Federal Asset Report: Who Files, Forms, and Penalties

If you take a federal job with real financial influence, you will be filing a financial disclosure report. Federal financial disclosure requirements split filers into two tracks: senior officials file the public OGE Form 278e, and mid-level employees whose duties create conflict-of-interest risk file the confidential OGE Form 450. Both cover your assets, income, liabilities, gifts, outside positions, and your spouse’s and dependent children’s finances, and both carry firm deadlines with penalties for missing them.

Which track you land on depends entirely on your position and what your job actually involves, not on what you own.

Who Files a Public Report

Public disclosure covers the government’s senior roles. Under the regulations, a public filer is any executive branch employee whose position is classified above GS-15, or whose pay rate equals at least 120 percent of the GS-15 minimum, plus uniformed service members at pay grade O-7 or higher.¹ Public filing also reaches:

The President and Vice President
Presidential appointees confirmed by the Senate
Administrative law judges appointed under the federal civil service system
Employees in policymaking or confidential positions excepted from the competitive service
The Postmaster General, Deputy Postmaster General, and Postal Service or Postal Regulatory Commission employees paid at or above 120 percent of GS-15
The OGE Director and each agency’s designated ethics official
Civilian employees in the Executive Office of the President who hold a presidential commission of appointment¹

Who Files a Confidential Report

Confidential disclosure catches employees below the public-filing threshold whose work still creates meaningful conflict risk. You file confidentially if your position is at GS-15 or below (or the equivalent pay rate) and your agency determines that your duties require you to participate directly and with significant independent judgment in any of the following:

Contracting or procurement
Administering or monitoring grants, subsidies, licenses, or other federally provided financial benefits
Regulating or auditing a non-federal entity
Other actions with a direct and substantial economic effect on a non-federal entity’s interests

The list also covers special government employees who help shape agency policy or serve on a federal advisory committee.² Whether you file is your agency’s call, based on your actual duties.

What Goes on the Report

Assets and Investment Income

Report any asset held for investment or income production that was worth more than $1,000 at the end of the reporting period, or that generated more than $200 in income during the year. That includes stocks, bonds, sector mutual funds, partnership interests, and income-producing real estate. Holdings inside a 401(k) or IRA are reported individually when they cross those thresholds, not as a lump.³

Diversified mutual funds do not need to be reported; sector-specific funds do.³ Your personal residence is excluded from property reporting.⁴

Earned Income

Report all noninvestment earned income over $200 from any single source, including salaries, fees, and commissions from outside employment. Retirement benefits from federal employment, the Thrift Savings Plan, and Social Security are excluded.⁵

Liabilities

Report liabilities that exceeded $10,000 at any point during the reporting period. Personal loans, lines of credit, and similar debts count. Mortgages on your personal residence are generally excluded, along with federal student loans and certain routine consumer obligations.

Gifts, Travel, and Outside Positions

Public filers report gifts and travel reimbursements totaling more than $390 from any single source during the year, with items valued at $166 or less excluded from the total. OGE adjusts these thresholds periodically.⁶ You also list positions held outside the federal government and any employment agreements, such as a severance package from a prior employer.⁷

Spouse and Dependent Children

Your spouse’s and dependent children’s assets, income, and liabilities are reported under the same thresholds and valuation categories as your own. A limited exception applies if a spouse is living separately with the intent to divorce or permanently separate.⁷

How Values Are Reported

You do not list exact dollar amounts. Each asset goes into a value range: $1,001–$15,000, $15,001–$50,000, $50,001–$100,000, $250,001–$500,000, and upward for larger holdings.⁸ Investment income uses the same bracket approach. Ethics reviewers get enough to spot conflicts without you pinning down precise market values.

Forms, Deadlines, and Extensions

Public filers submit the OGE Form 278e, which becomes available to the public after review. Confidential filers submit the OGE Form 450, which stays inside the agency.⁹ Filing is electronic. Most executive branch filers use Integrity, OGE’s secure web-based system, though some agencies run their own platforms.⁷

Three deadlines drive the calendar for public filers:

New entrant report: due within 30 days of assuming the duties of your covered position
Annual report: due no later than May 15 each year, covering the prior calendar year
Termination report: due within 30 days of leaving your covered position⁷

Confidential filers follow a similar annual cycle, and individual agencies may set their own internal schedules.

