IEC Journal

Govt attorney pleads guilty to conflict of interest

Consumer Products Safety Commission attorney plead guilty to a conflict of interest violation and filing false statements on his "ethics forms."  The charges stem from his claim to have “Insider Knowledge” in advertising his private law practice and his failure to disclose this outside business on his disclsoure reports.  He also represented a private client before the Federal Government.

Read the full DOJ press release, see http://www.justice.gov/usao/md/Public-Affairs/press_releases/press08/GovernmentLawyerGuiltyofConflictofInterestandFilingFalseDisclosureForms.html.

IT Contractor's Security Lapse on Disclosure Forms Creates Big Headaches for SEC

This morning's New York Times reports:

Two years ago, the S.E.C. began monitoring its employees’ investments more closely to allay public concern about possible conflicts of interest. Until then, its ethics office had encouraged employees to police themselves by checking a limited database of prohibited transactions.

The new system required employees to use a more comprehensive database, the Ethics Program System, to clear their securities transactions in advance and to record details about their financial holdings. To manage E.P.S., the agency hired Financial Tracking Technologies of Riverside, Conn., which provides similar services for money managers and large public companies.

At the time, the S.E.C. assured its employees that their brokerage account numbers and other financial data would be safe. The S.E.C.’s security personnel, the agency said, would test and audit the system. Besides, only “a small number of employees at the contractor” would have access to E.P.S., and those employees would undergo rigorous background checks, according to an e-mail sent to S.E.C. employees in the fall of 2009.

As it turns out, the IT contractor did not fulfill its security representations. The Times article describes the SEC's efforts to contain the problem and prevent similar issues. A National Treasury Employees Union representative noted:

This is particularly disturbing since the S.E.C. apparently had no mechanism to ensure that the outside contractor was maintaining the appropriate level of privacy and security in handling this private data.

By this time our more thoughtful ethics official readers will be asking themselves:

    How does my agency's security for financial disclosure information in electronic format stack up?

Determining Who Should File SF 450

Think maybe you are requiring too many people to file SF 450 forms? Not enough? 

One place to seek help is the analytical aid OGE released in 2009.

Update: With today's upgrade of the OGE website, the material is at a different URL. Thanks to Patrick Sheperd for the tip. 

OGE updates regs for gift reporting

The Office of Government Ethics issued its final rule (technical amendment) increasing the financial disclosure reporting threshold for gifts from $335 to $350, to correspond with the Foreign Gifts & Decorations Act.  See 5 CFR 2634.304 and 2634.907(g).  The rule is effective July 1, 2011, and retroactive to January 1, 2011.  The rule also increases the threshold for exclusion for individual items from $135 to $140.  The amendment also increases the gift exception ceiling for non-sponsor gifts of free attendance at widely attended gatherings.  See 5 CFR 2635.204(g).

See Fed. Reg. notice at http://www.gpo.gov/fdsys/pkg/FR-2011-07-01/pdf/2011-16642.pdf.

Former Army Contracting Officials Charged with ... Filing False Ethics Forms

A Justice press release reports that a former Army contracting official and his spouse were indicted for conspiracy to defraud the US, filing false tax statements, and filing false statements on their Government ethics financial disclosure documents.  See full press release at http://www.justice.gov/opa/pr/2011/June/11-tax-821.html.

President's 2010 Public Financial Disclosure Report Released

Cnn.com ran an article this morning that discusses the changes to President Obama's investments, as reflected on his 2010 public financial disclosure report, released Monday.  Among the biggest changes from last year's report- more college savings in his 529 plans and large investments in U.S. Treasury securities.  The President and Vice-President's reports are posted on the White House web site.

Interesting articles on Congressional Financial Disclosures

Amanda Becker authors an interesting article about Congressional financial disclosure requirements and penalties.  See full article at http://www.rollcall.com/issues/56_119/financial-disclosure-congress-205462-1.html.  She previously published another article on the same revision of the instruction manual from the House Ethics Committee, which avoided including same-sex spouse interests as a reportable information.  See http://www.rollcall.com/issues/56_117/financial-disclosure-same-sex-couples-205356-1.html?pos=adp.

