OGE Form 278e Exce Executive Branch Personnel Public Financial Disclosure R

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Overview

Instructions
Cover Page
Part 1
Part 2
Part 3
Part 4
Part 5
Part 6
Part 7
Part 8
Part 9
Summary of Contents

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Sheet 1: Instructions

General Instructions for Completing the OGE Form 278e
Should I Use This Form?		Extensions
Candidate: Yes, you should file your report using this form.		The employing agency may grant you an extension of up to 45 days for
		good cause shown with the possibility of one additional extension of
Other Category of Filer: In most cases, individuals will file their		up to 45 days. Extensions for Candidates are granted by the Federal
public financial disclosure reports through an electronic financial		Election Commission.
disclosure system. Do not use this form if you plan to file using
an electronic financial disclosure system.		Late Filing
When Must I File?		You will be subject to a $200 late filing fee if you file your report
		more than 30 days after the due date (including any extensions). A
Candidate: Within 30 days of becoming a candidate for nomination or		report is considered to be filed when it is received by the agency.
election to the office of President or Vice President, or by May 15 of		Agencies may waive this fee if the delay was caused by extraordinary
that calendar year, whichever is later, but at least 30 days before the		circumstances. Unless waived, the agency will collect the fee for
election, and on or before May 15 of each succeeding year you		deposit with the United States Treasury.
continue to be a candidate
		Warnings
Nominee: No later than 5 days after nomination by the President
		Knowing and willful falsification of information, or failure to file or report
New Entrant: Within 30 days of assuming a covered position		information required to be reported by section 102 of the Ethics in
		Government Act of 1978, as amended (the Act), may subject you to a
Annual: No later than May 15 annually		civil monetary penalty and to disciplinary action by your employing
		agency or other appropriate authority under section 104 of the Act.
Termination: Within 30 days of leaving a covered position		Knowing and willful falsification of information required to be filed
		by section 102 of the Act may also subject you to criminal prosecution.
Instructions for Completing Part 1 of the OGE Form 278e: Filer's Positions Held Outside United States Government
Applicability: All filers complete Part 1.
Reporting Period:		Completing the Fields:
Candidate, Nominee or New Entrant: Preceding two calendar years		Organization Name: Provide the name of the organization.
and current year to filing date
		City/State: Provide the city and state in which the organization is located.
Annual: Preceding calendar year and current year to filing date
		Organization Type: Describe the type of organization.
Termination: End of period covered by last report to termination date
		Position Held: Provide the title or a brief functional description of the
Reporting Requirement:		position you hold or held.
Report any positions that you held at any time during the reporting		From: Provide the month and year in which you began in the position.
period (excluding positions with the United States Government).
Reportable positions include those of an officer, director, trustee,		To: Provide the month and year in which the position ended. If you still
general partner, proprietor, representative, employee, or consultant		hold the position, write “present.”
of any for-profit or non-profit organization (whether compensated
or uncompensated).		Nothing to Report: If you do not have anything to report, write “None.”
Exceptions:
Do not report the following: (1) positions held as part of your official
duties with the United States Government; (2) positions with religious,
social, fraternal, or political entities; (3) positions solely of an honorary
nature; (4) mere membership in an organization; and (5) passive
investment interests as a limited partner or non-managing member of a
limited liability company.
In addition, you do not need to report service as a member of an
advisory board or committee if the following criteria are met:
(1) the advisory board or committee is that of a non-profit organization;
(2) your service is unpaid; and (3) you have no fiduciary duties of the
sort exercised by officers, directors, or trustees.
Instructions for Completing Part 2 of the OGE Form 278e: Filer's Employment Assets and Income
Applicability: All filers complete Part 2.
Reporting Period:		Completing the Fields:
Candidate, Nominee, or New Entrant: Preceding calendar year and		Description: Provide a description sufficient to identify the asset or
current year to filing date		source being reported.
Annual: Preceding calendar year		EIF: If you are reporting an investment vehicle that invests in assets
		of its own, you need to report each underlying asset that was individually
