” category that corresponds to the amount of income 

produced by the asset during the reporting period. You do not need to specify the 

type of income.
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• Dividends, capital gains, interest, rent, or royalties: If the income from the asset 

can be classified as dividends, capital gains, interest, rent, or royalties, select all 

applicable types of income in the “Income Type” field, unless the asset is an 

excepted investment fund. Also, select the category in the “Income Amount” 

field corresponding to the total amount of income you received during the 

reporting period.

• Other income: Describe the type of income in the “Income Type” field (e.g., 

“partnership share” or “distribution”). Also, in the “Income Amount” field, 

provide the exact amount of income produced during the reporting period, instead 

of selecting a category for the amount of income.

3. The fund in which I invest does not qualify as an excepted investment 

fund; however, it will not provide information about the underlying assets 

to me. How do I satisfy the reporting requirements for this fund?

Please consult with your ethics official for guidance specific to your situation.

In general, an agency may certify a report if the agency is satisfied that the filer has made 

a good faith effort to obtain the required information and that the potential for conflicts 

has been addressed. If you are a nominee to a full-time position requiring Presidential 

appointment and Senate confirmation (PAS), you will need to provide a letter from the 

fund stating that the fund will not disclose the underlying assets. You also need to note 

the following in the “Description” field for the entry: “Underlying assets are not 

ascertainable.” See OGE Legal Advisory LA-14-05 (September 30, 2014).

4. The fund in which I invest does not qualify as an excepted investment 

fund; however, I am bound by a confidentiality agreement from releasing 

information regarding the underlying assets. How do I satisfy the reporting 

requirements for this fund?

Please consult with your ethics official for guidance specific to your situation.

In general, an agency may certify a report if the agency is satisfied that the filer is unable 

to disclose the information publicly due to a preexisting confidentiality agreement and 

that the potential for conflicts has been addressed. If you are a nominee to a full-time 

position requiring Presidential appointment and Senate confirmation (PAS), you will 

need to agree to divest the fund after confirmation. You also need to note the following 

in the “Description” field for the entry: “Underlying assets are not disclosed due to a 

preexisting confidentiality agreement. I will divest this asset if confirmed.” See OGE 

Legal Advisory LA-14-05 (September 30, 2014).

5. I am filing a New Entrant report in March 2016, so I report income for 

2015 and 2016 up to the date of my filing. However, the only statement of 

income that I receive from the fund is an annual K-1 and I have not yet 

received that document for 2015. How should I calculate the income for 

2015 and for the period January through March of 2016?
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In those special cases where you cannot reasonably obtain income information, you are 

permitted to provide a good faith estimate. Given the facts presented above, a good faith 

estimate for 2015 might be your K-1 income for 2014 and a good faith estimate of your 

2016 income might be a pro-rated portion of 2014 income. Whatever method you use for 

arriving at a good faith estimate, it is recommended that you provide a brief note 

explaining the method.

6. Can I list the underlying assets of the investment fund in an endnote?

Yes. However, you must provide the total value of the investment in the fund and the 

total amount of income produced on the OGE Form 278e itself. In addition, if an 

underlying asset is a privately held company, report the line of business of the company 

in the endnote. If an underlying asset is another investment fund, indicate whether it is an 

excepted investment fund (EIF). If it is not an EIF, report the underlying assets.

FAQs: Law Firm (partnership)

1. I am a non-equity partner at my firm. What do I report in Part 2?

Report the income that you have received and any anticipated payments in Part 2. In the 

“Description” field, note that you are a non-equity partner. Report the exact amount of 

income received in the “Income Amount” field and provide an appropriate description of 

the type of income in the “Income Type” field.

FAQs: Leave of Absence

1. My leave of absence is for two years. What if my employer offers to 

extend my leave of absence beyond the initial two years?

Extensions of leaves of absence should be discussed with your agency’s ethics office. In 

many cases, additional leaves of absence or extended leaves of absence do not require 

additional ethics arrangements.

2. As a university employee, I pay a reduced rate of tuition for my children. 

Do I report this continuing benefit? Will government ethics rules prevent 

me from continuing to receive a reduced tuition rate from the university 

while I am in the government?

This reduced tuition benefit is a continuing agreement or arrangement with the university. 

Describe this benefit in Part 3. In the normal case, you do not need to report this benefit 

in Part 2. You will need to coordinate with your agency’s ethics office to determine 

whether this benefit presents any ethics issues.

Standard employee benefits usually are permissible if consistent with the university’s 

policy or practice for leaves of absence. Any nonstandard terms or benefits will 
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necessitate further analysis by an ethics official to determine whether the benefits are 

permissible. Whether your benefits are standard or nonstandard, you should discuss them 

with your ethics officials.

In addition, you will not be permitted to participate as a government official in certain 

matters affecting your university. More specifically, whether or not the benefit is 

standard, you will not be permitted to participate as a government official in any 

particular matter that will directly and predictably (1) have a “special or distinct effect” 

on your university, other than as a class of universities, or (2) have an effect on the 

university’s ability or willingness to continue providing this benefit to you. Your agency 

ethics official will be able to discuss conflicts of interest with you in detail.

3. As a tenured faculty member, I receive a housing subsidy. Do I report 

this subsidy? Will government ethics rules prevent me from continuing to 

receive this subsidy while I am in the government?

The housing subsidy is a continuing agreement or arrangement with the university. 

Describe this benefit in Part 3. In the normal case, you do not need to report this benefit 

in Part 2. You will need to coordinate with your agency’s ethics office to determine 

whether this benefit presents any ethics issues.