For access to the new House Ethics Committee guidance, see: http://ethics.house.gov/Subjects/List.aspx?subid=6 

Confirmation Process Reforms Proposed

Via The American Prospect

It's hard to overstate the extent to which the confirmation process has become a mess for everyone involved; presidents are responsible for filling thousands of positions, nominees are forced to endure endless background checks and intense personal scrutiny, and appointees -- even minor ones -- face the prospect of needless, partisan obstruction in the Senate. Over the years, a bevy of experts have offered a stream of suggestions on how to reform the process, but they tend to fall on deaf ears, for mostly straightforward reasons. Simply put, legislators are incredibly loath to give up influence, particularly when it affords them an opportunity to pressure the administration; it's not rare for presidential appointees to become bargaining chips in legislative fights, either as hostages (to be used against the White House) or as sweeteners (from the president) to placate lawmakers.

Resolving Conflicts If Google Exec Appointed to Cabinet

An IEC member tipped us off to a wonderful CNN article about conflicts of interest implicated by a possible appointment of Google Chairman Eric Google to be Secretary of Commerce. Here's an excerpt:

"Putting it in a blind trust would be hopelessly ineffective," said Alan Morrison, professor at George Washington Law School. "It's the worst kind of fig leaf, because it's not 'blind' in any sense of the word. What's Schmidt going to say? 'Do I own Google? Really?'"

The Office of Government Ethics mandates that employees of the executive branch can't own more than $15,000 of a stock or asset that would conflict with their work. Going from $5 billion to $15,000 isn't going to happen in a day.

To get around that requirement, the OGE allows people in conflict to recuse themselves from certain activities. That means even after his Google shares are put in trust, Schmidt would still have to recuse himself if a conflict arises with Google.

The good news for Schmidt is that the Department of Commerce doesn't deal all that heavily in Google's businesses.

Articles about high-profile, real-life occurrences make some of the best training material. It's hard to imagine a better example than this to illustrate the OGE 278, financial disclosure and divestiture of assets.

IEC Journal lives or dies by reader contributions, so keep us in mind when you come across something of interest to the community, especially something this useful.

 

What Information to Report on OGE Form 450

Not sure what should be reported on the OGE Form 450?

Here is a reformatted version of a resource list Mark Stone distributed last year.  As always, we welcome reader suggested additions and improvements:

1. The Confidential Financial Disclosure Report form (OGE Form 450). This contains some very good instructions. 
2. OGE's Frequently Asked Question (FAQ) sections, one for filers of the OGE Form 450, and one is for ethics officials who review the OGE Form 450. 
3. OGE's Guidance for Reviewers of the OGE Form 450, Part I (Assets & Income) (2008).
4. DAEO-Gram entitled “Diversified and Sector Mutual Funds.” (August 25, 2000). Contains guidance on how to determine whether a mutual fund is a “diversified mutual fund” (which does not have to be reported) or a “sector mutual fund” (which does have to be reported).  At the end of the memo are two helpful lists (lists of examples of each type of fund).
5. Public Financial Disclosure:  A Guide to Reporting Selected Financial Instruments (2008). Contains guidance on how to report 20 sophisticated financial assets (such as American Depositary Receipts and Phantom Stock).  Originally intended as guidance for the Public Financial Disclosure Report (SF 278), it can also be useful when completing or reviewing the OGE Form 450.  
6. 5 C.F.R. 2634.90

Former Staff Member in U.S. House of Representatives Convicted on Corruption Charges

A jury found a former staff member in the U.S. House of Representatives guilty on corruption charges relating to his acceptance of an all-expenses paid trip to Game One of the 2003 World Series.  See DOJ Press Release at: http://www.justice.gov/opa/pr/2011/February/11-crm-176.html.  Charges included lying on his financial disclosure about the gift from a lobbyist.

