FDM Web site - OGE 278 Common Questions

You may find it helpful to have this information to prepare your report:

A copy of your previous OGE 278 (if you have filed before)

A copy of your previous OGE 450 (if you were a 450 filer)

Electronic version of your job description (attach to OGE 278)

Brokerage and/or mutual fund statements

Bank, credit union, or any other financial institutions statements

Any agreements or arrangements from past, current or future employers (Schedule C, Part II)

Mortgage statement (if a rental)

Credit card and any other loan statements

The purpose of this report is to assist employees and their agencies avoid conflicts between duties and private financial interests or affiliations. Agency ethics official will use the information to determine whether any potential conflicts exist. The form also will be made available if it is requested by a member of the public. Public requesters are prohibited, however, from using the information on your form for any unlawful or commercial purpose, or from using it as a basis to establish your credit rating or to solicit any money from you.

If you are living apart from your spouse with the intent to divorce or separate permanently, you do not need to report your spouse's income, liabilities, or transactions involving your spouse's assets. Otherwise, you must disclose your spouse's interests as required.

Although your financial information reported in your Public Financial Disclosure Report is releasable in response to requests from the public, until such a request is made, the information is stored in this application and may be viewed only by those authorized to see your report. In addition, application administrators may, in the course of administering the application and supporting its users, view the financial data if necessary to maintain the application. Each application administrator is bound by agency regulation and a nondisclosure agreement to safeguard the information from unauthorized personnel.

SGEs are defined at 18 U.S.C. 202(a): Generally, employees performing temporary duty for 130 days or less in any 365 day period, including Reserve and National Guard officers while on active duty solely for training, or while serving involuntarily. While section 202(a) does not include enlisted members as SGEs, the Joint Ethics Regulation (JER), at section 1-232, applies the definition to enlisted members the same as it applies to officers. Unless excepted or required to file an OGE 278, all SGEs must file an OGE 450. See 5 C.F.R. 2634.904(b). DoD personnel: See exceptions in 7-300a(2) of the JER. One exception is reservists on active duty for less than 30 consecutive days in a calendar year.

The Filer category is used for statistical purposes to report how many Filers are Presidential Appointees-Senate Confirmed (PAS), military, career Senior Executive Service (SES), non-career SES, Schedule C, or other. Filers must pick a Filer category to proceed.

An incumbent filer is an employee who has worked for more than 60 days during the previous calendar year in a position which required filing of an OGE 278. This includes individuals temporarily promoted to such a position or who are temporarily detailed to such a position.

A new entrant filer is a Federal government employee who is required to file an OGE 278 when he or she first assumes a position that requires the employee to file an OGE 278. This does not include an employee who filed an OGE 278 in a previous position if less than 30 days have elapsed since leaving that position, or an employee who is not expected to work more than 60 days in a covered position in a calendar year, or certain employees who have filed as nominees or candidates for certain positions.

An incumbent and termination filer is an employee who anticipates terminating his/her covered position employment within 90 days of the annual filing deadline (May 15th) and requests extensions from the appropriate Agency DAEO or designee for up to 90 days. In such a case, the filer may file one consolidated annual and termination report as late as August 13th. If an employee terminates his/her covered position prior to that date, a combined report may be filed no earlier than the date of termination, but must be filed within 30 days of termination of employment. In no event may the combined report be filed after August 13th.

A termination filer is an employee who is leaving a position that had required the filer to file an OGE 278. This report is due within 30 days of leaving the position.

A new entrant report is not required if, within 30 days of assuming your current position, you left another position in which you filed an OGE 278. This would include a general officer who retired from active duty but was recalled within 30 days of retirement.

It is the calendar year of the annual filing due date of May 15. The calendar year covered by the report is the year prior to the year the report is due. For example, the Year Report Due is 2008 for an annual report that is due May 15, 2008 and the report covers calendar year 2007.

Your termination date is the last day in the position. If you continue to be paid after your final day of actually working because you are taking leave days or for any other reason, your termination date is not the last day you actually went to work but the last day you were paid for that position. For military personnel it is usually the day you are entered on the retired rolls (not the day you went on transition leave).

Please contact your Ethics Counselor who will coordinate with the agency DAEO.

A termination filer is an employee who is leaving a position that had required the filer to file an OGE 278. This report is due within 30 days of leaving the position.

