The tips below and the guidance in the OGE Form 450 should help you reduce the likelihood of follow-up inquiries from your servicing ethics advisors, the number of inquiries, and the overall time spent responding to such inquiries. A win-win for all, no matter how you figure it.
IMPORTANT: It is your responsibility to provide information on the OGE Form 450 that is complete and accurate. Please use the tips below and the instructions on the form itself as tools to help you with this reporting requirement.
1. Asset Valuation (Part I: Assets and Income).
You must report in Part I any asset with a value of more than $1,000 at the end of the reporting period or producing income over $200 belonging to you, your spouse or dependent children.
2. Spousal employment (Part I: Assets and Income).
DO list the NAME of your spouse’s employer or name of business (if spouse is self-employed); and
the source of honoraria in excess of $200 paid to your spouse; but
DO NOT report the AMOUNT of income or honoraria; and
DO NOT report your spouse’s employment with another Federal agency.
3. Mutual Funds, Unit Investment Trusts, and similar investments (Part I: Assets and Income).
List the full name of the investment (e.g., Fidelity Energy Fund). [Failure to list the names of specific funds (not just the name of the fund family) is probably the greatest cause for unnecessary follow-up inquiries.]
DO report sector funds [NOTE: Sector Mutual Fund – A mutual fund that concentrates its investments in an industry, business, single country other than the United States, or bonds of a single state within the United States.];
DO NOT report the fund VALUE;
DO NOT report diversified mutual funds. [NOTE: Diversified Mutual Fund (DMFs) – A mutual fund that does not have a stated policy of concentrating its investments in one industry, business, or single country other than the United States.]; and
DO NOT report your or your spouse’s holdings in the Thrift Savings Plan.
4. IRA, 401(k), 403(b), 453, Keogh, etc. (Part I: Assets and Income).
You should report any UNDERLYING assets that you would be required to report if held individually rather than as part of the plan. For example, let’s assume that your Merrill Lynch 401(k) has three underlying assets: Fidelity Magellan Growth Fund and Exxon-Mobil stock, each individually valued at more than $1,000; and IBM stock valued at $950 as of the end of the reporting period (December 31st). You also own a Citibank IRA with one underlying asset: the AIM International Fund, valued at $22,500.
|| Name of Assets:
Merrill Lynch 401(k)
|CORRECT REPORTING:|| Name of Assets:
Merrill Lynch 401(k) containing:
Remaining holding is a DMF
Citibank IRA containing:
AIM International Fund
You need not report the Fidelity Magellan Growth Fund because, for purposes of this example, it is a diversified mutual fund, i.e., DMF, or the IBM stock because its value is below the $1,000 reporting threshold. However, you should report the Exxon-Mobil stock as an underlying holding in the Merrill Lynch 401(k) and the AIM International Fund as the underlying holding in the Citibank IRA. NOTE: A 401(k) account and an IRA are not securities so merely reporting an IRA or 401(k) as standalone assets is not sufficient. They are retirement investment accounts that may contain securities, cash and other assets. All IRAs are self-directed because investors choose where to invest their funds. Consequently, you must report the individual assets, i.e., the underlying holdings, in IRA and 401(k) accounts if they meet the income and other reporting thresholds. DO NOT report your or your spouse’s holdings in the Thrift Savings Plan.
5. Income Valuation for Funds (Part I: Assets and Income).
In determining whether an asset value meets the reporting threshold, you would include earnings that are “rolled back” into the asset. For example, during the course of the year your IBM stock valued at $950 earned $150.00 in dividends that were rolled back. The new stock value of $1,100 as of December 26th meets the income threshold for purposes of the OGE Form 450 and should be reported.
6. Liabilities (Part II).
IMPORTANT: OGE 450 filers are not required to report mortgages on their primary residence or rental property as long as the mortgage is from a financial institution or business entity, and the mortgage was granted on terms made available to the general public. If your mortgage meets these criteria, you don't have to report it on the OGE 450 as a liability even though you may have in the past. The following examples may be useful to help you navigate this requirement. Example 1: You and your former college roommate, Joanne, started a dog-grooming business last year. Joanne’s father loaned you and Joanne the $25,000 franchise fee to start the business. Report this liability in Part II because it is a loan over $10,000 from a friend or business associate. Example 2: You and your spouse divorced last year. You were awarded the family home as part of the property settlement. However, you were unable to pay the monthly mortgage. Your ex-spouse loaned you the money to pay off the $205,000 mortgage, and now you are repaying your ex-spouse through bi-weekly installment payments. Report this liability in Part II. Example 3: You purchased a new $19,000 SUV for your birthday last July. The SUV serves as security for the $19,000 loan. DO NOT report this liability in Part II because the SUV serves a security for the loan, and the loan amount does not exceed the purchase price.
7. Outside Positions (Part III).
Report outside positions you currently hold, or held during the reporting period, with non-Federal entities, whether compensated or uncompensated. Report the income source of the position in Part I as well if you received more than $200 in compensation. DO NOT report positions you hold as official duty. Please be reminded USDA regulations require prior approval for certain outside employment with non-Federal entities. Consult your servicing ethics advisor for additional information about this requirement: https://ethics.usda.gov/advisor.htm
8. Agreements or Arrangements (Part IV).
If you are new to Federal service, report the title of your former position with the non-Federal entity in Part IV, if any, and indicate it is no longer held. (Also report the name of your former non-Federal employer in Part I as an income source.) Report a retirement plan, savings plan, stock purchase option, severance payment, or other plan in which you continue to participate with a former employer in Part IV, even though you and the former employer no longer contribute funds to your plan account. Also report the source of continued compensation over $200 that you received from a former non-Federal employer in the previous year, such as severance pay, or the source of compensation over $200 that you will receive from a future non-Federal employer, such as a signing bonus. (Remember to talk to your ethics specialist about future employment with a non-Federal entity.) DO NOT report information about your spouse’s agreements or arrangements.
9. Gifts and Travel Reimbursement (Part V).
Report gifts totaling more than $375 that you received from any one source during the reporting period except DO NOT report gifts from relatives, the U.S. Government, D.C., state, or local governments and gifts you received from a bequest or other form of inheritance. Also report travel-related reimbursements totaling more than $375 (such as lodging, transportation and food) that you received from any one source during the reporting period. However, DO NOT report sponsored travel given to USDA in connection with your official travel. Sponsored travel is considered a gift to the agency not to you. The following example may be useful to help you navigate this requirement. You serve on the board of directors of the Food Lovers Culinary Institute as an approved outside employment. Last year, you traveled to Paris to attend a conference on behalf of the Institute. The Institute reimbursed you for your travel expenses totaling $2,800. A local Paris shop, Boutique Élan, gave you a gift certificate worth $500 because you were the 1,000 customer. Report the $2,800 travel reimbursement from Food Lovers Culinary Institute in Part V and include a comment explaining where you traveled, the purpose, and dates of the trip. Also report Boutique Élan as the source of the gift certificate. You are not required to report the amount of the travel reimbursement or the value of the gift certificate.
10. Inclusion of City and State
Include location (city and state only, no address) for the following listings:
NOTE:If you own a financial interest in a farm, or engage in farming activities, see "Farming Interests" under "Rules of the Road," on our web site, for further guidance on reporting these interests.