Form OGE Form 278e OGE Form 278e EXECUTIVE BRANCH PERSONNEL PUBLIC FINANCIAL DISCLOSURE R

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)
U.S. Office of Government Ethics; 5 C.F.R. part 2634

Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e)
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 up to 45 days.
Extensions for candidates are granted by the Federal Election Commission.

Other Category of Filer: In most cases, individuals will file their public financial
disclosure reports through an electronic financial disclosure system. Do not use
this form if you plan to file using an electronic financial disclosure system.
When Must I File?
Candidate: Within 30 days of becoming a candidate for nomination or election
to the office of President or Vice President, or by May 15 of that calendar year,
whichever is later, but at least 30 days before the election, and on or before
May 15 of each succeeding year you continue to be a candidate.

Late Filing
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 report is considered to be filed
when it is received by the agency. Agencies may waive this fee if the delay was
caused by extraordinary circumstances. Unless waived, the agency will collect the
fee for deposit with the United States Treasury.
Warnings

Nominee: No later than 5 days after nomination by the President
New Entrant: Within 30 days of assuming a covered position
Annual: No later than May 15 annually
Termination: Within 30 days of leaving a covered position

Knowing and willful falsification of information, or failure to file or report
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 civil monetary penalty
and to disciplinary action by your employing agency or other appropriate authority
under section 104 of the Act. Knowing and willful falsification of information
required to be filed by section 102 of the Act may also subject you to criminal
prosecution.

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 1 of the OGE Form 278e: Filer's Positions Held Outside United States Government
Applicability: All filers complete Part 1.

Completing the Fields:

Reporting Period:

Organization Name: Provide the name of the organization.

Candidate, Nominee or New Entrant: Preceding two calendar years and current
year to filing date

City/State: Provide the city and state in which the organization is located.
Organization Type: Describe the type of organization.

Annual: Preceding calendar year and current year to filing date
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)

Position Held: Provide the title or a brief functional description of the position
you hold or held.
From: Provide the month and year in which you began in the position.

Reporting Requirement:
Report any positions that you held at any time during the reporting period
(excluding positions with the United States Government). Reportable positions
include those of an officer, director, trustee, general partner, proprietor,
representative, employee, or consultant of any for-profit or non-profit
organization (whether compensated or uncompensated).
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 or governmental organization; (2) your service is unpaid;
(3) you have no fiduciary duties of the sort exercised by officers, directors, or
trustees; and (4) your role does not involve sufficient supervision by the
organization to create a common law employee-employer relationship.

To: Provide the month and year in which the position ended. If you still hold the
position, write "present."
Nothing to Report: If you do not have anything to report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 2 of the OGE Form 278e: Filer's Employment Assets & Income and Retirement Accounts
Applicability: All filers complete Part 2.

Value: Report the value of an asset by selecting the appropriate category.

Reporting Period:

Income Type:

Candidate, Nominee, or New Entrant: Preceding calendar year and current year
to filing date

(1) Income Less than $201: Leave this field blank.
(2) Asset Qualifies as an EIF: Leave this field blank.

Annual: Preceding calendar year
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)

(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").

Reporting Requirement:
Income Amount:
• Report each source of your earned and other non-investment income over $200
during the reporting period (e.g., salary, fees, partnership share and other
business income, honoraria, scholarships, and prizes).
• Report each asset related to your business, employment, or other incomegenerating activities if the value of the asset at the end of the reporting period
exceeded $1,000 or if more than $200 in income was received during the reporting
period (e.g., equity in business or partnership, stock options, retirement plans/
accounts and their underlying holdings as appropriate, anticipated payments
such as severance payments, deferred compensation, and intellectual property,
such as book deals and patents).

(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 received during the reporting period.
(3) Dividends, Interest, Capital Gains or Rent or Royalties: Select the category that
corresponds to the total amount of income received during the reporting period.
(4) Other Cases: Provide the exact amount of income received during the reporting
period in the space provided.

Exceptions:

Nothing to Report: If you do not have anything to report, write "None."

Do not include assets or income from United States Government employment.
In addition, do not include assets that were acquired separately 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.