Standard employee benefits usually are permissible if consistent with the university’s 

policy or practice for leaves of absence. Any nonstandard terms or benefits will 

necessitate further analysis by an ethics official to determine whether the benefits are 

permissible. Whether your benefits are standard or nonstandard, you should discuss them 

with your ethics officials.

In addition, you will not be permitted to participate as a government official in certain 

matters affecting your university. More specifically, whether or not the benefit is 

standard, you will not be permitted to participate as a government official in any 

particular matter that will directly and predictably (1) have a “special or distinct effect” 

on your university, other than as a class of universities, or (2) have an effect on the 

university’s ability or willingness to continue providing this benefit to you. Your agency 

ethics official will be able to discuss conflicts of interest with you in detail.

4. As part of my employee benefit package, I have a reduced interest 

mortgage arrangement with my university. Do I report this arrangement? 

Will government ethics rules prevent me from continuing to participate in 

the university’s reduced interest mortgage program?

This is a continuing agreement or arrangement with the university. Report the mortgage 

in Part 3 and Part 8. You do not need to report this benefit in Part 2. You will need to 

coordinate with your agency’s ethics office to determine whether this benefit presents any 

ethics issues.

Standard employee benefits usually are permissible if consistent with the university’s 

policy or practice for leaves of absence. Any nonstandard terms or benefits will 
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necessitate further analysis by an ethics official to determine whether the benefits are 

permissible. Whether your benefits are standard or nonstandard, you should discuss them 

with your ethics officials.

In addition, you will not be permitted to participate as a government official in certain 

matters affecting your university. More specifically, whether or not the benefit is 

standard, you will not be permitted to participate as a government official in any 

particular matter that will directly and predictably (1) have a “special or distinct effect” 

on your university, other than as a class of universities, or (2) have an effect on the 

university’s ability or willingness to continue providing this benefit to you. Your agency 

ethics official will be able to discuss conflicts of interest with you in detail.

FAQs: Liabilities

In answering the questions below, we have assumed that the liability at issue exceeded 

$10,000 at some point time during the reporting period. Otherwise, the liability would 

not be reportable.

1. Do I have to report a mortgage on my vacation home?

A mortgage on your vacation home is treated like a mortgage on your primary home. 

Follow the guidance for mortgages that is provided on the main “Liabilities” page.

2. Do I have to report a revolving home equity line of credit if my personal 

residence serves as collateral for the loan?

An exercised line of credit secured by your personal residence is treated like a mortgage. 

Follow the guidance for mortgages that is provided on the main “Liabilities” page. You 

do not need to report a line of credit that has not been exercised.

3. Do I have to report a loan against my IRA or retirement plan?

No.

4. Do I have to report a loan against the cash value of my life insurance 

policy?

No.

5. Do I have to report loans taken out by a business I own?

You do not have to report the liabilities of a business, unless those liabilities are unrelated 

to the operations of the business.

6. What if I have paid off a liability?
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You still report the liability. If you wish, you may indicate that you have paid off the 

liability in your description of the liability in the “Type” column, but you are not required 

to indicate that you have paid off the liability.

The reporting rules for revolving charge accounts, such as credit card balances, are 

different from all other liabilities. You do not have to report credit card debt if you paid 

off the debt before the close of the reporting period. For a Nominee, New Entrant or 

Candidate report, the reporting period ends on the date on which you file the report.

7. Do I have to report personal loans from relatives?

It depends. The relevant statutory provision is somewhat complicated. You do not need 

to report personal liabilities that (a) you, your spouse, or your dependent child owe 

(b) to a spouse, child, parent, or sibling of (c) you, your spouse, or your dependent child.

Personal loans from other relatives are reportable. However, if you received the loan 

from a close relative or a family trust, you may write “family member” or “family trust”

in the “Creditor Name” column.

8. Do I have to report a personal loan from a close friend?

Yes, personal loans from friends are generally reportable.

9. Do I have to report a loan on which I co-signed?

If you are only a guarantor on a loan, such as a car loan for your child and you have no 

present legal obligation to repay that loan, then you do not have to report the loan as a 

liability. However, if by co-signing the loan you have created a current legal obligation 

to repay regardless of whether the person with whom you co-signed defaults on the loan, 

then report the loan.

10. Do I have to report any additional information for a current debt 

stemming from a co-signed loan?

Yes. Identify the co-signor in the “Type” column. If the party is a close relative, identify 

the party as a “family member” (e.g., “co-signed loan for family member”). Otherwise, 

provide the party’s name (e.g., “co-signed loan for Wilson Widgets”).

11. Do I have to report a debt that I dispute I owe?

You should consult with your ethics official in order to determine whether or not the 

disputed debt is reportable.

12. Do I have to report taxes I owe?

You never have to report taxes that you owe for the current year. In some cases, you may 

have to report overdue taxes. In the event of overdue taxes, you should talk to your 

ethics official about reporting requirements.
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13. Do I have to report a tax liability that is being enforced through a lien 

that has been placed on my personal residence?

Yes. A tax lien is significantly different from a mortgage so the reporting exception for a 

mortgage on a personal residence does not apply.

14. Where can I find the interest rate on my margin account?

This information should be available in your margin agreement.

15. Do I have to list the securities purchased through a margin account?

You do not need to list the securities in Part 8.

However, you would report in Part 6 securities that have a value of more than $1,000 or 

that produced more than $200 during the Part 6 reporting period.

16. Do I have to report all capital calls?

Usually, yes. You have to report capital calls that you would be legally required to meet 

upon demand.

17. Do I have to report a bill for services, such as legal fees or university 

tuition?

