Public Financial Disclosure - Frequently Asked Questions (2020)

To assist the public in accessing and understanding these reports, OGE has developed these Frequently Asked Questions.

Last updated: 12/15/20

Nominee Reports

Q. What type of public financial disclosure reports do individuals who may enter Presidentially appointed, Senate-confirmed positions have to complete?

Filers who hope to enter Presidentially appointed, Senate-confirmed positions file a nominee report.

OGE reviews the reports for approximately 985 positions in which the Presidentially appointed, Senate-confirmed (PAS) nominee is expected to serve in the position for more than 60 days in any one calendar year.

PAS nominees who are not expected to serve in the positions for more than 60 days in any one calendar year typically file confidential financial disclosure reports.



Q. Which PAS nominee reports does OGE review?

OGE does not review financial disclosure reports for all PAS nominees. The types of PAS nominees excluded from OGE review generally fall into four categories: (1) judicial officers; (2) members of the uniformed services; (3) Foreign Service Officers without the rank of ambassador; and (4) a select number of no-more-than-60-day PAS nominees, per agreement with the Senate. This workbook provides a list of all the PAS positions subject to OGE’s review.



Q. What type of information does the nominee report require?

The nominee report details the personal financial interests of the filer, the filer's spouse, and any dependent children. The financial disclosure guide available here provides detailed information on reporting requirements for various financial interests.



Q. What is the public financial disclosure process for prospective nominees subject to OGE review?

Prospective nominees for Presidentially appointed, Senate-confirmed positions file a draft public financial disclosure report in OGE’s electronic filing system. The draft report is reviewed by the nominee’s prospective agency and OGE for potential conflicts of interest and technical completeness. There are usually several rounds of revisions and changes made to the report during the review process which involve the prospective nominee, the prospective agency, and OGE.

When possible conflicts are identified, ethics officials identify steps that the nominee will need to take to avoid the conflict and document those steps in an ethics agreement.

Once the financial disclosure report and ethics agreement are finalized, OGE preclears (i.e., tentatively approves) the nominee financial disclosure report and ethics agreement and awaits the announcement of the President’s nomination or the President-elect’s intent to nominate the nominee.

If/when the President nominates or the President-elect announces an intent to nominate that individual, the nominee certifies the pre-cleared financial disclosure report. The prospective agency’s ethics official certifies the report and then OGE’s Director certifies the report. OGE then transmits the nominee’s financial disclosure report and ethics agreement to the Senate.

In the instance when the President nominates or the President-elect announces an intent to nominate an individual without preclearance, OGE waits for the report to begin the process for review and preclearance described above.



Q. When are nominee public financial disclosure reports available to the public?

The nominee’s financial disclosure report and ethics agreement are available to the public after they are received by the Senate. Reports and ethics agreements for filers in the 67 positions at Pay Levels I and II (including Cabinet secretaries) are typically posted on OGE’s website and available for download two days after the report is received by the Senate. Reports for other PAS filers are typically available after providing statutorily required information (collected by completing the OGE Form 201) two days after the report is received by the Senate.

Coronavirus (COVID-19)

Q. How will the disruptions resulting from the Coronavirus (COVID-19) pandemic affect filing of public financial disclosures?

Until further notice, OGE is unable to fill any PDF 201 request that does not provide an email address for the requestor.

The COVID-19 pandemic has no effect on who is required to file, or on the information that is required to be reported on public financial disclosures. OGE has not changed the deadlines for public financial disclosure reports.

OGE has issued guidance to agency ethics officials reminding them of their ability to grant extensions of up to a total of 90 days, when conditions warrant.

OGE regulations allow a filer’s agency ethics officials, for good cause shown, to grant the filer an extension of up to 45 days. Further, these agency ethics officials may grant an additional extension of up to 45 days.

You can see OGE’s latest guidance here (.pdf).

New Entrant Reports (OGE form 278e)

Q. What type of public financial disclosure reports do new filers have to complete?

All public financial disclosure filers are required to complete either a nominee or a new entrant report. Filers who hope to enter Presidentially appointed, Senate-confirmed positions file a nominee report.

All other public financial disclosure filers file a new entrant report. These reports are filed with the employing agency within 30 days of taking office. The new entrant report details the personal financial interests of the filer, the filer’s spouse, and any dependent children.


Q. Which new entrant public financial disclosure reports receive second-level review by OGE?

OGE provides a second-level review of the new entrant reports of filers for certain positions, including Designated Agency Ethics Officials (DAEOs), senior White House officials, senior officials in the Office of the Vice President, and the Postmaster General. For these positions, the reports are initially filed with the official’s employing agency, reviewed and certified by that agency, and then forwarded to OGE for a second level of review and certification or closure.

Ethics Agreements

Q. What is an ethics agreement and who is required to have one?

Generally, an ethics agreement takes the form of a letter from a filer to the senior agency ethics official at the filer’s employing agency. It details the steps that the filer and the employing agency have agreed the filer must take to resolve potential conflicts of interest.

OGE must approve in advance any ethics agreement, or proposed modification to an ethics agreement of an executive branch official who was appointed by the President and confirmed by the Senate (PAS official) whose report is reviewed by OGE. Modifications include substantive changes to the ethics agreement and any extensions of the previously agreed-upon time periods to comply with the ethics agreement.


Q. Are individuals who file new entrant reports required to enter into formal written ethics agreements?

No. Filers in positions that do not require Senate confirmation are not required to enter into formal written ethics agreements, unless their agencies requires them.

