Reports, at times, require additional information, clarification, or redaction.  In some cases, a filer may initiate an amendment to a report.  In other cases, a reviewer may make the amendment directly, either based on additional information from the filer or independent knowledge (e.g., indicating that a publicly traded mutual fund qualifies as an excepted investment fund).  The method of making changes to a report will depend on agency procedures as well as whether the report is being reviewed in hard copy or through an electronic filing system.     

Guidelines for Reviewer-Initiated Amendments and Annotations

Reviewers should inform filers of any additions, clarifications, or redactions made to the report.  Generally speaking, reviewers should also take care not to include more information than is required to be publicly disclosed by statute and regulation.  However, in certain cases, providing more information than is required may prove helpful in understanding a required entry.  In such cases, the reviewer may provide the information so long as the filer consents to its inclusion.

How to Amend Reports before Final Certification

Hard Copy Reports

Amendments to a hard copy report may be made through reviewer annotations to existing pages or by the filer providing replacement pages.  Reviewers should annotate reports using ink, initialing and dating the changes.  If replacing pages, the reviewer should add an annotation itemizing each replacement page in the “Comments of Reviewing Officials” section of the Cover Page.  It is also recommended, as a best practice, that filers initial and date each replacement page or provide a cover letter itemizing the replacement pages.

As appropriate, reviewers should include a brief explanation of the amendments on the affected page or in the “Comments of Reviewing Officials” section (e.g., “revisions per filer”).

Integrity

Integrity permits reviewers to add, change, or delete entries or to return the report to the filer for the necessary revisions.  Integrity records which user made the amendment within an audit trail.  The audit trail is not part of the public report; however, Integrity adds a revision date to the public version of the report.

As appropriate, reviewers should include a brief explanation of the amendments using the “public annotation” feature, which displays text in the “Comments of Reviewing Officials” section of the Cover Page.

Other Electronic Filing Systems

Agencies using other electronic filing systems should consult any relevant system documentation for assistance in making amendments.

How to Amend Reports after Final Certification by the Agency

The following guidance applies to reports that are not reviewed by OGE.  See the next section for reports that are required to be forwarded to OGE for review and certification.

Hard Copy Reports

Agencies may amend hard copy reports after certification in the same manner as they amend reports prior to certification; however, it should be clear that the report, as amended, meets the criteria for certification.

Integrity

Integrity does not permit edits to report data after final certification.  To amend a report filed in Integrity, the agency will need to upload an amendment letter and/or replacement pages as an appendix to the original report on the “Documents” tab.  These materials should make clear that they are an amendment to the original report and that the report, as amended, meets the criteria for certification.

Other Electronic Filing Systems

Agencies using other electronic filing systems should consult any relevant system documentation for assistance in making amendments.  Regardless of the mechanics used to make the amendment, a record should exist that makes clear that the report, as amended, meets the criteria for certification.

How to Amend Reports after Final Certification by OGE

To amend a report certified by OGE, the filer should provide the agency with a letter explaining the need for an amendment and the nature of the amendment.  In some cases, in lieu of itemizing each change in the body of the letter, the filer may provide replacement pages and reference those changes in the letter.  The filer’s agency would then forward the letter to OGE along with a separate transmittal letter reaffirming the agency’s original decision to sign the report (i.e., the agency certifying official continues to believe that the filer is in compliance with all applicable laws and regulations).  The filer’s amendment letter and any replacement pages will be incorporated into the filer’s original report for purposes of public availability.

To avoid the potential need for multiple submissions, agency ethics officials should coordinate with OGE prior to having the filer sign the amendment letter and transmitting the materials to OGE.