The reporting period for an Incumbent report due May 15 annually, covers the preceding calendar year. For example, the reporting period is January 1, 200X through December 31, 200X for an annual Incumbent report that is due by May 15, 200X + 1.

The Senior Legal Counsel assigned to the Organization where you are known as a 278 filer will be selected as your temporary Legal Counsel.

An email will be sent to your Report Certifying Official. You will receive a copy of the email.

Using the pre-populated report facilitates the reporting process and provides for a consistent and accurate disclosure of information from one calendar year to the next.

Please consult your agency's Ethics Counselor.

Yes. If you are serving in a designated combat zone when the report is due (e.g., May 15 for an Incumbent report), the due date is extended to 180 days from either the last day of service in the combat zone or the last day of hospitalization from an injury or disease incurred while in the combat zone, whichever is later. Consult your Ethics Counselor to determine which areas are designated as combat zones.

If you file more than 30 days after the date the report is required to be filed (including any extensions that were granted), you are subject to a $200 late filing fee.

You can request an extension in writing to your Ethics Counselor. Your request must explain why you cannot file by the deadline (e.g., extended travel, significant illness), and you must submit it before the filing deadline.

There is space for only four positions on the printed OGE 278. These four positions are the position for which you are filing plus three other positions held with the Federal Government within the last 12 months. If you held more than four positions with the Federal Government within the last 12 months, you can account for these additional positions in a comment attached to your report. To add a comment to your report, click on "Comments" located in the "My Reports" menu bar. Then click "Add Report Comment" located at the bottom of the page. Enter the required information about your remaining positions (title, organization, and dates held) and save the comment. To return to your report, click "Report Data" in the "My Reports" menu bar, and then Continue through to the Position History page.

If you wear dual hats you must submit a duty description that best describes the nature of your duties.

Yes. The scan may then be attached to the report.

Examples of reportable assets include the following:

(2) Stocks, bonds, securities, and future contracts;

(3) Livestock owned for commercial purposes;

(4) Commercial crops, either standing or held in storage;

(5) Antiques or art held for resale or investment;

(6) Beneficial interests in trusts and estates;

(7) Deposits in banks or other financial institutions;

(8) Pensions and annuities;

(10) Accounts or other funds receivable; and

(11) Capital accounts or other equity interests in businesses.

See online OGE Guide for comprehensive listing and instructions: https://www.oge.gov/Web/278eGuide.nsf

Yes. You must aggregate any cash accounts you have in a single financial institution and report them if they exceed $5000. For example, if you have $1000 in a checking account, $3500 in a savings account, and a $5000 certificate of deposit in the same bank, you must report. Note: For cash accounts held at U.S. financial institutions filers are not required to provide the name of the institution. Rather, filers may simply list "U.S. bank account (cash)" and provide the aggregate values of all cash accounts held at that institution. For multiple banks, just number each one as "#1, #2, etc."

Yes. The money you, your spouse or your dependent child lent to another person is a receivable that you should report in the Assets section. Other receivable assets are reportable, as well. For example, you should report any outstanding compensation that a former employer owes you. You should also report any money that a former customer or client owes you. Such a receivable is reportable if it is currently worth more than $1,000 or from which more than $200 in income was received during the reporting period.

In FDM, this is the date that you eSign (submit) your report for review. This is the date you submit the completed and signed OGE 278 to your supervisor or Ethics Counselor for review. A new entrant must file an OGE 278 within 30 days after assuming a covered position or 5 days after nomination to a PAS (Presidentially Appointed, Senate Confirmed) position.

Examples of reportable assets include the following:

(2) Stocks, bonds, securities, and future contracts;

(3) Livestock owned for commercial purposes;

(4) Commercial crops, either standing or held in storage;

(5) Antiques or art held for resale or investment;

(6) Beneficial interests in trusts and estates;

(7) Deposits in banks or other financial institutions;

(8) Pensions and annuities;

(10) Accounts or other funds receivable; and

(11) Capital accounts or other equity interests in businesses.

See online OGE Guide for comprehensive listing and instructions: https://www.oge.gov/Web/278eGuide.nsf

Retirement Accounts (401K, 403B, etc.), Asset Management Accounts, and Brokerage Accounts are accounts that hold other assets - they are not a standalone investment and have no value or income apart from the underlying assets held within the account. You must report all underlying assets that either: 1) ended the reporting period with a value greater than $1000; or 2) from which more than $200 in income was received during the reporting period. As an exception to this requirement, however, you do not need to report the underlying assets of an investment vehicle that qualifies as an excepted investment fund (EIF). The most common examples of EIFs are publicly traded mutual or exchange traded funds. Indicate whether your entry qualifies an excepted investment fund.

