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FINANCIAL DISCLOSURE


ETHICS COUNSELOR RESOURCES

Ethics Counselor Toolbox.  The Toolbox is intended to provide additional resources for DoD Ethics Counselors. In it, you will find additional guidance and materials, such as templates, forms, and worksheets.  Note: In using these tools for your own program, please ensure that you replace any references to SOCO with your ethics office contact information.

HANDOUTS

Note:  These Handouts provide general information. They are not a substitute for obtaining advice from ethics counsel on the application of the ethics laws and regulations to a specific set of facts and circumstances.

EMPLOYEE INFORMATION & OVERVIEW (For OSD Personnel)


General

The Standards of Conduct Office (SOCO) is responsible for the public and confidential financial disclosure program for the Office of the Secretary of Defense. The purpose of financial disclosure is to assist in identifying and preventing conflicts of interest between their DoD duties and personal financial interests. The financial disclosure program is a system to periodically review personnel interests to ensure prompt and timely redress of potential and actual conflicts.  DoD requires all financial disclosure reports to be completed electronically using the appropriate filing system. 
 

Public Financial Disclosure (OGE 278) 
Who Files:  Individuals subject to the public financial disclosure process include most political appointees, as well as General / Flag Officers and civilian career officials above a certain pay threshold (e.g., SES, SL, ST). 
  • Help for Filers:  OGE provides an online interactive Public Financial Disclosure Guide that will assist filers in collecting and reporting data for specific types of interests - it will save you time!  The Guide can be found at: https://www.oge.gov/Web/278eGuide.nsf.
  • Periodic Transaction Reports (OGE 278-T) - All public filers must file an OGE 278-T to report transactions in individually held securities (vice those in mutual or exchanged traded funds) for any purchase, sale or corporate exchange that exceeds $1000.  More information and tools are available in the Handouts section above.
  • Filing System: Integrity  (https://www.integrity.gov/efeds-login/)
  • Annual Post-Employment Certification: DoD 5500.07-R, Joint Ethics Regulation, requires DoD public filers to certify each year that they are aware of their post-Government employment restrictions. This certification is accomplished as part of the filer's report submission process in the Integrity system.

Confidential Financial Disclosure (OGE 450 or OGE Approved Alternate)
Supervisors
  • Responsibilities:  DoD supervisors have a legal obligation to conduct a timely review of the financial disclosure reports of their employees for potential conflicts of interest with the employee's duties.  If a potential conflict is identified, the supervisor should contact ethics counsel to discuss. 
  • Filer Determinations:  Supervisors are also responsible for determining whether an employee who is not a public filer should file a confidential report.  While some career categories are specifically identified as filing positions (e.g., contracting personnel), others may depend on the actual work to be performed by the employee.  In those situations, the supervisor must identify whether the employee is likely to work on matters impacting the interests of non-Federal persons or entities. 
    • SOCO provides a worksheet to assist supervisors in doing this, which can be accessed in the Handouts section above.