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AUGUST 2006 Ethics VTC 1 WELCOME VTC Tips: Mute your microphones unless you intend for all VTC participants to hear your remarks. While your microphone is turned on, please minimize noise. Paper shuffling noise carries through unmuted microphones. August 2006 2 Topics Website FDM Update Post-Government Employment Training OGE Conference WAGs AUSA CASAs FRGS Political Activities 3 WEBSITE 4 5 6 7 8 9 10 FINANCIAL DISCLOSURE MANAGEMENT 11 FDM Update Topics Thank you Numerology Supervisor Review SLC Success – notice; no reports to review OGE 450 Update Revised 450 Report Changes 12 FDM Numerology as of 31 July Registered 278 Filers: over 800 Reports Filed: 630 Reports in Draft: over 30 Extension to file – other than combat zone, expired Monitor your Filer’s progress Why still in draft? 13 SLC Login in View Review Filer Filters Use Filters to change role, reporting, and review status SLC/EC and Assistant use Filters to track and monitor reports 14 Review Filer Filters 15 Filters Use Filters to change role, reporting, and review status SLC/EC and Assistant use Filters to track and monitor reports 16 Filters 17 Supervisor Review Reviewers are checking the reported financial interests for completeness and to identify those financial interests that may conflict with the Filer’s official duties and that the report is administratively accurate and complete. Before signing off on the report the Reviewer must take appropriate steps to resolve any apparent conflicts of interest. Reviewer tools: Flags; Comments How to Review an SF 278 in FDM – Wizard Step-by-Step or Report View Reviewer Checklist Office of Government Ethics’ Public Financial Disclosure: A Reviewer’s Reference, available in FDM’s Help area (How To Guides). This 367-page reference manual for SF 278 Reviewers contains an introduction to the public financial disclosure system, the procedures and mechanics of review and conflict resolution, summaries of applicable ethics laws and regulations, sample SF 278 entries, model letters and documents related to the review process, and case studies. 18 Supervisor – Start View Use “ALL” to see all instead of by a category. Filters Supervisor starts on Review Filers, Reports List with the filter view shown above. Select View (far right column) to start review of desired report. 19 Notify Feature Supervisor & SLC should use Notify to alert other reviewers that report is ready for their action. 20 SLC – Review Filer’s Report After eSigning, SLC must click the Submit to ADAEO button before exiting FDM or navigate elsewhere using the navigation Tabs. 21 SLC Success No Reports 22 FDM Ahead • FDM Update 6 to SLCs (21 July) • Continuing to work with DoD, AF, Navy, NG POCs to make available DoD-wide in 2007; determine DoD Executive Agent • Working with OGE to improve FDM; make available to Executive Branch • Registering SLCs – email firstname.lastname@example.org • Feedback Comments Suggestions for FDM to help you Send to email@example.com 23 New OGE 450 Rules New rules in 5 CFR § 2634, §§ 2634.901-908 Impact on FDM: Waiting on OGE’s release of final, revised OGE Form 450 format to assess if FDM will be ready with revised report format in time for 2007 filing deadline Planning for it at least for those pilot 450 filers who have used FDM (data mapping) 24 Confidential Financial Disclosure Report Reporting period was 1 Oct to 30 Sep, due 30 Nov (JER). In the future use calendar year reporting period, with due date of 15 Feb. Transition: No annual OGE 450s due in 06. First annual report under revised format due 15 Feb 07, with a 15- month reporting period (1 Oct 05 through 31 Dec 06). 2006 new entrant filers continue using current OGE 450 until 1 Jan 07. Expect JER revision – date TBD 25 Revised Report Content New 5 CFR § 2634.907, Report Contents, includes useful examples Text online at http://www.usoge.gov/pages/laws_regs_fedreg_stats/lrfs_files/f edreg/71fedreg/71fr28229.txt Eliminates reporting of : diversified mutual funds the type of income (e.g., capital gains, dividends) earned on reportable assets student loans, credit card debts, and loans from financial institutions based on terms generally available to the public dates on which agreements/arrangements were entered 26 Revised Report Content Adds 5 CFR § 2634.907(h)(2)– Report assets and income of spouse/dependent child of the filer unless: The filer certifies that the item represents the spouse's or dependent child's sole financial