An excepted investment fund (EIF) is an investment fund that is (1) widely held; (2) either "publicly traded or available" or "widely diversified"; and (3) independently managed, meaning you neither exercise control nor have the ability to exercise control over the financial interests held by the fund. A fund is widely diversified if it does not have a stated policy of concentrating its investments in any industry, business, or single country other than the United States or bonds of a single state within the United States.

Report each asset related to your business, employment, or other income-generating activities if the value of the asset at the end of the reporting period exceeded $1,000 or if more than $200 in income was received from the asset during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, anticipated payments such as severance payments, deferred compensation, and intellectual property such as book deals and patents).

Assets acquired separately from your business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account) are reportable, but not as employment related assets. Do not check the employment related asset box for these non-employment related assets.

Yes. You must aggregate any deposit accounts you have in a single financial institution and report them if they exceed $5000. For example, if you have $1000 in a checking account, $3500 in a savings account, and a $5000 certificate of deposit in the same bank, you must report. Note: For cash accounts held at U.S. financial institutions filers are not required to provide the name of the institution. Rather, filers may simply list "U.S. bank account (cash)" and provide the aggregate values of all cash accounts held at that institution. For multiple banks, just number each one as "#1, #2, etc."

Yes. The money you, your spouse or your dependent child lent to another person is a receivable that you should report in the Assets section. Other receivable assets are reportable, as well. For example, you should report any outstanding compensation that a former employer owes you. You should also report any money that a former customer or client owes you. Such a receivable is reportable if it is currently worth more than $1,000 or if more than $200 in income was received during the reporting period.

In FDM, this is the date that you eSign (submit) your report for review. This is the date you submit the completed and signed OGE 278 to your supervisor or Ethics Counselor for review. A new entrant must file an OGE 278 within 30 days after assuming a covered position. Annual reports for incumbent filers are due on or before May 15th of each year (or the next business day).

For you and your spouse, report each source of your and your spouse's earned and other non-investment income over $200 during the reporting period. Do not include income from United States Government employment.

The following are examples of reportable non-investment income that should be reported in the Other Income section:

(1) Salaries, fees, commissions, wages and any other compensation for personal services (other than from United States Government employment);

(2) Retirement benefits (other than from United States Government employment, retirement plans, or from Social Security);

(3) Any honoraria, and the date services were provided, including payments made or to be made to charitable organizations on behalf of the filer in lieu of honoraria; and

(4) Any other non-investment income, such as prizes, awards, or discharge of indebtedness.

Yes. Report the source of a spouse's earned income if it is over $1000. Do not report the actual amount of the income.

If your spouse is self-employed in business or a profession and earned more than $1,000 during the reporting period, report only the nature of such business or profession (e.g., dental practice).If the spouse has formed a business organization (e.g., LLC, LLP, Corporation, Partnership, etc.), report the name of the business and the general industry in which it operates (e.g., IT consulting, legal practice, etc.). You should also report any equity interest that your spouse has in the business itself as an employment related asset.

For you or your spouse, you must report the source, the date of the services performed, and the actual amount of any honorarium over $200, including payments made or to be made to charitable organizations in lieu of honoraria

Underlying assets are assets that are held in another investment vehicle in which a filer has a financial interest. For example, a filer's underlying assets may include the portfolio holdings of a partnership, a trust, or an investment fund. Full disclosure often requires a filer to report both the investment vehicle itself and the underlying assets that it holds, unless the investment vehicle is an Excepted Investment Fund (EIF). For example, if Trust X holds Stocks 1, 2, and 3, you should report both Trust X and Stocks 1, 2, and 3 because the stocks are the underlying assets of the trust.

To the extent that such underlying assets meet the reporting threshold, you must report all underlying assets of a reportable asset except:

You do not need to report the underlying assets of an Excepted Investment Fund (EIF).

You do not need to report the underlying assets of a trust in which you have a beneficial interest if your beneficial interest is not vested.

You do not need to report the underlying assets of a revocable inter vivos trust (also known as a "living trust") if you have (or your spouse or dependent child has) only a remainder interest, provided that neither you, your spouse nor your dependent child is the trust's grantor.