Definitions:

Completing the Fields:
Description: Provide a description sufficient to identify the asset or source
being reported.
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 worth more than
$1,000 at the end of the reporting period or from which more than $200 in
income was received during the reporting period. As an exception to this
requirement, however, you do not need to report the underlying assets of an
investment vehicle that qualifies as an excepted investment fund (EIF). Indicate
whether your entry qualifies as an excepted investment fund. If your entry is not an
investment vehicle at all, select "N/A."

Definition of "Excepted Investment Fund": An excepted investment fund is an
investment fund that is (1) widely held; (2) either publicly traded or available
or widely diversified; and (3) independently managed, meaning you neither
exercise control nor have the ability to exercise control over the financial interests
held by the fund. A fund is widely diversified if it does not have a stated policy of
concentrating its investments in any industry, business, or single country other than
the United States or bonds of a single state within the United States.
Definition of "Received": You have received income when you have the right to
exercise control over the income regardless of whether you have taken actual
possession.

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 3 of the OGE Form 278e: Filer's Employment Agreements and Arrangements
Applicability: All filers must complete Part 3.

Completing the Fields:

Reporting Period:

Employer or Party: Provide the parties to the agreement or arrangement, other than
yourself. In most cases, the other party will be your employer.

Candidate, Nominee, or New Entrant: As of the date of filing
City/State: Provide the city and state of the other parties.
Annual: Preceding calendar year and current year to filing date
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)
Reporting Requirement:
Report any agreements or arrangements that you had during the reporting period
for the following: (1) continuing participation in an employee welfare
or benefit plan maintained by a former employer; (2) leave of absence;
(3) future employment; or (4) continuation of payments by a former employer
(e.g., severance payments).
Exceptions:
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; and (3) if you are
filing a Nominee, New Entrant, or Candidate report, any agreement or arrangement
that will end before you file your report.

Status and Terms: Briefly describe the type of agreement or arrangement, its terms
(in particular, the timing and form of any payments), and its current status.
Date: Provide the month and year in which the agreement or arrangement began.
In many cases, this will be when you joined the employer or otherwise became
eligible for coverage under the agreement or arrangement.
Nothing to Report: If you do not have anything to report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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.

Completing the Fields:
Source Name: Provide the name of the source.

Reporting Period:
City/State: Provide the city and state in which this source is located.
Nominee or New Entrant: Preceding two calendar years and current year to
filing date

Brief Description of Duties: Provide a brief description of your duties or the
type of services rendered.

Other Reports: N/A
Reporting Requirement:
Report any source (except the United States Government) that paid more than
$5,000 for your services during any year of the reporting period. Report
employers and any clients to whom you personally provided services. You
must report a source even if the source made its payment to your employer and
not to you. Do not report a client who paid your employer if you did not provide
the services for which the client made the payment.
Exception:
The name of a source of compensation may be excluded only if that information is
specifically determined to be confidential as a result of a privileged relationship
established by law and if the disclosure is specifically prohibited:
• by law or regulation,
• by a rule of a professional licensing organization, or
• by a client agreement that at the time of engagement of the filer's services
expressly provided that the client's name would not be disclosed publicly to any
person.
If you exclude the name of any source, you must indicate in the report that such
information has been excluded, the number of sources excluded, and, if applicable,
a citation to the statute, regulation, rule of professional conduct, or other authority
pursuant to which disclosure of the information is specifically prohibited.

Nothing to Report: If you do not have anything to report and you are filing
a Nominee or New Entrant report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 5 of the OGE Form 278e: Spouse's Employment Assets & Income and Retirement Accounts
Applicability: All filers complete Part 5.

Completing the Fields:

Reporting Period:

Complete these fields using the instructions from Part 2 with two exceptions. First,
you do not need to provide the exact amount of your spouse's earned income, other
than honoraria. Instead, simply describe the type of income in the Income Type field
and leave the Income Amount field blank. Second, the value and income amount
fields include a category labeled "Over $1,000,000." You may use this category
or you may use the higher value and amount categories.

Candidate, Nominee, or New Entrant: Preceding calendar year and current year
to filing date
Annual: Preceding calendar year
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)
Reporting Requirement:
• 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 (1) that ended the reporting period with a value
greater than $1,000 or (2) from which more than $200 in income was received
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.

Nothing to Report: If you do not have anything to report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 6 of the OGE Form 278e: Other Assets and Income
Applicability: All filers complete Part 6.

Completing the Fields:

Reporting Period:

Complete these fields using the instructions from Part 2 with one exception.
The value and income amount fields include a category labeled "Over $1,000,000."

