Financial Disclosure

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Financial Disclosure
Heart of EthicsorA Royal Pain
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Before we start . . .
lets check out the references
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BottomLine
Financial disclosure is a tool to prevent
conflicts of Interest
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Financial Disclosureworks by

• Filer and supervisor identifying financial
  interests recognizing potential conflicts

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Financial Disclosureworks by

• Ethics official recognizing potential
  conflicts, reminding filers, and demonstrating
  official interest.

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Financial Disclosureworks by

• Providing evidence of knowledge(if prosecuted)

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Confidential Financial Disclosure
OGE Form 450 OGE Optional Form 450A
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Your Job Manage your Program
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Who files?
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• COs, XOs, Heads, Dep Heads of
• NAVY shore installations with more than 500
  employees
• Army, Air Force, Marines all bases,
  installations, and air activities

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• Special Government Employees

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• Civilian employees atGS-15 and below, or
  military personnel at 0-6 and below,
• when they . . .

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• participate personally substantially
• through decision or exercise of significant
  judgment
• in taking official action for

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• contracting or procurement
• administering grants, subsidies, or licenses
• regulating or auditing any non-Federal entity,
  or
• other activities in which the final decision may
  have a direct and substantial economic impact on
  the interest of any non-Federal
  entity

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• Personnel required by supervisor

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• Personnel serving under the Intergovernmental
  Personnel Act in a
• covered position

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• Exceptions

(Excluded by component head)
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• Remote possibility of conflict of interest
• Substantial supervision and review
• Inconsequential effect on Federal Government
  integrity

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• Non-procurement personnel with authority to
  purchase
• lt2,500 / purchase,
• lt20,000 / year

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Optional Form 450A
Certificate of No New Interests (or change of
duties)
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• New Entrant Reports
• System to identity
• New entrants

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• New Entrant Reports
• System to identity
• New entrants

• Transfers - get a copy of their 450

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• New Entrant Reports
• System to identity
• New entrants
• Transfers - get a copy of their 450

• Personnel whose duties change

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• New Entrant Reports
• System to identity
• New entrants
• Transfers - get a copy of their 450
• Personnel whose duties change

SGEs and Reservists file PRIOR to assuming duties
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• Annual Reports
• Deadlines

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• Annual Reports
• Deadlines

• Timelines

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• Annual Reports
• Deadlines
• Timelines

• OF 450-A
• Annual Form 450 filers only
• Not used every 4th year starting 2000
• Filer must attach most current Form 450
• Supervisor must review and certify

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• Annual Reports
• Deadlines
• Timelines
• OF 450-A

• Notices

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• Documentation
• Develop good tracking system
• Date of filing
• Everyone files

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Time Management
RememberIts easier for you and the filersif
they get it right the first time!
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• Sample Forms on SOCO Website
• 25K Kr list on SOCO Website
• Offer training on filling out reports
• Offer software
• Be available for questions
• Provide copy of previous report

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Confidentiality of Process
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Your Job EnforcementUltimate threat -
reassignment/removalLate filing - admin
actionGet Command support
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Report delinquent filers by Dec 15
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Public Financial Disclosure
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Who files?
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• Generals Admirals
• Senior Executive Service
• Non-GS employees, including IPAs, earning 120 of
  GS 15 or more
• PAS
• Political Appointees (Schedule C)
• Civilians detailed to these positions

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New Entrant Reports

• Reporting Periods
• Filing Date

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• New Entrant Reports-Contd
• Reporting Periods
• Filing Date

• Review
• Reports

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Annual Reports

• Reporting Periods
• Dates

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• Annual Reports-Contd
• Reporting Period
• Dates

• Database
• Notification
• Certification
• Reminder

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• Termination Reports
• Reporting Periods

• Filing Date

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• Extensions
• Initial up to 45 days Ethics Counselor
• Addl up to 45 days DAEO or designee
• Combat Zone 180 days

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• Documentation
• Develop good tracking system
• Date of filing

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Time Management
Accurate Reporting
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• Sample Forms on SOCO Website
• 25K Kr list on SOCO Website
• Offer training on filling out reports
• Offer software
• Be available for questions
• Provide copy of previous report

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• Confidential
• vs
• Public

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• Enforcement

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The EndThank you for your attention!