Thomas to amend financial disclosures for past 13 years

Supreme Court Justice Thomas neglected to include it, as required, on the report of his spous's positions with Michigan's Hillsdale College, the Heritage Foundation and the Republican leadership in the House. Thomas blamed the error on misunderstanding the filing instructions.  See Washington Post article at http://www.washingtonpost.com/wp-dyn/content/article/2011/01/24/AR2011012404092.html or CNN article at http://www.cnn.com/2011/US/01/24/thomas.financial.disclosure/index.html.

To view Supreme Court Justices' financial disclosures see http://moneyline.cq.com/flatfiles/editorialFiles/moneyLine/reference/scotus/scotus.html.

SF 450 Review Checklist

The Pipeline and Hazardous Materials Safety Administration (PHMSA) was gracious enough to provide their formatted user-friendly, one-page checklist to help with OGE Form 450 reviews.  It is based on their interpretation of materials and notes from an OGE course.

Download 450 Review ChecklistPHMSA

We very much appreciate PHMSA's generous spirt, and we strongly encourage other IEC members to share their similar work products.  We can all operate more efficiently if we are not constantly reinventing the wheel. We have been receiving many more user contributions this month. Please help continue this desirable trend!

OGE 2009 Prosecution Survey

The Office of Government Ethics issued DAEOgram DO-10-017 on November 9, 2010 announcing the publication of the 2009 Conflict of Interest Prosecution Survey.   The survey contains summaries of cases involving conflict of interest violations.  The Department of Justice prosecuted the cases. See http://www.usoge.gov/ethics_guidance/daeograms/dgr_files/2010/do10017.pdf

Difference in conflict rules for Congressional and Executive Branch Personnel

An interesting article from the Wall Street Journal which discusses how Congressional staffers can gain from trading on stock related to the Congressional work without fear of legal consenquences in part because Insider Training rules don't apply to Congress.  See full article at http://online.wsj.com/article/SB10001424052748703431604575522434188603198.html#

Full Disclosure for Military Mentors

A Federal Times story discusses a development in the "senior mentor" issue.  Here's the lead:

After pressure from two key senators, the Pentagon has reversed course and will require that the retired generals and admirals it hires as consultants file public, not confidential, financial disclosure statements, according to letters from Congress and the Defense Department.

Senators Carl Levin, D-Mich., and John McCain, R-Ariz., the chairman and ranking member on the Armed Services Committee, told the Pentagon that "senior mentors exercise a level of ... influence" that demands public disclosure. They wrote that if the Pentagon resisted, they would propose legislation mandating it.

Questions About Medicare Chief Interests

A Washington Times article raises questions about possible undisclosed conflicts of interest on the part of the chief administrator for Medicare and Medicaid: 

White House officials say Dr. Berwick is in full compliance with all ethics rules, and his financial disclosure form instructs nominees to list only former clients of a business or nonprofit in which the nominee was directly involved in providing a service for a fee for more than $5,000.

Dr. Berwick, 63, would have faced standard questioning about the finances of the Massachusetts-based nonprofit group if he had gone through the normal confirmation process, but his recess appointment last month means he can serve until the end of the next session of Congress without a Senate vote or a hearing. ...

"Dr. Berwick will be responding to Senator Grassley's letter," White House spokesman Reid Cherlin said. "But the independent office of government ethics has certified that Dr. Berwick is in full compliance with all of the ethics rules and conflict rules that Congress has set forth."

Scrutiny of Military Senior Mentor Program

This morning's USA Today has an article discussing the loosening of financial disclosure requirements in the Pentagon's "senior mentor" program. 

SF-278 Forms for Pres & V.P. Available

2009 financial disclosure forms for the President and Vice President are available at the White House web site. These could make good training examples.

FBI Agent Indicted for Ethics Violations

An FBI agent in Oxford, Mississipi has been indicted for, among other things, failing to disclose to the FBI the fact that he had a financial interest in an under-construction building Oxford FBI Building, and failing to truthfully complete an annual report of his assets and income, liabilities, and positions with organizations outside of his FBI employment.  The indictment further alleges that the agent knowingly and willfully made and used, and caused to be made and used, a false writing and document (that is, his 2004 and 2005 Confidential Financial Disclosure Reports), knowing the Reports to contain material false and fraudulent statements and entries. A DOJ press release is available.

