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Public Financial Disclosure Report Review: A Collective Effort

June 14, 2023

David Apol, General Counsel

Today marks 30 days since the majority of the 2023 annual public financial disclosure reports were due to ethics offices across the executive branch. Today is also the first day that many of these reports become publicly available from the agencies where they were filed. The reports you request or read about are the end product of an extensive review process that involves thousands of officials across the executive branch.

Once a filer files their report, their ethics official will review the report to ensure it is complete and to identify any possible conflict of interest between the disclosed entries and the duties of the filer. When ethics officials identify an entry as a possible conflict of interest, they will seek additional information to determine if a potential conflict actually exists. For example, if a filer has stock in a company regulated by the filer’s agency, the reviewer will determine if the employee has any responsibilities that could affect that stock. If a potential conflict does exist they will work with the filer to implement remedies to ensure potential conflicts don’t become actual conflicts. Only once the ethics official is satisfied a report is complete and all potential conflicts are resolved does the official certify the report. 

For more than 1,000 of the highest level senior officials, the process doesn’t end here. After the agency certifies the report it is transmitted to OGE for a second-level certification. When the OGE reviewer has questions about completeness or identifies entries that might pose a potential conflict, the OGE reviewer contacts the agency for further information and clarification. Only once OGE is satisfied the report is complete, accurate, and free from conflicts does the report receive OGE certification.   

Whether a report comes to OGE for second-level certification or stays at the employing agency, it becomes publicly available from the agency where it is filed 30 days after it is filed. For most reports that day is today, June 14th. Reports that come to OGE are made available through our Officials’ Individual Disclosures Search Collection 30 days after OGE receives them.

So when you request a report or read a news article about financial disclosure reports, know that these reports are the product of many hours of expert review and analysis designed to keep executive branch officials free from conflicts of interest.