Termination: End of period covered by last report to termination date		worth more than $1,000 at the end of the reporting period or that
		individually produced more than $200 in income during the reporting
Reporting Requirement:		period. As an exception to this requirement, however, you do not need
		to report the underlying assets of an investment vehicle that qualifies as
• Report each source of your earned and other non-investment income		an excepted investment fund (EIF). Indicate whether your entry qualifies
over $200 during the reporting period (e.g., salary, fees, partnership		an excepted investment fund. If your entry is not an investment vehicle
share and other business income, honoraria, scholarships, and prizes).		at all, select "N/A."
• Report each asset related to your business, employment, or other		Definition of “Excepted Investment Fund”: An excepted investment
income-generating activities if the value of the asset at the end of the		fund is an investment fund that is (1) widely held; (2) either “publicly
reporting period exceeded $1,000 or if the asset produced more than		traded or available” or “widely diversified”; and (3) independently
$200 in income during the reporting period (e.g., equity in business or		managed, meaning you neither exercise control nor have the ability to
partnership, stock options, retirement plans/accounts and their		exercise control over the financial interests held by the fund. A fund is
underlying holdings as appropriate, anticipated payments such as		widely diversified if it holds no more than 5% of the value of its
severance payments, deferred compensation, and intellectual property		portfolio in the securities of any one issuer (other than the United States
such as book deals and patents).		Government) and no more than 20% in any particular economic or
		geographic sector.
Exceptions:
Do not include assets or income from United States Government		Value: Report the value of an asset by selecting the appropriate
employment. In addition, do not assets that were acquired separately		category.
from your business, employment, or other income-generating activities
(e.g., assets purchased through a brokerage account) because you will
report these assets in Part 6.
(Instructions continue on the following page.)
Income Type:		Nothing to Report: If you do not have anything to report, write “None.”
(1) Income Less than $201: Leave this field blank.
(2) Asset Qualifies as an EIF: Leave this field blank.
(3) Dividends, Interest, Capital Gains, or Rent or Royalties: Enter these
types of income into the field.
(4) Other Income: Provide an appropriate description (e.g., “salary”).
Income Amount:
(1) Income Less than $201: Select “None (or less than $201).”
(2) Asset Qualifies as an EIF: Select the category that corresponds to
the total amount of income produced during the reporting period.
(3) Dividends, Interest, Capital Gains or Rent or Royalties: Select the
category that corresponds to the total amount of income produced
during the reporting period.
(4) Other Cases: Provide the exact amount of income produced during
the reporting period in the space provided.
Instructions for Completing Part 3 of the OGE Form 278e: Filer's Employment Agreements and Arrangements
Applicability: All filers must complete Part 3.
Reporting Period:		Completing the Fields:
Candidate, Nominee, or New Entrant: As of the date of filing		Employer or Party: Provide the parties to the agreement or arrangement,
		other than yourself. In most cases, the other party will be your employer.
Annual: Preceding calendar year and current year to filing date
		City/State: Provide the city and state of the other parties.
Termination: End of period covered by last report to termination date
		Status and Terms: Briefly describe the type of agreement or arrangement,
Reporting Requirement:		its terms (in particular, the timing and form of any payments), and its
		current status.
Report any agreements or arrangements that you had during the
reporting period for the following: (1) continuing participation in an		Date: Provide the month and year in which the agreement or
employee welfare or benefit plan maintained by a former employer;		arrangement began. In many cases, this will be when you joined the
(2) leave of absence; (3) future employment; or (4) continuation of		employer or otherwise became eligible for coverage under the
payments by a former employer (e.g., severance payments).		agreement or arrangement.
Exceptions:		Nothing to Report: If you do not have anything to report, write “None.”
Do not report the following: (1) agreements and arrangements with the
United States Government, such as your participation in the Federal
Employees Retirement System or the Civil Service Retirement System;
(2) agreements and arrangements of your spouse or your dependent
children; (3) if you are a Presidential nominee, any agreement or
arrangement that will end before you file your Nominee report; and
(4) if you are filing a New Entrant report, any agreement or arrangement
that ended prior to the beginning of your appointment to your current