Report a bill for services only if it was overdue and exceeded $10,000 at the end of the 

reporting period. If the bill was not overdue, you do not need to report it.

FAQs: Life Insurance (variable)

1. How do I value a variable life insurance policy?

For purposes of financial disclosure, the value of a variable life insurance policy and its 

underlying assets is the cash surrender value, not the face value.

2. Do I report proceeds from a relative’s variable life insurance policy?

No.

FAQs: Life Insurance (whole or universal)

1. What do I select for the “Excepted Investment Fund” field?

Whole and universal life insurance policies are not viewed as excepted investment funds 

because they represent an obligation of the sponsoring company rather than an interest in 

an investment fund. For this reason, select “N/A.”
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2. How do I value a whole life or universal life insurance policy?

For purposes of financial disclosure, the value of a whole life or universal life policy is 

the cash surrender value, not the face value.

3. Do I report proceeds from a relative’s whole life or universal life 

insurance policy?

No.

FAQs: Loan Made to Another Party

1. How do I determine the “value” of the loan for purposes of financial 

disclosure?

Use the amount of the liability owed as of the end of the reporting period.

2. What if a loan I had made previously was paid off during the reporting 

period?

Report the loan only if it produced more than $200 in income during the reporting period. 

The value of the loan in the “Value” field will be “None (or less than $1,001)” because it 

has been paid off.

3. Do I report co-signers on a loan?

Yes. A co-signer has a present obligation and is primarily liable for the note along with 

the principal obligor/debtor.

4. Do I report guarantors on a loan?

Not normally. Report a guarantor only if the principal debtor has defaulted on the 

obligation.

FAQs: Managed Account

1. I have always thought of my managed account as being similar to a 

publicly traded mutual fund. Why doesn’t it qualify as an excepted 

investment fund? 

Unlike a managed account, which is not an “excepted investment fund,” a publicly traded 

mutual fund qualifies as an “excepted investment fund” because:

• The publicly traded mutual fund is an investment fund in which various investors 

have “pooled” their money.
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• The publicly traded mutual fund is independently managed. As an investor in 

such a fund, you have no ability to direct the fund manager to buy or sell any 

investments.

• The publicly traded mutual fund, which is actually an investment company, is 

publicly traded or available.

• The publicly traded mutual fund is widely held. As a “pooled investment” a 

publicly traded mutual fund issues shares of an investment company that typically 

has thousands, and in some cases millions, of investors.

By contrast, a managed account is not a pooled investment fund because:

• The managed account is not an investment fund in which various investors have 

“pooled” their money. As an investor in a managed account, you have not 

“pooled” your money with other investors. Instead, you hold a separate account of 

your own. Although the account manager may have offered you the option of 

selecting a predetermined “portfolio” of assets, you own each of these assets 

individually and directly in your own name.

• The managed account is not independently managed. As an investor in a 

managed account, you likely have the ability to direct the account manager to 

make some adjustments to your personal account in order to customize your 

portfolio of holdings. Even in the rare case in which an account manager will not 

honor some limited requests to sell or refrain from purchasing certain securities, 

you may be able to remove the portfolio of securities from the account and 

manage the securities yourself.

• The managed account is not publicly traded or available. As stated above, a 

mutual fund sells its own shares. But the manager of your account does not sell 

shares of your account. It may be true that the manager offers to purchase for 

investors securities from an established list that it describes as a “portfolio” in its 

marketing literature, but the “portfolio” is not a company or other legal entity. 

The “portfolio” is merely a list of securities that the account manager is willing to 

purchase for individual account holders.

• The managed account is not widely held. You are the only investor in your 

account. While other investors may have selected the same securities for their 

own accounts, they maintain their accounts separately from yours. Thus, while a 

mutual fund may have millions of investors, your account has only one investor.

For these reasons, a managed account does not satisfy the required criteria for qualifying 

as an “excepted investment fund” that are established in 5 C.F.R. § 2634.310(c).
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FAQs: Money Market Fund

1. What is the primary difference between a money market account and a 

money market fund?

A money market account is an ordinary cash account. A money market fund is a type of 

mutual fund.

2. What is the dollar threshold for reporting a money market fund?

$5,000 value or $200 income

3. What is the dollar threshold for reporting a money market account?

$5,000 value or $200 income

FAQs: Mutual Fund

1. Do I need to provide the ticker symbol of the mutual fund in my financial 

disclosure report?

You are not required to provide the ticker symbol, but we encourage you to provide the 

ticker symbol if you know it. Providing ticker symbols will expedite the review of your 

report, which will enable you to clear the certification process more quickly.

FAQs: OGE Form 278-T

1. I purchased $1,500 worth of the Allied Business Computing, Inc., during 

the last week in the following amounts: $200, $500, and $800. Do I report 

anything?

No. You only have to report transactions that individually exceeded $1,000. None of 

your purchases exceeded $1,000, so you have nothing to report (even though the total 

amount purchased exceeded $1,000).

2. Do I report dividend reinvestments?

Yes. Dividend reinvestments are purchases. However, you only have to report those 

dividend reinvestment transactions that exceeded $1,000 each.

3. Do I report sales that resulted in losses?

Yes. The reporting threshold for transactions is tied to the size of the transaction, not the 

gains or losses produced. If the transaction exceeded the $1,000 threshold, report the 

transaction even if the asset is not reported.
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4. I changed investment options within my 401(k). Do I have to report 

anything?

It depends. Moving your funds from one option to another option entails a sale of the 

first investment and purchase of the second. If these transactions exceeded $1,000, you 

need to report them, unless the investment options qualify for a reporting exception. The 

most likely exception that may apply is the exception for what are called “excepted 

investment funds.”

