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can you a question oh now I could turn.the call over to you first speaker today.mr. Patrick Shepherd you may begin great.thanks very much for you.good afternoon and welcome to the ethics.fundamentals series my name is Patrick.Shepherd bright pleased to be joined.today by Cheryl cane Piasecki welcome.Cheryl thanks very much Patrick I'm what.are we gonna be talking about today well.we're going to be debriefing a 450.review exercise that deals with someone.who has the position of a loan officer.we had last year done massive open.online course that provided an overview.of 450 review requirements and there had.been two exercises that were attendant.to that that MOOC and what were as you.know what we're planning to do is to.continue to build a library of exercises.that will be attendance to that MOOC so.that when folks watch it will just.continually provide new opportunities to.engage in some sort of application based.learning excellence and this is very.timely because we know the deadline for.filing 450s is coming up in just a few.days yes it is so hopefully this will.serve as a reminder or refresher for.those of you I love and look to the 450.in awhile I would also like to remind.you about some upcoming events next week.we will be back for the advanced.practitioner series where we will share.some best practices tips and techniques.for ethics instructors and we're going.to be focusing specifically on handling.difficult questions we'd also like to.remind everyone that the national.government ethics summit is coming up.March 8th 9th and 10th very quickly very.quickly very very quickly and we will be.bringing you many of the sessions from.the summit virtually so if you're not.able to join us in Washington DC do not.fret a lot of the information and the.sessions will be available on our.YouTube channel which is youtube.com.slash GE Institute social should we pull.up the slide deck that would be.wonderful and we can get started.um for those of you who I'm hoping those.of you who are new to 450 review I had.an opportunity to view the first part of.the MOOC because in that I actually.walked you through the forum itself.and gave you some some pointers as to.what is required to be reported and.sensibilities about how to sort of.navigate the form because today while.while we're obviously going to be.discussing some aspects of that we're.going to be doing it entirely in the.context of of a Mach 450 axon so we're.assuming uh at least some familiarity.with the form its purpose and the.general mechanics of the filing process.so if you're missing that information we.would encourage you to go back and.listen to that first session exactly.exactly.so one thing I do want to do a little.bit of before we actually get started in.the Indy briefing the the form itself is.I always like to remind people that you.know that the entire purpose and the.singular purpose of confidential.financial disclosure is to prevent.conflicts of interest and other ethics.issues and so I like us to be reminded.of that when we go into the review of.our 450s because I think it's important.for us to sort of remember what we're.prioritizing right before we begin the.review and clearly the the the priority.for a 4:50 review is a set is there your.substantive review right and that's sort.of nice a luxury that we have with the.450 system is that it's designed only to.help us prevent these conflicts of.interest so when we're going through.those are the questions that we want to.ask and be thinking about is am i able.to assess whether there's a potential.for conflict and if I am can I take.steps to mitigate it to me exactly.so one of the primary things that we are.looking for the primary analyses that.we're doing is sort of a nexus test and.this is mostly with respect to the.application of the criminal conflict of.interest statute 18 USC Section 208 and.when we're talking about looking for a.nexus effectively there are two pieces.of information that we're going that.we're going to need to be in possession.of and then we're going to try to assess.whether or not we think there's any.relationship between those two pieces of.information the first is what types of.government matters the employee is going.to work on so in order to do your.conflict analysis you're gonna have to.know what your employee does so whether.you get a position description whether.you D ask the person directly through.some mechanism you do need to have some.fundamental understanding about the.types of work.the employee is going to perform.programmatically this is a important.feature and it's one of the main reasons.that we have a decentralized program the.reason that you all work in the agencies.and don't work directly for GE is.because it puts you in a position to.find out and understand the work of your.employees right so once you get the 450.what the what the employee is actually.doing is providing you with that second.piece of information that you need to do.your Nexus test which is what holdings.or other types of interest as the.employee have that could ostensibly be.affected by some of the work that.they're going to be performing and in.this vein we like to remind you that the.financial disclosure program is really.is really a request for advice and.counsel so when your employees are.submitting their 450s their get.providing you with a set of facts and.they're asking you to take a look at.those facts and based on what you.understand of the work that they're.doing help them spot any place where.they may have a potential for a conflict.or for some or to bump up against one of.the other criminal conflict of interest.statutes or the standards of ethical.conduct so from that standpoint this is.where your technical review is in.support of your substantive review when.you're going through the report as.you're looking at each thing that the.person disclosed is you need to have.sufficient understanding of what that.thing is in order to be able to do a.robust complex analysis against it so.for those things that you know that you.don't believe would ever present a.conflict you may not have to drill down.into things like that but for something.where you either can't recognize on its.face