position.
Instructions for Completing Part 4 of the OGE Form 278e: Filer's Sources of Compensation Exceeding $5,000 in a Year
Applicability: Complete Part 4 if you are filing a Nominee or
New Entrant report. Otherwise, leave this Part blank.
Reporting Period:		* Confidential Clients: You do not need to report the identity of a
		client if the client’s identity is protected by a court order or is under
Nominee or New Entrant: Preceding two calendar years and current		seal. In limited circumstances, the exception may also apply if the client
year to filing date		is considered confidential because:
Other Reports: N/A		1. the client is the subject of a pending grand jury proceeding or other
		non-public investigation in which there are no public filings, statements,
Reporting Requirement:		appearances, or reports that identify him or her;
Report any source (except the United States Government) that paid		2. disclosure is prohibited by a rule of professional conduct that can be
more than $5,000 for your services during any year of the reporting		enforced by a professional licensing body; or
period. Report such payments both from employers and from any
clients to whom you personally provided services. You must report a		3. a privileged relationship was established by a written confidentiality
source even if the source made its payment to your employer and not		agreement, entered into at the time that your services were retained,
to you. Do not report a client’s payment to your employer if you did		that expressly prohibits disclosure of the client's identity.
not provide the services for which the client is paying.
		A client will not be deemed confidential merely based on the filer’s
Exception:		belief that the client would prefer not to be disclosed or based on the
		fame or social standing of the client.
In certain rare cases, you need not provide the identity of confidential
clients. In those cases, indicate the number of confidential clients that		Nothing to Report: If you do not have anything to report and you are
have not been disclosed (e.g., “2 confidential clients not disclosed”).		filing a Nominee or New Entrant report, write “None.”
Completing the Fields:
Source Name: Provide the name of the source.
City/State: Provide the city and state in which this source is located.
Brief Description of Duties: Provide a brief description of your duties
or the type of services rendered.
Instructions for Completing Part 5 of the OGE Form 278e: Spouse's Employment Assets and Income
Applicability: All filers complete Part 5.
Reporting Period:		Completing the Fields:
Candidate, Nominee, or New Entrant: Preceding calendar year and		Complete these fields using the instructions from Part 2 with two
current year to filing date		exceptions. First, you do not need to provide the exact amount of your
		spouse’s earned income, other than honoraria. Instead, simply describe
Annual: Preceding calendar year		the type of income in the Income Type field and leave the Income
		Amount field blank. Second, the value and income amount fields
Termination: End of period covered by last report to termination date		include a category labeled “Over $1,000,000.” You may use this
		category or you may use the higher value and amount categories.
Reporting Requirement:
		Nothing to Report: If you do not have anything to report, write “None.”
• Report each source of earned income, excluding honoraria, for your
spouse over $1,000 during the reporting period.
• Report each source of honoraria for your spouse over $200 during the
reporting period.
• Report each asset related to your spouse’s employment, business
activities, other income-generating activities that (1) ended the
reporting period with a value greater than $1,000 or (2) produced more
than $200 in income during the reporting period (e.g., equity in business
or partnership, stock options, retirement plans/accounts and their
underlying holdings as appropriate, deferred compensation, and
intellectual property, such as book deals and patents).
Exceptions:
Do not include assets or income from United States Government
employment. In addition, do not include assets that were acquired
separately from your spouse’s business, employment, or other income-
generating activities (e.g., assets purchased through a brokerage account)
because you will report these assets in Part 6.
Instructions for Completing Part 6 of the OGE Form 278e: Other Assets and Income
Applicability: All filers complete Part 6.
Reporting Period:		Completing the Fields:
Candidate, Nominee, or New Entrant: Preceding calendar year and		Complete these fields using the instructions from Part 2 with one
current year to filing date		exception. The value and income amount fields include a category
		labeled “Over $1,000,000.”
Annual: Preceding calendar year
		You may use this category only for your spouse’s or dependent child’s
Termination: End of period covered by last report to termination date		assets. Do not use this category for your assets or assets held jointly