interest, and that the filer has no specific knowledge regarding that item; The item is not in any way, past or present, derived from the income, assets or activities of the filer; and The filer neither derives, nor expects to derive, any financial or economic benefit from the item. OGE Note: One who prepares a joint tax return with his spouse will normally derive a financial or economic benefit from assets held by the spouse, and will also be charged with knowledge of such items; therefore, he could not avail himself of this exception. Likewise, a trust for the education of one's minor child normally will convey a financial benefit to the parent. If so, the assets of the trust would be reportable on a financial disclosure report. 27 Post-Government Employment PGE format finalized Make sure you tailor to your needs PGE Questionnaire finalized Briefing Attachments 28 Training Training Topics and Formats Email: Ms. Cindy Kelson at firstname.lastname@example.org Send in materials for posting Training Numbers Better progress than last year 29 Training Numbers CY 05 % CY 06 % Annual 99,909 13 159,114 23 Not Not Acquisition Reported Reported 10,064 26* 30 OGE Conference 2007 The 2007 National Office of Government Ethics Conference will be held March 13-16, 2007 at the Wyndham Orlando Resort in Orlando, Florida. Within the Army, ethics counselors nominated to attend this conference must be processed through command channels with a recommendation from Chief, DA Standards of Conduct Office, General Counsel, U.S. Army Materiel Command, or General Counsel, U.S. Army Corps of Engineers. Personnel are not to contact the Office of Government Ethics. 31 WAGS Check listings at: http://www.hqda.army.mil/ogc/eandf- ethics_links.htm Will list whether conference, social event, or both are approved as WAGs. 32 OSD –PAO Notice “The Department of Defense Office of Public Affairs has determined that DoD personnel may merely attend this event in their personal capacity. The DoD Public Affairs Office has also determined that, for purposes of accepting a gift of reduced or free attendance, the event is a widely attended gathering pursuant to 5 CFR 2635.204(g). This determination is not a DoD endorsement of the event nor approval for widespread attendance. If individual DoD Component commands or organizations determine that attendance by particular personnel is in DoD interest, those personnel may accept the gift. As other exceptions under 5 CFR 2635.204 may allow the acceptance of gifts, DoD personnel are urged to consult their Ethics Counselor." 33 ASSOCIATION OF THE UNITED STATES ARMY (AUSA) 34 AUSA What is AUSA? NFE (PO) Mission ―represent every American soldier‖ (voice) Foster public support Educational and informational programs and events What events? Annual Meeting and Exposition Winter, Logistics, Medical symposia 35 AUSA The Problem – First Class Support! Army develops, plans, coordinates; provides speakers, panelists, displays, soldier staff, etc. Use of Army personnel, equipment, other resources for unauthorized purposes Endorsement Preferential treatment Authority? 10 U.S.C. § 2558 authorizes limited support for annual conference only 36 AUSA The Solution – A legislative proposal (FY08) All events Every kind of service Endorsement permitted Preferential treatment expected Funding Within existing funds up to $1M/year Reimbursable over $1M Absent legislation, support only within limits of 10 U.S.C. § 2558, Fiscal Law, and JER 37 CIVILIAN AIDES TO THE SECRETARY OF THE ARMY (CASAs) 38 CASAs What are CASAs? Represent Army in communities Provide feedback to Army leaders Part-time, unpaid The Problem SGEs (18 U.S.C. § 202(a)) JER Financial disclosure Acceptance of gifts Fundraising 39 CASAs The Solution – A legislative proposal (FY08) Amend 10 U.S.C. § 1588 Authority to accept voluntary services CASAs will be category 9 If personnel meet statutory definition of SGE, they are SGEs, unless and until covered by voluntary services statute 40 FAMILY READINESS GROUPS 41 FRG INFORMAL FUNDS 42 FRG Informal Funds References DoD 5500.7-R (Joint Ethics Regulation) AR 215-1 (Morale, Welfare, And Recreation Activities And Nonappropriated Fund Intstrumentalities) AR 600-20 (Command Policy) AR 608-1 (Army Community Service Center) (New release!!) 