How Government Officials Report Their Finances — And What That Actually Tells You
A guide to public financial disclosure rules across the executive branch, Congress and the federal judiciary
The federal government requires thousands of officials to publicly disclose their personal finances every year. The goal is straightforward: prevent conflicts of interest and give the public a way to see whether the people making policy are personally profiting from it.
But the rules aren’t uniform. The forms are different. The deadlines are different. What counts as a reportable asset is different. And the gaps — what officials are not required to disclose — are significant and often misunderstood.
Here’s how it actually works.
The Executive Branch
Senior executive branch officials file under the Ethics in Government Act of 1978, using forms administered by the U.S. Office of Government Ethics. The president, vice president and most Senate-confirmed appointees are required to file publicly.
Two forms drive most of what you’ll read about here.
OGE Form 278e — The Annual Report
The OGE Form 278e is the primary public financial disclosure document. It covers assets, income, liabilities, positions held outside the government and agreements. Filers must disclose:
Assets and investment income — Securities, real estate held for investment, business interests and other income-producing property. Values are reported in ranges, not exact figures — for example, $1,001 - $15,000 or $15,001 - $50,000, up to $50,000,001 or more for the filer.
Non-investment income — Salaries, speaking fees, book royalties and other earned income from outside government.
Liabilities — Outstanding loans and debts above $10,000, with limited exceptions.
Positions — Outside board memberships, partnerships or advisory roles held in the prior two years.
One important nuance: the 278e does not exclude mutual funds or U.S. Treasury securities — those exclusions apply only to the 278-T. The annual report can be quite detailed for officials with complex portfolios.
Value ranges have a ceiling. For assets held by the filer, the top reportable bracket is “Over $50,000,000.” For assets held by a spouse or dependent child, the top bracket is “Over $1,000,000” — meaning spousal holdings can be substantially understated by the form’s own structure.
Annual 278e reports are due May 15 for the prior calendar year. Extensions of up to 45 days — with a possible second 45-day extension for good cause — are available through the employing agency.
OGE Form 278-T — The Periodic Transaction Report
The OGE Form 278-T is a separate form that captures securities transactions — purchases, sales and exchanges — above $1,000. Executive branch filers must report these within 30 days of receiving notification of a transaction, and no later than 45 days after the transaction itself.
The 278-T excludes several common transaction types:
Mutual funds and other excepted investment funds
Certificates of deposit, savings accounts, checking accounts and money market accounts
U.S. Treasury bills, notes and bonds
Thrift Savings Plan accounts
Real property
Bond or note maturity
Transactions solely between the filer, their spouse and dependent children
That means an official with a portfolio concentrated in individual stocks and municipal bonds will generate far more 278-T reports than one whose assets sit primarily in index funds or Treasuries — even if the two portfolios are similar in size.
Late 278-T reports — more than 30 days past the statutory deadline — trigger a $200 fee. OGE notes on the cover page when the fee has been paid.
Congress
Members of Congress file under a separate but parallel system established by the Ethics in Government Act and reinforced by the STOCK Act of 2012. Each chamber’s ethics committee manages the process, and reports are made available via the House Clerk and the Secretary of the Senate’s Office of Public Records.
Hunter Index covers both chambers, including congressional candidates who are required to file.
Annual Financial Disclosure Reports
Congressional annual reports require disclosure of assets, income, liabilities, positions and certain agreements — structurally similar to the executive branch 278e. Members must disclose assets and income sources above $1,000 in value or generating more than $200 in income from a single asset during the year. Personal property not held for investment such as primary residences, personal vehicles, or vacation homes with no rental income is excluded.
Annual reports also require disclosure of gifts and reimbursements for travel — including trips, meals and lodging paid for by outside sources — above applicable thresholds.
Annual reports are due May 15 for the prior calendar year.
Periodic Transaction Reports (PTRs)
The STOCK Act requires members of Congress, their spouses and dependent children to report securities transactions above $1,000. PTRs must be filed within 30 days of receiving written notification of a transaction, and in no case later than 45 days after the transaction — regardless of whether the member knew it occurred.
The penalty for a late PTR — filed more than 30 days after the due date — is $200 per report. The House and Senate ethics committees have discretion to waive it. Critics have noted the fee is low enough that it provides little real deterrence.
The Federal Judiciary
Federal judges — including Supreme Court justices — file annual financial disclosure reports under the same Ethics in Government Act framework, administered by the Administrative Office of the U.S. Courts. Judges are also subject to periodic transaction reporting for securities transactions above $1,000.
Access to those reports improved significantly in 2022, when President Biden signed the Courthouse Ethics and Transparency Act. Before that law, judicial disclosure reports were available primarily via paper copies. The Federal Judicial Financial Disclosure Reports database now provides free electronic access.
One meaningful structural difference: judges are not subject to OGE oversight. Reports go to the Judicial Conference’s Committee on Financial Disclosure, an internal body created in 1990, which reviews reports for compliance.
Supreme Court justices have historically treated compliance with rules as voluntary. Justice Clarence Thomas and Justice Samuel Alito both faced documented allegations of undisclosed gifts, and the Code of Conduct the Court adopted in 2023 includes no mechanism to investigate or penalize violations.
What Disclosures Can and Can’t Tell You
Financial disclosure is a powerful accountability tool — but it has real limits.
What you can know:
Whether an official holds assets in industries they regulate
The approximate scale of an official’s wealth, within ranges
Sources of outside income beyond a government salary
Transaction history for securities above the reporting threshold
Outside positions, board memberships and potential institutional conflicts
What you can’t know:
Exact dollar values — only ranges are required
The value of a primary residence or personal property not held for investment
Holdings below the reporting threshold
The full value of spousal assets once they exceed $1 million
Income from any individual asset generating less than $200 annually
The identities of private equity partners, LLC co-investors or minority interest holders
Assets held in excepted investment funds, which are excluded from transaction reporting
A note on value ranges: Because exact figures aren’t disclosed, any analysis of official wealth requires assumptions. Hunter Index uses median values for all reported ranges — the midpoint between the floor and ceiling of each bracket. For the top executive branch bracket (”Over $50 million”), we apply a floor value of $50,000,000 rather than estimating above it. If public officials decide to disclose more information than is required, we note that too. For example, President Trump lists exact income figures for some of his assets, so we use that figure.
We flag this methodology whenever aggregate figures appear in our reporting.
What Hunter Index Covers
Hunter Index focuses primarily on annual financial disclosures of federal officials and nominees, members of Congress and congressional candidates and select justices and judges. Our flagship project, Trump’s Wallet, contains more than 11,000 asset records drawn from Donald Trump’s OGE reports — spanning from January 2015 through the end of 2024.
Every figure in our database traces directly to the original report. We don't interpret or alter the values officials report. We take each filer’s report as accurate since that’s what they are required to certify by law when filing. That said, officials sometimes make errors that require amended reports once identified. When our fact-checking process surfaces a likely error, Hunter Index reaches out to the relevant office privately.
Questions about our methodology? Reach us at hunterindex.org.
Managing Hunter Index and its exclusive database which makes reporting like this article possible is extremely expensive and labor intensive.
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