USDA Ethics

10 SIMPLE WAYS TO MAKE THE 450 REVIEW PROCESS EASIER

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 OGE Form 450), 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 OGE Form 450 (Confidential 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.

10 SUGGESTIONS:

1. Asset Valuation:

You must report in Part I any asset worth more than $1,000 at the end of the reporting period or producing income over $200. If you can do so, put a check next to those assets that have a value of $15,001 or more as of the date of the report. You are required to report those assets, if worth more than $1,000 or producing income over $200, but we normally do not have to review them for potential conflicts of interest. (One of the biggest wastes of time in this process is having to bother filers to ask if an asset is worth $15,001 or more).

2. Spousal employment:

DO list the NAME of the employer or name of business (if spouse is self-employed);
DO identify your spouse’s position or title; but
DO NOT report the AMOUNT of income.

3. Mutual Funds, UITs, 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].

4. 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 has four underlying assets: AIM International Fund, Fidelity Magellan Fund and Exxon-Mobil stock, all individually worth more than $1,000; and IBM stock worth less than $1,000.

INCORRECT REPORTING:

CORRECT REPORTING:
 Name of Asset
Merrill Lynch 401K

Name of Asset
Merrill Lynch 401 containing
AIM International Fund
Fidelity Magellan Fund
Exxon-Mobil

You would not report the IBM stock.

5. Income Valuation for Funds

In determining whether an asset has generated income in excess of $200 during the reporting period, you would include earnings that are “rolled back” into the asset.

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 Parts I and IV.

7. Signing and Dating the Form

Be sure to sign and date the form, and to send us the report containing your original signature.

8. 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. "Not applicable" or annotating "NA" don’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 it later.

9. Inclusion of City and State

Include location (city and state) for the following listings:

    a. Any private businesses listed in Part I;
    b. Non-public companies in which you list stock in Part I;
    c. Rental and commercial property listed in Part I;
    d. Local (non-national) creditors listed in Part II; and
    e. Non-national organizations/entities listed in Part III;

10. Copies of Approval(s) for Outside Employment

Please remember to submit a copy of any approval for outside employment that you received from your supervisor or higher-level manager.

NOTE: If you own financial interest in a farm, or engage in farming activities, see "Farming Interests" under "Rules of the Road," on our web site, for further guidance on reporting these interests.