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The Annual Public Financial Disclosure System: The Ongoing Work of Preventing Conflicts of Interest

May 16, 2022

From: Dave Apol, General Counsel

This is an important time of year for government ethics. Every May, approximately 26,000 senior government employees are required to file public financial disclosure reports. These filers include not only the President, the Vice President, Cabinet Secretaries, and Deputy and Assistant Secretaries, but also almost 25,000 other political and high-level career officials in the executive branch. All of these officials have an ongoing obligation to avoid conflicts of interest when carrying out the duties of their position. The financial disclosure system is an important tool to assist in fulfilling that obligation. 

The financial disclosure reports that tend to get the most attention are the ones filed at the beginning of an official’s tenure, and for good reason. The nominee or new entrant report is the first chance for ethics officials to identify potential financial and other conflicts of interest and remedy those and other ethics concerns.

The first report is important but it isn’t the end of the story. Officials’ financial holdings, and sometimes their official duties, change. Therefore, these employees also file an annual financial disclosure report, due in mid- May of each year. These reports give ethics officials and the employees a chance to do an “annual ethics checkup” to make sure potential conflicts created by new financial interests or official duties are addressed. After these reports are filed, ethics officials in each of the 139 executive branch agencies will get to work reviewing the reports and advising the officials who file them.

While the annual public financial disclosure filing season is a particularly busy time for ethics officials, remember that the financial disclosure program is active throughout the year, with ethics officials constantly working at preventing conflicts of interest on the part of senior government officials. In addition to the annual reports, these employees also file periodic transaction reports throughout the year whenever they buy or sell stocks or other securities, so that any ethics issues raised by a new financial interest can be addressed quickly.

Additionally, ethics officials work year-round to provide ethics counsel and training to the other employees throughout their agencies. If you want to see some of these reports for yourself, the reports are available to the public upon request 30 days after they are filed with an employee’s agency. In addition, the reports of the approximately 1,000 highest-level appointees are available from OGE upon request 30 days after OGE receives the reports from the agencies. You can make an electronic request for those reports using the “Officials’ Individual Disclosures Search Collection” page on OGE’s website.

The annual financial disclosure system represents a regularly scheduled, systematic way ethics officials and filers identify and avoid potential conflicts of interest. I’m grateful for the efforts of both filers and ethics officials during this important and busy time and wish them all a successful financial disclosure season.