You do not need to report the underlying assets of a revocable inter vivos trust from which you (or your spouse or dependent child) have received a cash distribution, provided that neither you, your spouse nor your dependent child is the trust's grantor. However, you do need to report the exact amount of the cash distribution in the Income section of the OGE 278.

You do not need to report the underlying assets of a qualified blind trust, a qualified diversified trust, or an excepted trust.

First, make sure the parent asset is entered. Then click the "Add Underlying Asset" button in the row of the parent asset. Enter the appropriate information for the underlying asset and click the "Save" button. If the underlying asset's parent asset is incorrect, edit the underlying asset, and check "This is an underlying asset" and select the correct parent asset.

To the extent that such underlying assets meet the reporting threshold, you must report all underlying assets of a reportable asset except:

You do not need to report the underlying assets of an Excepted Investment Fund (EIF).

You do not need to report the underlying assets of a trust in which you have a beneficial interest if your beneficial interest is not vested.

You do not need to report the underlying assets of a revocable inter vivos trust (also known as a "living trust") if you have (or your spouse or dependent child has) only a remainder interest, provided that neither you, your spouse nor your dependent child is the trust's grantor.

You do not need to report the underlying assets of a revocable inter vivos trust from which you (or your spouse or dependent child) have received a cash distribution, provided that neither you, your spouse nor your dependent child is the trust's grantor. However, you do need to report the exact amount of the cash distribution in the Income section of the OGE 278.

You do not need to report the underlying assets of a qualified blind trust, a qualified diversified trust, or an excepted trust.

To the extent that such underlying assets meet the reporting threshold, you must report all underlying assets of a reportable asset except:

You do not need to report the underlying assets of a qualified blind trust, a qualified diversified trust, or an excepted trust.

You do not need to report the underlying assets of an Excepted Investment Fund (EIF).

You do not need to report the underlying assets of a trust in which you have a beneficial interest if your beneficial interest is not vested.

You do not need to report the underlying assets of a revocable inter vivos trust (also known as a "living trust") if you have (or your spouse or dependent child has) only a remainder interest, provided that neither you, your spouse nor your dependent child is the trust's grantor.

You do not need to report the underlying assets of a revocable inter vivos trust from which you (or your spouse or dependent child) have received a cash distribution, provided that neither you, your spouse nor your dependent child is the trust's grantor. However, you do need to report the exact amount of the cash distribution in the Income section of the OGE 278.

The following are examples of reportable non-investment income that should be reported in the Other Income section:

(1) Salaries, fees, commissions, wages and any other compensation for personal services (other than from United States Government employment);

(2) Retirement benefits (other than from United States Government employment, including the Thrift Savings Plan, or from Social Security);

(3) Any honoraria, and the date services were provided, including payments made or to be made to charitable organizations on behalf of the filer in lieu of honoraria; and

(4) Any other non-investment income, such as prizes, awards, or discharge of indebtedness.

Report the source of a spouse's earned income only if it is over $1000. Do not report the actual amount of the income.

For you or your spouse, you must report the source, the date of the services performed, and the actual amount of any honorarium over $200.

The following are examples of reportable non-investment income that should be reported in the Other Income section:

(1) Salaries, fees, commissions, wages and any other compensation for personal services (other than from United States Government employment);

(2) Retirement benefits (other than from United States Government employment, including the Thrift Savings Plan, or from Social Security);

(3) Any honoraria, and the date services were provided, including payments made or to be made to charitable organizations on behalf of the filer in lieu of honoraria; and

(4) Any other non-investment income, such as prizes, awards, or discharge of indebtedness.

Yes, you must report any honorarium that you have received, even if it is donated to charity. If you specify or recommend that the payor give the honorarium directly to a charity, you still have "received" the honorarium and must report it.

Examples include scholarships, prizes, awards, bonuses, severance pay, and deferred compensation.

If your interest in the partnership is greater than $1,000 or has generated income over $200 during the reporting period, you are required to report any underlying assets, unless it is an Excepted Investment Fund (EIF). See the Glossary for information regarding the criteria for meeting the EIF standard. In some cases involving hedge funds, you may be unable to obtain the names, values and income amounts of the underlying assets. If this is the case, report just the name of the hedge fund and its overall value and income. You will have to obtain a letter from the fund manager stating that the fund does not disclose asset and income information to its investors, and that no exception will be made for you. In such a case, non-disclosure of underlying assets will be permitted when you file your first OGE 278, but you will have to divest the partnership because you will be unable to meet the Ethics in Government Act's continuing requirement to fully disclose your assets.

