Disclosure of the Filer’s Receipt of a Conflict-of-Interest Waiver

Office of Government Ethics 1201 New York Avenue, NW, Suite 500 Washington, DC 20005 Submitted via email to usoge@oge.gov Subject: OGE PRA Form 278e and OGE Form 450 Review Dear Director Rounds: The Project On Government Oversight (POGO) submits the following comment in response to a solicitation of public comments by the Office of Government Ethics (OGE) regarding potential changes to the Executi. [...] POGO recommends that OGE change OGE Form 278e to collect and disclose three new pieces of information: a declaration as to whether the filer has received a conflict-of-interest waiver, the filer’s type of appointment, and the filer’s date of appointment. [...] Disclosure of the Filer’s Receipt of a Conflict-of-Interest Waiver The primary conflict-of-interest law grants the public a right to access written waivers exempting executive branch employees from its restrictions, but the executive branch has made it difficult for the public to exercise this right.2 OGE should address this program weakness by requiring filers to indicate in OGE Form 278e whether. [...] This change would restore a public right the executive branch has impeded, a benefit that would far outweigh the minimal burden of requiring filers to respond “yes” or “no.” Disclosure of the Filer’s Type of Appointment OGE should add a data field to the cover page of OGE Form 278e that indicates the type of appointment a filer holds. [...] The excepted investment fund field asks filers whether an item disclosed in OGE Form 278e is an investment fund that qualifies for an exception to the requirement of disclosing the underlying holdings of investment funds.