MEMORANDUM

TO:      Designated Agency Ethics Officials

FROM:    Daniel D. Dunning
         Deputy Director for Administration and
         Information Management

SUBJECT: New Edition of the OGE Form 450 Confidential Financial
         Disclosure Report

    The Office of Government Ethics (OGE) recently obtained from the Office of Management and Budget (OMB) renewed approval for three years under the Paperwork Reduction Act for a slightly revised version of the OGE Form 450 Executive Branch Confidential Financial Disclosure Report. The 04/99 edition of the form currently in circulation may still be used for the fiscal year 2002 annual reporting period. After that, the new 09/02 edition of the OGE Form 450 should be used in place of previous editions.

    Revisions to the new edition of the OGE Form 450 include one substantive change (involving gifts and travel reimbursements) and several minor ones. The General Services Administration (GSA) raised "minimal value" under the Foreign Gifts and Decorations Act, 5 U.S.C. § 7342, to $285 or less for the three-year period 2002-2004, effective January 1, 2002 (see OGE's DAEOgram DO-02-021 dated September 27, 2002). As a result, OGE raised the thresholds on both the instructions and the report form (part V) of the OGE Form 450 for reporting of gifts and travel reimbursements to "more than $285" for the aggregation level for reporting, and "$114 or less" for the de minimis threshold for gifts and reimbursements from any one source.

    The Office of Government Ethics made minor changes to the form by updating the contact information to reflect recent OGE organizational changes, formally adding a Part I (Assets and Income) continuation page (which the fillable version on OGE's Web site already incorporates), and updating the edition date.

    Furthermore, OGE is in the process of updating the OGE/GOVT-2 system of records notice (covering Confidential Statements of Employment and Financial Interests). Once the new language in OGE's forthcoming Privacy Act systems notice is finalized (anticipated completion date is early 2003), OGE will revise the routine uses language contained in the Privacy Act Statement on the OGE Form 450, advise departments and agencies of the Privacy Act statement changes, and make the modified form available on the OGE Web site.

    The Office of Government Ethics will continue to make the OGE Form 450 available to departments and agencies and their reporting employees through the "Forms, Publications & Other Ethics Documents" section of OGE's Web site at www.usoge.gov. This allows employees two different fillable options for preparing their report on a computer (in addition to a downloadable blank form), although a printout and manual signature of the form are still required unless specifically approved otherwise by OGE.

    Moreover, OGE permits departments and agencies to develop or utilize their own electronic versions of the OGE Form 450 provided they precisely duplicate the paper original to the extent technically possible. While OGE sees no legal bar to electronic filing and electronic signatures for the OGE Form 450, agencies must meet the requirements of the Government Paperwork Elimination Act (GPEA) and other applicable laws and issues such as security, verification, non-repudiation, etc. Those agencies seeking to develop or utilize an electronic version of the OGE Form 450, and who have not so informed OGE, are asked to advise OGE's Deputy Director for Administration and Information Management of their intentions to do so and to provide assurance of their adherence to the previously mentioned requirements.

    Any questions about the new OGE Form 450 can be directed to your OGE desk officer.