Mark Stone: What Must Be Reported on SF-450

Mark Stone's e-mail newsletter is a great source of ethics information. His annotated bibliography of guidance on what must be reported on a Form 450 is a recent example. Old issues of the newsletter are available on the Air Force Materiel Command (AFMC) ethics website (registration required). Contact Mr. Stone to be added to the mailing list (address modified to reduce spam):

Mark --DOT-- Stone --AT-- wpafb -- DOT af --DOT-- mil

Former DHS Chief Nominee Guilty of Lying to White House Vetters

Kerik Confesses to Cheating I.R.S. and Telling Lies - NYTimes.com.

Bernard B. Kerik, a former detective who rose to lead the New York Police Department through the 9/11 attack before his career crumbled in scandal, pleaded guilty Thursday to eight charges including tax fraud and lying to White House officials.

Proposed FAR Change To Address Contractor Employee Conflicts of Interest

A November 13 Federal Register notice outlines a proposal to amend the Federal Acquisition Regulation (FAR) to address personal conflicts of interest by employees of Government contractors.

Government Executive has analysis of the proposal, including these comments:

But the burden for enforcing the rule -- written by the Civilian Agency Acquisition Council, Defense Acquisition Regulations Council and the Office of Federal Procurement Policy -- is placed almost exclusively on the contractor.

The company would be required to inform covered employees of their obligation to disclose and prevent "even the appearance of personal conflicts of interest." To enforce the rule, the contractor would be required each year to obtain, maintain and update financial disclosure statements from each covered employee assigned to a task under the contract.

The disclosure statement would spell out all personal conflicts of interest the employee could face in impartially executing the contract, including the financial assets of the worker or their close family members. The rule stipulates a host of financial connections that must be disclosed, including salaries, consulting relationships, research funding, stocks and real estate.

The deadline for comments on the proposed rule is January 12, 2010.

Vetting Gone Wrong

Fedblog has some comments about the vetting process in the case of the recent TSA nominee:

Tax errors and employer reprimands are the front line of things that show up in a background check of someone. If you miss them, something is wrong. And it's unstrategic to have this stuff leak out the way it has. It means you're setting up your own minefield, and forcing your own people to walk through it with you. I have no idea how things got to this state, but it's pretty pronounced.

Controversy Over Failure To Disclose Lobbying Tie

The Washington Times reports on a controversy involving a Department of Homeland Security nominee.  Here's an excerpt:

Dr. Tara O'Toole, whose confirmation as undersecretary of science and technology is pending, never reported her involvement with the lobbying group called the Alliance for Biosecurity in a recent government ethics filing.

The alliance has spent more than $500,000 lobbying Congress and federal agencies -- including Homeland Security -- since 2005, congressional records show.

However, Homeland Security officials said Dr. O'Toole need not disclose her ties to the group on her government ethics form because the alliance is not incorporated: "There's no legal existence so she wouldn't have to disclose it," said Robert Coyle, an ethics official for the Department of Homeland Security.

Analysts say the lack of disclosure reflects a potential loophole in the policies for the Obama administration, which has boasted about its efforts to make government more transparent. They also question lobbying laws that allow such a group to spend hundreds of thousands of dollars without the public knowing exactly how much money each of the companies that belongs to the group contributes, though such arrangements are permitted under the law.

"You're not allowing the public to know the full background of this nominee," said Judy Nadler, a senior fellow at the Markkula Center for Applied Ethics at Santa Clara University in California. "It shouldn't matter whether it's incorporated or not."

Craig Holman, legislative director of the nonpartisan watchdog group Public Citizen, said the lack of disclosure "definitely and clearly runs counter to the intent of the law."

Ethics rules require nominees to report any paid or unpaid positions held outside of government, including but not limited to those of "officer, trustee, general partner, representative, employee or any consultant of any corporation, firm, partnership or other business enterprise ...." Dr. O'Toole signed a letter on behalf of the group sent to the White House as recently as March.