what it is or you kind of think it.might be something that caused a.conflict but you're not entirely sure.what it is in those instances you have.to get more facts just as you would need.if somebody came to you directly with an.ethics question and the thing I like to.think about when I'm going through these.forms is to look at each entry and ask.myself the following question do I have.enough information about this entry and.about this employee to determine a that.this will not pose a potential for.conflict or that be it does pose a.potential for conflict of interest and.we need to take steps to remedy it.if the answer is neither of those or if.I don't have an information enough.information to make one of those.determinations I know I need more.information.yes that's and that's a very nice way of.putting in Patrick that's a really nice.we sort of like three-step process.because we just want to remind you that.when you're certifying a report the the.certification statement is that you're.concluding that the filers in compliance.with applicable laws and regulations so.it's really important that we do due.diligence in our substantive review and.in the context of that again we'd like.to remind people document document.document so we really strongly encourage.you to have reviewers notes when you're.asking questions of employees and/or.asking for additional information.whether or not you include that directly.on the financial disclosure form itself.you should have at least some sort of.notes to document those those questions.and the answers that you get and the.additional information that you received.because those are going to be in support.of your substantive determinations so.that if if for whatever reason someone.needs to come in behind you and either.recreate the analysis that you did or is.coming in to somehow second-guess the.analysis that you did you have all the.relevant facts at your disposal and at.their disposal so that you know that.that everybody understands what was.known what was considered and what the.overall analysis was but I think there's.another suggestion that we could make.and that folks could consider as a best.practice when conducting 450 reviews and.that is you mentioned earlier that we.can think of the document itself as a.request for advice so if it's a request.to revise the outcome the work product.that we should be producing should be.ethics advice so something that you.might consider is for those employees.where you do not find a possibility of.conflict is letting them know that their.report has been certified and that you.don't believe they have any conflicts to.be concerned about and certainly in.employees who have the potential for.conflict letting those folks know what.steps they need to take to stay out of.out of difficulty so you could consider.notifying everyone right also they.understand the purpose of the program.and receive the benefits of the program.yeah I know and I think that in keeping.with that I know that there are some.agencies that issue cautionary memos I.don't know how often people actually.formally make people enter into ethics.agreements I don't think it's a bad idea.particularly if you have something that.you think is a fairly a real likelihood.for conflict but I agree with Patrick.that that you know at the end of the day.too often I think people are unaware of.the purpose of the 4:50 the people who.file at 4:50 and they sort of send this.form away just thinking it's just.something they have to submit and that.nothing gets done with it so I think to.report back to them that I conducted.this review and I found the following or.I or I didn't find anything that would.raise any questions again I think.reaffirms for the for the person who.submitted it that there was a point to.them having submitted this information.exactly okay so before we get started I.just want to make sure everybody has a.few things in front of them you need the.you need a copy of the of the 450 that.we the hypothetical 450 that we provided.for you on Macs.you also need a copy of the agency.profile and the employee profile which.will tell you who it is that we work for.and on whose behalf we're reviewing.these forms and whose form it is that.we're reviewing and you may want to have.handy or at least have up on your.screens the 450 review guide that I that.I we included in the materials because I.am going to be making reference to.portions of that throughout the rest of.today's broadcast so when we get started.let's let's look at our agency profile.we we created this this agency out of.whole cloth it may bear some semblance.to actual an actual agency that exists.but we're certainly not pretending that.we are that any agency that may appear.like this where we're with the.Department of farming we are the farm.loan agency so when we're reviewing this.form we're doing it from the from the.standpoint of being an ethics official.at the farm loan agency as our name.implies or expressly indicates we.provide government-backed loans to.farmers and would-be farmers to buy or.to improve farms and just as a piece of.information that that could could.supplement this is.these are not direct from the agency.loans to farmers these are these are.these are loans that are underwritten by.private financial institutions our.agency does have a supplemental reg we.have a prior written approval for.outside activities but we also have a.provision where Fla employees and their.spouses and their minor children are not.allowed effectively to have sort of.business dealings with program.participants that means people who are.seeking loans from our agency so we.neither know they're our employees nor.our spouses their spouses and minor.children can sell lease purchase.property from an Fla program participant.who can be affected by the decisions of.the particular office the employee is a.gs-13 loan officer we've illuminated.some of the duties of that position I.think they're probably self-evident I.think most people have a familiarity.with what a loan officer does but this.person is responsible for processing the.applications that come in from would be.what's the word I'm looking for farmers.I guess they counsel the applicants on.the requirements they collect