OGE - 450 - PRA Supporting Statement 2021

U. S. OFFICE OF GOVERNMENT ETHICS
SUPPORTING STATEMENT FOR THE OGE FORM 450
EXECUTIVE BRANCH CONFIDENTIAL FINANCIAL DISCLOSURE REPORT
AUGUST 2021
A. Justification
1.-2. Explain the circumstances that make the collection of information necessary.
Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.
The primary use of the information on this form is for review by Government
officials of the filer’s agency to determine compliance with applicable Federal conflict of
interest laws and regulations. The authority for collection of the information on the OGE
Form 450 as provided in the underlying Office of Government Ethics (OGE) regulation,
primarily at subpart I of 5 CFR part 2634, is two-fold. First, section 201(d) of Executive
Order 12674 of April 12, 1989, as amended, directs OGE to establish a system of
nonpublic (confidential) financial disclosure by executive branch employees to
complement the system of public disclosure under the Ethics in Government Act of 1978
as amended (EIGA), 5 U.S.C. appendix 101. Second, section 107(a) of EIGA authorizes
OGE, as the supervising ethics office for the executive branch of the Federal
Government, to require that executive agency employees file confidential financial
disclosure reports, “in such form as the supervising ethics office may prescribe.” The
OGE Form 450, together with the underlying OGE regulation initially adopted in 1992
and subsequently modified at 5 CFR part 2634, constitutes the format prescribed by OGE
for such confidential financial disclosure in the executive branch.
OGE maintains the form in three formats on its website: a PDF version, a 508
compliant PDF version, and an Excel spreadsheet version.
OGE is submitting the OGE Form 450 confidential financial disclosure form
package for an extension of a currently approved collection by the Office of Management
and Budget (OMB) under the Paperwork Reduction Act (control number 3209-0006).
3. Describe whether, and to what extent, the collection of information involves the
use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology.
The OGE Form 450 is available on OGE’s website at http://www.oge.gov. The
form is a viewable and downloadable PDF version of the form that is both fillable and
printable, providing a locally reproducible form for use as needed by agencies and the
public. In addition, OGE will continue to allow agencies to electronically duplicate the
OGE Form 450, provided that the electronic versions precisely duplicate the paper

original. The basis for these electronic initiatives is to lessen burden and to facilitate
dissemination to and use of the form by agencies and filers.
4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in item 2 above.
Not applicable. The OGE Form 450 is the only executive branchwide form used
for employee confidential financial disclosure, though individual agencies have obtained
OGE approval for the collection of alternative forms or have separate or supplemental
disclosures of information based on independent statutory authorities or other unique
circumstances.
5. If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.
Not applicable. This collection of information does not involve small businesses
or other small entities.
6. Describe the consequence to Federal program or policy activities if the collection
is not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing the burden.
Not applicable. The collection, including its frequency, is required by 5 CFR part
2634, subpart I, which OGE has promulgated under the cited statutory and executive
order authority.
7. Explain any special circumstances that would cause an information collection to
be conducted in a manner:
• Requiring respondents to report information to the agency more often than
quarterly;
• Requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
• Requiring respondents to submit more than an original and two copies of
any document;
• Requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records, for more than 3 years;
• In connection with a statistical survey, that is not designed to produce valid
and reliable results that can be generalized to the universe of study;
• Requiring the use of a statistical data classification that has not been
reviewed and approved by OMB;
• That includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure and
data security policies that are consistent with the pledge, or that

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unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or
Requiring respondents to submit proprietary trade secrets or other
confidential information unless the agency can demonstrate that it has
instituted procedures to protect the information's confidentiality to the
extent permitted by law.