Opening Arguments in Safavian Retrial

Government Executive has a story about the first day of former GSA contracting official David Safavian's retrial. Here's an excerpt:

Prior to the trip, Safavian solicited the opinion of a GSA ethics officer about the appropriateness of accepting free travel from Abramoff. Safavian told the ethics officer that Abramoff "did not have business with GSA" and that he worked only on Capitol Hill.

The ethics officer wrote that Safavian could accept the trip for free. Nonetheless, before the trip began, Safavian wrote Abramoff a check for $3,100, a figure Abramoff allegedly suggested would cover Safavian's portion of the costs.

"Safavian was the only person who wanted to pay his fair share," Sauber said.

Prosecutors, however, argued that Safavian knew $3,100 would not cover his portion of the excursion, which ultimately cost a combined $150,000.

Edmonds added that Abramoff's "lobbying" of Safavian for the two GSA properties was tantamount to doing business with the agency. That information, he said, should have been passed along to the ethics officer before the trip.

"The evidence will confirm the simplicity of this case," Edmonds said. "It's about a public official lying about what's going on."

The information Safavian shared with Abramoff was not secret, nor was it valuable, defense attorneys said. The post office was not up for bids and the White Oak land was highly contaminated and was not suitable for a school, they noted.

Safavian's attorneys maintained that Abramoff did not have business with the GSA because the lobbyist did not have a contract with the agency. Sauber plans to call government witnesses who will corroborate Safavian's interpretation of "doing business."

OGE issue Guide on Reporting Select Financial Instruments

The Office of Government Ethics issues "Public Financial Disclosure: A Guide to reporting Selcted Financial Instruments."

OGE Guidance on Reviewing Final PAS Financial Disclosure

In anticipation of the upcoming change in administrations, OGE has issued new guidance on review and certification of mandatory public financial disclosure termination reports (SF 278s).

New OGE Crossword Puzzle Available

The newest OGE training crossword puzzle is on the subject of SF 278 Financial Disclosure. The DAEOgram announcing it has information on system requirements.

Reminder: Public Financial Disclosure Reports Due Friday

Unless you have received an extension, Friday, August 1 is the deadline to forward Public Financial Disclosure reports of PAS, DAEO, and other persons whose Public Financial Disclosure reports are required to be forwarded to OGE for review and certification. The 2008 OGE Calendar lists this and other deadlines.

Key May Due Date Reminders

May 15 is the filing deadline for certain SF 278s that are sent to OGE for final review and certification. DAEOgram DO-08-018 has details. Extensions are possible.

May 27 is the deadline to submit comments on the FAR Council's proposal on addressing service contractor employees' personal conflicts of interest in light of the concerns raised by OGE, the findings of a GAO report, the recommendations of the Services Acquisition Reform Act panel, two recent FAR cases (2006-07 and 2007-06), and some agency approaches to the issue. under 31 U.S.C. § 1353. DAEOgram DO-08-017 has more information.

Templates for Financial Disclosure Review

Thanks to Wayne Johnson for sharing two spreadsheet templates he designed to assist in reviewing SF 278 and SF-450 filings:

Download sf_278_spread_sheet_generic.xls
Download oge_450_generic_spread_sheet.xls

Wayne notes that the "comments" column can be used for following outside activities, as potential conflicts may be noted even in agencies that don't require prior review.

We dislike reinventing the wheel, and strongly encourage others with useful templates to make them available to the broader community.

More on Hill Financial Disclosure Controversy

The Washington Post has a story about the Capitol Hill controversy reported here Wednesday. The personal information in question has been available for years, but it looks like Internet disclosure was the flash point:

For several years, LegiStorm has published salary and expenditure reports that are released regularly by the House and Senate. The reports, released quarterly by the House and semiannually by the Senate, provide detailed information on how much each lawmaker spends, along with the names, titles and salaries of every employee.

In late February, however, LegiStorm expanded the data it provides by putting the staffers' personal financial disclosure forms online. Those documents, which must be filed by senior aides, contain explicit detail on aides' finances -- including bank accounts and investment portfolios -- as well as some home addresses and signatures.  ...