5. Do I report transactions for assets held within a brokerage or managed 

account?

Yes.

6. Do I have to report a purchase and sale of an asset which occurred on 

the same day?

If the purchase exceeded $1,000, report the purchase. Similarly, report the sale if it 

exceeded $1,000. If you made multiple purchases or sales of the same asset on a single 

day, you may, however, aggregate transactions of the same type (i.e., report all purchases 

together on one line and report all sales together on another line).

7. Do I report stock splits?

No. Stock splits are not purchases, sales, or exchanges. Similarly, do not reports gifts 

given or received, bond calls or maturity, or the expiration of options.

FAQs: Oil, Gas, or Other Mineral Rights Lease

1. What if I have several leases with the same company?

In that case, you may describe these leases as a single entry. For example, write the 

following in the “Description” field: “Oil Leases in Texas and Oklahoma, Humble Oil & 

Refining Co.”

FAQs: Option (incentive stock option plan)

1. The sale of stock that I purchased using an incentive stock option 

produced ordinary income. How do I report that income?

Generally, the sale of stock would produce a capital gain or loss. However, in some 

situations, the sale of stock acquired through an incentive stock option may produce 

ordinary income as well.

In these cases, report the exact amount of ordinary income in the “Income Amount” field. 

Describe the income in the “Income Type” field as “option exercise, ordinary income.”
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FAQs: Option (put or call purchased)

1. I have an option based on an index rather than an option for a particular 

security. How do I report that?

If exercised, options based on an index are settled for cash rather than through buying or 

selling an underlying security.

a. Reporting an open, outstanding option on an index (i.e., the option has not expired, 

been exercised, or closed through an offsetting transaction):

Report an open index option in the same manner than you would report an open option on 

a security. The only difference is that you will list the name of the underlying index 

rather than the name of an underlying security.

b. Report an index option that has been exercised or closed through an offsetting 

transaction:

Report the option if it produced more than $200 in income during the reporting period.

Description: Provide the name of the option, which should include whether the option 

was a call or put and the identity of the underlying index (e.g., “Call option, S&P 500”).

Value: Report the value of the option by selecting the appropriate category, which 

should be “None (or less than $1,001).”

Income Type: Specify the type(s) of income if the total amount of income produced 

during the reporting period is more than $200.

Income Amount: Select the category corresponding to the total amount of income

produced.

c. Report an option on an index that expired:

You do not need to report an expired index option that you bought.

FAQs: Option (put or call written)

1. Do I have to report written options as transactions?

Yes, if you are filing an Annual or Termination report. Report the writing of an option in 

Part 7. In the interests of clarity, OGE recommends that you leave the “Type” field blank 

and instead specify the type of transaction by noting “opened written call option position” 

or “opened written put option position” in the “Description” field.
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In addition, if the option holder chooses to exercise the option, report your purchase or 

sale of the underlying security as a separate transaction in Part 7.

FAQs: Positions Held Outside U.S. Government

1. I am on the Board of Directors of my home owners association but do 

not get paid. Do I have to report that position even though it could not be a 

conflict with my job?

Yes. Report any position you hold as a director, unless the organization qualifies as a 

religious, social, fraternal, or political organization. A home owners association does not 

qualify as one of these types of organizations that are excepted from the reporting 

requirement.

2. I am a member of an advisory board committee to a nonprofit 

organization. Do I report this position?

It depends. You do not need to report service as a member of an advisory board or 

committee if the following criteria are met: (1) your service is unpaid; (2) the board or 

committee is that of a non-profit or governmental organization; (3) you have no fiduciary 

duties of the sort exercised by officers, directors, or trustees; and (4) your role does not 

involve sufficient supervision by the organization to create a common law employeeemployer relationship.

3. I am the president of my son’s PTA. Do I report this position?

Yes. Mere membership in the PTA, however, is not reportable.

4. Do I report service as a conservator or guardian?

Yes.

5. Do I report a power of attorney as a position?

No.

6. I am named as the executor in the will of a family member who is still 

alive. Do I report this position?

No.

7. I am a court-appointed administrator of an estate. Do I report this as a 

position?

Yes.
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8. I am the custodian of an UTMA account. Do I report this as a position?

No.

9. I am a representative on a Federal Advisory Committee Act (FACA) 

committee. Do I report this as a position?

Reporting your service as a separate line entry is not necessary. Service as a 

representative is sometimes related to the representative’s position with his or her 

employer or another non-federal organization. If this is the case for you, you may note 

your service as a representative as part of your description of a related non-federal 

position.

10. I am a special Government employee on a Federal Advisory Committee 

Act (FACA) committee. Do I report this as a position?

Do not report service as a special Government employee in Part 1. Instead, report your 

service as a federal position held within the preceding twelve months. If you are filing in 

Integrity, you would enter this information in the “Your Prior Federal Positions” data 

entry table. If you are completing a hard copy of the OGE Form 278e, you would enter 

this information on the Cover Page of the report.

11. I placed my consulting LLC into inactive status prior to the start of the 

reporting period. Do I report my role as managing member of this inactive 

LLC as a position?

Yes. If you had dissolved the LLC, however, you would no longer hold a reportable 

position.

12. I am on a leave of absence from my university employer, which began 

prior to the start of the reporting period. Do I have a position to report?

Yes, you need to report the position from which you have taken a leave of absence.

13. I am the uncompensated section chair of a professional association. 

Do I have a position to report?

No.

FAQs: Precious Metal

1. How do I know whether my precious metal is “held for investment 

purposes”?

