From: "Palmer, Breanne J" <breanne.palmer@sol.doi.gov> To: "Rigas, Laura C" <laura_rigas@ios.doi.gov>, "Hanson, JoDee M" <jodee_hanson@ios.doi.gov>, "Johnson, Ashley A" <ashley_johnson@ios.doi.gov>
Subject: Welcome New Entrant Public Financial Disclosure Filer: Wynn Radford Date: Wed, 22 Jan 2025 17:14:54 +0000
Importance: Normal Attachments: unnamed; Public_Financial_Disclosure_Frequenty_Asked_Questions.pdf
Hi Wynn, Welcome! I'm Breanne Palmer, and I am reaching out to conduct your new entrant interview as a public disclosure filer. We'll use this time to review the ways and means of filing a public financial disclosure report. I will also answer any initial questions and concerns you may have and will be available as you complete your report. I've used your calendar availability to schedule this interview, but please do let me know if there is a more convenient time to meet. Attached are public financial disclosure FAQs and below are a few helpful links, if you'd like to skim them before we meet or review them in-depth afterward:
OGE Public Financial Disclosure Guide Public Financial Disclosure Report (OGE Form 278) What To Gather Before You Start Your Public Financial Disclosure Report Resources for Financial Disclosure Filers
Looking forward to meeting you soon,
Breanne
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Sierra Club v. Dept of Interior - 3:25-cv-05375-PHK
0001552 SC_EVERSPLIT0015848
Public Financial Disclosures Frequently Asked Questions (FAQs)
Why does the ethics office need this personal information?
In the Ethics in Government Act, Congress required senior executive branch leaders to file detailed information about their financial interests. The information you provide will aid your ethics officials in determining whether you have actual or potential conflicts between your official responsibilities and your personal or imputed financial interests. If your ethics officials identify a potential for a conflict, we will work with you to help resolve those conflicts.
How do I file?
DOI uses Integrity, an electronic 278e reporting system, for all public financial disclosure filers. You should use Integrity for all 278e reports (transactions reports, annual reports, etc.) and should already have an email invitation from Integrity; the invitation includes instructions for getting started and setting up your profile.
You have the option of asking someone else to enter this information for you (for example, your spouse or financial advisor). If you choose this option, we can assist you in adding a "filer designee" in Integrity. Even if you add a filer designee, you must personally certify your financial disclosure report. This is important because the disclosure requirements and ethical obligations are personal to you. Please note that the overwhelming majority of DOI employees, including Senate-Confirmed Appointees, personally enter this information.
Once you've completed your financial disclosure report, you will be prompted to approve your report so that it can be submitted. The action of submitting your report generates an electronic signature that is your certification that the information you provided is true, complete, and correct to the best of your knowledge.
What happens if I don't file?
If you do not timely file your financial disclosures or submit inaccurate information, you may be subject to criminal, civil, or disciplinary actions. In addition, the Office of Government Ethics requires payment of a $200 late filing fee for each report that is filed after the due date, payable to the U.S. Treasury. Please contact us promptly if you ever need an extension of your reporting deadlines.
What happens after I file?
Your form will be transmitted directly to your ethics official who will review the form for conflicts of interest and to ensure it is complete. If your ethics official has any questions, he or she will follow up with you. Sometimes additional information may be necessary. For information about how to report assets or other information on your financial disclosure report, contact your ethics official or read the Office of Government Ethics Public Financial Disclosure Guide at https://oge.gov/Web/278eGuide.nsf.
Transactions
Sierra Club v. Dept of Interior - 3:25-cv-05375-PHK
0001553 SC_EVERSPLIT0015849
What is a 278-T?
In addition to annual financial disclosure reports, you are also required to file periodic transaction reports, also known as 278-T reports. You must report certain, covered transactions throughout the year.
What do I report in a 278-T?
Report the sale, purchase, or exchange greater than $1,000 made by you, your spouse, or dependent children of the following types of assets:
Stocks Bonds Commodity futures Other securities
You are not required to file a 278-T to report transactions of mutual funds, excepted investment funds, or real property transactions, but must disclose these types of transactions in your annual report. You may elect to voluntarily report transactions of mutual funds or real property in a 278-T, but this type of reporting is not required.
You are not required to file a negative report reflecting that no transactions occurred in any given time period.
When must I file transaction reports?
You must file a 278-T for reportable transactions:
Within 30 days of receipt of notification of a transaction (for example, an online sale confirmation); but
No later than 45 days after the transaction (for example, if you learn of the transaction from a monthly transaction statement).
What is the difference between transactions reported in 278-T versus the transaction section of my annual report?
You are not required to report a transaction in your annual report if you previously reported the transaction in a 278-T. Remember that 278-T reports are not required for mutual fund or real estate transactions, but those types of transactions must be disclosed as part of your annual report. If you prefer to report all your transactions as 278-T reports, you may do so.
Negotiations with potential employers
Do I have to report negotiations for non-federal employment?
Sierra Club v. Dept of Interior - 3:25-cv-05375-PHK
0001554 SC_EVERSPLIT0015850
Yes. As a public financial disclosure filer, you are required to file a statement notifying your ethics officials within 3 business days after commencing negotiations, or agreements, for future employment or compensation with a non-federal entity. You must also confirm that you will recuse from any official matters that may affect your potential employer.
Training
Do I have other ethics requirements?
Yes. In addition to filing financial disclosures, you must complete your initial ethics training within three (3) months of your entry on duty date. You must also complete one hour of annual ethics training each calendar year. You will receive more information about ethics training at a later date.
Sierra Club v. Dept of Interior - 3:25-cv-05375-PHK
0001555 SC_EVERSPLIT0015851