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

What to Report

5 U.S.C. app. §§ 102(a)(1) & (a)(3); 5 C.F.R. §§ 2634.301 & 2634.302

Filers report an asset related to employment in Part 2 if the value of the asset was more than $1,000 at the end of the reporting period or if the filer received more than $200 in income during the reporting period.  For purposes of this Part, “employment-related” is interpreted broadly to cover all of the filer’s non-investment activities as well as the filer’s retirement accounts.

In addition, filers report each source, whether a natural person or an entity, from which the filer received more than $200 in earned income and other non-investment income during the reporting period.

How to Report

Generally, filers report employment-related assets and sources of non-investment income as follows:

Description:  Filers must provide a description sufficient to identify the asset or source being reported.  The amount of information needed for a sufficient description will depend on the type of asset or income being reported. 

(1) Stock:  Provide the name of the issuing company.  For stock in a privately held company, describe the issuer’s business.  For publicly traded stocks, it is helpful to provide the ticker symbol in addition to the name of the stock.

(2) Other assets with specific names (e.g., bonds and mutual funds):  Provide the full name of the asset and, unless clear from the name, describe the type of asset.  For publicly traded securities, it is helpful to provide the ticker symbol in addition to the name of the security.

(3) Assets without specific names:  Describe the type of asset, including the city and state (or county and state) for real estate.

(4) Sources of earned or other non-investment income:  Provide the name of the source and, for privately held companies, the nature of the business.  In addition, for honoraria, include the date that the services were provided.

EIF:  If a filer is reporting an investment vehicle that invests in assets of its own, the filer would report each underlying asset that was individually worth more than $1,000 at the end of the reporting period or from which more than $200 in income was received during the reporting period.  As an exception to this requirement, however, a filer does not need to report the underlying assets of an investment vehicle that qualifies as an excepted investment fund (EIF).  A filer marks the “EIF” field to indicate whether an entry qualifies as an excepted investment fund.  Click here for the definition of “excepted investment fund.”

Value:  Filers report the value of an asset by selecting the appropriate category.  Filers of New Entrant, Nominee, and Candidate reports may determine the value of an asset by choosing its value on any date that is fewer than 31 days before the filing date.  Filers of Annual and Termination reports should value assets as of the end of the reporting period.

Income Type:  Filers skip this section if the amount of income during the reporting period was less than $201 or if the filer is reporting an investment vehicle that qualifies as an excepted investment fund.  In all other cases, filers specify the type(s) of income (e.g., salary, consulting fees, dividends, interest, capital gains, rent, royalties, etc.).

Income Amount:

(1) Income less than $201:  Filers select the “None (or less than $201)” amount category.

(2) Dividends, capital gains, interest, rent, royalties, or income from excepted investment funds:  Filers select the category that corresponds to the total amount of income received during the reporting period.

(3) Other income:  Filers provide the exact amount of income received during the reporting period.

Assets and Income That Are Not Reportable

Assets or income from United States Government employment are not reportable in the OGE Form 278e.  In addition, filers should not report in Part 2 assets that were acquired separately from business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account).  Filers should instead report such assets in Part 6; nonetheless, reviewers need not treat the reporting of such assets in Part 2 as an error requiring follow-up.  Reviewers may wish to notify the filer of the appropriate placement of such assets if the misplacement can cause confusion on the part of the reader.

No Assets or Income to Report

The filer must affirmatively state that he or she does not have any assets or sources of non-investment income 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.”