If your interest in the partnership is greater than $1,000 or has generated income over $200 during the reporting period, report the partnership in Assets. Enter the name of the limited partnership and a brief description of its purpose or operations (i.e. "Office building rental in Portland, Oregon" or "Investment partnership"). If it is not publicly traded, also include its location (city, state). Select the category of asset value that reflects your interest in the partnership. Report the actual amount of partnership income you have received in "Other Income." For investment partnerships that do not meet the Excepted Investment Fund (EIF) standard, each underlying asset that meets the reporting threshold must be reported in Assets as a separate line item. See the Glossary for information regarding the criteria for meeting the EIF standard.

Additionally, any purchases, sales or exchanges over $1,000 that you have made of your partnership interest or of its underlying assets should be reported in Transactions. As a reminder, the $1,000 threshold refers to the value of the transaction, not the amount of gain or loss.

Finally, if you are a general partner of the limited partnership, the position should be reported in Outside Positions; if you received compensation over $5,000 for this position, it should be reported in Compensation.

This purchase or sale must still be reported in the Transactions section whether the asset or income is listed in the Assets section. You may add a comment that the asset itself was not reportable in the Assets section.

You must report transactions involving any entity unless the entity is an Excepted Investment Fund (EIF). However, you do not need to report transactions made by a business entity that you own if the transaction is incidental to the primary trade or business of the entity.

An exchange generally occurs when one company acquires another. The shareholders of the acquired company are often given the option to sell their shares to the acquiring company or exchange their existing stock for stock of the acquiring company. When a filer exchanges his/her stock, they must specify both the stock tendered and the stock acquired in its place.

Example: ABC Corporation recently acquired XYZ Corporation. ABC gave its shares to the shareholders of XYZ in exchange for their XYZ shares. A filer would report this exchange on Schedule B, Transactions.

You must specify both the assets divested and the assets acquired in their place. Accordingly, this will usually require reporting the two exchanged items as separate entries.

List the item name once, in the Transaction Information area select purchase, sale or exchange, then for "Number of Transactions" select multiple, and the aggregate amount of the sales or purchases.

Only those transactions that individually exceed $1,000 need to be reported. Filers may combine multiple purchases (or sales) for a single security. This includes dividends reinvested from a single security or mutual fund.

Example: A filer who purchases $1,100 per month of a particular mutual fund may report one transaction in the $1,001-15,000 range with the number of transactions as multiple. A filer who purchases only $50 per month of a particular mutual fund does not report the individual transaction ($50 each month) or the aggregate value of the monthly purchases ($600) because the aggregate transactions are below the $1001 reporting threshold.

You do not need to provide geographic information about publicly traded companies (e.g., Exxon Mobil). You do need to provide geographic information about less well-known assets, such as a private real estate partnership.

An EIF is a basic concept that reduces the degree of disclosure of certain investments. The concept of the EIF was created by statute and is solely a characterization for financial disclosure purposes.

An EIF is a pooled investment vehicle (e.g., mutual fund, unit investment trust, exchange traded fund, partnership) that meets the test described below. Unless a pooled investment vehicle qualifies as an EIF, you should report its underlying assets. An EIF is an investment vehicle that is:

2. either (a) publicly traded (or publicly available) or (b) widely diversified; and

3. independently managed, which means that it is arranged so that the filer neither exercises control nor has the ability to exercise control over the assets held in the investment vehicle.

To qualify as an EIF, an investment vehicle must satisfy the requirements of both paragraphs 1 and 3 above, and either 2(a) or 2(b). With regard to 2(b), a fund is "widely diversified" if it does not have a stated policy of concentrating its investments in any industry, business, or single country other than the United States or bonds of a single state within the United States.

It is extremely unusual for a filer to have a qualified trust. No trust is a qualified trust unless the U.S. Office of Government Ethics certified it as a qualified trust at the time it was established. If you think you have a qualified trust, you should contact your Ethics Counselor to discuss the standard for qualified trusts before designating a trust as a qualified trust on your financial disclosure report.

Unlike a "529" college savings plan, a "529" prepaid tuition plan will not involve reportable underlying transactions. You should report a "529" prepaid tuition plan in the Assets section, but you do not need to report a "529" prepaid tuition plan in the Transactions section.

