Financial Disclosure

The financial disclosure system serves to prevent conflicts of interest by providing for a systematic review of the financial interests of both current and prospective employees.

Responsibilities of the Designated Agency Ethics Official (DAEO)

The DAEO, acting directly or through other officials, is responsible for carrying out an effective financial disclosure program, which encompasses both a public and a confidential filing system. These responsibilities include:

  • Developing and maintaining written policies and procedures
  • Identifying filers and making exclusion determinations
  • Providing guidance to filers in completing reports
  • Collecting reports, reviewing requests for extensions, and assessing late filings
  • Reviewing reports for technical sufficiency and substantive ethics concerns
  • Identifying remedies and tracking completion of those remedies
  • Submitting to OGE the reports that require second-level review
  • Releasing public reports upon request
  • Maintaining adequate systems of records in accordance with applicable disposition rules

In addition, the DAEO works with OGE on the financial disclosure reports of potential Presidential nominees to Senate-confirmed (PAS) positions. Of note, only the DAEO may personally certify PAS nominee reports.


Key Legal Authorities

5 U.S.C. app. § 101, et seq. – Public financial disclosure requirements

5 C.F.R. § 2638.104(c)(8) – Responsibilities of the DAEO for carrying out an effective financial disclosure program

5 C.F.R. part 2634 – Executive Branch financial disclosure requirements


Key Advisories

PA-20-02: Deadlines and Procedures for Annual Public Financial Disclosure Reports of Executive Branch Employees - 2020 Filing Cycle (PDF)

This program advisory provides filing deadlines for the public financial disclosure reports of executive branch employees and procedures for the reports agencies are required to transmit to OGE.

For additional relevant advisories, search the Legal Research Collection


Public Financial Disclosure Resources

Filing

Integrity

This is the electronic system for filing public financial disclosure reports. Integrity is accessible only to those with an assigned role, a username, and a password.

Integrity User Guide

This guide is a reference manual for agency ethics officials using Integrity, the web-based system developed by OGE for filing and reviewing executive branch public financial disclosure reports (OGE Form 278e and OGE Form 278-T).

Integrity Resources

These resources include job aids for filers, reviewers, and administrators. Ethics officials will need a MAX.gov username and password to access these resources.

278e (XLS) | (accessible PDF)

This version of the OGE Form 278e, the Public Financial Disclosure Report, is for individuals who cannot file using an electronic financial disclosure system.

278-T Form (XLS | Accessible PDF)

The OGE Form 278-T is used by employees within the executive branch who must file public periodic transaction reports. This version of the report is for individuals who cannot file using an electronic financial disclosure system.

Guidance

Public Financial Disclosure Guide (HTML) | (PDF)

This interactive tool assists in the administration and review of public financial disclosure reports (OGE Form 278e or OGE Form 278-T). View the For Ethics Official section for comprehensive guidance geared toward ethics officials.

Guide for Nominees, 2020 (PDF)

The Guide for Nominees is a resource for potential Senate-confirmed, Presidential nominees. It is organized to take a nominee through the life cycle of a person who will serve as a Senate-confirmed Presidential appointee (PAS official). It includes sections explaining what to expect during the nominee process, how to have an ethical start to Federal service, how to be a leader in ethics, and what to consider when planning to leave Federal service. The appendix contains detailed reference information, such as instructions for Integrity and financial disclosure checklists.

PAS Nominee Ethics Agreement Guide (DOC)

This guide contains sample language and commentary designed to enhance the quality of nominee ethics agreements.

Nominee Public Financial Disclosure Review Checklists (2020) (PDF)

These checklists provide a non-exhaustive list of items nominee filers should include in each part of the public financial disclosure report.

Public Financial Disclosure Review Curriculum

This page brings together training videos and OGE resources in the form of a learning curriculum designed to educate ethics officials on how to designate confidential filers and how to review confidential financial disclosure reports.


Confidential Financial Disclosure Guide Resources

Filing

Confidential Financial Disclosure Report (OGE Form 450) (PDF) | (accessible PDF) | (XLS)

This form is used by executive branch employees who are less senior than public filers to report their financial interests as well as other interests outside the government. (For individuals using a pre-2010 version of Adobe: To save the form, use the "Save as" option.) Do not use the "Save a Copy" option, because this option will lock the form, preventing you from making changes.)

Guidance

Confidential Financial Disclosure Guide (2019) (PDF)

This revised version of the Confidential Financial Disclosure Guide reflects the regulatory requirements that became effective January 1, 2019.

Determining Which Positions Should File a Confidential Financial Disclosure Report: A Worksheet (2016) (PDF)

This job aid is designed to assist ethics officials in determining whether a career employee should file a Confidential Financial Disclosure Report (OGE Form 450). Some Schedule C employees and special Government employees may also be required to file an OGE Form 450.

Confidential Financial Disclosure Review Curriculum

This page brings together training videos, OGE resources, and job aids in the form of a learning curriculum designed to educate ethics officials on how to designate confidential filers and how to review confidential financial disclosure reports.

Other Resources

Certificate of Divestiture (CD) Fact Sheet (2016) (PDF)

This one-page reference guide summarizes key elements of the CD program, including eligibility requirements, instructions on how employees can request a CD, and what to do after one is issued.

PA-19-10: Revised Format for Requesting a Certificate of Divestiture (PDF)

This revised format incorporates the changes in 5 C.F.R. part 2634, subpart J, which became effective on January 1, 2019. Use of the format remains optional.

Certificate of Divestiture Request (PDF)

OGE strongly recommends that agencies use this format to request a certificate of divestiture for eligible employees. This request form must be signed by the DAEO or Alternate DAEO.


Agency Practices

As the supervising ethics office, OGE has insight into the methods, procedures, and practices of over 130 agency ethics programs and seeks to highlight these practices as a resource for improving ethics programs across the executive branch. The following practices are gathered from OGE program reviews, agency responses to Annual Agency Ethics Program Questionnaires and data calls, and OGE summits and conferences. While no single approach is one-size-fits-all, ethics officials may find other agencies’ practices useful to the effective and efficient administration of their own ethics program.

  • Review financial disclosure lists annually, in coordination with division directors, to ensure that employees at risk for conflicts and those required by law to file are designated as filers. Remove from the list employees no longer required to file.
  • Schedule monthly check-ins with senior management, human resources leadership, and administrative officers to ensure that the agency is timely identifying new financial disclosure filers, including detailees and employees in "acting" filer positions.
  • Use financial disclosure filing as a training vehicle by building training modules and advice and counseling sessions around the filing process.
  • Establish training sessions and “office hours” to help filers report accurate and timely information on financial disclosures.
  • Use a checklist in the review process to spot critical, recurring, substantive, and technical issues.
  • Send an acknowledgement to financial disclosure filers upon completion of the review and certification.
  • Craft a personalized guidance memo for each filer that includes ethics advice on potential issues regarding their holdings.
  • Automate monthly email reminders to public financial disclosure filers of the requirement to file periodic transaction reports (278-Ts), as necessary.
  • Delay or preclude promotions or awards for employees who fail to timely file financial disclosure reports.