"Who knew it was going to get posted on the Web? It's shocking," said one House Democratic chief of staff, who requested anonymity to discuss her personal finances. "Now that anybody can look it up on the Web, I don't know if I like it anymore." ...

Limiting Unnecessary Risk Exposure

A transparency-oriented watchdog-type web site recently created controversy by exposing personal information from Congressional financial disclosure forms that could arguably be used in identity theft.

An alert reader suggests that this controversy illustrates the desirability of reminding SF-278 filers that their children's names and the filer's personal home addresses do not need to be listed on the SF-278 report. OGE allows filers to identify assets belonging to a filer's child as belonging to a "dependent child" (without referencing the child's age, gender or name).  This fully complies with the disclosure rules while preserving the children's personal privacy. Thanks for the timely tip!

OGE Updates Reporting Thresholds

Thanks to Mark Stone for the alert that OGE has published a Federal Register posting changing the reporting thresholds for gifts, reimbursements and travel expenses on the SF 278 and OGE Form 450, and the ceiling on non-sponsor gifts under the widely attended gathering rule (from $305 to $335). Mark notes the need to keep track of these changes, since the financial disclosure forms will not reflect these new dollar amounts until they are updated.

OGE Priority Training on Disclosure Reviews

In preparation for the upcoming change of admistrations, OGE is encouraging maximum attendance at its conference on financial disclosure by Presidential nominees requiring Senate confirmation (i.e., PAS nominees). The free conference will be held February 28, 2008in Washington, D.C. OGE is asking DAEOs to send all experienced ethics officials who will be involved in reviewing PAS nominee reports during the Presidential transition.

OGE will issue further details about the conference and the registration process next month, but needs to estimate an attendance figure to help their preparations. Therefore, DAEOS should send e-mails to nomineess@oge.gov with a tentative indication as to how many ethics officials will be sent to the conference. The deadline for this preliminary response is January 11, 2008.

Update December 20, corrected typos.

DOD SOCO Advisory: Filers Penalized & More

Having problems with employees failing to file financial disclosure reports, or filing incomplete information? The latest SOCO Advisory has a couple of examples of criminal charges against recalcitrant/incomplete filers.

The advisory also explains DOD's new conclusion on "anonymous" gift exchanges (i.e., they don't exist, as a practical matter). SOCO's conclusion on this subsequently received support from a surprising source: The "Miss Manners" column in the Washington Post recently condemned "Secret Santa" gift exchanges, mocking those who believe in their confidentiality, "regardless of their long knowledge that nothing has ever successfully remained a secret in that office."

There is also advice on complying with the White House directive on Hatch Act training, and a link to the new DOD Standards of Conduct Directive (formatting changes, but nothing new substantively).

Training on Certifying Confidential Financial Disclosure Reports

OGE will hold training on December 4, 5, 11 and 12 on the subject of Certifying Confidential Financial Disclosure Reports (OGE 450).  The course objectives are:

• Increase your knowledge and skills in reviewing reports
• Learn how the conflict of interest laws and standards of conduct relate to your review of each
  part of the OGE 450 report
• Learn the most common errors employees make in completing the report and how to resolve them

Frequently Asked Questions About SF 278

OGE has published a list of Frequently Asked Questions (FAQs) about the SF 278 financial disclosure form.

Travel Reimbursement Controversy Continues

Today's Washington Post has still more on alleged violations of travel reimbursement rules at the Consumer Products Safety Commission. Thanks to the alert Cary Williams for tipping us off to this issue. We welcome suggestions from our readers. Use the "Contact Us" address at left (changed occasionally to evade spammers).

Reporting Payments from Non-Federal Sources: OGE Guidance & News Reports

OGE has issued additional guidance concerning required semiannual reports of payments for travel, subsistence and related expenses received from non-Federal sources in connection with the attendance of employees at certain meetings or similar functions (31 U.S.C. § 1353). The guidance clarifies the OGE role:

OGE is responsible for making the information provided by the agencies available to the public. It is each agency’s responsibility to file the accurate and complete reports and to make the appropriate conflict of interest analysis. (See 68 Federal Register 12602-12610 published March 17, 2003.)

