Financial Disclosure 

All BOR employees are subject to conflict of interest restrictions and may be required to file either a Public Financial Disclosure Report (OGE Form 278e) or Confidential Financial Disclosure Report (OGE Form 450). These Reports are among the primary tools used by ethics officials to determine whether employees are in compliance with the ethics and standards of conduct provisions covering a particular position.

The BOR supervisor is the final authority in determining whether a BOR employee is designated a confidential financial disclosure filer. In consultation with the AEC and using the BOR Job Aid: Filer Determination Worksheet for Confidential Financial Disclosure Reports, the BOR supervisor must review the details of the work the BOR employee is required to perform and the level of responsibility to act on behalf of BOR to determine if the employee’s duties warrant the filing designation.

OGE Form 278 (Public Financial Disclosure Reports)

The OGE Form 278e must be filed by Presidentially appointed, confirmed by the Senate (PAS) employees; non-career Senior Executive Service (SES) employees; SES employees; Senior Level (SL) employees; Professional (ST) employees; Schedule C employees; certain SGEs, and certain IPA detailees.

Additionally, all BOR employees who file public financial disclosure reports (OGE Form 278e) must file Periodic Transaction Reports (OGE Form 278T) for transactions over $1,000 in stock, bonds, and securities by the filer, spouse, or dependent child no later than 30 days after receiving notification of the transaction. If an employee who is required to file an OGE Form 278e or a Periodic Transaction Report files more than 30 days after the statutory deadline (and any extension periods), he or she is subject to a $200 late filing fee.

Annual OGE 278 forms are due May 15 each year. New entrant forms are due within 30 days of entrance into a “public filing” position. All reports are filed electronically through the system.

Resources for OGE 278 Filers:


The STOCK Act, enacted April 4, 2012, mandates additional requirements for ethics officials and employees who file the OGE 278 Public Financial Disclosure Report. See the full text of the Act, new forms, and explanations on the STOCK Act page.

OGE Form 450 (Confidential Financial Disclosure Reports)

The OGE Form 450 must be filed by BOR employees whose positions are designated by their BOR supervisors as requiring confidential financial disclosure reporting using the criteria in 5 C.F.R. § 2634.904, as well as by SGEs and IPA employees who are not required to file OGE Form 278e.

BOR employees who are below the “senior level” and are designated by their BOR supervisors as Confidential Filers are required to file a Confidential Financial Disclosure Report (OGE 450) within 30 days of entering the Agency and on an annual basis thereafter. The OGE 450 is like the OGE 278 report; however, it is shorter, requires less detail, and is not available to the public.

Annual notifications to complete the OGE 450 forms are distributed to employees in January through the FDOnline System. Annual OGE 450 forms are filed electronically and are due February 15.

Resources for OGE 450 Filers:

Termination reports are due on the day of separation from a “public filing” position and no later than 30 days after separation.

Special Note: Compliance with financial disclosure requirements is a condition of employment. BOR employees who are required to file and fail to do so in a timely manner may be subject to disciplinary action up to and including removal from Government service. A BOR employee who willfully falsifies the information on his or her report, willfully omits information, or willfully fails to file his or her report may be subject to civil penalties and/or criminal prosecution by the Department of Justice.

Last Updated: 1/13/23