If you cannot meet a deadline, your reviewing official can grant an extension of up to 45 days for good cause. A second 45-day extension is possible, but you must request it in writing and explain why. The reviewing official’s decision, approval or denial, must also be documented in writing and kept in your file.¹⁰

STOCK Act Periodic Transaction Reports

Public filers have a second, faster-moving obligation. Under the STOCK Act, you must file a Periodic Transaction Report (OGE Form 278-T) whenever you, your spouse, or a dependent child buys, sells, or exchanges stocks, bonds, commodity futures, or other securities in a transaction exceeding $1,000. The report is due within 45 days of the transaction date, or 30 days of learning about a spouse’s or child’s transaction, whichever comes first.¹¹

This is where filers most often trip up. A spouse sells a few thousand dollars of stock and mentions it a couple of weeks later, and the clock is already running. If anyone in the household trades individual securities with any regularity, a system for catching transactions in real time matters more than perfecting the annual report.

What Happens After You File

Every report goes to the agency’s Designated Agency Ethics Official or their staff. The reviewer compares your reported holdings against your official duties to identify actual or potential conflicts.⁹ If a conflict shows up, the ethics official works with you to resolve it, usually through one of three tools:

Recusal, in which you agree not to participate in official matters affecting the conflicting interest
Divestiture, in which you sell the asset, sometimes with a certificate of divestiture that defers capital gains taxes on the sale
A qualified blind trust, in which an independent institutional trustee takes over the assets and stops communicating with you about the holdings¹²

Qualified blind trusts are uncommon in practice. The trustee must be an unaffiliated bank or financial services company, the trust must follow OGE’s model document, and OGE has to certify the instrument, the asset list, and the trustee before the arrangement takes effect.¹²

Who Can See Your Report

Public OGE Form 278e reports are available to anyone who asks. The employing agency keeps the report accessible for six years after receipt, then destroys it unless it is relevant to an ongoing investigation.¹³ Home addresses, personal phone numbers, and similar sensitive details are redacted before release.

Confidential OGE Form 450 reports work the opposite way. They are withheld from the public, and only the agency’s ethics official (and in some agencies the filer’s supervisor) reviews the form for conflict-of-interest purposes.¹⁴

Penalties for Late or False Filings

A report filed more than 30 days past the deadline, or past the end of any granted extension, triggers an automatic $200 late filing fee.⁷ That is the smallest consequence in the system.

For more serious violations, the Attorney General may bring a civil action in federal court, and the court can impose civil penalties of up to $75,540 for violations occurring after November 2, 2015.¹⁵ Knowingly and willfully falsifying information on a disclosure report can lead to criminal prosecution under federal false-statement laws, with a potential prison sentence of up to five years.¹⁶ Agencies can also pursue administrative discipline, including suspension or removal, on their own track.

1
eCFR. 5 CFR Part 2634 Subpart B – Persons Required To File Public Financial Disclosure Reports
2
eCFR. 5 CFR 2634.904 – Confidential Filer Defined
3
U.S. Office of Government Ethics. Part I – Assets and Income
4
eCFR. 5 CFR 2634.301 – Interests in Property
5
eCFR. 5 CFR 2634.302 – Income
6
U.S. Office of Government Ethics. Part V – Gifts and Travel Reimbursements
7
U.S. Office of Government Ethics. OGE Form 278e Overview
8
U.S. Office of Government Ethics. OGE Form 278e Part 6 – Other Assets and Income
9
USAJOBS Help Center. What Is Financial Disclosure and Why Does This Job Require It
10
eCFR. 5 CFR 2634.201 – General Requirements, Filing Dates, and Extensions
11
U.S. Department of Energy. STOCK Act Periodic Transaction Reporting Requirements
12
eCFR. 5 CFR Part 2634 Subpart D – Qualified Trusts
13
GovInfo. 5 CFR 2634.603 – Procedures for Collection and Filing
14
Defense Security Cooperation Agency. OGE Form 450 Frequently Asked Questions
15
eCFR. 5 CFR Part 2634 Subpart G – Penalties
16
Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally