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Financial Disclosure and Ethics

Financial Disclosure and Ethics

Appointees are expected to be guardians of the public trust, so as a nominee, be prepared for an extensive financial and ethics screening process. The specifics of the screening process will depend on your proposed position, with senior positions requiring more public disclosure. You will be asked to provide information about your personal finances and the finances of your spouse and dependent children so that ethics officials can identify and resolve any potential conflicts of interest. Appointees to the current administration will also be asked to sign the Biden-Harris Administration Ethics Pledge.

Familiarize yourself with the financial and ethics forms and questions, and get your answers and materials ready. One of the biggest bottlenecks involves nominees who do not submit their forms in a timely fashion – so start early!

This section includes the key forms you will need to complete, the ethics review process and top tips. 

Key Forms Top Tips The Ethics Review Process
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FROM THE PODCAST

Leslie Kiernan on What Nominees Should Do Now

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ON THE BLOG

Advice for prospective political appointees: Get an early start filling out security and financial disclosure forms

Demystifying the presidential appointee vetting process

How the Biden Transition Team Ethics Plan Compares With the Biden Administration’s Ethics Pledge

Nine Tips for Following Government Ethics Rules

WEBINAR
Tips for Aspiring Political Appointees: Financial Disclosure, Taxes and Conflicts of Interest

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Key Forms

The White House Office of Presidential Personnel may ask you to complete its own questionnaires. The questionnaires cover a variety of topics and may require attachments such as tax returns. The Trump administration used a personal data statement and research questionnaire. The George W. Bush administration used this questionnaire, while the Obama administration phased out the use of this personal data statement.

The administration or transition team will review this information early in the process to determine whether they want to move forward with your candidacy. You may be asked to discuss the information in more detail during personal interviews with the administration or transition team.

This draft checklist for screening potential political appointees outlines some of the financial and legal information that you may be asked to provide.

Most prospective appointees will be asked to complete the Public Financial Disclosure Report (OGE Form 278e), a nine-part financial disclosure document that must be updated annually and when you make certain financial transactions. The Office of Government Ethics’ Public Financial Disclosure Guide provides detailed instructions.

It is important to start gathering the information for this form well in advance of when you are required to submit it. The form requires financial records for you, your spouse and your dependent children. Use this OGE Checklist to gather documents before you start.

A small number of prospective appointees are not required to submit a public report. Instead, they must submit the Confidential Financial Disclosure Report (Form OGE 450). The appointees in this category include many part-time members of boards and commissions, as well as some Schedule C appointees. This report is shorter and generally kept confidential. It will be reviewed by your prospective agency without additional review by OGE.

For detailed instructions, see the Office of Government Ethics’ Confidential Financial Disclosure Guide: Form OGE 450.

Individuals who are nominated for positions that require Senate confirmation must also complete questionnaires developed by Senate committees. Each committee has its own questionnaire, and they differ in their subject matter and length.

The Senate committees receive copies of your Public Financial Disclosure Report from the Office of Government Ethics. Some Senate questionnaires may ask for personal financial information similar to the public financial disclosure report.

Top Tips

Download the OGE Form 278e and compile information early
If your paperwork isn’t completed quickly and fully, it can delay or endanger your appointment. The OGE Form 278e is long and will require you to research your financial records. Once you are given a preliminary offer, you may have only 24 to 72 hours to enter the information in the online system known as Integrity. Anticipate this quick timeframe and give yourself several weeks or months to gather the information.

Be honest and forthcoming
You must be fully transparent. Everything about your financial life should come to light. Many financial and ethics issues can be resolved if administration officials know about it. Omissions or errors will delay your confirmation and, in some cases, raise red flags for your reviewers.

Respond to requests quickly 
Ethics officials may ask you for information multiple times throughout the process and it is essential that you respond quickly to keep the process moving.

Declare and pay all your tax obligations
Numerous high-profile appointees have had their nominations withdrawn because of tax issues.

Expect different ethics standards in the public sector 
If you are coming from the private sector, you may not be aware of the differences in ethical standards between the private and public sectors.

At the appropriate time, work with your agency ethics official 
After the White House has decided to move forward with you as a prospective nominee, you may be allowed to work with your future designated agency ethics official. These officials have valuable expertise that will help you during the nomination process, and later with performing your role with integrity.

Consider if you may need independent advice  
The resources and opinions offered here are meant to give you a broad overview of the process and key considerations. If you have sizable assets and complex financial and legal portfolios, you may wish to seek independent legal and financial advice early in the process. You can request a list of attorneys from the Partnership to assist you in finding professional advice here.

Jonathan Burks, who served as a White House appointee and as chief of staff to former Speaker of the House Paul Ryan.
Former Secretaries of State Henry Kissinger, James Baker, Madeleine Albright, Colin Powell, Hillary Clinton, and John Kerry.
Carolyn Kaster/AP/Shutterstock

The Ethics Review Process 

The ethics review process varies based on the type of appointment. The Office of Government Ethics, the White House Counsel’s Office, agency ethics officials and Senate committees may all play a role. The goal of this process is to identify and resolve possible conflicts of interest. Your responsiveness and the complexity of your financial holdings can determine the length of the review process, which ranges from weeks to months.

For Non-Senate-confirmed Positions

Your prospective agency leads the review of the information you provided on either the public or confidential financial disclosure report in light of the position for which you are being considered. Agency ethics officials may ask for additional information throughout the process and work with you to resolve any potential conflicts of interest.

For Senate-confirmed Positions 

OGE works closely with the White House counsel’s office or the presidential transition team, as well as your prospective agency, to understand the job for which you are being considered. OGE may also prepare an ethics agreement that outlines how you can resolve any conflicts of interest. Your prospective agency and OGE determine if any conflicts of interest have been resolved sufficiently to enable you to serve in the job. Finally, OGE provides your certified Public Financial Disclosure Report to the Senate, whose committees may ask for additional information. More details on the process for Senate-confirmed appointments are described in OGE’s Nominee Guide.

Government officials take an oath of office to serve the public interest and to act as stewards of the public trust. When you take this oath, you are accepting the obligation to put the interests of the American people above your own. These values are at the heart of the Partnership for Public Service’s Public Service Leadership Model and apply to career public servants and political appointees alike.

Read our article in Harvard Business Review