How to Fill Out and Submit OGE Form 278-T: Deadlines and Filing

OGE Form 278-T, the Periodic Transaction Report, is how senior executive branch officials disclose a purchase, sale, or exchange of stocks, bonds, or other securities worth more than $1,000. File it through Integrity at integrity.gov within 30 days of learning about the transaction, and in no case later than 45 days after the transaction itself.¹ A report filed more than 30 days past that deadline triggers a $200 late fee.²

Who Has to File

The reporting requirement runs to public filers as defined in 5 U.S.C. § 13105(l) and 5 C.F.R. § 2634.202.³ That covers the President and Vice President; executive branch employees in positions classified above GS-15 or paid at 120 percent of the GS-15 minimum or more; uniformed service members at O-7 or above; administrative law judges; senior Postal Service and Postal Regulatory Commission officials; the OGE Director and each agency’s designated ethics official; certain commissioned civilians in the Executive Office of the President; policymaking excepted-service employees not carved out by the OGE Director; and Members of Congress and covered congressional staff.

You file for your own reportable transactions and for those of your spouse and dependent children. If you have left a covered position but have not yet completed your termination filing obligations, you are still a public filer under the same rules.³

What Counts as a Reportable Transaction

Any purchase, sale, or exchange of stocks, bonds, commodity futures, or other securities over $1,000, by you, your spouse, or a dependent child, triggers a 278-T.⁴ An exchange counts as two events: if you swap one stock for another and both sides exceed the threshold, both are reportable.

Managed accounts are the trap. A trade an investment advisor, robo-advisor, or account manager makes on your behalf is still your transaction, and trades inside a 401(k), IRA, variable annuity, or 529 plan are reportable too.⁴ Set up trade confirmations or frequent statement access so you actually learn about these trades in time to file.

What You Do Not Have to Report

Several categories fall outside the 278-T:

Excepted investment funds: a mutual fund or similar pooled fund that is independently managed, widely held (at least 100 investors), and either publicly traded or widely diversified.⁵
U.S. Treasury bills, notes, bonds, and savings bonds.⁶
Your personal residence, unless it was rented out at any point in the reporting period.⁶
Transactions solely between you, your spouse, and your dependent children.⁴
Assets held in qualified blind trusts and excepted trusts.⁵

The excepted investment fund category causes most of the errors. An ETF is not automatically exempt; it has to meet all three criteria. A fund concentrated in a single industry, or in a single country other than the United States, is not widely diversified and does not qualify.⁵ Check with your agency ethics official before assuming a fund is exempt.

The 30-Day and 45-Day Deadlines

You have two clocks running at once, and whichever runs out first is your deadline. Thirty days from the date you are notified of the transaction. Forty-five days from the transaction itself, no matter when you found out.¹

For a trade you place yourself, both clocks start on the same day and the 30-day rule controls. For a managed account where a statement arrives weeks after the fact, the 45-day cap can hit first. If notification reaches you about a transaction that happened early the previous month, the 45-day window from the trade date may close before your 30 days from notification runs out, and that earlier date is your deadline.⁷

Extensions

Your agency can grant up to a 90-day extension for good cause. An extension of 45 days or fewer can be approved orally; anything from 46 to 90 days needs a written request and written approval. Total extension days go on the cover page of your report.⁸ Ask before the deadline passes; agencies are expected to decide before the due date.

A separate automatic extension applies if you are serving in or supporting the Armed Forces in a designated combat zone. It runs until 180 days after the later of your last day in the combat zone or your last day of any resulting hospitalization.⁸

What Late Filing Costs

A report filed more than 30 days past its deadline carries a $200 late fee, paid into the U.S. Treasury.² The supervising ethics office can waive it in extraordinary circumstances, but waivers are uncommon. The fee is charged per late report, not per transaction, so a single late report bundling several overdue transactions still costs $200.

The real risk is not the fee. Willfully failing to file or falsifying report data triggers a mandatory referral to the Department of Justice and civil penalties that can exceed $50,000.

Filling Out the Form

Pull a full transaction history for the reporting period before you start. For each reportable trade, the form asks for:

Asset description, including the ticker symbol or full security name.
Type of transaction: purchase, sale, or exchange.
Transaction date, which is the trade date, not the settlement date.⁹
Notification date, meaning when you first learned the transaction occurred. For self-directed trades this is the trade date; for managed accounts it is the day a statement or confirmation reached you.
Value range, selected from brackets such as $1,001–$15,000, $15,001–$50,000, and $250,001–$500,000, with higher brackets above.¹⁰
Whose transaction it was: yours, your spouse’s, or a dependent child’s.

Recurring mistakes: using the settlement date instead of the trade date, listing an excepted investment fund that did not need to be listed, and omitting an account manager’s trades inside a retirement plan.

Submitting Through Integrity

Most executive branch filers submit through Integrity, OGE’s web-based system, at integrity.gov.¹ You cannot register yourself; your agency ethics official handles that.¹¹

PIV or CAC cardholders log in with their card. Everyone else logs in through Login.gov using the email address on file with Integrity. Confirm that email with your ethics official before you try; repeated failed attempts can lock the account and force a ticket to Integrity@oge.gov.¹¹

Integrity walks through each required field and will not accept an incomplete report. After you submit, your agency’s designated ethics official reviews and certifies it. If your agency does not use Integrity, file a paper version with your ethics official for the same review and certification.

Your Filing Becomes Public

Certified 278-T reports are public records, searchable through OGE’s Officials’ Individual Disclosures Search Collection. Some are downloadable directly as PDFs; others require a request through OGE’s online document request tool.¹² Journalists and watchdog groups routinely read them looking for conflicts between an official’s trades and their policy responsibilities, and an amended filing draws more attention than an accurate original. Get the details right the first time.

1
United States Office of Government Ethics. OGE Form 278-T
2
Office of the Law Revision Counsel. 5 USC 13106 – Failure to File or Filing False Reports
3
eCFR. 5 CFR 2634.202 – Public Filer Defined
4
Department of Energy. STOCK Act Periodic Transaction Reporting Requirements for OGE-278 Filers
5
United States Office of Government Ethics. Definitions
6
United States Office of Government Ethics. OGE Form 278e Part 7 Transactions – Section: Transactions That Are Not Reportable
7
U.S. Office of Government Ethics. Executive Branch Personnel Public Financial Disclosure Report – Periodic Transaction Report (OGE Form 278-T)
8
United States Office of Government Ethics. For Ethics Officials
9
U.S. Office of Government Ethics. Periodic Transaction Report – OGE 278-T Job Aid
10
United States Office of Government Ethics. OGE Form 278e Part 7 Transactions
11
Integrity. Integrity
12
U.S. Office of Government Ethics. Officials Individual Disclosures Search Collection