Full disclosure requires you to report transactions of the investment vehicle itself, and if the investment vehicle does not qualify as an Excepted Investment Fund, transactions of its underlying assets. Report purchases, sales, and exchanges of the investment vehicle itself by selecting the Mutual Fund, Investment Fund, or Pool radio button. If the pooled investment vehicle qualifies as an Excepted Investment Fund (EIF), select the EIF radio button. If the investment vehicle does not qualify as an EIF, report transactions of its underlying assets. For example, if Partnership Y purchased Stocks 1, 2, and 3 for $1,500 each during the reporting period, you should report each purchase as a separate transaction (type of asset: Stock).

A relative is any individual who is your husband, wife, son, daughter, father, mother, brother, sister, grandfather, grandmother, grandson, granddaughter, uncle, aunt, great uncle, great aunt, first cousin, nephew, niece, father-in-law, mother-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, stepfather, stepmother, stepson, stepdaughter, stepbrother, stepsister, half brother, half sister, your spouse's grandfather or grandmother or your fiancé or fiancée.

Personal hospitality of any individual means hospitality extended for a non-business purpose by an individual, not a corporation or organization, at the personal residence of, or on property or facilities owned by, that individual or his family.

Gifts of travel for personal or unofficial purposes, and gifts of training under 5 U.S.C. § 4111 must be reported on OGE 278 if they exceed $390. Consult your Ethics Counselor if you have any questions. You do not need to report on the OGE 278 a gift of travel, lodging, or meals accepted from a non-Federal source under 31 U.S.C. § 1353. To accept such a gift to the Government, you must have obtained approval from your Travel Approving Official (after consultation with an Ethics Counselor). Such gifts valued in excess of $250 must be reported separately to your Ethics Counselor. Travel expenses for your spouse must first be approved by the Secretary of the Army.

Yes, you must report on your OGE 278 gifts of travel received as part of a job interview process.

You must disclose the travel itinerary, the dates of travel, the nature of expenses provided; and a description of the gift. Reporting of the gift must include the identity of the source, the address of the source, and the fair market value of the gift.

You must disclose the travel itinerary, the dates of travel, the nature of expenses provided and a description of the reimbursement. Reporting of the reimbursement must include the identity of the source, the address of the source, and its fair market value.

You must report on the OGE 278 that the gift was received pursuant to the Government Employees Training Act, 5 U.S.C. Section 4111. This authority allows a government employee to accept travel expenses from certain non-profit organizations for training or meetings, even though the trip is for official duty. In addition, the filer must disclose the following: the travel itinerary, the dates of travel, the nature of expenses provided and a description of the gift. Reporting of the gift must include the identity of the source, the address of the source, and the fair market value of the gift.

You must identify the source of a gift, and provide a brief description and value of the gift, if all gifts that you received from that source exceed $390. When calculating the aggregate value of reportable gifts from one source, you do not need to include any individual gift that is worth $156 or less. If the aggregate value is $390 or greater, you should report all individual gifts from that particular source that are worth more than $156. If the aggregate value is no more than $390, you do not need to report any gifts from that source, regardless of the value of the individual gifts. For example: A filer received three gifts this year from the same source. Gift 1 was worth $55; Gift 2 was worth $255; Gift 3 was worth $151. In this hypothetical situation, Gift 1 is not included in the aggregate value of gifts from the source because it is not worth more than $156. The filer should add only Gift 2 and Gift 3 to determine the aggregate value of reportable gifts. In this case the aggregate value is $406 ($255 + $151). This aggregate value is greater than the $390 reporting threshold. Therefore, the filer should report both Gift 2 and Gift 3 on the OGE 278.

Reportable gifts include tangible items, food, lodging, transportation or entertainment received by you, your spouse or your dependent child. Reportable reimbursements are any cash reimbursements (except those from the United States Government or otherwise excluded) aggregating more than $390 that you, your spouse or your dependent child received from any one source. Reportable travel expenses are travel related expenditures received from sources other than the US Government, by you, your spouse, or your dependent child. However, you do not need to report gifts your spouse and dependent children received when such gifts are given to them independent of their relationship to you.

Examples of liabilities are mortgages on rental property, student loans, investment loans, and personal lines of credit. If you are a general/flag officer or Presidentially Appointed, Senate Confirmed (PAS) official, you must report a mortgage or home equity loan secured by your personal residence as you would a mortgage on any other property.

