HomeOrganizationsGCAEthicsFinancial Disclosure ReportsOGE-278STOCK Act

The Stop Trading on Congressional Knowledge Act

On April 4, 2012, the President signed the Stock Act which prohibits Members of Congress from using nonpublic government information to profit from stock trades (insider trading). The law also imposes new requirements upon the Executive Branch outlined below.

Home Mortgage Reporting
Requires disclosure of personal residence mortgage, but only for - Presidential appointees confirmed by the Senate (PAS), and flag and general officers O-7 and above--NOT SES. Mortgage information should be reported on Schedule C, Part I of the OGE Form 278. The information required to be disclosed includes: Name of lender, loan terms and conditions, and a notation if the mortgage is on a personal residence. You are not required to disclose the location of your residence. If the residence does not produce rental income, do not report it on Schedule A.

Prompt Transaction Reporting (For all OGE-278 Filers)
Mandates disclosure of securities trades within 30 days of "receiving notification" of the transaction, but no later than 45 days after the actual purchase, sale, or exchange. Trades of stocks, bonds, commodities futures, and other forms of securities are reportable when the amount involved exceeds $1,000. Transactions that are EXCLUDED from this requirement include those on real property, mutual funds, qualified blind or excepted trusts, treasuries, life insurance and annuities, cash accounts, and assets in TSP or other retirement system maintained by the United States. Transactions between the filer and his or her spouse or dependent children are also exempt from reporting.
Filers are strongly encouraged to simplify the process by submitting a report on the Fifteenth (15th) day of each calendar month. The report would contain all necessary transactions that occurred during the previous calendar month and transactions that the filer received notification of during the first 14 days of the current calendar month. This should ensure that most transactions are reported within 30 days of receiving notification and not later than 45 days after the transaction actually occurred.
EXAMPLE: On July 7, John Doe receives a statement from his broker containing 5 transactions over $1000 on assets owned solely by him that took place on June 3, 5, 8, 23, and 29. Mr. Doe will include these transactions on his July 15 report. Then, on July 10, Mr. Doe receives an email notification confirming a stock transaction earlier that day. Mr. Doe will also include this transaction on his July 15 report. The July 15 report is timely with regard to all of these transactions because they occurred within the past 45 days and notification occurred within the past 30 days. Mr. Doe should not wait to report the July 10 transaction in his August 15 report because August 15 is more than 30 days after notification of the transaction.
Filers must use the OGE 278-T, located on the Office of Government Ethics, to report transactions.
Forms must be submitted to the filer's local SJA office. For filers assigned to Air Staff or Secretariat, forms must be submitted to the AIR FORCE ETHICS OFFICE, SAF/GCA, 1740 Air Force Pentagon, RM 4C934.
Ethics attorneys will review the reports for potential conflicts of interest and provide cautionary advice when warranted.
Please note, those who file an OGE 278-T report at any point during the year will be required to report those transactions again on their Incumbent OGE-278 report for the period covered by the Incumbent report. This process ensures accuracy in reconciling annual reports, especially as DoD moves to electronic OGE-278 reporting for all filers.
Example: A filer submits OGE 278-T transaction reports in August, October, and December 2012. On the filer's 2013 OGE-278 Incumbent report which covers calendar year 2012, the filer WILL report those transactions that were on his or her OGE 278-T reports filed in August, October, and December 2012 IN ADDITION to any other transactions that were not required to be reported on the OGE 278-T report, but are required to be reported on the OGE 278 report (such as transactions for mutual funds and real estate or assets of a spouse or dependent child).
FAILURE TO REPORT any covered transactions in a timely fashion may result in a $200 fine, just as for the annual OGE-278 reporting requirement.

Agency Website Posting of Public Financial Disclosure Reports - REPEALED (by S.716, April 15, 2013)
Requires that all OGE-278 reports (not OGE-450s), extension requests, and stock transactions throughout the year be posted to an agency website NLT April 15, 2013, and thereafter within 30 days of filing. The website must allow the public to find and view reports without any identification or access restriction. IMPORTANT: Avoid over-reporting of personal information. See handout on information to avoid over-reporting reporting on the 278 report.

Job Search Disqualification--Effective Immediately
Requires that all OGE-278 filers submit a disqualification statement to their ethics office once they begin seeking post-Government employment with a non-Federal entity. You are considered to be seeking employment when you submit a resume to or schedule an interview with a non-Federal entity. See template disqualification statement.

Electronic Filing of Financial Disclosure Reports - Effective January 1, 2014*
Directs that all financial disclosure filers file reports electronically. FDM www.fdm.army.mil/ is already used widely in DoD; FDM may become the software system to implement this requirement. More to follow. The Air Force Ethics Office strongly encourages use of FDM.

*deadline amended from September 2013 by S. 716, signed into law on April 15, 2013

OGE to Establish a Searchable, Sortable Database - REPEALED (by S.716, April 15, 2013)
By the end of FY 2013, the U.S. Office of Government Ethics must post all public reports and do so with tools that will allow the public (without logging in) to search and sort data.

Please contact your local SJA office with any questions. For Air Force personnel assigned to the Air Staff or Secretariat, please contact the Air Force Ethics Office (SAF/GCA) at usaf.pentagon.saf-gc.mbx.SAF-GCA-Ethics-Workflow@mail.mil or (703) 693-0417.