2.13: Differences between the OGE Form 278e and the OGE Form 278



OGE redesigned the Executive Branch Personnel Public Financial Disclosure Report in 2015 to support the two fundamental goals of the public financial disclosure system: preventing conflicts of interest and promoting transparency.  The new report form, the OGE Form 278e, replaced the old report form, the OGE Form 278.

Both the OGE Form 278e and the old OGE Form 278 collect the same information.  The information is merely organized differently.  The following table cross-references the two forms.

OGE Form 278e Sections

Corresponding OGE Form 278 Sections

Cover Page

Cover Page

Part 1: Filer’s Positions Held Outside United States Government

Schedule D, Part I: Positions Held Outside U.S. Government

Part 2: Filer’s Employment Assets & Income and Retirement Accounts

Schedule A: Assets and Income

Part 3: Filer’s Employment Agreements and Arrangements

Schedule C, Part II: Agreements or Arrangements

Part 4: Filer’s Sources of Compensation Exceeding $5,000 in a Year

Schedule D, Part II: Compensation in Excess of $5,000 Paid by One Source

Part 5: Spouse’s Employment Assets & Income and Retirement Accounts

Schedule A: Assets and Income

Part 6: Other Assets and Income

Schedule A: Assets and Income

Part 7: Transactions

Schedule B, Part I: Transactions

Part 8: Liabilities

Schedule C, Part I: Liabilities

Part 9: Gifts and Travel Reimbursements

Schedule B, Part II: Gifts, Reimbursements, and Travel Expenses

OGE reorganized the disclosure of information based on its experience that filers, particularly filers entering government service for the first time, occasionally forget to report financial interests related to employment.  It is not uncommon for agency ethics officials to have to instruct filers to add these items to their reports.  By segregating financial interests related to employment, the OGE Form 278e reduces the risk of inadvertent omission.  This structure also promotes transparency by highlighting information of significant interest to the public.  (Note that, for purposes of Parts 2 and 5, “employment-related” is interpreted broadly to cover all non-investment activities as well as retirement accounts.)

In addition to the reorganization of disclosures, the OGE Form 278e eliminates the antiquated grid format.  For example, where a filer would previously have entered an “X” in a column to signify that the value of an asset is in the range of $50,001 to $100,000, the OGE Form 278e produces the following text: “$50,001 - $100,000.”