What are OGE Form 278e and OGE Form 278-T?

What is the OGE Form 278e?

The Office of Government Ethics (OGE) publishes a Public Financial Disclosure Guide for completing and reviewing the Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) and the supplemental Periodic Transaction Report (OGE Form 278-T). The guide explains that Congress enacted the financial disclosure provisions of the Ethics in Government Act because it determined that citizens should know their leaders' financial interests, and that the forms request only as much information as the Act requires.

The guide's overview lists the occasions on which a 278e is filed:

Candidates download the form from OGE and submit it to the Federal Election Commission. Other filers, in most cases, file electronically through Integrity, a web-based system developed and administered by OGE, or another agency-supported system.

What is the OGE Form 278-T?

The 278-T is the periodic transaction report. Per the guide, you must file one if you are in a covered position, have served or are expected to serve in it for more than 60 days, and have a reportable transaction. You do not file a negative report when there is none. The report has a general information section and a section for transactions. The guide gives two due dates under the Ethics in Government Act: within 30 days of receiving notification of a transaction, but no later than 45 days after the transaction.

The rule behind it, 5 CFR 2634.309, says reports must include a brief description, the date and the value (using the regulation's categories of value) of any purchase, sale or exchange of stocks, bonds, commodity futures and other securities in which the amount exceeds $1,000. Exceptions include transactions solely among the reporting individual, spouse and dependent children, Treasury securities, money market funds and bank accounts on terms available to the public, and transactions that occurred when the person was not a filer.

Who is a public filer?

The regulation 5 CFR 2634.202 defines the public filer. It includes the President, the Vice President, and each officer or employee in the executive branch, including a special Government employee, whose position is classified above GS-15 of the General Schedule or whose basic pay is fixed at a rate equal to or greater than 120 percent of the minimum rate for GS-15, and members of the uniformed services at specified pay grades. We have not listed the full set.

For timing, 5 CFR 2634.201 says an incumbent who performed the duties of a position for more than 60 days in a year files a report on or before 15 May of the following year, and a new entrant files within 30 days of assuming the position.

How is this different from the Congress report?

Both come from Title I of the Ethics in Government Act, and the STOCK Act added the same transaction-report rule for the President, the Vice President, executive-branch officers and employees and others, as its text shows: a report no later than 30 days after notification and never later than 45 days after the transaction. The differences are the form and the place of filing. Members of the House file a periodic transaction report with the Clerk of the House (see how the House and Senate publish disclosures), while executive-branch filers use OGE's forms and systems.

Where do you find the reports?

OGE's home page has a task called "Find an Individual's Ethics Document" and a collection described as "View Officials' Individual Disclosures", which lists Financial Disclosure Reports, Certificates of Divestiture, Ethics Pledge Waivers, Ethics Agreements and other documents.

How do the House and executive-branch transaction reports compare?

The deadline and the threshold are the same because the STOCK Act added the same transaction rule for each group. The forms and the offices that receive them are different.

What this does not tell you

A 278-T says that a covered person reported a transaction above $1,000, with a value category and dates. It does not say why the transaction happened, who decided it, or whether the person was aware of nonpublic information. A person with no reportable transactions files none. A 278e shows holdings and income as reported at the time of filing, not afterwards. OQRO's White House page lists officials and presidential actions from official pages and does not load their financial disclosures; the reports themselves are on OGE's site. This article does not suggest any use of the information by anyone.