Annual and Termination Financial Disclosure Reports (OGE form 278e)

Q. Who files public financial disclosure reports and where do they file their reports?

There are approximately 26,000 public financial disclosure filers comprising:

  • the President and the Vice President;
  • officers and employees in positions that have a rate of basic pay equal to or greater than 120% of the minimum rate of basic pay for GS-15 of the General Schedule;
  • administrative law judges;
  • employees in positions which are excepted from the competitive service because of their confidential or policymaking character;
  • The Postmaster General, the Deputy Postmaster General, each Governor of the Board of Governors of the United States Postal Service and each officer or employee of the United States Postal Service or Postal Regulatory Commission that have a basic rate of pay that is equal to or greater than 120% of theminumum rate of basic pay for GS-15 of the General Schedule;
  • The Director of the Office of Government Ethics and each agency's Designated Agency Ethics Official; and
  • civilian employees in the Executive Office of the President (other than special Government employees) who hold commissions of appointment from the President.

To see who files, where they file, and how to access their documents, click here: https://www.oge.gov/web/OGE.nsf/accessdocs_disclosure-quickstart?OpenForm


Q. When can I access annual public financial disclosure reports?

Unless an extension is granted, public filers must file their annual reports by May 15 and agencies must make the reports available within 30 days of receipt. See the “2020 Schedule of Important Ethics Dates” on OGE’s Dates and Deadlines page. The deadline for filing annual reports can be extended by the appropriate ethics official for up to 90 days.

Agencies must review reports within 60 days of receiving them and, if no additional information or remedy is required, agencies must also certify the reports before the 60-day period expires.

For public financial disclosure reports requiring a second-level review by OGE, agencies must forward the reports to OGE promptly after the agencies certify the reports. Those reports are available from OGE 30 days after receipt or after OGE closes the reports (i.e., certifying or declining to certify).


Q. Who files termination financial disclosure reports?

Public financial disclosure filers are required to file termination public financial disclosure reports within 30 days of leaving a filing position, unless they are entering another filing position.

Availability of Reports and Related Documents

Q. Which public financial disclosure reports are available on OGE’s website?

OGE provides a second-level review of about 1,100 of the approximately 26,000 public financial disclosure reports filed by officials in the executive branch. OGE reviews the reports filed by Presidential and Vice Presidential candidates, the President, Vice President, Presidential appointees in positions requiring Senate confirmation, certain White House appointees, certain appointees in the Office of the Vice President and the most senior ethics official at each agency. Click here to view a spreadsheet listing nominee positions which file with OGE. The remaining approximately 25,000 public financial disclosure reports are available from the filing official’s agency.


Q. How can I access the public financial disclosure reports that are available on OGE’s website and the reports that are available from agencies?

The annual reports of filers at Executive Pay Levels I and II (the highest-level 67 presidentially appointed, Senate-confirmed positions, including Cabinet secretaries) are available on OGE’s website after OGE has closed the report by either certifying or declining to certify. To access these reports from OGE’s homepage:

  • Navigate to “Access Ethics Document” menu
  • Click on "View Officials’ Individual Disclosures"
  • Affirm that you will not use any report for unlawful purposes
  • Search and sort within the collection to locate the filer
  • Immediately download the documents

The other reports filed with OGE (e.g., presidential appointees confirmed by the Senate, senior White House personnel, and Designated Agency Ethics Officials) are available after OGE has closed them and after a requestor submits a completed OGE Form 201, as required by the Ethics in Government Act.

To access these reports from OGE’s homepage:

  • Navigate to “Access Ethics Document” menu
  • Click on "View Officials’ Individual Disclosures"
  • Search and sort within the collection to locate the filer
  • Click on the prompt to complete the OGE Form 201
  • Fill out the OGE Form 201 and submit it to OGE
  • OGE will review your request and email you any responsive documents

To request one of the remaining more than 25,000 public financial disclosure reports filed by executive branch officials, but not required to be reviewed by OGE, you must complete an OGE Form 201 (.pdf) and submit it to the official’s employing agency. Contact information for submitting the OGE Form 201 at a particular agency is located here.


Q. Why are some reports readily available on OGE’s website while I have to file a request form for other reports?

The Ethics in Government Act, as amended, specifies which public financial disclosure reports are publicly posted and which must be released subject to a request process.

Publicly posted reports are those:

  • submitted by the President and Vice President; and
  • submitted by filers at Executive Pay Levels I (5 U.S.C. 5312) and II (5 U.S.C. 5313).

Reports released subject to the Ethics in Government Act process are those:

  • submitted by approximately 1,000 other PAS filers whose reports OGE reviews (available to request from OGE or a filer’s employing agency via the submission of a completed Form 201); and
  • submitted by the remaining approximately 25,000 public filers that are not reviewed by OGE (available to request from the filer’s agency via the submission of a completed Form 201).

Periodic Transaction Reports (OGE form 278-T)

Q. How can I learn about financial transactions made by senior government officials since December 31, 2019?

Filers of public financial disclosure reports are also required to file Periodic Transaction Reports (PTRs) when they make certain kinds of financial transactions such as buying or selling stock. Unless an extension is granted, PTRs are required to be filed with the employing agency no later than 45 days after the transaction occurs.

Agencies are required to make these reports available 30 days after they are filed with the agency whether the PTR has been certified or not, if requested using the OGE Form 201. The 201 Form and agency points of contact for making these requests can be found here: https://www.oge.gov/web/oge.nsf/about_ethics-contact-list

For officials who are appointed by the President and confirmed by the Senate, PTRs are forwarded to OGE from the filer’s agency after agency certification for second-level review and certification by OGE. Those reports are available from OGE 30 days after OGE’s receipt or after OGE closes the reports by certifying or declining to certify. You can find these reports here: https://www.oge.gov/web/OGE.nsf/Officials%20Individual%20Disclosures%20Search%20Collection?OpenForm