Effective July 3, federal career employees and others who must file public financial disclosure forms must report more quickly when they buy or sell stocks, bonds or certain other securities, according to Office of Government Ethics guidance.
The guidance reflects a requirement in the Stock Act, passed earlier this year that includes several provisions affecting all public financial disclosure filers, even though the measure itself was directed primarily at members of Congress.
Under traditional law, certain financial transactions involving $1,000 or more had to be included in the annual filing of the Form 278, but under the new policy, they generally must be reported within 30 days – 45 days under certain conditions.
Certain transactions are excepted, however. These include real property; excepted investment funds; underlying holdings of an excepted investment fund, a qualified blind or diversified trust, or an excepted trust; assets owned by the employee’s spouse or dependent child, if the employee does not also own the asset; Treasuries; life insurance and annuities; cash accounts; assets in the Thrift Savings Plan; and assets in any other retirement system maintained by the United States.
There are also exceptions for transactions involving assets of the employee’s spouse or dependent children, unless the employee also owns the asset.
The guidance is here: http://www.oge.gov/OGE-Advisories/Legal-Advisories/LA-12-04–Public-Financial-Disclosure—Periodic-Transaction-Reports/