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May 10, 2000
DO-00-018
MEMORANDUM
TO: Designated Agency Ethics Officials
FROM: Stephen D. Potts
Director
SUBJECT: Update of Listing of Executive Branch Agency Officials
Subject to Annual Public Financial Disclosure Report
Filing with the Office of Government Ethics (OGE) for
CY 1999
Title I of the Ethics in Government Act of 1978, as amended,
requires annual public financial disclosure reports (SF 278) to
be filed with the appropriate department or agency no later than
May 15. The 278s of Presidential appointees confirmed by the
Senate (PAS) and Designated Agency Ethics Officials (DAEO) must
be submitted to this Office for final review and certification.
Attached is a list of the names and positions of those officials
who were required to submit a nominee, new entrant, or annual
SF 278 for CY 1998. The list also includes PAS officials who
worked 60 days or less in CY 1998 and were not required to
complete an annual report covering that year.
Please annotate this list to reflect any changes to
(additions or deletions) the officials named or positions
identified. Kindly return the list, as annotated, to this
Office by May 31, 2000. For your convenience, you may phone in,
fax, or E-mail "No Change" lists. The fax number for the
Financial Disclosure Division is 202-208-8038. In annotating
your lists, please note whether an official has terminated or
transferred from the position and the termination or transfer
date. For transfers, please indicate whether the official
transferred within 30 days to another covered position (PAS or
non-PAS) requiring SF 278 reporting. If not, a termination
report is required within 30 days of the transfer. In
addition, please indicate which officials did not work more than
60 days in CY 1999 and are not required to file an annual
report. Conversely, please add to the list the names of any PAS
special Government employees who actually worked in excess of
60 days in CY 1999 at an annual rate of basic pay equivalent to
120 percent of GS-15, step 1, which equaled $89,727.60 (or
$343.95 per day) in CY 1999. However, do not include the names
of officials serving in PAS positions in an acting capacity,
because those officials do not go through Senate confirmation.
Finally, while Schedule C employees do not submit their reports
to this Office, they are required to file SF 278s with their
agencies, unless they have received filing exclusions from the
Director of the Office of Government Ethics.
The annual SF 278s for the PAS officials and DAEOs
identified on this list should be submitted to OGE as soon as
approved by your department or agency. This is particularly
important for the financial disclosure report of your agency
head. As you know, their reports are among the most requested
by the news media and public. Your timely report submissions
will allow OGE to begin its review process sooner than in the
past, with our goal being to review and certify the majority of
reports within 60 days of receipt. In instances where the
report cannot be approved by the agency and submitted to this
Office by September 15, due to pending resolution of a conflict
of interest, or the need for additional information or
clarification, we ask that you notify us, in writing, of the
names and positions of the officials involved, the nature of the
problems, and the date you expect to transmit the report to this
Office.
This Office will be following up on the late filing of
reports submitted by PAS officials and DAEOs. To assist us in
this effort, we ask that you note any agency-granted filing
extensions on the officials' SF 278 cover sheet. Finally, we
request your assistance in providing us with changes to this
list as they occur throughout the year. Although agencies are
not required to provide such periodic information, we have found
that the receipt of this information on an ongoing basis enables
us to compile more accurate annual filing lists.
For your convenience, we have provided the 2000 due dates
for annual reports as well as the 45-day and 90-day filing
extensions as shown below:
2000 Due Dates
________________
Report Late if $200 Fee Due if
Filed After Report Filed After
________________ ___________________
Annual Reports May 15 June 14
45-Day Extension June 29 July 31
90-Day Extension August 14 September 13
Of special note, OGE DAEOgram, DO-99-048, dated December 21,
1999, provided information regarding a second paperwork round
for a proposed moderately revised version of the SF 278 report
form. Because it will be some time yet before the new 2000
edition of the SF 278 report form will be ready, agencies should
continue to use the 6/94 (or 1/91) edition of the SF 278 for
this annual report cycle. Agencies will have to notify their
personnel of, among other things: (1) incorporation again of
higher-category reporting, as required by amendments to the
Ethics in Government Act, for any assets, income, and
liabilities, which are over $1,000,000 in value (see OGE
DAEOgram, DO-96-006, dated January 29, 1996) and (2) reflection
of the new slightly higher thresholds for gifts and
reimbursements (over $260 overall, with a $104 or less
"de minimis" threshold).
If you have any questions, please contact Tom Zorn, Chief,
Financial Disclosure Division, or Mike Shifrin at 202-208-8000,
extension 1123, or extension 1155, respectively. Their E-mail
addresses are tfzorn@oge.gov and mnshifri@oge.gov.
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