43 FRG Informal Funds Informal Funds Private funds generated by FRG members used to benefit the FRG Authorized by the Commander IAW AR 600-20 Examples—parties, social outings, volunteer recognition, unofficial information 44 FRG Informal Funds Fiscal Issues Do not use for purchases for which APFs are appropriate Do not augment unit cup-and-flower fund Do not commingle with APFs, NAFs, MWR, or personal funds 45 FRG Informal Funds Management Issues Fund custodian and alternate appointed by commander (cannot be Cdr, deployable Soldier, or FRG leader) Establish non-interest bearing account in FRG name Commander not a signatory on the account Accounting reports required by Appendix J SOP maintained to establish purpose for infromal funds 46 FRG Informal Funds Fundraising Issues Only authorized fundraising IAW JER, paragraph 3- 210a(6) No external fundraising Annual gross receipt cap of $5000 per calendar year Fundraising event must be consistent with informal fund purpose 47 FRG Informal Funds Fundraising Issues (cont.) Units commanders may accept gifts of $1000 or less for informal fund POs with similar family readiness goals and objectives not limited in fundraising scope, but . . . Conflicts of interest must be avoided PO should not be treated like FRG Must not be command-established or directed 48 POLITICAL ACTIVITIES 49 Political Activities References Military members—DoDD 1344.10 (Political Activities by Members of the Armed Forces on Active Duty) Civilian employees—DepSecDef Memo, Subject: Civilian Employees’ Participation in Political Activities (updated for 2006) AR 600-20 (Command Policy) AR 670-1 NGB All-States Memo 05-002 (soon to be reissued) 18 U.S.C. § 1913, Anti-Lobbying Act 50 Political Activities Military Members Spirit and intent of DoDD 1344.10 prohibits any activity that may be viewed as directly or indirectly associating DoD with partisan politics ―Any activity that may be viewed as associating the Department of Defense . . . or any component . . . directly or indirectly with a partisan political activity shall be avoided.‖ DoDD 1344.10, para E3.4 51 Political Activities Military Members—What’s Permitted Register to vote and vote Encourage others to participate in political process Express purely personal opinions (caution) Join a political club Attend meetings, rallies as spectator Give money to political organizations Personal letters to editor (caution) Normal bumper stickers 52 Political Activities Military Members—What’s NOT Permitted 53 Political Activities Military Members—What’s NOT Permitted No official influence No campaigning Cannot be candidate or nominee No participation in partisan political campaigns, speeches, articles Even in ―private‖ capacity Or as ―honoree‖ No large signs or posters on POVs 54 Political Activities Military Members—Public Office Generally, may not hold or exercise federal, state, or local civil office Reserve member ordered to AD for 270 days or less: limited exception Still subject to noninterference Reserve member on AD for 271 days or more May not hold certain federal office May hold state office but may not exercise functions Must read regulation 55 Political Activities Military Members—Wear of Uniform AR 670-1 regulates wear of uniform Uniform wear issues different than whether a member may participate in political activity Status of military member not relevant to whether uniform may be worn 56 Political Activities Military Members—Reserves Reserves not regulated when in civilian status DoDD applies to active duty only Reserves have more latitude during IDT or AD for 270 or fewer days Watch uniform and endorsement issues 57 Political Activities Civilian Employees Note: different rules for SESs, political appointees, employees of intelligence agencies Most civilian employees: rules somewhat more relaxed than for military 58 Political Activities Civilian Employees—What’s Permitted May participate in political organizations As officer Nominating causes Help organize Participate in conventions or rallies 59 Political Activities Civilian Employees—What’s Permitted May participate in political campaigns Canvass voters Endorse candidates (in private capacity) Address convention, rally, or caucus Manage campaigns Participate in election process 60 Political Activities Civilian Employees—What’s NOT Permitted Run for partisan office Use official authority to interfere Use official authority or title to fundraise Personally solicit political contributions Political activity while on duty, while in Federal workplace, while wearing insignia, or while using government resources 61 VTC Training Materials are available at: http://www.hqda.army.mil/ogc/eandf-VTC%20MAIN.htm 62
"August 2006 VTC"