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August 29, 2011
PA-11-04
MEMORANDUM
TO: Designated Agency Ethics Officials
FROM: Rashmi Bartlett
Associate Director for Program Reviews
SUBJECT: Financial Disclosure Certification
This Program Management Advisory serves as a reminder and clarification of the requirements for timely certification of financial disclosure reports under 5 C.F.R. § 2634.605(a). During recent program reviews, PRD has found some confusion and different interpretations among agencies regarding the requirement to accomplish final certification of financial disclosure reports within 60 days of their receipt.
Final certification of the OGE Form 278 and OGE Form 450 must occur within 60 days of report receipt when the reports do not require additional information or remedial action.[1] For agencies with intermediate certification and multiple review levels, OGE will determine that an agency is in compliance with the 60-day requirement if (1) someone designated as a reviewing official (versus the DAEO) has reviewed the report and (2) the reviewing official certifies that the report is in compliance with applicable laws and regulations. Certification of the OGE Form 278 by either the DAEO or reviewing official must be indicated by a signature in the “Agency Ethics Official’s Opinion” block. (See Figure 1) Certification of the OGE Form 450 by either the DAEO or reviewing official must be indicated by a signature in either the “Intermediate Reviewer” or “Final Reviewing Official” block. (See Figure 2)
Please contact me at (202) 482-9317 or by email at Rashmi.Bartlett@oge.gov if you have any questions.
Figure 1: OGE Form 278 signature block.
Figure 2: OGE Form 450 signature block.
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[1] See the Reviewer’s Reference (page 4-3) and 5 C.F.R. § 2634.605(a).