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. Attachment