Candidate, Nominee, or New Entrant: Preceding calendar year and current year
to filing date
Annual: Preceding calendar year
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)
Reporting Requirement:
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 from which more than $200 in income was received 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 (unless the income exceeded $200); (5) shares in a single
money market mutual fund aggregating $5,000 or less (unless the income exceeded
$200); (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.

You may use this category only for your spouse's or dependent child's assets.
Do not use this category for your assets or assets held jointly with your spouse
or dependent child.
Nothing to Report: If you do not have anything to report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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.

Completing the Fields:
Description: Provide the name of the asset.

Reporting Period:
Type: Specify the type of transaction as a purchase, sale, or exchange.
Candidate, Nominee, or New Entrant: N/A
Date: Provide the month, day, and year of the transaction.
Annual: Preceding calendar year
Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)

Amount: Report the amount of the transaction by selecting the appropriate category.
You may use the "Over $1,000,000" category only for transactions involving
your spouse's or dependent child's 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."
Report any purchase, sale, or exchange of real property or securities in excess
of $1,000 that was made by you, your spouse, or your dependent child during
the reporting period.
Exceptions:
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 held within 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 a public financial
disclosure filer or 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.

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Instructions for Completing Part 8 of the OGE Form 278e: Liabilities
Applicability: All filers complete Part 8.

ambassador; or (3) a position in the uniformed services for which the pay grade
prescribed by section 201 of title 37, United States Code is O–6 or below.

Reporting Period:
Candidate, Nominee, or New Entrant: Preceding calendar year and current year
to filing date

• If you are a nominee or appointee to any other type of PAS position, you must
report a mortgage or home equity loan secured by your personal residence as you
would a mortgage on any other property.

Annual: Preceding calendar year

Completing the Fields:

Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)

Creditor Name: Provide the name of the creditor/lending institution.
Type: Identify the type of liability.

Reporting Requirement:
Report liabilities over $10,000 that you, your spouse, or your dependent child
owed at any time during the reporting period.
Exceptions:
Do not report the following: (1) loans secured by a personal motor vehicle,
household furniture, or appliances, provided that the loan does not exceed the
item's purchase price; (2) revolving charge accounts, such as credit card balances,
where the outstanding liability did not exceed $10,000 at the end of the reporting
period; (3) personal liabilities owed to a spouse, parent, sibling, or child of yours,
your spouse, or your dependent child; (4) liabilities of a spouse living separate
and apart with the intention of terminating the marriage or 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.
Additional Exception for Certain Mortgages:
• If you are not a nominee or appointee to a Presidentially-appointed, Senateconfirmed (PAS) position, you do not need to report a mortgage or home equity
loan secured by your personal residence, unless you rented out the personal
residence during the reporting period. However, you must report mortgages or
home equity loans on properties that do not qualify as personal residences.
• 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 equity loan secured by your
personal residence, unless you rented out the personal residence during the
reporting period. However, you must report mortgages or home equity loans on
properties that do not qualify as personal residences. The three types of PAS
positions are: (1) a position in which you will serve as a special Government
employee (SGE); (2) a position as a Foreign Service Officer below the rank of

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."
Nothing to Report: If you do not have anything to report, write "None."

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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.

Completing the Fields:
Source Name: Provide the identity of the source.

Reporting Period:
City/State: Provide the source's city and state of business or residence.
Candidate, Nominee, or New Entrant: N/A

Termination: Current calendar year to termination date (in addition, the preceding
calendar year if an Annual report for that year is required but has not yet been filed)

Brief Description: Describe the nature of the item or reimbursement received.
For travel-related gifts and reimbursements, include a travel itinerary, the dates of
travel, and the nature of the expenses. Although not required, it is helpful to specify
your relationship to the source or note the basis on which you accepted the gift or
reimbursement.

Reporting Requirement:

Value: Provide the fair market value of the gift(s) or travel reimbursement(s).

• Gifts totaling more than $415 that you, your spouse, and your dependent
children received from any one source during the reporting period.

Nothing to Report: If you do not have anything to report, write "None."

