Employment with a Company that Manages an Investment Fund

If you have ever worked for the company that manages the investment fund, additional reporting requirements may apply to you. This depends on whether you have other financial interests related to the investment fund or your employer that have not been captured in your financial disclosure report.

1.  If you participate in the investment fund through a current or former employer, you need to describe the terms of your participation in Schedule C, Part II. For further information, see the general guidance for reporting agreements or arrangements.

2.  Compensation and Other Benefits: If you or your spouse 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 compensationdefined 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.

3.  Co-Investment Interest: In Schedule A, 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 Block A. Provide a brief explanation of your interest in the report or in an attachment to the report. Please be aware that any attachment will be released publicly along with the report. In Schedule C, Part II, report any arrangement with your employer related to this co-investment interest that will continue after you enter government service.

4. Carried Interest: If you have a “carried interest,” contact an ethics official at your agency for additional assistance.

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. 

 

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

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