and review.the application documents they assess.the financial situation and make some.decisions about the the appropriateness.of the of the loan request and then they.make a recommendation to approve or.disapprove the loan so this is someone.who has some fairly substantive duties.this isn't just a you know I file the.application form and I don't have an.ability to act with discretion or.judgment so in this case the employee is.making the approve disapprove.recommendation right but we would have.equal concerns if they were a part of.odd advise keeping process or something.like that the important thing here is.the employees participating in the.substance of the decision to issue the.lemon exactly the this person's duties.are not ministerial these this person.has duties where they are taking.decisions and they are providing.recommendations and advice that reach to.the substantive merits of a final.decision that's probably why I lose.Bethesda well that's why she's a.confidential file.so what I wanted what I want to.encourage you all to do and maybe you do.do this but but I know that that when I.review public financial schools reforms.here and when we teach people with.energy E to file.I mean how to review public financial.disclosure reports I always encourage.people to take a minute before you.actually dip into the form to be.thinking about based on what you know.this person does based upon that what.you understand about what the agency.does to take a few minutes just to think.about what kinds of things might be.problematic so that you're kind of.prepared to identify them as soon as you.open the form rather than you're looking.through stuff on the form and you're.kind of trying to get your head around.it so so we might imagine the kinds of.entries this if we would see them on the.form might give us pause exactly so that.we are looking for something we're not.just looking at the form exactly exactly.so and these might seem self-evident to.you but I think that it's always useful.to think about them and to try to think.about specific things they could fall.within each of these broad categories so.clearly where the farm loan agency this.person is a loan officer clearly we have.to be concerned about financial.institutions or financial services.organizations and then you have to think.about well in what way could somebody.have an interest in one of these things.so then you look at investment interests.what kinds of investment interests well.it could be a stock you know in or it.could be a mutual fund that contains.these things so it could be a sector.mutual fund non investment types of.interest does somebody does the employee.or somebody in the employee's immediate.family have an employment interest with.a financial institution does the.employee him or herself have an outside.position like us as on a board of.directors or president or anything.that's associated with a financial.institution and then also we have to be.thinking about liabilities do does the.person have any loans or lines of credit.and one thing I'd like you to be.thinking about with these is not be.thinking in terms necessarily about.whether or not any and all of these.things are reportable because not.necessarily everything that could.present a conflict for someone is is.reportable in the form but I think you.have to bear those things in mind just.so that you're prepared to see things.when they do pop up and.ask relevant questions if you if you see.certain things on the form that you.think might lead to other types of.interests that maybe aren't as school as.well on the form right sometimes you.know the form is a balancing act you.know we try and collect just enough.information to make the determination.about whether or not someone has a.potential conflict but sometimes there.will be an entry that's suggestive of a.potential problems that require some.digging in and it's impossible for us to.make the reporting requirements a.perfect fit for the information we need.to make those determinations so you want.to can to keep the broader view in mind.yes exactly exactly there are 300,000.you know plus confidential filers in the.government and any regulation that og.would have hoped to have written to.require disclosure was never going to be.one size fits everybody so so that's or.the other thing obviously that sort of.is an obvious thing it would be any.farming or agriculture interest because.we are the Department of farming and.these are farm loans but again you have.to think of it in terms of what type of.investment vehicles might involve.farming or agriculture so again some.kind of ownership interest stock or.mutual funds sorry there should be a.comma between those two commodities.futures so if you've got somebody who's.who's invested in in commodities.partnerships wreaths which are real.estate investment trusts actual real.estate leasing arrangements there are a.lot of farms that have leasing.arrangements with with you know they.people own the farm but they leased the.farm for somebody else to manage and.also like crops and livestock so these.are all sorts of things that that you're.gonna want to be prepared to possibly.see on the form right non investment.would be any outside activities that are.related to farming again employment.subsidies and I put familial and.personal relationships because even.though they would not expressly be you.know disclosable and the same thing with.a lot of government back subsidies they.wouldn't be expressly disclosed on the.form but again if you see that someone.owns a farm you might want to ask and.you're probably going to want to ask.like what are you receiving any.government subsidies or you know do you.have any family members who are also in.farming.such that they might come before our.agency in requesting a loan these are.also questions that you can ask in the.context of a matter right so you could.ask those in the context of your annual.review of the confidential financial.disclosures report but likewise if we.were assigning work to Elizabeth and we.had some concerns about potential.conflicts or appearance issues at the.time of the assignment we could check in.and make sure that there isn't a.personal friend or a family member who.would be affected by