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May 16, 2007DO-07-014
Designated Agency Ethics Officials, General Counsels and Inspectors General
Robert I. CusickDirector
Guidance on Electronic Filing of Public and Confidential Financial Disclosure Reports
At OGE’s recent National Ethics Conference, in Orlando, Florida, I discussed OGE’s plans for any continued involvement in the development of an executive branch‑wide system for electronic filing of the public and confidential financial disclosure reports. As some of you may know, the Office of Management and Budget (OMB) informed OGE that its request to undertake an OMB sanctioned e-Gov Initiative for the development of an e-filing system for financial disclosure reports in the executive branch will not be approved. OGE considered the possibility of attempting to manage an informal non‑OMB sanctioned e-Gov initiative, but rejected that approach because OGE has neither the finances nor staff resources to oversee such an uphill effort of a strictly voluntary nature without definite funding sources.
Instead, OGE decided to allow each agency to undertake its own development of an electronic filing process to use with either the public (SF 278) or confidential (OGE Form 450) reporting system. Electronic filing (e-filing) involves electronic completion of the form with electronic signing by the filer, followed by an electronic certification by the reviewing official(s), and storage of the report in an electronic storage system. An e-filing system would not allow a filer to e-mail an electronically fillable (but not electronically signed) form to the reviewer. Likewise, it would not allow the electronic forwarding of an electronically scanned paper report to a reviewer.
Each agency that wishes to implement an electronic filing system must adhere to the guidelines listed below:
We recognize that each department or agency’s information technology infrastructure may differ, and that each agency may choose the software that will be most appropriate for accomplishing the development of an e-filing system for financial disclosure reporting. At present, the Department of the Army is the only executive branch agency that is offering, for a fee, an e-filing service to other agencies. If interested, you may contact Mr. Hancock for information.
Even though it will be each department or agency’s responsibility to decide its own progression into the electronic filing arena, the integrity of financial disclosure processes will continue to be one of OGE’s highest priorities. Accordingly, OGE will continue to monitor the executive branch’s movement into this area by requesting basic information on future Annual Ethics Program Questionnaires. In addition, OGE will oversee this area as part of its Program Review Division’s future reviews of agency ethics programs.
If you have any questions or comments, please contact Tom Zorn, Deputy Associate Director for Financial Disclosure, Program Services Division, at (202) 482-9287. His e-mail address is firstname.lastname@example.org.