You do not have to report loans on automobiles or household furniture. You do not have to report mortgages on your personal residence unless your personal residence is rented out. You do not have to report loans against your Thrift Savings Plan (TSP). You do not have to report a personal liability owed by you, your spouse or dependent child to you or your spouse or to the parent, brother, sister or child of you, your spouse or your dependent child. Exception: If you are a general/flag officer or Presidentially Appointed, Senate Confirmed (PAS) official, you must report a mortgage or home equity loan secured by your personal residence as you would a mortgage on any other property.

Yes. You do report such a loan, but you do not report it in the Liabilities section. The money you, your spouse or your dependent child lent is a receivable you need to report in the Assets section. Other types of receivables are reportable in the Assets section, as well. For example, you should report in the Assets section any outstanding compensation that a former employer owes you. You should also report in the Assets section any money that a former customer or client owes you. Such a receivable is reportable if it is currently worth more than $1,000 or if it produced more than $200 in income during the reporting period.

Only if the outstanding liability exceeds $10,000 at the end of the reporting period.

Examples of liabilities are mortgages on rental property, student loans, investment loans, and personal lines of credit.

A filer need not report the following:

Any liability owed to a spouse or dependent child, or to a parent, sibling, or child of the filer, her spouse, or her dependent child;

Any mortgage or home equity loan secured by a personal residence of the filer or spouse, unless the personal residence is rented out or any loans of a townhouse, condominium, or cooperative association when the filer uses the townhouse, condominium or cooperative as a personal residence. Exception: General/Flag Officers and Presidentially Appointed, Senate Confirmed (PAS) officials must report a mortgage or home equity loan secured by their personal residence as they would a mortgage on any other property.

Any loan secured by a personal motor vehicle, household furniture, or appliances, if the loan does not exceed the item's purchase price;

Any revolving charge account, such as credit card balances, where the outstanding liability did not exceed $10,000 at the close of the reporting period;

Any liability of the filer's spouse or dependent child which meets the four tests for separateness of assets;

Obligations arising from a filer's divorce or permanent separation; or

Liabilities that are solely incidental to the primary trade or business of an entity reported as an Asset.

No, you do not have to report a mortgage or home equity loan secured by your or your spouse's personal residence, unless the personal residence is rented out. Exception: If you are a general/flag officer or Presidentially Appointed, Senate Confirmed (PAS) official, you must report a mortgage or home equity loan secured by your personal residence as you would a mortgage on any other property.

No. Provide only the creditors' city and State.

Only if the outstanding liability exceeds $10,000 at the end of the reporting period.

In the interest rate section of the information area, select Formula and indicate the formula (e.g., Prime +2%).

Yes, if the aggregate amount owed to any single broker exceeds $10,000 during the reporting period.

Except for credit card/revolving charge card debts select the range with the highest amount owed during the reporting period. For credit card/revolving charge card debts report the range with the amount owed at the end of the reporting period.

Examples include future employment; leaves of absence from a former employer; continuing payments from a former employer, including payments not yet received for previous work; and continuing participation in a former employer's employee welfare, retirement, or other benefit plan.

Yes, you must report severance agreements.

Yes, you must report any arrangements or agreements for future non-Federal employment.

No. Information concerning employment by the Federal Government or other benefits received from the United States is not reportable.

You should describe the terms of the agreement or arrangement. The description should identify what will happen under the agreement or arrangement (e.g., you will retain, forfeit or roll-over certain equity interests in your former employer; you will receive a certain number of payments in a specified amount; etc.), as well as the timing.

You should report any other agreement in which a former employer has committed to provide compensation, equity or benefits to you in the future. Such agreements sometimes provide for future payments or grants of equity.

Reportable positions include, but are not limited to, those of an officer, director, trustee, general partner, proprietor, representative, employee, or consultant of any for-profit or non-profit organization (whether compensated or uncompensated). Do not include positions held as part of your official duties with the United States Government; positions with religious, social, fraternal or political entities; positions solely of an honorary nature; mere membership in an organization; and passive investment as a limited partner or non-managing member of a limited liability company. Also, do not report service as a member of ad advisory board or committee if the following criteria are met: (1) the advisory board or committee is that of a non-profit or governmental organization; (2) your service is unpaid; (3) you have no fiduciary duties of the sort exercised by officers, director, or trustee; and (4) your role does not involve sufficient supervision by the organization to create a common law employee-employer relationship.

