Financial Disclosure Management (FDM)

Financial Disclosure Management (FDM) is a secure, electronic filing (e-filing) system for its authorized users to file and maintain required financial interest reports. The FDM Program Office, under the supervision of the Deputy General Counsel for Ethics Fiscal, Office of the General Counsel, operates FDM as Executive Agent for Department of Defense use.

Army personnel use an online program, Financial Disclosure Management (FDM), to electronically file the financial disclosure. Consult your Ethics Counselor for information and assistance about filing an SF 278 or OGE 450. (Both of these forms are available on the homepage of the FDM website).

SF 278, Public Financial Disclosure

Certain senior Army officers and employees are required to file publicly available reports disclosing their financial interests as well as the interests of their spouse and minor children. Public filers must report:

  • interests in property held in a trade or business or for investment or the production of income (real estate, stocks, bonds, securities, futures contracts, beneficial interests in trusts or estates, pensions and annuities, mutual funds, etc.) that meet reporting thresholds
  • earned income, retirement benefits, honoraria and any other non-investment income
  • gifts and reimbursements that meet reporting thresholds
  • liabilities (personal loans from certain family members, a mortgage on a personal residence, automobile, furniture and appliance loans, revolving charge accounts that do not exceed $10,000 at the close of the reporting period are excluded from reporting)
  • agreements or arrangements with respect to future employment, leaves of absence and continuation of payments or benefits from a former employer, and
  • outside positions as an officer, director, trustee, general partner, proprietor, employee, consultant, etc. of any organization (but positions with religious, social, fraternal or political entities are excluded, as are solely honorary positions).

Note: The SF 278 is releasable to the public upon request. Filers should avoid including unnecessary or personal information. For example, do not include account numbers and instead of using the names of a spouse or child the Filer could use “spouse” or “child 1.”

OGE Form 450, Confidential Financial Disclosure

Certain other Army employees whose duties involve the exercise of discretion in sensitive areas such as contracting, procurement, administration of grants and licenses, and regulating or auditing non-Federal entities are required to file confidential financial disclosure reports. This reporting system generally tracks the approach of the public disclosure system with some differences. For example, asset values and income amounts are not required to be reported, nor are interests in or income from bank accounts, money market and diversified mutual funds, U.S. obligations and Government securities. The most notable difference between public and confidential reports, however, is that confidential reports are not available to the public.

Reference:
5 C.F.R. part 2634.

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