Precious metal held in the form of ingots or warehouse certificates would normally be

reportable because they are held for investment purposes.
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Jewelry or coins held strictly for enjoyment or utility would not be reportable. Periodic 

sales from a collection or an expectation of such a sale in the foreseeable future would 

indicate that the jewelry or coins are held for an investment purpose.

If you are unsure whether precious metal is held for investment purposes, consult your 

ethics official.

2. I have a gold fund. How do I report that?

If you are invested in precious metals through securities, such as a metals mutual fund, a 

gold exchange-traded fund, or silver futures, report your interest according to the type of 

security.

FAQs: Real Estate

1. What should I use to value my real estate?

You may use a tax assessment, recent appraisal, purchase price, or a good faith estimate.

2. I own multiple properties in the same city. Can I report them as a single 

entry?

You may aggregate real estate properties that are:

a. located in the same city and state;

b. held directly by you, your spouse, or your dependent children; and

c. held only for investment or rental income (i.e., the real estate is not used in connection 

with a business in which you, your spouse, or a dependent child has an interest).

In addition, if the properties are of different types, indicate each type of property in the 

“Description” field (e.g., “residential and commercial real estate in Baltimore, MD”).

3. Why not provide street addresses?

Do not provide street addresses in your OGE Form 278e because the report is publicly 

available.
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FAQs: Real Estate Holding Company

1. The real estate holding company in which I have a financial interest is a 

limited liability company for holding and managing my family’s rental 

house at the beach. How do I value this interest if I and my 3 siblings own 

it equally?

Report only the value of your share, not the overall value of the house. You may use a 

current assessment of the value of the house or a good faith estimate of its value.

2. The company in which I have a financial interest does not hold any real 

estate. Instead, it manages apartment buildings throughout Miami. How 

do I describe this fund?

Provide the full name of this entity and describe the nature of the holdings as “apartment 

building management services.”

3. The real estate holding company in which I have a financial interest owns 

or operates a farm. How do I report this interest?

This guide contains instructions for reporting farms. If you have an active management 

role in the farm, see the instructions for reporting a farm business. If you are a passive 

investor in the farm, see the instructions for reporting a farm or farmland.

FAQs: Restricted Stock

1. How do I value unvested restricted stock for purposes of the “Value” 

field?

Value shares of unvested restricted stock as equivalent in value to the same number of 

shares of stock.

FAQs: Restricted Stock Unit (RSU)

1. How do I value a restricted stock unit for purposes of the “Value” field?

Value restricted stock units as equivalent in value to an equivalent number of shares of 

stock, unless your employer’s plan provides another means for determining value.
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FAQs: Salary

1. Do I report my annual salary or the total amount of salary income 

received during the reporting period?

Report the total amount of salary income that you received during the entire reporting 

period, not just the amount that you received in a calendar year.

2. What if I received a form of compensation other than salary?

Rather than writing “salary,” you may write another description that more accurately 

describes the type of income you received.

3. What if I received a bonus?

If you received a bonus, you may write the phrase “salary and bonus” and provide the 

combined amount of your salary and bonus.

4. May I combine salary and forms of compensation other than a bonus? 

Do not combine salary with forms of compensation other than a cash bonus. For 

example, do not combine salary with income in the form of stock options, and do not 

combine salary with deferred compensation.

5. Do I report income from salary as an employee of the United States 

Government?

No.

6. What if my spouse or I received income as a contractor for the United 

States Government?

Although you do not report salary received as a United States Government employee, you 

do report income received as a contractor for the United States Government.

7. What if I worked for a state or local government?

You would need to report your salary from a state or local government.

8. What if my minor or dependent child received salary or wages from 

employment?

Do not report wages or salary that a minor or dependent child received.
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FAQs: Severance Payment

1. I received salary and cash severance from the same employer. Can I 

combine these?

Yes. You may write the phrase “salary and severance” and provide the combined amount 

of the income that you have received from this employer. However, do not combine 

salary with a severance payment that you have not yet received (a “severance 

receivable”). Report salary and a severance receivable as two separate line items in your 

report.

2. My employer has not yet fixed the amount that I will receive. How should 

I value a severance receivable?

If you are a Presidential nominee for a position requiring Senate confirmation, you 

normally will need to fix the amount before you can complete your financial disclosure 

report. Contact your agency’s ethics official if fixing the amount before you complete 

your report does not appear to be possible.

If you are a current government official who is completing a “New Entrant” report, you 

should be aware that, in some circumstances, a criminal statute places restrictions on 

certain payments to government officials. In that case, contact your ethics official 

immediately and before you receive the payment, in order to determine whether you may 

receive the payment.

FAQs: Short Sale

1. What if I shorted the same stock on multiple occasions during the 

reporting period?

For multiple completed short sales of the same asset, aggregate the income from those 

transactions and report the income as one line entry in the report.

2. Do I have to report short sales as transactions?

Yes, if you are filing an Annual or Termination report. Report in Part 7 your sale of a 

borrowed security to open the short position. Likewise, report your purchase of the 

security used to close the short position.

In the interests of clarity, OGE recommends that you leave the “Type” field blank and 

instead specify the type of transaction by writing “opened short position” or “closed short 

position” in the “Description” field.
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FAQs: Sources of Compensation

1. I was paid exactly $5,000 for teaching one class at a local community 

college. I have not taught any other classes or received any other 

payments. Do I have to list the college in Part 4? 

You do not have to report the college in Part 4 because your compensation did not exceed 

$5,000.

However, you would report your position in Part 1. You also may need to report this 

income in Part 2 if you received the income during the Part 2 reporting period. 

