OGE Form 278 Checklist: Nominees, New Entrants, and Candidates

We have developed this list to help you avoid some common mistakes. Of course, we did not try to make this list comprehensive because the entire Nominee and New Entrant 278 Guide is essentially a checklist. If you have followed the instructions in the guide and have done your best to identify all of your financial interests, you probably are in good shape. This checklist will help speed up the review process by making sure that you have not overlooked some basic items that can be easy to overlook.

COVER PAGE

1.  In addition to providing your name, the title of your new or intended position and the agency, did you complete the following?
•  The “New Entrant, Nominee, or Candidate” box
•  The “Address and Telephone” fields (Do not use home address/phone or a direct line.)
•  The “Previous Positions with U.S. Government in Last 12 Months” field
•  (Nominees only): The “Committee” field (This is the Senate committee that will consider your nomination.)
•  (Nominees only): The “Qualified Diversified Trust” box (Most filers mark “no” –“yes” would be an unusual answer that you should discuss with your ethics official.)

2.  Did you sign and date the form?

SCHEDULE A

3.  Did you remember to report information for your spouse and dependent children, if applicable?

4.  Did you capture all reportable assets and sources of income? The following common items are sometimes overlooked:

a. Employment-Related
•  Salary, bonus, severance, director fees, consulting fees, or honoraria
•  Anticipated bonus or severance
•  Retirement plans (e.g., defined benefit pension plan or defined contribution plan)
•  Deferred compensation
•  Equity in an employer (e.g., stock or stock options)
•  TIAA-CREF accounts
*  Note: Do not report federal salary or retirement benefits.

b. Other Assets and Investment Income
•  Bank accounts (e.g., checking, savings, CDs, money market accounts)
•  Real estate (However, do not report a personal residence, unless it has been rented.)
•  Stock, bonds, mutual funds, etc.
•  Qualified tuition programs, also called 529 plans (i.e., college savings plans or prepaid tuition plans)
•  Whole, universal, or variable life insurance
•  Fixed or variable annuities
•  Books and other intellectual property
•  Interests in or income from a trust or estate

5.  If you have nothing to report, did you mark the “None” box?

SCHEDULE B

6.  Leave this page of your report blank. (Because Nominees and New Entrants do not complete Schedule B, you should not even mark the “None” boxes.) 

SCHEDULE C, PART I

7.  Did you report liabilities (excluding credit card debt) that exceeded $10,000 at any time during the reporting period?

8.  Did you report credit card debt that exceeded $10,000 at the end of the reporting period?

9.  If you have nothing to report, did you mark the “None” box?

SCHEDULE C, PART II

10.  If you are on a leave of absence or will go on a leave, is that reported?

11.  Have you reported your participation in any retirement or deferred compensation plans?

12.  Have you reported any anticipated payments from your firm or employer, such as a bonus, severance, return of capital account, payment of outstanding partnership share, or buyout?

13.  Have you reported any employment-related benefits that will continue after your resignation or during your leave of absence (e.g., health insurance, life insurance, use of car or office, IT or secretarial support, housing benefits, tuition benefits, discounts on company services or products, tickets to events or use of company skybox, etc.)?

14.  Have you described what will happen to any vested or unvested stock options, any restricted stock, or other equity-related interests (e.g., forfeit upon resignation, vest, exercise, etc.)?

15. If you have nothing to report, did you mark the “None” box?

SCHEDULE D, PART I

16.  Have you reported non-federal positions held at any time during the reporting period? Remember to list your current employer(s). Remember to report positions with non-profit organizations.

17.  If you have nothing to report, did you mark the “None” box?

SCHEDULE D, PART II
(New Entrants and Nominees complete this part. Presidential candidates do not complete this part.)

18.  Have you reported all non-federal sources of compensation that exceeded $5,000 in any one calendar year during either of the two preceding calendar years or the current year? Remember to list your current employer(s) if you earned more than $5,000 in a year from your employer.

19.  If you have nothing to report, did you mark the “None” box?

FINAL REVIEW

20.  Did you include your name and a page number on each page?

21.  (Nominees only): If you have already completed your Senate questionnaire, is the information that you provided in that questionnaire fully consistent with the information that you provided in your OGE Form 278? The Senate questionnaire requirements differ in certain respects from the OGE Form 278, but where the requirements overlap, your agency ethics official will need to have you explain any inconsistencies.

 

This guide is not intended to provide investment advice, and you should not rely on statements in this guide when making investment decisions.