2.10: Part 7 - Transactions (Annual and Termination Reports Only)

What to Report

5 U.S.C. app. §§ 102(a)(5) & (e)(1); 5 C.F.R. §§ 2634.303 & 2634.311

Filers report a purchase, sale, or exchange of real property or securities that occurred during the reporting period if the amount of the transaction was more than $1,000. 

How to Report

Generally, filers report transactions as follows:

DescriptionFilers provide a description sufficient to identify the asset being reported (or both assets in the case of an exchange).  The amount of information needed for a sufficient description will depend on the type of asset being reported. 

(1) Stock:  Provide the name of the issuing company.

(2) Other securities with specific names (e.g., bonds and mutual funds):  Provide the full name of the asset and, unless clear from the name, describe the type of asset.

(3) Real estate:  Describe the type of real estate (e.g., “residential,” “commercial,” “industrial,” or “undeveloped”) and provide the city and state in which it is located. Providing the county and state is also acceptable.  Do not provide a street address.

If the asset is an underlying holding of some other investment vehicle (e.g., held within a fund that does not qualify as an excepted investment fund), it is helpful if the filer identifies the investment vehicle (e.g., Positron Investments, LLC: Chevron Corp.).

TypeFilers specify the type of transaction as a purchase, sale, or exchange.

DateFilers provide the month, day, and year of the transaction.

AmountFilers report the amount of the transaction by selecting the appropriate category.

Transactions That Are Not Reportable

Filers do not need to report transactions that concern 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, certificates of deposit, money market accounts) and money market mutual funds; (3) Treasury bills, bonds, notes, and savings bonds; (4) holdings within a Thrift Savings Plan account or other retirement account for United States Government employees; (5) an underlying asset of an excepted investment fund, an excepted trust, or a qualified trust; and (6) assets of a trade or business, unless the assets are unrelated to the operations of that trade or business.

In addition, filers do not need to report: (1) transactions that occurred when the filer was not a public financial disclosure filer or an employee of the United States Government; (2) actions that do not constitute purchases, sales, or exchanges (e.g., gifts given or received, stock splits, bond calls or maturity, or expiration of options); (3) transactions that occurred solely by and between the filer, the filer’s spouse, or the filer’s dependent children; (4) transactions involving the interests of a spouse living separate and apart with the intention of terminating the marriage or providing for a permanent separation; and (5) transactions involving the interests of a former spouse or a spouse from whom the filer is permanently separated.

Relationship to Periodic Transaction Reports

Filers do not need to report a transaction in an Annual or Termination report (OGE Form 278e) if the transaction has already been reported in a Periodic Transaction report (OGE Form 278-T), unless the filer’s agency requires duplicate reporting.  Filers using Integrity can import transactions disclosed in prior Periodic Transaction reports without additional data entry.  Other electronic filing systems may offer similar functionality.  Agencies using such systems may determine that the benefits of aggregating all transactions within a reporting period in an Annual or Termination report outweigh the minimal burden imposed on the filer. 

No Transactions to Report

The filer must affirmatively state that he or she does not have any transactions to report.  Within Integrity, the filer would make this statement by marking the “I do not have...” checkbox.  For hard copy reports, the filer would write “None.”