U.S. Office of Government Ethics

This Legal Advisory briefly describes Real Estate Investment Trusts (REITs), Master Limited Partnerships (MLPs), and Business Development Companies (BDCs), and provides guidance on the financial disclosure reporting requirements and conflicts of interest analysis applicable to each of these assets. Ethics officials should consider REITs and MLPs as operating businesses and BDCs as investment funds, and report and analyze them accordingly. The appendices to this document serve as a quick reference for disclosure guidance and conflicts of interest analysis for these assets.

This Legal Advisory identifies the 2021 thresholds for: (1) determining which senior employees are subject to the post-employment restrictions; (2) identifying which officers and employees must file public financial disclosure reports; and (3) implementing the outside employment and outside earned income restrictions for certain covered noncareer employees.

This Legal Advisory reminds executive branch employees of the gifts and fundraising rules relevant to 2021 Presidential Inaugural events.

This Legal Advisory addresses recurring questions about the gifts analysis for virtual events. The Legal Advisory clarifies that ethics officials should analyze virtual events under the same framework as in-person events.