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August 2006 VTC

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August 2006 VTC Powered By Docstoc
					AUGUST 2006

  Ethics VTC

               1
               WELCOME
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                   August 2006
                                                    2
                   Topics
   Website
   FDM Update
   Post-Government Employment
   Training
   OGE Conference
   WAGs
   AUSA
   CASAs
   FRGS
   Political Activities
                                 3
WEBSITE



          4
5
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7
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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 george.hancock2@hqda.army.mil
•   Feedback
     Comments
     Suggestions for FDM to help you
     Send to george.hancock2@hqda.army.mil


                                                        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
      cindy.kelson@hqda.army.mil
     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




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