April 30, 1999 DO-99-022 MEMORANDUM TO: Designated Agency Ethics Officials FROM: Stephen D. Potts Director SUBJECT: Update of Listing of Executive Branch Agency Officials Subject to Annual Public Financial Disclosure Report Filing with the Office of Government Ethics (OGE) for CY 1998 Title I of the Ethics in Government Act of 1978, as amended, requires annual public financial disclosure reports (SF 278) to be filed with the appropriate department or agency no later than May 15. However, because the May 15, 1999 filing deadline falls on a Saturday, the annual public financial disclosure reports covering calendar year 1998 may be filed Monday, May 17. Please note that for purposes of granting filing extensions and calculating delinquencies, the filing deadline will be May 17. Attached is a list of the names and positions of Presidential appointees confirmed by the Senate (PAS), and Designated Agency Ethics Officials (DAEO) who were required to submit either an annual or new entrant SF 278 for CY 1997 to this Office for final review and certification. The list also includes PAS officials who worked less than 60 days in CY 1997 and were not required to complete an annual report covering that year. Please annotate this list to reflect any changes to (additions or deletions) the officials named or positions identified. Kindly return the list, as annotated, to this Office by May 21, 1999. For your convenience, you may phone in, fax, or E-mail "No Change" lists. The fax number for the Financial Disclosure Division is 202-208-8038. In annotating your lists, please note whether an official has terminated or transferred from the position and the termination or transfer date. For transfers, please indicate whether the official transferred within 30 days to another covered position (PAS or non-PAS) requiring SF 278 reporting. If not, a termination report is required within 30 days of the transfer. In addition, please indicate which officials did not work more than 60 days in CY 1998 and are not required to file an annual report. Conversely, please add to the list the names of any PAS special Government employees who actually worked in excess of 60 days in CY 1998 at an annual rate of basic pay equivalent to 120 percent of GS-15, step 1, which equaled $87,030 (or $333.60 per day) in CY 1998. However, do not include the names of officials serving in PAS positions in an acting capacity, because those officials do not go through Senate confirmation. Finally, while Schedule C employees do not submit their reports to this Office, they are required to file SF 278s with their agencies, unless they have received filing exclusions from the Director of OGE. The annual SF 278s for the PAS officials and DAEOs identified on this list should be submitted to OGE as soon as approved by the department or agency, but not later than September 15, 1999. This date allows for agency review and approval of the reports and takes into account any possible filing extensions. In particular, the financial disclosure report of your agency head should be sent to OGE immediately after agency review and approval. As you know, their reports are among the most requested by the news media and public. In instances where the report cannot be approved by the agency and submitted to this Office by September 15, due to pending resolution of a conflict of interest, or the need for additional information or clarification, we ask that you notify us, in writing, by September 15, of the names and positions of the officials involved, the nature of the problems, and the date you expect to transmit the report to this Office. This Office will be following up on the late filing of reports submitted by PAS officials and DAEOs. To assist us in this effort, we ask that you note any agency-granted filing extensions on the officials' SF 278 cover sheet. Finally, we request your assistance in providing us with changes to this list as they occur throughout the year. Although agencies are not required to provide such periodic information, we have found that the receipt of this information on an ongoing basis enables us to compile more accurate annual filing lists. For your convenience, we have provided the 1999 due dates for annual reports as well as the 45-day and 90-day filing extensions as shown below: ______________________________________________________________________ 1999 Due Dates Report Late if $200 Fee Due if Filed After Report Filed After Annual Reports May 17 June 16 45-Day Extension July 1 August 2 90-Day Extension August 16 September 15 ______________________________________________________________________ As a reminder, the DAEOgram of January 29, 1996 (DO-96-006), provided information regarding new reporting categories for SF 278s filed on or after January 1, 1996. Section 20 of the Lobbying Disclosure Act of 1995 (Public Law 104-65) amended the Ethics in Government Act of 1978 to require new categories of amount or value on public financial disclosure reports for assets, income and liabilities exceeding $1 million (except for interests of a spouse or dependent child, unless jointly held with the filer). Please ensure that all reports are appropriately annotated on the SF 278 or on an attachment, if filers have disclosable interests that fall within these high-value categories. If you have any questions, please contact Tom Zorn, Chief, Financial Disclosure Division, or Mike Shifrin at 202-208-8000, extension 1123, or extension 1155, respectively. Their E-mail addresses are tfzorn@oge.gov and mnshifri@oge.gov. Attachment (not included with this file)