TO:       Designated Agency Ethics Officials

FROM:     Jack Covaleski
          Deputy Director for Agency Programs

SUBJECT:  Due Dates for Public Financial Disclosure Reports of
          Executive Branch Officials Required to File with the
          Office of Government Ethics (OGE)

    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 SF 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.

   Our April 19, 2002 DAEOgram (DO-02-007) requested updated lists for PAS and DAEOs required to file with this Office. This memorandum is to inform you about the various due dates for reports filed with OGE and to provide some general guidance on report review issues and the review process.

    All annual SF 278s for PAS officials and DAEOs filed by May 15, 2002, that require little or no follow-up, should be submitted to OGE as soon as approved by your agency or department, but generally no later than August 1, 2002. 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 August 1, 2002, due to an extension, pending resolution of a conflict of interest, or the need for additional information or clarification, we ask that you submit the report, at the latest, by September 16, 2002. If you are unable to do this, please 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.

    Termination reports for PAS officials and DAEOs should be submitted to OGE immediately after you certify the reports. Do not wait until September 16 or the next filing cycle to send them.

    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 extension on the officials’ SF 278 cover sheet.

    For your convenience, we have provided the 2002 due dates for annual reports as well as the 45-day and 90-day filing extensions as shown below:

    Please ensure that all sections of the report are complete. If a filer has nothing to report for an applicable schedule, the "None" box should be checked. Remember that "None" and "Not Applicable" should not be used interchangeably. In addition, please guard against the overreporting of unneeded personal information, including home addresses, social security numbers, and account numbers. This type of information should not appear on the form or on any attachments. For rental property, filers should provide only the city and state where the property is located (i.e. do not list the street address). Lastly, in accordance with our February 22, 2000, DAEOgram (DO-00-007), brokerage statements can only be attached if they readily disclose in a clear and concise fashion all information which the filer would otherwise have been required to enter on the schedules.

    If you have any questions, please contact Tom Zorn, Chief, Financial Disclosure Division, or Teresa Weakley at 202-208-8000, extension 1123, or extension 1233, respectively. Their E-mail addresses are tfzorn@oge.gov and tlweakle@oge.gov.