Financial Transparency Project

Financial Transparency Project

Financial disclosures are mandatory for all appointees, but the federal bureaucracy has created a byzantine system for making this information available to the public. Financial disclosure forms (278 and 450) are excluded from release under the Freedom of Information Act (FOIA) process and only a small subset of high-ranking officials’ forms is posted on the Office of Government Ethics (OGE) website. Yet even this process is fraught with repeated extensions granted to officials with complicated personal finances and potential conflicts of interest requiring divestiture, resulting in major gaps even on the designated OGE website.

In general, OGE posts the financial disclosures only of those officials who are subject to Senate confirmation. The financial disclosures of officials who are required to file forms but who do not require Senate confirmation for their roles are often hidden at the agency level. Obtaining these financial disclosures requires specific knowledge of the official’s name and sometimes an extended conversation with the agency ethics office to obtain the proper form to even request the hidden financial disclosures. Discovering the names of relevant officials is itself no small feat as only a small handful have published pages on their websites listing appointees.

Protect the Public’s Trust believes this level of transparency is woefully inadequate and the entire financial disclosure process is in dire need of repair.

Kicking off this Project, PPT submitted a letter calling on the Department of Justice (DOJ) and OGE to take urgent action to fix this “broken” financial disclosure process. DOJ and OGE can build on recent momentum toward transparency as reflected in Attorney General Merrick Garland’s memorandum to the heads of executive departments and agencies. The memo declares, “Transparency in government operations is a priority of this Administration and this Department,” urging agencies toward proactive disclosures. The same principles should apply to the potential financial conflicts of those making decisions impacting virtually every aspect of our lives.

As it stands, the financial disclosure process is a black box for most Americans. This project aims to change that reality. To begin, we have begun identifying known appointees at the biggest federal Departments and comparing this list with those high-ranking officials listed on the OGE website. The initial results show a major gap in transparency. Stay tuned as we dig deeper.

Update: Check out the financial disclosures we have received.

Agency Department Announced/
Estimated Appointees
Financial Disclosures
Available via OGE
Unavailable via OGE
% Financial Disclosures
Available via OGE
White House 560 71 489 13%
Dept of Agriculture 102 11 91 11%
Dept of Commerce 79 21 58 27%
Dept of Defense 252 43 209 17%
Dept of Education 126 9 117 7%
Dept of Energy 96 15 81 16%
Dept of Health and Human Services 104 12 92 12%
Dept of Homeland Security 75 16 59 21%
Dept of Housing and Urban Development 25 9 16 36%
Dept of Justice 111 45 66 41%
Dept of Labor 88  12  76 14% 
Dept of State 191 130 61 68%
Dept of the Interior 59 13 46 22%
Dept of Transportation 42 14 28 33%
Dept of Treasury 58 22 36 38%
Dept of Veterans Affairs 26  8  18 31% 
Environmental Protection Agency 42 14 28 33%
Export-Import Bank 7  4  3 57% 
Federal Energy Regulatory Commission 2 1 1 50%
Office of Personnel Management 21 2 19 10%
Small Business Association  36 34  6% 
US Agency for International Development  51 13 38   25%
Totals 2153 487 1666 23%