3.02: Reporting Periodic Transactions




What to Report

5 U.S.C. app. § 103(l); 5 C.F.R. § 2634.309

Filers report any purchase, sale, or exchange by the filer, the filer’s spouse, or dependent child of stocks, bonds, commodity futures, and other securities if the amount of the transaction exceeded $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):  Provide the full name of the asset and, unless clear from the name, describe the type of asset.

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.

Notification Received Over 30 Days AgoFilers select this field only if notice of the transaction was received more than 30 days ago.  Absent an extension, filers would likely not select this field because filers are required to report transactions within 30 days of notification.

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) real property (e.g., apartment building or farmland); (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) an excepted investment fund, such as a mutual fund; (5) holdings within a Thrift Savings Plan account or other retirement account for United States Government employees; (6) underlying holdings of an excepted trust or a qualified trust; and (7) 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.

Voluntary Reporting of Annual and Termination Information

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.  Annual and Termination reports, however, also require filers to report purchases, sales, or exchanges of: (1) mutual funds and other excepted investment funds and (2) real property (excluding a personal residence).  If filers prefer to report such transactions in Periodic Transaction reports, filers may do so.

* Note that Integrity allows filers to import Periodic Transaction reports into Annual or Termination reports without additional data entry.  Other electronic filing systems may offer similar functionality.