Documents/OGE/2: Conflicts of Interest/2.3: Financial Disclosure

2.3: Financial Disclosure

Administer an effective confidential financial disclosure system.

Other Information:

OGE administers a second financial disclosure system that is directed to employees who serve in positions with important decision-making authority and responsibility but who are not in positions that require public financial disclosure.  This system involves the submission and review of confidential financial disclosure reports.  Like public financial disclosure reports, confidential reports are used as a tool to identify potential conflicts of interest and to counsel employees about avoiding such conflicts.  Agencies make extensive use of this system; for example, the confidential reports are filed by temporary employees and thousands of members of advisory committees to ensure that advice received by the Government is objective.  As with the public financial disclosure reporting system, OGE’s challenge is to ensure that the system is as effective and efficient as possible, while at the same time ensuring that it meets its primary purpose of preventing conflicts of interest. Strategies for Objective 2.3: Use technology to improve the confidential financial disclosure system. As with the public financial disclosure reporting system, the confidential system could be improved by on-line preparation, submission, review and certification of reports.  OGE plans to develop a confidential financial disclosure form that can be filed electronically. Encourage agencies to use alternative confidential financial disclosure reporting where appropriate. OGE has, by regulation, established a uniform system of confidential financial disclosure reporting for the entire executive branch.  However, because agency missions (or the components of agencies) vary greatly, it may be more practical and useful for identifying conflicts to tailor the confidential disclosure requirements to the needs of a particular agency.  This may be true particularly in cases involving disclosure by members of advisory committees.  OGE regulations permit such deviations where circumstances dictate that an alternative reporting system would enhance agency operations.  OGE will encourage the increased use of these alternative systems by advertising existing approved alternatives; identifying, through our program review process, agencies that might benefit from the use of an alternative system; and by assisting agencies in developing such  systems for their own needs.

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