2. I am paid $3,000 per year for my services as board director for Allied 

Business Computing, Inc. I receive no other compensation from the 

company. Do I report the company in Part 4?

No. Even though you may have received more than $5,000 across the entire reporting 

period, you do not have to report this source in Part 4 because you received only $3,000 

per year, which is less than the threshold of more than $5,000 in any one calendar year.

However, you would report your position in Part 1. You also may need to report this 

income in Part 2 if you received the income during the Part 2 reporting period.

3. I provided consulting services to the United States Government. Do I 

report the United States in Part 4?

No.

4. Do I report my sources of honoraria in Part 4?

Yes, report each source in excess of $5,000. You also need to report these sources in Part 

2.

FAQs: Stock

1. Do I need to provide a ticker symbol?

Providing a ticker symbol will expedite the approval of your report, but a ticker symbol is 

not required.

2. Do I need to provide the line of business of the company that issued the 

stock?

You do not need to provide the line of business of the company if the company is 

publicly traded. However, if the company is not publicly traded (i.e., the company is 

privately held), you should provide the line of business of the company.
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3. What is a “publicly traded” stock?

A stock is publicly traded if it is listed on a national exchange (NYSE or NASDAQ) or a 

regional exchange in the United States.

FAQs: Stock Appreciation Right

1. My company does not provide a value estimate for my stock appreciation 

right. How do I value it?

For purposes of financial disclosure, you may value a stock appreciation right based on 

the difference between the current market value and the grant price. This formula is: 

(current market value – grant price) x number of shares = value.

2. What does it mean to say a stock appreciation right is “underwater”? 

And how do I value a stock appreciation right that is underwater?

The stock appreciation right is said to be “underwater” if the value is zero or a negative 

number. This situation occurs when the current market value of a share is less than the 

grant price. In other words, the stock decreased in value after the employer granted the 

stock appreciation right, and the employee would not benefit from exercising the right. 

However, stock appreciation rights that are underwater are reportable because they have 

value. Stated differently, there is a value to holding a stock appreciation right, even if the 

right is currently underwater.

If you have no reasonable means for valuing an underwater stock appreciation right, you 

may employ an alternate form of reporting. The alternate form of reporting is intended to 

provide sufficient details for a reader to assess the value of the stock option. 

Accordingly, in that case, provide the following information in the “Description” field: 

(1) grant price; (2) number of shares; (3) expiration date; (4) vesting status; and (5) for an 

unvested stock appreciation right, the vesting date.

FAQs: Third-Party Escrow Agreement

1. I have an escrow agreement that does not relate to the sale of a 

business. How do I report it?

The guidance in this section is intended merely to provide an example of the handling of 

one type of escrow agreement. When reporting another type of escrow agreement, follow 

the guidance in this section to the extent possible. Your agency’s ethics official is 

available to assist you in ensuring full reporting of the agreement.
Public Financial Disclosure Guide, Appendix B 348

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FAQs: Transactions

1. I reported a purchase in a Periodic Transaction report (OGE Form 278-T). 

Do I have to report the transaction again in my Annual or Termination 

report?

You do not need to report a transaction in an Annual or Termination report (OGE Form 

278e) if the transaction has already been reported in a Periodic Transaction report (OGE 

Form 278-T), unless your agency requires duplicate reporting. Filers using Integrity can 

import transactions disclosed on prior Periodic Transaction reports without additional 

data entry. Other electronic filing systems might offer similar functionality. Agencies 

using such systems may determine that the benefits of aggregating all transactions within 

a reporting period in a single report outweigh the minimal burden imposed on the filer. If 

your agency does not require duplicate reporting, your agency may still require you to 

incorporate your Periodic Transaction reports by reference or by attaching prior Periodic 

Transaction reports. See Legal Advisory LA-12-04 (June 20, 2012).

In addition, you may have to report the asset in Part 2, 5, or 6 if it meets the value or 

income reporting thresholds.

2. Are the transaction reporting requirements for an Annual or Termination 

OGE Form 278 the same as for my Periodic Transaction reports (OGE Form 

278-T)?

No. In addition to the transactions that are reportable in a Periodic Transaction report, 

your Annual or Termination report includes purchases, sales, and exchanges of real 

property and excepted investment funds, such as mutual funds.

3. I purchased $1,500 worth of the ABC Health Sciences Fund last year in 

the following amounts: $200, $500, and $800. Do I report anything?

No. You only have to report transactions that individually exceeded $1,000. None of 

your purchases exceeded $1,000, so you have nothing to report (even though the total 

amount purchased exceeded $1,000).

4. I purchased the ABC Health Sciences Fund multiple times during the 

past year in amounts greater than $1,000. Do I have to report the date of 

each purchase?

You may combine multiple purchases or multiple sales of an excepted investment fund, 

such as a mutual fund, in a single entry, listing each date or providing a more general 

description, such as “monthly” or “multiple.”
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5. I purchased stock in Allied Business Computing Corp. multiple times 

during the past year in amounts greater than $1,000. Do I have to report 

the date of each purchase?

As noted in question 1 above, you do not need to report a transaction in an Annual or 

Termination report (OGE Form 278e) if the transaction has already been reported in a 

Periodic Transaction report (OGE Form 278-T), unless your agency requires duplicate 

reporting. An agency that requires duplicate reporting may require you to provide the 

specific dates again or may permit a more general reference.

If, however, you have not previously disclosed transactions that are reportable in a 

Periodic Transaction report (OGE Form 278-T), you need to list the date of each such 

transaction.