		with your spouse or dependent child.
Reporting Requirement:
		Nothing to Report: If you do not have anything to report, write “None.”
Each asset held for investment or the production of income, not already
reported in Part 2 or Part 5, that ended the reporting period with a value
greater than $1,000 or that produced more than $200 in income during
the reporting period. For purposes of the value and income thresholds,
aggregate your interests with those of your spouse and your dependent
children.
Exceptions:
Do not report any of the following: (1) a personal residence that you
did not rent out during the reporting period; (2) retirement benefits
from the United States Government, including the Thrift Savings Plan;
(3) income from social security, veterans’ benefits, and other similar
United States Government benefits; (4) deposits in a single financial
institution aggregating $5,000 or less in money market accounts,
certificates of deposit, savings accounts, checking accounts or other
cash deposits; (5) shares in a single money market mutual fund
aggregating $5,000 or less; (6) loans made by you or your spouse to
each other or to a parent, sibling, child, or grandchild; (7) interests of a
spouse living separate and apart with the intention of terminating the
marriage or providing for a permanent separation; (8) interests of a
former spouse or a spouse from whom you are permanently separated;
and (9) payments from a spouse or former spouse associated with a
divorce or permanent separation.
Instructions for Completing Part 7 of the OGE Form 278e: Transactions
Applicability: Complete Part 7 if you are filing an Annual
or Termination report. Otherwise, leave this Part blank.
Reporting Period:		Completing the Fields:
Candidate, Nominee, or New Entrant: N/A		Description: Provide the name of the asset.
Annual: Preceding calendar year		Type: Specify the type of transaction as a purchase, sale, or exchange
Termination: End of period covered by last report to termination date		Date: Provide the month, day, and year of the transaction.
Reporting Requirement:		Amount: Report the amount of transaction by selecting the appropriate
		category. You may use the “Over $1,000,000” category only for
Report any purchase, sale, or exchange of real property or securities in		transactions involving your spouse’s or dependent child’s assets.
excess of $1,000 that was made by you, your spouse, or your dependent		Do not use this category for your assets or assets held jointly with your
child during the reporting period.		spouse or dependent child.
Exceptions:		Nothing to Report: If you do not have anything to report, write “None.”
Do not report the following: (1) a personal residence, unless the
personal residence was rented out at any point during the reporting
period; (2) cash accounts (e.g., checking, savings, CDs, money market
accounts) and money market mutual funds; (3) Treasury bills, notes,
and bonds; (4) Thrift Saving Plan accounts; (5) an underlying asset of
an excepted investment fund, an excepted trust, or a qualified trust;
(6) transactions that you already reported in your periodic transaction
report (OGE Form 278-T), unless your agency requires duplicate
reporting; (7) transactions that occurred when you were not an
employee of the United States Government; (8) transactions that
occurred solely by and between you, your spouse, and your dependent
children; (9) interests of a spouse living separate and apart with
the intention of terminating the marriage or providing for a permanent
separation; and (10) interests of a former spouse or a spouse from
whom you are permanently separated.
Instructions for Completing Part 8 of the OGE Form 278e: Liabilities
Applicability: All filers complete Part 8.
Reporting Period:		Additional Exception for Certain Mortgages:
Candidate, Nominee, or New Entrant: Preceding calendar year and		• If you are not a nominee or appointee to a Presidentially-appointed,
current year to filing date		Senate-confirmed (PAS) position, you do not need to report a mortgage
		or home equity loan secured by your personal residence, unless you
Annual: Preceding calendar year		rented out the personal residence during the reporting period.
		However, you must report mortgages or home equity loans on
Termination: End of period covered by last report to termination date		properties that do not qualify as personal residences.
Reporting Requirement:		• If you are a nominee or appointee to one of the three types of PAS
		positions listed below, you do not need to report a mortgage or home
Report liabilities over $10,000 that you, your spouse, or your		equity loan secured by your personal residence, unless you rented out
dependent child owed at any time during the reporting period.		the personal residence during the reporting period. However, you
		must report mortgages or home equity loans on properties that do not
Reporting Exceptions:		qualify as personal residences. The three types of PAS positions are:
		(1) a position in which you will serve as a special Government