No such special circumstances exist. The confidentiality of the information
collected is protected according to the requirements of the Ethics in Government Act, and
the Privacy Act, and all other applicable laws and regulations.
8. If applicable, provide a copy and identify the date and page number of
publication in the Federal Register of the agency's notice, required by 5 CFR
1320.8(d), soliciting comments on the information collection prior to submission to
OMB.
OGE published a first round Federal Register notice soliciting comments on this
information collection on June 2, 2021. See 86 FR 29584. OGE received five responses
to that notice, one of which did not directly address the information collection. The other
four comments suggest requiring additional information, apparently for the benefit of the
government employees tasked with reviewing the information. These suggestions would
add additional reporting burden to filers and could have privacy implications. One of the
suggestions would also require a regulatory change. Accordingly, OGE declined to adopt
these suggestions in seeking Paperwork Reduction Act renewal for the OGE Form 450.
OGE published a second round Federal Register notice soliciting comments to be
directed to OMB on August 13, 2021. See 86 FR 44719.
OGE continually seeks comments from persons outside the agency concerning the
impact of its information collection instruments upon filers and agency ethics programs.
OGE provides opportunities for comment at ethics symposia and other events. OGE
routinely alerts professionals in the ethics community to recently published OGE Federal
Register notices via its listserv, various social media applications, and Advisory
Memoranda. Visitors to the OGE Website are provided the opportunity to contact OGE
with comments or suggestions. In addition, OGE has remained open to any suggestions
for improvement received in the course of public comment on the first and second round
paperwork notices published in the Federal Register. Any ongoing comments received by
OGE as a result of these various means of availability will be considered by OGE for the
next Paperwork Reduction Act renewal cycle in three years.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable. Respondents receive no payments or gifts.

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10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
Assurance of confidentiality is provided to respondents directly in the instructions
to the OGE Form 450. That confidentiality is guaranteed by section 107(a) of the Ethics
in Government Act of 1978, 5 CFR 2634.604 of OGE's regulation, and the OGE/GOVT2 Executive Branch Confidential Financial Disclosure Reports Privacy Act system of
records.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private.
All of the personal financial information required to be reported on the OGE
Form 450, as provided in 5 CFR part 2634, is deemed necessary by OGE to permit
sufficient agency review for conflict of interest purposes. No sensitive non-financial
personal information is collected.
12. Provide estimates of the hour burden of the collection of information.
OGE estimates that an average of approximately 30,449 OGE Form 450 reports
will be filed each year by private citizen filers. This number was calculated based on
OGE's annual agency ethics program questionnaire responses. (Private citizen filers are
potential incoming employees whose positions are designated for confidential financial
disclosure reporting).
OGE estimates that three hours is the average time required to complete the form.
The time to complete an OGE Form 450 varies depending on the personal finances of the
filer. The three hour figure is an average based on the estimated burden on all types of
filers.
Based on the above, the annual reporting burden for private citizen filers is
estimated to be 91,347 burden hours. The estimated annualized hour burden cost to
private citizen filers is $6,851,025. This estimate is based on the average annual number
of private citizen filers multiplied by an estimated average filer wage rate of $75 per
hour.
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
For the OGE Form 450, OGE estimates annual burden hours and annual burden
hours cost, not annual cost burden to the respondents.
14. Provide an estimate of annualized costs to the Federal Government.

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OGE previously reported that the estimated total annual cost of the OGE Form
450 to the Federal Government was $3,418,932. This estimate was based on the cost to
administer the program to private citizen filers only, not the entire confidential financial
disclosure program (private citizen filers constitute approximately 7% of all confidential
financial disclosure filers). Based on adjustments for inflation since the previous
estimate, the new estimated total annual cost is approximately $3,624,068.
15. Explain the reasons for any program changes or adjustments reported in items
13 or 14.
For 14, the estimate of annualized costs to the Federal Government has been
adjusted for inflation since the previous estimate.
16. For collections of information whose results will be published, outline plans for
tabulation and publication.
Not applicable. This is a confidential financial disclosure reporting form.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
Not applicable.
18. Explain each exception to the topics of the certification statement identified in
Certification for Paperwork Reduction Act Submissions.
Certification items (c), (f) and (i) are not applicable to this information collection.
B. Collections of Information Employing Statistical Methods
Not applicable. This collection of information does not employ statistical
methods.

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