6. Do I report dividend reinvestments?

Yes. Dividend reinvestments are purchases. However, you only have to count those 

dividend reinvestment transactions that exceeded $1,000 each.

7. Do I report sales that resulted in losses?

Yes. The reporting threshold for Part 7 is tied to the size of the transaction, not the gains 

or losses produced. If the transaction exceeded the $1,000 threshold, report the 

transaction.

8. I changed investment options within my 401(k). Do I have to report 

anything?

It depends. Moving your funds from one option to another option entails a sale of the 

first investment and purchase of the second. If these transactions exceeded $1,000, report 

them.

9. Do I report transactions for assets held within a brokerage or managed 

account?

Yes.

10. Do I report transactions for underlying assets held within an investment 

fund?

You do not need to report transactions if the investment fund qualifies as an excepted 

investment fund (e.g., although you report purchases of mutual funds, you do not need to 

report the purchases of stocks held by a mutual fund). Otherwise, report the transactions 

in the same way that you would report transactions involving your other assets.
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11. Do I have to report a purchase and sale of an asset which occurred on 

the same day?

If the purchase exceeded $1,000, report the purchase. Similarly, report the sale if it 

exceeded $1,000. If you made multiple purchases or sales of the same asset on a single 

day, you may, however, aggregate transactions of the same type (e.g., report all purchases 

together on one line and report all sales together on another line).

12. How do I report transactions involving futures, foreign exchange 

positions, short sales, and written options?

You may report transactions involving futures, foreign exchange positions, short sales, 

and written options using the standard drop-down options within the “Type” field. 

However, in the interests of clarity, OGE recommends leaving the “Type” field blank and 

writing “opened position” or “closed position” in the “Description” field.

Description Type Date Amount

Crude oil futures, opened position 6/12/15 $1,001 - $15,000

Silver futures, closed position 6/18/15 $1,001 - $15,000

Euro-US Dollar (EUR/USD), 

opened position 6/12/15 $1,001 - $15,000

BMSL Propulsion, opened short 

position 6/12/15 $1,001 - $15,000

Widgets Unlimited, opened written 

call option position 6/12/15 $1,001 - $15,000

FAQs: Treasury Security

1. What are Treasury Securities?

United States Treasury securities, often simply called Treasuries, are debt obligations 

issued by the United States Government and secured by the full faith and credit (the 

power to tax and borrow) of the United States.

2. What are some examples of Treasury securities?

Treasuries include:

• Treasury bills, also called T-bills -- short-term obligations having maturities of 

one year or less (issued at a discount from their maturity value);

• Treasury notes -- intermediate-term obligations with maturities of 1 to 10 years;

• Treasury bonds -- long-term obligations with maturities of 10 years or more; and

• U.S. savings bonds -- obligations issued in smaller denominations than Treasury 

bonds and not traded on the secondary market like other Treasuries (issued either 

at a discount from maturity value or at face value with periodic interest).
Public Financial Disclosure Guide, Appendix B 351

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3. What are STRIPS?

STRIPS (Separate Trading of Registered Interest and Principal of Securities) are created 

by the Treasury when it strips the coupons (interest) from Treasury bonds and sells the 

coupons and the principal separately, at a discount from face value.

4. What are commercially marketed Treasuries?

Investment firms also strip Treasury bonds and market them under acronyms such as 

CATS (Certificates of Accrual on Treasury Securities) and TIGRS (Treasury Investors 

Growth Receipts). Though these securities represent ownership interests in Treasuries, 

the investment firm becomes the obligor for repayment, rather than the U.S. Treasury.

5. I owned several Treasury securities that matured this past year. How do 

I report them?

In Part 6, write “U.S. Treasury securities” in the “Description” field. In the “Value” 

field, select the “None (or less than $1,001)” category, in the “Income Type” field select 

“interest,” and in the “Income Amount” field select the category corresponding to the 

amount of interest produced during the reporting period. You do not need to list each 

security separately.

FAQs: Trust (irrevocable)

1. Do I need to report the assets of a revocable trust?

See the “Trust (revocable living)” entry in this guide for more information about 

revocable living trusts.

2. The old OGE Form 278 had a column for “qualified trusts.” How do I 

report a “qualified trust” on the OGE Form 278e?

The “qualified trust” column on the old OGE Form 278 was used for OGE approved 

blind trusts (“qualified blind trusts” and “qualified diversified trusts”); however, the use 

of such trusts is very rare so the column was not included in the new OGE Form 278e. 

For more information, click here.

3. Do I report transactions involving the assets of the trust?

You need to report transactions on an Annual or Termination report if you have a vested 

beneficial interest in the trust, unless the trust qualifies as an excepted trust.

4. Do I report my interest as a beneficiary of a legal defense fund?

Report a legal defense fund in Part 6 if you, your spouse, or your dependent child has a 

vested beneficial interest in or received income from the fund. Gifts to a legal defense 
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fund for your benefit (or the benefit of your spouse or your dependent child) would be 

reported in Part 9.

FAQs: Trust (revocable living)

1. Do I need to report the assets of a revocable living trust that I 

established for myself and my family?

Yes. Although a revocable trust that someone outside your immediate family established 

for your benefit is not normally reportable, report the assets of a revocable trust that you 

established for yourself or your family.

2. I have a remainder interest in my father’s revocable living trust. Is that 

reportable?

As with most revocable trusts, as opposed to irrevocable trusts, you generally do not 

report an interest in a revocable living trust (unless you, your spouse, or your dependent 

child is the grantor of the trust). For a detailed discussion of revocable living trusts, see 

an OGE memorandum entitled “Revocable Living Trusts,” DO-02-015, dated June 11, 

2002. However, you should consult your agency’s ethics official if you are a beneficiary 

of a revocable living trust because trusts are often highly individualized and state laws 

governing trusts vary.