Do not report the following: (1) loans secured by a personal motor		employee (SGE); (2) a position as a Foreign Service Officer below
vehicle, household furniture, or appliances, provided that the loan does		the rank of ambassador; or (3) a position in the uniformed services for
not exceed the item’s purchase price; (2) revolving charge accounts,		which the pay grade prescribed by section 201 of title 37, United
such as credit card balances, where the outstanding liability did not		States Code is O–6 or below.
exceed $10,000 at the end of the reporting period; (3) personal
liabilities owed to a spouse, parent, sibling, or child of yours, your		• If you are a nominee or appointee to any other type of PAS position,
spouse, or your dependent child; (4) liabilities of a spouse living		you must report a mortgage or home equity loan secured by your
separate and apart with the intention of terminating the marriage or		personal residence as you would a mortgage on any other property.
providing for a permanent separation; (5) liabilities of a former spouse
or a spouse from whom you are permanently separated; and
(6) obligations arising from divorce or permanent separation.
(Instructions continue on the following page.)
Completing the Fields:		Nothing to Report: If you do not have anything to report, write “None.”
Creditor: Provide the name of the creditor/lending institution.
Type: Identify the type of liability.
Amount: Select the appropriate category of amount or value. For
revolving charge accounts, use the value of the liability at the end of the
reporting period. For all other liabilities, select the category that
corresponds to the highest amount owed during the reporting period.
You may use the “Over $1,000,000” category only for your spouse’s
or dependent child’s liabilities. Do not use this category for your
liabilities or a joint liability for you and your spouse or dependent child.
Year Incurred: Provide the year that the liability was incurred.
Rate: Provide the interest rate. Describing the rate in reference to a
prime rate, such as “prime + 1,” is also sufficient.
Term: Specify, in years or months, the time that the loan allows for
repayment. If applicable, you may write “on demand” or “revolving.”
Instructions for Completing Part 9 of the OGE Form 278e: Gifts and Travel Reimbursements
Applicability: Complete Part 9 if you are filing an Annual or
Termination report. Otherwise, leave this Part blank.
Reporting Period:		totally independent of their relationship to you; (7) gifts in the nature
		of communications to your office, such as subscriptions to newspapers
Candidate, Nominee, or New Entrant: N/A		and periodicals; (8) gifts of hospitality (food, lodging, entertainment)
		on the donor’s personal or family premises, as defined in 5 C.F.R.
Annual: Preceding calendar year		Part 2634; (9) any gifts and travel reimbursements received when you
		were not an employee of the United States Government; and (10) any
Termination: End of period covered by last report to termination date		reimbursements you received for political trips that were required to
		be reported under section 304 of the Federal Election Campaign Act
Reporting Requirement:		of 1971 (2 U.S.C. § 434).
• Gifts totaling more than $375 that you, your spouse, and your		Completing the Fields:
dependent children received from any one source during the reporting
period.		Source Name: Provide the identity of the source.
• Travel reimbursements totaling more than $375 that you, your		City/State: Provide the source’s city and state of business or
spouse, and your dependent children received from any one source		residence.
during the reporting period.
		Brief Description: Describe the nature of the item or reimbursement
If more than one gift or travel reimbursement was received from a		received. For travel-related gifts and reimbursements, include a travel
single source: (1) Determine the value of each item received from		itinerary, the dates of travel, and the nature of the expenses. Although
that source; (2) exclude each item valued at $150 or less; and (3) add		not required, it is helpful to specify your relationship to the source or
the value of those items valued at more than $150. If the total is more		note the basis on which you accepted the gift or reimbursement.
than $375, then you must report each item valued at more than $150.
		Value: Provide the fair market value of the gift(s) or travel
Exceptions:		reimbursement(s).
Do not report the following: (1) anything received from a relative;		Nothing to Report: If you do not have anything to report, write “None.”
(2) bequests and other forms of inheritance; (3) suitable mementos of
a function honoring you (e.g., retirement party); (4) food, lodging,
transportation, and entertainment or reimbursements provided by a
foreign government within a foreign country or by the United States
Government, the District of Columbia, or a State or local government;
(5) food and beverages not consumed in connection with a gift of
overnight lodging; (6) anything given to your spouse or dependent child