Annual: Preceding calendar year

• Travel reimbursements totaling more than $415 that you, your spouse, and your
dependent children received from any one source during the reporting period.
If more than one gift or travel reimbursement was received from a single source:
(1) Determine the value of each item received from that source; (2) exclude each
item valued at $166 or less; and (3) add the value of those items valued at more
than $166. If the total is more than $415, then you must report each item valued
at more than $166.
Exceptions:
Do not report the following: (1) anything received from a relative; (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 totally
independent of their relationship to you; (7) gifts in the nature of communications
to your office, such as subscriptions to newspapers and periodicals; (8) gifts of
hospitality (food, lodging, entertainment) on the donor's personal or family
premises, as defined in 5 C.F.R. Part 2634; (9) any gifts and travel reimbursements
received when you were not an employee of the United States Government; and
(10) any reimbursements you received for political trips that were required to be
reported under section 304 of the Federal Election Campaign Act of 1971
(2 U.S.C. § 434).

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)
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 Considering 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 Review Conducted By:
Signature:

Date:

U.S. Office of Government Ethics Certification (if required):
Signature:

Date:

Comments of Reviewing Officials:

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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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Organization Name

City/State

Organization Type

Position Held

From

To

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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 & Income and Retirement Accounts
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Description

EIF

Value

Income Type

Income Amount

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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
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City/State

Status and Terms

Date

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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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Source Name

City/State

Brief Description of Duties

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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 & Income and Retirement Accounts
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Description

EIF

Value

Income Type

Income Amount

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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
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Description

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Value

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Income Amount

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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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Description

Type

Date

Amount

OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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
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OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

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
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OGE Form 278e (Updated Nov. 2019) (Expires 12/31/21)

Summary of Contents
1. Filer's Positions Held Outside 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 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 & Income and Retirement Accounts
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 (1) that ended the reporting period with a value greater than $1,000 or (2) from which
more than $200 in income was received 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 Agreements and 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 Exceeding $5,000 in a Year
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 (Updated Nov. 2019) (Expires 12/31/21)

5. Spouse's Employment Assets & Income and Retirement Accounts
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 (1) that ended the reporting period with a value greater than $1,000 or
(2) from which more than $200 in income was received 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, (1) that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in investment income
was received during the reporting period. For purposes of the value and income thresholds, the filer aggregates 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 in income was received). 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 the 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 $415 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.
• Travel reimbursements totaling more than $415 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 $166 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 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 (Updated Nov. 2019) (Expires 12/31/21)

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. Failure to provide the requested
information may result in separation, disciplinary action, or civil action. 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 a source
when necessary to obtain information relevant to a conflict of interest investigation or determination; (4) to the National Archives and Records Administration or the General Services
Administration in records management inspections; (5) to the Office of Management and Budget during legislative coordination on private relief legislation; (6) when the disclosing
agency determines that the records are arguably relevant to a proceeding before a court, grand jury, or administrative or adjudicative body, or in a proceeding before an administrative
or adjudicative body when the adjudicator determines the records to be relevant to the proceeding; (7) to reviewing officials in a new office, department or agency when an employee
transfers or is detailed from one covered position to another, a public financial disclosure report and any accompanying documents, including statements notifying an employee’s
supervising ethics office of the commencement of negotiations for future employment or compensation or of an agreement for future employment or compensation; (8) to a Member
of Congress or a congressional office in response to an inquiry made on behalf of and at the request of an individual who is the subject of the record; (9) 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 this system of records;
(10) on the OGE Website and to any person, department or agency, any written ethics agreement, including certifications of ethics agreement compliance, filed with OGE by an individual
nominated by the President to a position requiring Senate confirmation; (11) on the OGE Website and to any person, department or agency, any certificate of divestiture
issued by OGE; (12) on the OGE Website and to any person, department or agency, any waiver of the restrictions contained in Executive Order 13770 or any superseding executive order;
(13) to appropriate agencies, entities and persons when there has been a suspected or confirmed breach of the system of records, the agency maintaining the records has determined that
there is a risk of harm to individuals, the agency, the Federal Government, or national security, and the disclosure is reasonably necessary to assist in connection with the agency's efforts
to respond to the suspected or confirmed breach or to prevent, minimize, or remedy such harm; and (14) to another Federal agency or Federal entity, when the agency maintaining the
record determines that information from this system of records is reasonably necessary to assist the recipient agency or entity in responding to a suspected or confirmed breach or in
preventing, minimizing, or remedying the risk of harm to individuals, the recipient agency or entity, the Federal Government, or national security. 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 ten 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, N.W., 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).