10 SIMPLE WAYS TO MAKE THE 278 REVIEW PROCESS EASIER

• Spousal Employment
• Mutual Funds, Unit Investment Trusts, and Similar Investments
• IRA's, 401(k)'s, 403's, Keoughs, and other retirement accounts.
• Income Valuation
• Assets/Transactions and Total Liquidation of Asset
• Assets/Transactions
• Total Liquidation of Asset
• Former Employment
• Other Income
• Signing and Dating the Form
• Use of "None" vs. "Not Applicable"
• Financial Relationships & Official Dealings

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While filing your financial disclosure report is an inconvenience, responding to requests from ethics officials for more information may be an even greater inconvenience. The steps below, if followed (in addition to the guidance on the SF 278), should reduce either the likelihood of follow-up inquiries from ethics advisors, the number of inquiries, or the overall time spent responding to such inquiries. A plus, no matter how you figure it.

IMPORTANT: It is your legal responsibility to fill out the SF 278 (Public Financial Disclosure Report) completely and accurately. While ethics specialists are happy to help ease you through these often bizarre and confounding requirements, the ultimate responsibility for preparing the form correctly is yours. NOTE: If you have an accountant or financial advisor, you may wish to have that individual work directly with this office in preparing your SF 278 for filing.

10 SUGGESTIONS:

1. Spousal employment:

DO list the NAME of the employer or name of business (if spouse is self-employed), the city and state of the employer or business and the type of business (if the employer is not a publicly-traded company);
DO identify your spouse’s position or title; but
DO NOT report the AMOUNT of income.

2. Mutual Funds, Unit Investment Trusts, and Similar Investments.

List the full name of the investment (e.g., Fidelity Aggressive Growth Fund). [Failure to list the names of specific funds (not just the name of the fund family) is probably the greatest cause for unnecessary follow-up inquiries].

3. IRAs, 401ks, 403s, 453s, Keoughs, etc.

You need to report any UNDERLYING assets that you would be required to report if held individually rather than as part of the plan. For example, let’s assume that your Merrill Lynch 401k is worth $15,001-$50,000 and within the plan you had three underlying assets, AIM International Fund, Fidelity Magellan Fund and Exxon-Mobil stock that were each worth between $1,001-$15,000.

INCORRECT REPORTING: CORRECT REPORTING:

Name of Asset Merrill Lynch 401(k) Name of Asset Merrill Lynch 401(k) containing: AIM International Fund Fidelity Magellan Fund Exxon-Mobil (common)

Value of Asset $15,001-$50,000 Value of Asset $1,001-$15,000 $1,001-$15,000 $1,001-$15,000

4. Income Valuation.

This amount includes earnings that are "rolled back" or reinvested into the investment.

5. Assets/Transactions & Total Liquidation of Asset.

5.a. Assets/Transactions.

If, on Schedule A, you:



• List an asset for the first time this year; or
• Do not list an asset that was listed last year; or
• Have a substantial change in the value of an asset


you should check to see whether a related transaction (sale / purchase / exchange) needs to be reported on Schedule B, Part I. Normally, a change on Schedule A will require a transaction to be reported on Schedule B. If no transaction needs to be reported on Schedule B, Part I, you may wish to note an explanation when you submit your SF 278. It will save us having to contact you to confirm this fact.

If, on Schedule B, you:

• List a purchase of an asset not previously reported, or an exchange that results in your receiving a new asset for a previously-reported asset, please check to see whether there should be a listing for a new asset on Schedule A.
• Note a sale or exchange of a previously-reported asset, you should also check to see whether there needs to be a corresponding listing on Schedule A [also see 5.b., below].

NOTE: An "exchange" for reporting purposes is rare. The term is only used where there is a trade of one asset for another. The term, "exchange," does NOT encompass a situation where one asset is sold and another is purchased with the proceeds. Use two separate transactions for this common occurrence.

5.b. Total Liquidation of Asset.

If you totally liquidated an asset during the reporting period and earned in excess of $200 in income from that asset (i.e., dividends, capital gains, interest, etc.), report the asset on Schedule A. Include the amount and type of income earned in Block C and check the "None (or less than $1,001) box in Block B. If you liquidated with a loss, sorry, don't report the "asset" in Schedule A. You may note "(loss)" along with the listing in Schedule B. For example, a complete sale of a stock that earned both dividends (while held) and capital gains (upon sale) would be listed as follows:

Block A	Block B	Block C	Block D
Colgate Palmolive Stock	None	"X" for Div & Cap. Gains	Total of Block C

6. Former Employment.

If you have a retirement plan, savings plan, stock purchase option, severance payment, or other plan with a former employer, this needs to be reflected on both Schedule A and Schedule C, Part II. Also, if you are planning to leave USDA employment in the near future and have reached agreement with a prospective employer, you must report this under Schedule C, Part II. This is especially common on termination reports.

7. Other Income.

If you have salary income, farm income, or other income that is NOT covered under “Types of Income” columns on the SF 278, you report in the "Other Income" column both:

• The exact amount of the income; and
• The nature of the income.

For example: "Sale of corn, $25,573."

8. Signing/Dating the Form.

Be sure to sign and date the form and keep a copy for your records. Please note that Incumbent (annual) reports may not be signed before January 1, and termination reports may not be signed before your last day at USDA.

9. Use of "None" vs. "Not Applicable."

If you have nothing to include in a given Schedule, please, please, please, take the time to either check the "none" box, or to write "none" on the Schedule itself. Annotating "Not applicable" or "NA" doesn't get us past the Office of Government Ethics auditors. This may seem like a waste of time as you prepare your report, but it’s an even bigger waste of time for you to have to answer a piddling inquiry from us later.

10. Financial Relationships & Official Dealings.

If you believe you may take official action that involves or directly affects any entities recorded on your report, please contact us immediately by phone (202-720-2251) or email (DAEO.ethics@usda.gov). If you are sure that your official duties have no connection either to a financial interest or outside activity, annotate that fact in the comments portion of the front page of the form.

NOTES: If you own financial interest in a farm, or engage in farming activities, see "Farming Interests," under the "Financial Disclosure" section of Rules of the Road, on our website, for further guidance on reporting those interest.