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Sheet 2: Cover Page

OGE Form 278e (March 2014)
U.S. Office of Government Ethics; 5 C.F.R. part 2634 | Form Approved: OMB No. (3209-0001)
Report Type:
Year (Annual Report only):
Date of Appointment/Termination:
Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e)
Filer's Information
Last Name	First Name	MI	Position	Agency
Other Federal Government Positions Held During the Preceding 12 Months:
Name of Congressional Committee Consideration Nomination (Nominees only):
Filer's Certification - I certify that the statements I have made in this report are true, complete and correct to the best of my knowledge:
Signature:			Date:
Agency Ethics Official’s Opinion – On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations (subject to any comments below)
Signature:			Date:
Other Reviewer Conducted By:
Signature:			Date:
U.S. Office of Government Ethics Certification (if required):
Signature:			Date:
Comments of Reviewing Officials:

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Sheet 3: Part 1

OGE Form 278e (March 2014)
Instructions for Part 1
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name					Page Number
Part 1: Filer's Positions Held Outside United States Government
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Sheet 4: Part 2

OGE Form 278e (March 2014)
Instructions for Part 2
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name						Page Number
Part 2: Filer's Employment Assets and Income
#	Description	EIF	Value	Income Type	Income Amount
1.		Specify whether the entry qualifies as an Excepted Investment Fund. If the entry is not an investment vehicle at all, select "N/A."			Select a category of income if appropriate. See Part 2 instructions for more information.	Provide the exact amount of income in this field if appropriate. See Part 2 instructions for more information.
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Sheet 5: Part 3

OGE Form 278e (March 2014)
Instructions for Part 3
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name					Page Number
Part 3: Filer's Employment Agreements and Arrangements
#	Employer or Party	City/State	Status and Terms			Date
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Sheet 6: Part 4

OGE Form 278e (March 2014)
Instructions for Part 4
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name					Page Number
Part 4: Filer's Sources of Compensation Exceeding $5,000 in a Year
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Sheet 7: Part 5

OGE Form 278e (March 2014)
Instructions for Part 5
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name						Page Number
Part 5: Spouse's Employment Assets and Income
#	Description	EIF	Value	Income Type	Income Amount
1.		Specify whether the entry qualifies as an Excepted Investment Fund. If the entry is not an investment vehicle at all, select "N/A."			Select a category of income if appropriate. See Part 5 instructions for more information.	Provide the exact amount of income in this field if appropriate. See Part 5 instructions for more information.
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Sheet 8: Part 6

OGE Form 278e (March 2014)
Instructions for Part 6
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name						Page Number
Part 6: Other Assets and Income
#	Description	EIF	Value	Income Type	Income Amount
1.		Specify whether the entry qualifies as an Excepted Investment Fund. If the entry is not an investment vehicle at all, select "N/A."			Select a category of income if appropriate. See Part 6 instructions for more information.	Provide the exact amount of income in this field if appropriate. See Part 6 instructions for more information.
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Sheet 9: Part 7

OGE Form 278e (March 2014)
Instructions for Part 7
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name					Page Number
Part 7: Transactions
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Sheet 10: Part 8

OGE Form 278e (March 2014)
Instructions for Part 8
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name								Page Number
Part 8: Liabilities
#	Creditor		Type		Amount	Year Incurred	Rate	Term
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Sheet 11: Part 9

OGE Form 278e (March 2014)
Instructions for Part 9
Note: This is a public form. Do not include account numbers, street addresses, or family member names. See instructions for required information.
Filer's Name					Page Number
Part 9: Gifts and Travel Reimbursements
#	Source Name	City/State	Brief Description			Value
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Sheet 12: Summary of Contents

OGE Form 278e (March 2014)

Summary of Contents

1. Filer's Positions Held Outside the United States Government

Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the filer

the filer did not receive compensation. This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an

honorary nature; (3) positions held as part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests

as a limited partner or non-managing member of a limited liability company.

2. Filer's Employment Assets and Income

Part 2 discloses the following:

• Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria, scholarships,

and prizes)

• Assets related to the filer's business, employment, or other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than

$200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred

compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or other

income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset

qualifies as an excepted investment fund (EIF).

3. Filer's Employment Arrangements

Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as

the following:

• Future employment

• Leave of absence

• Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer)

• Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan

• Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a company's

profits, etc.)

4. Filer's Sources of Compensation

Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period. The filer

discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its payment to the

filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client is paying.