Reportable positions include, but are not limited to, those of an officer, director, trustee, general partner, proprietor, representative, employee, or consultant of any corporation, firm, partnership, non-profit organization, educational institution or other business enterprise. You must report these positions regardless of whether or not you received compensation for holding the position. Do not include positions held with religious, social, fraternal or political entities. Do not include positions solely of an honorary nature and for which you have no fiduciary obligations; mere membership in an organization; and passive investment interests as a limited partner or non-managing member of a limited liability company.

For New Entrant Filers, the reporting period is the preceding two calendar years and the current calendar year up to the date of filing.

Report the names of any client for whom you personally provided more than $5,000 in services, even if the client directed payment to your employer. Do not report payments to your employer if you were not directly involved in providing the services. For example, an associate with the law firm of Doe, Jones, & Smith earned $150,000 last year and provided services to one of the firm's clients, Metro University. Metro University paid the firm over $5,000 for the associate's services. Zed Construction also paid the firm over $5000 last year, but the associate did not provide any services to Zed Construction.

The associate should report the following sources of compensation over $5,000:

Doe, Jones & Smith; Hometown, State - Legal services

Metro University; Moneytown, State - Legal services

The associate should not report Zed Construction as a source because the associate was not directly involved in providing legal services to Zed Construction.

Report the source, such as a law firm. Also, report as a separate line item the name of each client for whom you directly provided services that generated a fee or payment of more than $5,000. Briefly describe the nature of services rendered (e.g., "legal services").

The name of a source of compensation may be excluded only if that information is specifically determined to be confidential as a result of a privileged relationship established by law and if the disclosure is specifically prohibited: (1) by law or regulation, (2) by a rule of a professional licensing organization, or (3) by a client agreement that at the time of engagement of the filer's services expressly provided that the client's name would not be disclosed publicly to any person. If you exclude the name of any source, you must indicate in the report that such information has been excluded, the number of sources excluded, and, if applicable, a citation to the statue, regulation, rule of professional conduct, or other authority pursuant to which disclose of the information is specifically prohibited. If you have any questions about reporting a client's name, consult your Ethics Counselor.

Consult your ethics advisor. In rare circumstances a filer need not disclose a confidential relationship. For example, if a filer and his client entered into a confidentiality agreement at the time the Filer's services were retained, then disclosure of the client's name may not be required. In addition, if the Filer represents a client in a matter that is covered by a court order or is under seal; that involves a grand jury investigation; or that involves some other non-public investigation and there are no public filings or statements, disclosure of the client name is not required. Finally, if disclosure is prohibited by a specific bar rule provision, disclosure of the client is not required. If certain clients are not disclosed because of the above reasons, enter this in the Name box: "Confidential client not reported".

Flags identify missing or incomplete information. Red flags identify required information that must be provided before the report is considered complete for filing (submission). Yellow flags are cautionary for report reviewers and may cause a request for additional information.

To view the red flags, select Review my Flags and click Continue on the Report Not Ready for Submission page. Or, click on the Flags menu item under the My Reports tab.

When you are ready to submit your report, click on eSign in the Report Data progress bar to get back to this page. Or, you can click Continue through the report to the eSign.

Only the filer can submit his/her report; a filer's assistant cannot submit a report for a filer. When you are ready to submit your report, click on eSign in the Report Data progress bar to get back to this page. Or, you can click Continue through the report to eSign.

The Joint Ethics Regulation requires DoD personnel who file Public Financial Disclosure Reports (OGE 278) certify annually that they are aware of the disqualification and employment restrictions in 18 U.S.C. 207 and 208, and 41 U.S.C. 423, and that they have not violated those restrictions. The Annual Post-Employment Certification and Notification contains the contents of those provisions. FDM users complete the required certification and acknowledgement concurrent with certifying the accuracy of the information reported in the OGE 278 when eSigning (submitting) the report. The FDM Resources page has the current and previous Post-Employment Certifications for the current and previous years.

No. Unlike the combat zone extension to file a Public Financial Disclosure Report (OGE 278), DoD has not authorized such an extension for the Annual Post-Employment Certification and Notification. Instead, FDM DoD users who are not efiling their OGE 278 in FDM should check the FDM Resources page to select and print the certification for the current calendar year. The annual certification must be completed and forwarded to your Ethics Counselor/SJA/Legal Advisor by the end of the current calendar year. Consult your Ethics Counselor for additional information.