3. I received a discretionary distribution from my mother’s revocable living 

trust. Is that reportable?

As with most revocable trusts, as opposed to irrevocable trusts, you generally do not 

report discretionary distributions received from a revocable living trust (unless you, your 

spouse, or your dependent child is the grantor of the trust). However, you should consult 

your agency’s ethics official if you are a beneficiary of a revocable living trust because 

trusts are often highly individualized and state laws governing trusts vary.

4. Can you give me an example of an instance in which a revocable living 

trust established by someone for my benefit would be reportable?

Yes. One example arises in the context of mandatory distributions.

In many cases, the trust instrument for a revocable living trust either will be silent as to 

distributions to beneficiaries or will make clear that such distributions are discretionary.

Normally, you do not need to report your interest in a revocable living trust if you are the 

beneficiary, rather than the grantor. However, as an exception to this rule, report your 

beneficial interest in a revocable living trust if the trust instrument expressly directs the 

trustee to make present, mandatory distributions of trust income or principal to you (or 

your spouse or dependent child). In such situations, even though the grantor retains the 

power to revoke the trust or change beneficiaries, the fact remains that the trust 
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instrument gives you a right to present enjoyment of trust assets – not merely a future 

interest– and this present enjoyment cannot be interrupted except by an affirmative act of 

the grantor to alter the trust.

For a detailed discussion of revocable living trusts, see an OGE memorandum entitled 

“Revocable Living Trusts,” DO-02-015, dated June 11, 2002.

5. Do I report transactions involving the assets of a revocable living trust?

You need to report transactions in an Annual, Termination, or Periodic Transaction report 

if you, your spouse or a dependent child is the grantor of the revocable living trust or 

received mandatory distributions during the reporting period.

FAQs: UGMA or UTMA Account

1. My child’s grandmother established the UTMA account. All of the funds 

were contributed by his grandmother, who also acts as the custodian. Is 

my dependent child’s financial interest reportable?

Yes. Even though the funds were contributed by, and are currently controlled by, the 

grandparent, the funds have been irrevocably transferred to your child. Consequently, the 

contents of the account are considered to be your child’s assets for financial disclosure 

purposes.

2. What if none of the assets were individually worth more than $1,000 at 

the end of the reporting period or produced more than $200 during the 

reporting period?

If each individual asset had a value of $1,000 or less and produced $200 or less in 

income, you need not report the child’s financial interest in the assets of the account or in 

the account itself, even if the child’s aggregate interest in the entire account exceeds the 

$1,000 and $200 thresholds.

FAQs: Unit Investment Trust (UIT)

1. Am I required to provide a ticker symbol?

Providing a ticker symbol will expedite the approval of your report, but a ticker symbol is 

not required if you are unable to find the ticker symbol. Do not forget to provide the 

exact name of the unit investment trust (e.g., list “Invesco Van Kampen Intermediate 

Corporate Investment Grade Trust” rather than just “Invesco Van Kampen”).
Public Financial Disclosure Guide, Appendix B 354

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FAQs: Will or Estate

1. I am the executor of an estate. Do I report the assets?

If you have a beneficial interest or have received any of the assets, report the interest or 

the assets received in Part 6 using the instructions provided on the main “Will or Estate” 

page.

2. Do I need to report particular assets within an estate that have not been 

distributed to me?

No. As specified in OGE Informal Advisory Opinion 02 x 2, OGE “requires that the 

financial disclosure report indicate only that the filer (or the filer’s spouse or dependent 

child) is the beneficiary of a particular estate that has not been distributed. The filer must 

identify the decedent, but need not attempt to identify specific assets or report specific 

value or income categories. This level of disclosure recognizes that filers have an 

interest, and it alerts ethics officials to the need to provide counseling, as appropriate, 

about possible conflicts issues. However, this approach does not require filers to provide 

more specific information that may be difficult or impossible to ascertain, or that could 

even present a misleading picture of the true interest the beneficiary ultimately may 

receive after distribution of the estate.”

With regard to the identification of the decedent, note that you may write “Estate of a 

Family Member” when the decedent is a family member.
Public Financial Disclosure Guide, Appendix C 355

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Appendix C: Differences between the July 2016 

and May 2018 Print Versions 

The following table identifies the pages that differ in the July 2016 and May 2018 print 

versions of the Public Financial Disclosure Guide. 

Section Topic July 2016 Page # May 2018 Page #

OGE Form 278e, Part 6: Trust (irrevocable) 190 190

OGE Form 278e, Part 9: Gifts and Travel 

Reimbursements

202 202

For Ethics Officials, 1.01: Officials Required 

to File

210 210

For Ethics Officials, 1.02: Types of Reports 

and Filing Deadlines

212 212 and 213

For Ethics Officials, 2.02: Spouses and 

Dependent Children

225 and 226 225 and 226

For Ethics Officials, 2.12: 

OGE Form 278e, Part 9, Gifts and Travel 

Reimbursements 

243 243 

For Ethics Officials, 4.02: Review Timeframes 251 251

Appendix A: Confidential Clients 270 270

Appendix A: Excepted Trust: Definition 274 274

Appendix A: Gifts and Travel 

Reimbursements: Aggregation

285 and 286 285 and 286

Appendix B: FAQs: Gifts and Travel 

Reimbursements

323 through 325 323 through 326

Appendix B: FAQs: Trust (irrevocable) 350 351 and 352