December 24, 1992


MEMORNNDUM FOR DESIGNATED AGENCY ETHICS OFFICIALS

FROM:          STEPHEN D. POTTS
               DIRECTOR

SUBJECT:       Gift thresholds on financial disclosure reports


     As discussed in our DREO-gram a year ago on December 19, 1991,
Congress amended the Ethics in Government Act to modify the dollar
threshold and exclusion for disclosure of gifts and reimbursements
on the SF 278, effective January 1992.  See section 314(a) of
Public Law 102-90, and our regulatory implementation at § 2634.304
of the new financial disclosure regulation (57 Federal Register
11800-11830 of April 7, 1992).  The correct thresholds are $250 for
gifts from a single source and $250 for reimbursements from a
single source, excluding items valued at $100 or less from the
aggregation requirement.

     That change did not affect SF 278 reports filed by incumbents
in 1992, but it does apply to annual reports due from incumbents on
May 15, 1993.  It also applies to termination SF 278 reports.  New
entrant filers are unaffected, as they are not required to disclose
gifts and reimbursements.

     While this Office is revising the SF 278 to reflect the
corrected values, that revision will not be available until late
1993.  Therefore, we are providing this reminder, so that you can
advise incumbents of the change in connection with their upcoming
annual reports, as well as those who will be filing termination
reports.  The $250 threshold and $100 exclusion will result in
fewer disclosures of gifts and reimbursements than the previous
values, so we encourage your prompt dissemination of this
information to help filers avoid over disclosure.

     The statute which modified these thresholds and exclusions
also provided for future readjustment tied to GSA's regulatory
redefinition every three years of "minimal value" for purposes of
the Foreign Gifts Act.  This definition will be readjusted in 1993,
but we do not anticipate an increase sufficient to effect the
values specified above.  In any event, a change would not affect
incumbent filings which cover calendar year 1992 and are due on
May 15, 1993.

     One final note: the confidential financial disclosure form, SF
450, which parallels the public system and was issued a few months
ago, correctly reflects the $250 threshold and $100 exclusion.