Such payments to federal employees has been a hot topic in the Washington Post, which published feature stories about problems at the Consumer Products Safety Commission on  November 2, November 3 and November 6, as well as a November 3 editorial. The November 2 article attracted 338 public comments, a large number, before the Post editors closed it to additional comments.

Comparing Employees in Different Pay Systems

Have you ever confronted the issue of comparing unusual pay systems to the more familiar General Schedule and SES pay scales, for the purpose of determing when certain employees should be required to file public financial disclosure reports? Check out OGE's new guidance on this topic.

Update: Edited August 29 to remove reference to "wage grade" pay scales. Marilyn Glynn notes:

The type of alternative pay systems the DAEOgram discusses  are those that are created specially for employees at particular agencies.  For example, most banking agencies have their own pay systems, as does the SEC and CFTC.  Usually these systems are designed to address pay for performance, or to provide employees with highly specialized skills higher pay than they might other get under the GS or SES systems.

SF 278 Training

The Office of Government Ethics is sponsoring four courses on reviewing Executive Branch Public Financial Disclosure Report (SF 278) at its Washington headquarters:

Tuesday, May 8, 2007
Thursday, May 10, 2007
Tuesday, May 15, 2007
Thursday, May 17, 2007

NOTE: May 8, 10, and 15 classes are for reviewers with 0-2 years experience.  The May 17 class is for reviewers with 2+ years experience. Each course will last from 9:00 A.M. to 3:30 P.M., except the May 17 course, which will end at 2:30.

You can register using OGE's online form.

Top Ten SF 450 Errors

SOCO ADVISORY 07-03 has a useful list of the Top Ten Errors made on SF 450 forms.

Confidential Disclosure Reports

Reminder:

The deadline for filing  Confidential Financial Disclosure with agency ethics officials will be on us in a couple of weeks (February 15). Any extensions should be documented. (5 CFR § 2634.903(a) & 2634.903(d)).

OGE's list of Frequently Asked Questions about Form 450 is available.

Office of Government Ethics Issues Notice on SF-278

The Office of Government Ethics (OGE) published a Notice in today's Federal Register requesting comment on the unmodified Public Financial Disclosure Form (SF-278) for extension of approval of the form for 3 years by the Office of Management and Budget (OMB) under the Paperwork Reduction Act.  OGE invites comments on the need for and practical utility of this collection of information.  Comments must be received by February 28, 2007.  Attached is the Notice. Download fed_reg. January 29 2007.pdf

OGE Releases new Form 450

On December 12, 2006, the Director of OGE issued DAEOgram DAEOgram DO-06-036 (PDF-HTML-TXT) announcing the release of the new OGE Form 450. Use of this form will begin on January 1, 2007 when amendments to OGE's confidential reporting regulation become effective. Also, OGE has posted on its website an online training course and a set of frequently asked questions to help confidential filers complete their reports.

OGE Form 450: Final Rule Published

   OGE published in the Federal Register (May 16, 2006, p 28229) http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pdf/06-4529.pdf the final rule amending 5 CFR parts 2634 and 2640, regarding the confidential financial disclosure report, OGE Form 450.  The rule becomes effective on 1/1/07 and will change the annual filing date, clarify the criteria for designating confidential filers, and narrow the information required to be reported, among other changes.

  This notice in the Federal Register also contains the preamble, which will not be published in the amended CFR, and contains useful explanations and interpretation of the regulation.  For this reason, the final rule should be saved for reference.

False Statements on SF 450

On February 9, 2006 a federal grand jury indicted a HUD employee on four counts related to false statements on a financial disclosure form, OGE 450. A copy of the indictment is available.

OGE Proposes Changes to Confidential Financial Disclosure Regulation

OGE announced a proposed rule to amend 5 CFR 2638, the financial disclosure report regulation.  Proposed changes include changes to the annual filing dates and annual reporting period; clarify the criteria for designating confidential filers; and narrow the information required to be reported.  Comments must be received by OGE by October 11, 2005.   Federal Register, August 12, 2005, page 47138.