OGE Form 278e (March 2014)

5. Spouse's Employment Assets and Income

Part 5 discloses the following:

• Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership share)

• Sources of honoraria for the filer's spouse greater than $200 during the reporting period

• Assets related to the filer's spouse's employment, business activities, other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or

(2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as

appropriate, deferred compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business,

employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200

or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria).

6. Other Assets and Income

Part 6 discloses each asset, not already reported, that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in investment income during

during the reporting period. For purposes of the value and income thresholds, the filer aggregate the filer's interests with those of the filer's spouse and dependent children. This section

does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits associated

with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial institution

with a value of $5,000 or less (unless more than $200 of income was produced). Additional exceptions apply. Note: The type of income is not required if the amount of income is

$0 - $200 or if the asset qualifies as an excepted investment fund (EIF).

7. Transactions

Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during reporting

period. This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money market

accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions apply.

8. Liabilities

Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period. This section does not include the following types

of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a personal motor vehicle, household furniture, or appliances,

unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances, if the outstanding liability did not exceed $10,000 at the end of the

reporting period. Additional exceptions apply.

9. Gifts and Travel Reimbursements

This section discloses:

• Gifts totaling more than $375 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.

• Travel reimbursements totaling more than $375 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.

For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $150 or less. Regardless of the value, this section does not include the

following items: (1) anything received from relatives; (2) anything received from the United States federal government or from the District of Columbia, state, or local governments;

(3) bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food,

lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their relationship to the

filer. Additional exceptions apply.

OGE Form 278e (March 2014)

Privacy Act Statement

Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. app. § 101 et seq., as amended by the Stop Trading on Congressional Knowledge Act of 2012

(Pub. L. 112-105) (STOCK Act), and 5 C.F.R. Part 2634 of the U. S. Office of Government Ethics regulations require the reporting of this information. The primary use of the

information on this report is for review by Government officials to determine compliance with applicable Federal laws and regulations. This report may also be disclosed upon request

to any requesting person in accordance with sections 105 and 402(b)(1) of the Act or as otherwise authorized by law. You may inspect applications for public access of your own form

upon request. Additional disclosures of the information on this report may be made: (1) to any requesting person, subject to the limitation contained in section 208(d)(1) of title 18, any

determination granting an exemption pursuant to sections 208(b)(1) and 208(b)(3) of title 18; (2) to a Federal, State, or local law enforcement agency if the disclosing agency becomes

aware of violations or potential violations of law or regulation; (3) to another Federal agency, court or party in a court or Federal administrative proceeding when the Government is a

party or in order to comply with a judge-issued subpoena; (4) to a source when necessary to obtain information relevant to a conflict of interest investigation or determination; (5) to

the National Archives and Records Administration or the General Services Administration in records management inspections; (6) to the Office of Management and Budget during

legislative coordination on private relief legislation; (7) to the Department of Justice or in certain legal proceedings when the disclosing agency, an employee of the disclosing agency, or

the United States is a party to litigation or has an interest in the litigation and the use of such records is deemed relevant and necessary to the litigation; (8) to reviewing officials in a

new office, department or agency when an employee transfers or is detailed from one covered position to another; (9) to a Member of Congress or a congressional office in response

to an inquiry made on behalf of an individual who is the subject of the record; (10) to contractors and other non-Government employees working on a contract, service or assignment for

the Federal Government when necessary to accomplish a function related to an OGE Government-wide system of records; and (11) on the OGE Website and to any person, department

or agency, any written ethics agreement filed with OGE by an individual nominated by the President to a position requiring Senate confirmation. See also the OGE/GOVT-1 executive

branch-wide Privacy Act system of records.

Public Burden Information

This collection of information is estimated to take an average of three hours per response, including time for reviewing the instructions, gathering the data needed, and completing the

form. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Program Counsel,

U.S. Office of Government Ethics (OGE), Suite 500, 1201 New York Avenue, NW., Washington, DC 20005-3917.

Pursuant to the Paperwork Reduction Act, as amended, an agency may not conduct or sponsor, and no person is required to respond to, a collection of information unless it displays a

currently valid OMB control number (that number, 3209-0001, is displayed here and at the top of the first page of this OGE Form 278e).