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

What to Report

5 U.S.C. app. § 102(a)(6)(A); 5 C.F.R. § 2634.307

Filers report in Part 1 any compensated or uncompensated position held with an organization other than the United States Government at any time during the reporting period, unless an exception applies.

How to Report

Organization Name:  Filers provide the name of the organization.

* Reporting a Family Trust:  For a trust that benefits the filer or a relative, filers may use initials in lieu of a person’s name (e.g., “2003 J.S. Trust”) or simply refer to the entity as a family trust (e.g., “family trust #1”).  In addition, if the trust is a revocable trust, it is helpful for the filer to note that and to indicate whether the trust is the filer’s own revocable trust or a revocable trust for some other relative.

City/State:  Filers provide the city and state in which the organization is located.

Organization Type:  Filers describe the type of organization.

Position Type (This question is for internal purposes within Integrity and is not displayed on the printed OGE Form 278e.):  Filers indicate the general type of organization by selecting one of the options provided in the drop-down list.  The list of options changes based on the type of organization.  If none of the listed options matches the type of position, filers may enter their own description.  The type of position held determines the types of questions Integrity asks concerning possible assets, income, and arrangements.

Position Held:  Filers provide the title or a brief functional description of the position.

From:  Filers provide the month and year in which service in the position began.

To:  Filers provide the month and year in which the position ended.  If a filer still holds the position, the filer should indicate “present.”

Positions That Are Not Reportable

Filers do not need to report the following in Part 1:

  • Positions held by a spouse or dependent children.
  • Positions held with the United States Government and positions held in an official capacity as a representative of the United States Government.
  • Positions held in a religious, social, fraternal, or political entity.
  • Positions solely of an honorary nature.
  • Mere membership in an organization.
  • Passive investment interests as a limited partner or non-managing member of a limited liability company (i.e., the filer is just an investor and provides no services).

In addition, filers do not need to report service as a member of an advisory board or committee if the following criteria are met: (1) the filer’s service is unpaid; (2) the board or committee is that of a non-profit or governmental organization; (3) the filer does not have fiduciary duties of the sort exercised by officers, directors, or trustees; and (4) the filer’s role does not involve sufficient supervision by the organization to create a common-law employee-employer relationship.

No Positions to Report

The filer must affirmatively state that he or she does not have any positions 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.”