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A former DoD consultant failed to file the final public financial disclosure report (SF 278) when the consultant's appointment expired. The filer received several reminders, but chose to ignore them and never filed the report. Unfortunately, the consultant was unable to ignore the Department of Justice. After being warned of criminal prosecution, followed by substantial negotiations, the filer agreed to pay a $2,000 fine, to pay the $200 late filing fee, and to file the financial disclosure report that should have been filed in the first place. (And don't forget attorney fees.) Bottom line: The failure to file a financial disclosure report was very costly.
Spouse's Employment. If your spouse is employed by someone other than the Federal Government, please list your spouse's employer.
Spouse's Pension / Retirement Plan. Report the plan. If it includes only diversified mutual funds - which are no longer required to be reported - simply note this in parenthesis. Ex: "Mitre Corp, Alexandria, VA, 401k (invested entirely in diversified mutual funds)".
Underlying Assets within Investment Accounts (401k, IRA, Annuities, Investment Life Insurance, and Managed Accounts) must be reported.
Underlying Assets of Managed Accounts must be reported. (Even though you do not personally manage the account, you must disclose the assets invested in them because you own the account.) Annual filers may use their end-of-year account statements to determine their reportable assets. New Entrants may ask their fund managers to provide an account summary for the 12 months prior to their appointment.
Trusts and Partnerships. You must disclose underlying assets, and list positions you hold in Part III (Outside Positions).
Mutual Funds Not Fully Identified. "Mutual Fund" or "Fidelity Mutual Fund." is inadequate identification. Please name the individual fund: "Fidelity Magellan Fund." Please also provide the ticker symbol.
College Savings Plans. Some offer a wide range of investment options. As in other investment accounts, you must disclose all of the underlying assets. If the account is a single fund, you should be able to locate it - and that is what you should annotate on your OGE Form 450. Example: "Virginia College 529 Plan (Government Securities Fund)". (This is an example of a sector fund disclosure. If the plan is invested entirely in diversified funds - see the example in Error #2, above.)
New Entrant or Annual Filer? If you have not filed a financial disclosure report before, you are not an "annual" filer. Upon a new assignment which requires filing the financial disclosure report, mark the "New Entrant" block - and provide the date of your new assignment or appointment.
IPA Personnel. Please complete Parts I (Assets and Income), III (Outside Positions) and IV (Agreements or Arrangements). List the position held with your parent organization at Part III. In Part IV, you must indicate the nature of your retirement accounts (401k, Stock plan, Defined Benefit Retirement, etc.) You should also disclose the potential for future employment at the close of the IPA assignment in Part IV. List your parent organization as your employer in Part I, as well as the reportable underlying assets of your continuing 401k or other pension plans.
Supervisor Review. The most immediate reviewer in the financial disclosure process is the direct supervisor. Supervisors confirm that their employees are in compliance with applicable laws and regulations. Therefore, it is important that they know to review each of these areas and be fully cognizant of what questions to ask employees if incomplete entries are made. This assists the employee, the supervisor, the Agency - and the Department of Defense, in avoiding potential conflicts of financial interests.
DISCLAIMER: The purpose of this advisory is to disseminate relevant information and sources of general guidance, policy and law on Government Ethics issues to the Department of Defense ethics community. Advisories are not intended to be and should not be cited as authoritative guidance, DoD policy, or law.