Financial disclosure management is the process of providing accurate and timely financial information to investors and regulators. This information is critical for a stable and healthy financial market where capital allocations are optimized and regulated in line with statutory and regulatory requirements and standards.
It includes everything required to organize and maintain a company’s financial disclosure process internally. This can include ensuring that all financial statements are GAAP or IFRS compliant, XBRL tagging, and other statutory and regulatory guidelines. It also involves a corporate governance structure that ensures accountability and internal controls, audits, and processes that are optimized and timely.
Another challenge is the organization of a narrative in a financial report that requires management to explain how numbers were generated and what they mean for the business. Typically, companies use a combination of word processing tools, Excel spreadsheets, and presentation software to pull together the information they need for reports. These tools often fall short of what’s needed to deliver effective and accurate financial disclosures.
A few things can help to bring order and efficiency to these processes, including the development of standardized disclosure processes and collaboration between internal stakeholders. This can help to remove any kinks in the process and make it more reliable and accurate. It can also be beneficial to have a transparent two-and-fro communication channel between the company and its shareholders that allows the company to engage with them on a regular basis to understand their priorities and perspectives.
Financial Disclosure Management in the Army
The Army is no stranger to financial stewardship and has many tools and technologies at its disposal to promote ethical behavior by its employees. One of these tools is the FDM system or Financial Disclosure Management. It is a secure, electronic filing (e-filing) system for its authorized users to file and maintain their required financial interest reports anywhere and anytime using a Web browser.
To learn more about FDM, call your local Army OGC eFOG or visit the FDM website. You may also opt to sign up for an FDM swag bag! This swag bag will include items deemed to be of a high quality and value.
FDM is a global workforce enablement firm that has made a splash with their high-tech recruiting and training programs. The company has a well-deserved reputation for excellence and innovation and boasts an impressive client list including some of the biggest names in the business. In addition to the usual suspects, FDM is constantly on the hunt for new and exciting tech talent to help clients take their game to the next level. Their best-in-class talent is deployed to clients spanning the globe and is backed by superior customer service that translates into tangible ROI for their customers. For example, they’ve won multiple awards for their customer experience and have been named one of the top 5 IT staffing firms in the world. To learn more about the FDM Group, check out their website or give them a call to see how they can help your organization improve your bottom line.
In order to maintain the integrity of government and ensure that citizens have confidence in the Federal Government, Congress has mandated financial disclosure requirements for high-level executive branch officials. These reports must disclose all significant financial interests of the official and outside business activities. They also help to prevent conflicts of interest, identify potential conflicts and assist agencies in administering ethics programs.
To meet these goals, the Federal Government has created a confidential reporting system to complement the public disclosure requirement. Employees whose duties include substantial discretion in sensitive areas are required to file a confidential report (OGE 450). Examples of employees who may be required to file confidential reports include those involved in contracting, procurement, grant administration, regulating or auditing non-Federal entities and those who investigate or prosecute a case.
Confidential reports must be filed within 30 days of entering a covered position and annually by February 15th. An employee may request an extension of time to file his report from his Component Head, who may grant an extension of up to 90 days. If the filer fails to report his or her financial interests or outside business activities, the President, Vice President, Director of the Office of Government Ethics, Secretary concerned, and head of each agency may take appropriate personnel or other action in accordance with applicable law or regulation against him or her. These actions can include disciplinary action under 5 CFR part 752, if applicable.
Who is required to file an OGE 450?
A federal employee must file an OGE 450 (Confidential Financial Disclosure Report) when he or she is required to do so under federal law, including Executive Branch regulations and the Office of Government Ethics regulations. This form is used to collect and report financial information that can affect an individual’s ability to conduct official business without exposing the Service to a conflict of interest.
A new entrant must complete and submit the OGE 450 within 30 days of assuming a position that is covered by this requirement. This report must be filed for the preceding 12 months, or if the reporting period is shorter than that, for the entire period that is less than 12 months.
The decision to file an OGE 450 is driven from the top down and rests with the immediate “owner” or supervisor of an employee. This person could be the Director, Department Head, Division Head or other senior authority.
Each bureau ethics official or designee is responsible for timely collection of OGE 450s and for completing the review of these reports, as provided by Bureau policy. The review may be performed by the bureau ethics official or designee or by Bureau employees designated as filer reviewers, and may be completed no later than 60 days after receipt of the report.
The OGE 450 requires that each filer answer 5 yes/no questions and sign and date each page of the report. These questions should include whether the filer has any interests in a corporation, partnership, or trust. If the filer has such an interest, he or she should also describe the interest and the nature of its acquisition.
If you work in a position that is designated by your agency as requiring a financial disclosure report, you are required to file an OGE 450. This includes employees who manage contracts and grants, grant-making personnel in the Office of Justice Programs, and others with responsibilities related to where money goes.
In addition, Presidentially-appointed, confirmed by the Senate (PAS) employees; non-career Senior Executive Service (SES) employees; Senior Level (SL) employees; Professional (ST) employees; Schedule C employees; certain SGEs, and Intergovernmental Personnel Act (IPA) detailees must all file the OGE Form 450 annually after entering their positions. However, a special exception applies for those employees who leave their covered positions prior to the due date of an annual report.
You should get training each year to help ensure that you are prepared to complete your OGE 450. This can be verbal or in writing (reading training materials and informational documents), but it must be provided by a qualified instructor.
You should also consult your ethics official or counselor to ensure you understand the information you need to include in your report and how to prepare it in a way that is compliant with the regulations and your agency’s supplemental standards of conduct requirements. For example, if your agency requires you to add a broker’s statement to your OGE 450, make sure you add it in a manner that is compliant with OGE’s regulations and your agency’s supplemental standards.
