U.S. Office of Government Ethics
1201 New York Avenue, NW.
Suite 500
Washington, DC 20005-3917




                                   August 25, 2003
                                   DO-03-015


MEMORANDUM

TO:       Designated Agency Ethics Officials

FROM:     Daniel D. Dunning
          Deputy Director for Administration and 
          Information Management

SUBJECT:  Unmodified SF 278 Executive Branch Personnel Public
          Financial Disclosure Report


     The Office of Government Ethics (OGE) recently obtained from
the Office of Management and Budget (OMB) renewed approval for
three years under the Paperwork Reduction Act for an unmodified SF
278 Executive Branch Personnel Public Financial Disclosure Report. 
The SF 278 is henceforth to be accompanied by agency notification
to filers of the adjustment of the gifts/travel reimbursements
reporting thresholds and the revisions to the Privacy Act
Statement.  Both revisions have not been incorporated into the form
itself at this time, since OGE plans a more thorough revision of
the form in the next year or two.

     Executive branch departments and agencies should inform SF 278
filers, through cover memorandum or otherwise, of these two changes
when the existing March 2000 edition of SF 278 report forms are
provided for completion.

Gifts/Reimbursements Reporting Thresholds

     Effective January 1, 2002, GSA raised "minimal value" under
the Foreign Gifts and Decorations Act, 5 U.S.C. 7342, to $285 or
less for the three-year period 2002-2004.  See OGE's September 27,
2002 memorandum to designated agency ethics officials DO-02-021. 
As a result, the thresholds for SF 278 reporting of gifts and
travel reimbursements received from any one source has increased to
"more than $285" for the aggregation level for reporting and to
"$114 or less" for the de minimis aggregation exception threshold.


Routine Uses Paraphrased in the Privacy Act Statement

     Effective May 22, 2003, OGE updated the OGE/GOVT-1 system of
records (covering SF 278 Public Financial Disclosure Reports and
other name-retrieved ethics program records).  See 68 FR 27891-
27897 (05/22/03).  As a result, agencies should inform SF 278
filers that the Privacy Act Statement on page 11 of the
instructions now includes three additional routine uses to the six
currently listed on the form:

     7) to reviewing officials in a new office, department or
     agency when an employee transfers from one covered position to
     another;
     (8) to a Member of Congress or a congressional office in
     response to an inquiry made on behalf of an individual who is
     the subject of the record; and
     (9) to contractors and other non-Government employees working
     for the Federal Government to accomplish a function related to
     an OGE Governmentwide system of records.     

Availability

     For now, OGE will continue to make the unmodified SF 278
available to departments and agencies and their reporting employees
through the Forms, Publications & Other Ethics Documents section of
OGE's Web site.  This allows employees two different fillable
options for preparing their report on a computer (in addition to a
downloadable blank form), although a printout and manual signature
of the form are still required.  The SF 278 is also available for
purchase by agencies from GSA Customer Supply Centers (see OGE's
November 15, 2000 memorandum to designated agency ethics officials
(DO-00-042)) and fillable versions are now posted on the forms
library of GSA's own Web site at www.gsa.gov.