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September 28, 2012 - President Obama signs Amendment to Extend STOCK Act Posting Deadline to December 8. On September 28, 2012, the President signed into law S. 3625, which extends the date by which certain Executive Branch public financial disclosure forms must be made available on the internet to December 8, 2012. Subsection 11(a)(1) of the STOCK Act (Public Law 112-105), originally required that by August 31, 2012, public financial disclosure forms filed be made available to the public on the official websites of the respective Executive Branch agencies not later than 30 days after such forms were filed. The STOCK Act was amended by S. 3510 (Public Law 112-173) to move this deadline to September 30, 2012, and the U.S. District Court for the District of Maryland Southern Division subsequently enjoined posting under the STOCK Act until October 31, 2012. Click here to read the Court's opinion. Section 1 of S. 3625 extends the effective date of subsection 11(a)(1) of the STOCK Act to December 8, 2012, except for certain high-level filers occupying positions listed at Level I and II of the Executive Schedule (at HUD, that is the Secretary and the Deputy Secretary). S. 3625 also directs a study by the National Academy of Public Administration of issues raised by website publication of financial disclosure forms and to issue a report with findings and recommendations. In addition, section 3 of S. 3625 clarifies that an employee subject to the periodic transaction reporting requirement under subsection 103(l) of EIGA must also report any purchase, sale, or exchange of securities by the employee's spouse or dependent children. The periodic transaction reporting requirements for an employee's spouse and dependent children covers transactions occurring on or after January 1, 2013. Read S. 3625.

  September 13, 2012 - Update on the STOCK Act's Public Posting of 278s Requirement. On September 13, 2012, the Federal District Court for the District of Maryland Southern Division postponed the effective date of Section 11 of the STOCK Act, which requires all public financial disclosure reports to be posted on a public website from September 30, 2012 until October 31, 2012. Other activities related to collection, review, and disclosure of financial information pursuant to Sections 101 et seq. of the Ethics in Government Act ("EIGA"), 5 U.S.C. app. 4 §101 et seq., may continue. Click   here to read the Court's opinion.

Key Changes for HUD employees

  1. Mortgage Reporting for Presidentially appointed, Senate confirmed (PAS) officials:As of April 4, 2012, PAS officials must report mortgages on personal residences on their OGE-278 reports. 
  1. Negotiating Employment:As of April 4, 2012, all OGE-278 filers must file a notification statement within three business days of directly negotiating private employment. Please view the link below for more information on this notification process.
  1. Involvement in IPOs:As of April 4, 2012, OGE-278 filers may not purchase securities at initial public offerings in ways not available to the general public.
  1. Reporting Transactions:On July 3, 2012, all OGE-278 filers must start reporting certain financial transactions to the Ethics Law Division (ELD).  Filers must report transactions over $1,000 involving stocks, bonds, and commodities (not mutual funds) within 30 days of notification or 45 days of the transaction, not just once a year on the annual filing.  The STOCK Act also requires HUD to post these transaction reports on its website.
  1. Posting Reports Online:By September 30, 2012, HUD must post all OGE-278 reports and transaction reports on its website within 30 days of being filed and include information on extensions given to filers.
  1. Uniform Electronic Filing System:By October 4, 2013, unless Congress grants OGE an extension, OGE must create a uniform electronic filing system for all filers, both public (OGE-278) and confidential (OGE-450). The database will be publically available, but only the data from OGE-278 reports must be publically searchable.