Appendix: Change List

This new version of the guide contains OGE’s current interpretation of filing and review requirements, as well as best reporting practices under the Ethics in Government Act, the Stop Trading on Congressional Knowledge Act, and the revisions to 5 C.F.R. part 2634 that became effective January 1, 2019.  As a result, the guide differs in a number of places from OGE’s earlier issuances.  The table below provides a list of notable changes relative to the May 2018 version of the guide.

Section of Guide


Definitions: Confidential Clients

Revised text to follow the revised regulatory text more closely.

Definitions: Excepted Investment Fund

Explains the revised “widely diversified” criteria with respect to excepted investment funds.


Definitions: Received

Defines “receipt of income” and provides general guidance. Of particular note, income is treated as received from a tax-deferred account/plan when distributions are made; however, dividends, capital gains, and other income within a regular, taxable account are received regardless of whether funds are transferred out of the account.

Definitions: Reporting Periods

Explains the revised reporting period applicable to Termination reports.  The difference applies primarily to filers who terminate prior to completing a first Annual report.

Definitions: Valuation of Assets

Clarifies guidance on valuing assets, noting that a good faith estimate should not be used for threshold purposes when the filer can easily obtain the actual value.

Definitions: Valuation of Gifts and Travel Reimbursements

Revises guidance on valuing gifts and reimbursements, in particular gifts of free attendance.

Parts 2, 5, and 6: Various items

Explains how the receipt standard for income applies to specific types of entries.  In particular, as examples of the new guidance, see the entries for Annuity (fixed); Annuity (variable); Brokerage Account; College Savings Plan; Deferred Compensation; Defined Contribution Plan; Investment Fund; IRA, Roth IRA, SEP IRA, or Keogh Plan; Stock; Trust (irrevocable); Trust (revocable); and Will or Estate.


Clarifies that filers apply the relatedness test when determining whether to report the assets held by an operating business.  Filers need not report liabilities owed by a business, unless the filer, the filer’s spouse, or a dependent child is also personally liable. 

Parts 2 and 5: Carried Interest

Clarifies that filers must report the underlying assets on which a carried interest is based, unless those assets are otherwise disclosed as part of a direct equity interest.  In addition, requires filer to provide basic information about how the carried interest is calculated if a value has not been specified.

Parts 2 and 5: Incentive Stock Options, Phantom Stock, Restricted Stock, Restricted Stock Units, Stock Appreciation Rights

Explains that filers must indicate whether the equity compensation is vested even if a value category has been selected.

Part 6: Trust (irrevocable)

Explains the new regulatory text with respect to current and future interests in trusts.

Part 6: Trust (revocable)

Clarifies that a revocable trust is reported in the same manner as an irrevocable trust if the filer, spouse, or a dependent child receives mandatory distributions from a third party’s revocable trust.

Part 7

Notes the new reporting exclusion for transactions occurring before the filer became a public filer.

Part 8

Makes clear that installment loans are reportable.


Part 8

Revises credit card example to require a description of the rate terms, consistent with the existing instructions.

Part 9

Notes the new reporting exclusion for travel reimbursements from a non-federal employer.

For Ethics Officials, 1.01: Types of Reports and Filing Deadlines

Addresses early filing of Termination reports and elaborates on guidance applicable to filers moving between positions.

For Ethics Officials, 1.02: Individuals Required to File

Discusses the new exclusion process for non-policy-making Schedule C positions.

For Ethics Officials, 4.01: Certification Requirements

Notes that certification also includes a determination that no interest or position disclosed on the form violates or appears to violate any other applicable Executive Order in force at the time of the review.

For Ethics Officials, 4.02: Review Timeframes

Explains the new standards with regard to review timeframes. In particular, requests for additional information must require a response within 30 days unless a written extension is granted.

For Ethics Officials, 4.05: Report Amendments and Annotations

Addresses amendments to reports after certification.

For Ethics Officials, 4.10: Special Procedures for PAS Nominees

Adds a brief overview of the review process for PAS Nominees.