January 29, 1996
                                  DO-96-006

MEMORANDUM

TO:       Designated Agency Ethics Officials

FROM:     Stephen D. Potts
          Director 

SUBJECT:  New reporting categories for SF 278s


     Section 20 of the Lobbying Disclosure Act of 1995 (Pub. L. 
104-65) amended the Ethics in Government Act of 1978 to require new
categories of amount or value on public financial disclosure
reports for assets, income and liabilities exceeding $l million
(except for interests of a spouse or dependent child, unless
jointly held with the filer).  This applies to all SF 278 reports
filed on or after January 1, 1996.  

     The Office of Government Ethics (OGE) has decided not to
revise the SF 278 with new columns for these categories, because
relatively few filers are affected and space on the form is too
limited.  Therefore, agencies should advise filers in writing that,
if their disclosable interests fall within these high-value
categories, they are required to so indicate, either by footnote or
other annotation directly on the SF 278 or on an attachment.

     Effective immediately, agencies should provide the following
supplemental instructions to all filers by memorandum at the same
time that blank SF 278s are distributed:  

          Recent changes to the financial disclosure law added
     new categories of value or amount that are not shown on
     the SF 278.  If you have any entry checked in a column
     labeled "over $1 million" on Schedules A or C, you must
     annotate that entry, either by footnote or other notation 
     directly on the form or on a separate attachment, to
     specify the following:

          In the case of ASSETS (Block B of Schedule A)
          or LIABILITIES (Part I of Schedule C), whether
          the value or amount is 

                 between $1,000,001 and $5,000,000;

                 between $5,000,001 and $25,000,000;

                 between $25,000,001 and $50,000,000; or

                 over $50,000,000.

          In the case of INCOME (Block C of Schedule A),
          whether the value or amount is

                 between $1,000,001 and $5,000,000; or

                 over $5,000,000.

               EXCEPTION:  For assets, income or
          liabilities of your spouse or dependent
          children, you are only required to specify
          these additional categories of value or amount
          if the assets, income or liabilities are held
          jointly with you.

     For reports that are filed on or after January 1, 1996,
without this supplemental guidance having been provided, reviewers
will need to contact the filer, in order to clarify any entry where
the "over $1 million" column was checked on Schedules A or C.    

     The Lobbying Disclosure Act of 1995, at Section 22, also
amended the Ethics in Government Act of 1978 to require certain
additional public financial disclosures relating to qualified blind
trusts.  However, because that requirement is limited to newly
created trusts and covers a very small number of filers, it will be
handled through advice from OGE to each affected individual at the
time those trusts are certified.