that decision or we.could include it in training so.Elizabeth's aware if she's asked to.participate in a loan determination that.would affect the family member a friend.that she ought to seek advice before.participating exactly so this fits into.our our sort of whole ethics program.yeah the Caesars have to work together.yes that they're not they're not.unrelated to one another right and then.finally again additional liabilities so.if we look at our confidential financial.disclosure report we we noticed that.she's filled out everything appears to.be correctly I want to note that up in.the upper left hand corner this would be.where you would date stamp when the.agency actually received it because just.a reminder you're supposed to review.these within sixty days so that would be.your date stamp that would indicate when.that when that starts to toll she.appears to have things disclosed on.parts one two and three and she doesn't.have anything on four and five.and then she's signed it she's dated it.it looks like it's an annual report so.it looks like she's she's submitted it.on time which is great so let's jump.into the report and we're gonna walk.through each of the each line of the.report and each of the things that are.disclosed in turn but I always think.it's useful before you jump in on part.one to take a look at the whole form.because the form is a little bit like a.storybook and sometimes something that's.on one schedule or one part will help.you understand what you're seeing on.another part so if we look at part 1 we.see she's got Cornwell organics we don't.quite know what that is.maybe another part of the form will help.us understand that Oklahoma AG credit.that's a spousal thing she's got.farmland.P REI T with a ticker symbol we'll have.to figure out what that is.Mutual Financial Services fund and then.she's got this USAG thing which again.this not self-evident on its face what.the heck that is so if we go to the next.page she's got a liability from Farm.Credit of Central Oklahoma and then.she's got if we look on part three she's.got Cornwell organics listed again and.she's indicated that it's a farm and.that she's a co-owner so that gives us.some insight before we ever get to part.one about what it is we're looking at.there and that will help shape our.questions a little bit better because.now we know what it is that we're.looking at and then she lists a.nonprofit mentoring volunteer position.with Oklahoma small business development.and that's all she has disclosed on the.form so a couple of things here before.we get started is just a reminder that.Elizabeth is a loan officer and she's.working in an Oklahoma regional office.okay so that should inform part of our.discussion here too and how we look at.these things and the information that we.need about each of the things that's on.the form is knowing exactly where this.employee is located so what part of the.country what geographic part of the.country is actually affected by the.matters that she works on so let's look.at the first one which is Cornwell.organics we know that she is an OCO.owner and we know that it's a farm so.you got to start with you know what is.this okay so we know it's a farm and we.know that her interest is ownership but.is that enough Patrick for us to be able.to kind of get our heads around what.that is about I think we're gonna need.some more information here you know.knowing it's a farm I think tells us by.its relationship to the mission of our.agency that this is an area where we are.at least going to need to collect more.information but itself that's not going.to be enough information to determine.affirmatively whether or not they.suppose a potential conflict or will.definitely not pose a conflict so we're.gonna have to ask some questions yeah we.are gonna have to ask some questions and.one of the first things that you need to.know about a business when someone.indicates that they have an ownership.interest in a business and whether it's.a farm or it's some other kind of.business is you need to know what the.how the business is structured.and we gave you the og form 450 guide.and there's a discussion of business.ownership and employment relationships.in there that I think is helpful so one.of the first questions we're going to.have to ask is this business ownership.of this farm is the pharma sole.proprietorship because if it's a sole.proprietorship then that basically means.that the farm and the employee are kind.of coextensive they are one in the same.thing right okay so then anything that.can affect the farm is going to be.deemed to affect our employee is it a.partnership it is a general partnership.because if it's fun if it's founded as a.general partnership then our employees.going to have a financial interest not.only in the partnership itself but in.what else also in the general partner.and the general partners the conflict of.interest statute tells us that - the.financial interests and that's the.personal financial interest of the.general partner or imputed to us yes.their general partner is their partner.mm-hmm and particularly in a situation.like a farm I mean I think particularly.if it's a family farm and it's got the.family name on it um that there's a.great likelihood that our employees.going to know what the financial.interests of the other general partners.are absolutely it could be it could be a.family relation or your close friend or.someone that they grew up with but.that's probably a fairly close business.relationship and it's gonna be a similar.analysis for a limited partnership.because even if you're only a limited.partner in a general partnership you.still have a financial interest in the.general partner assume the general.partners now there are some limited.exemptions in 26:44 the general partner.interests and that's not the partnership.itself that's the general partner's.interests but it is a limited exemption.but again if you know that that's what.you're dealing with then you know you're.gonna have to become familiar with that.exemption to decide whether or not this.person actually has a conflict with.certain matters and then and then it.could be a corporation and if the farm.is incorporated it may or may not you.know I guess issue struck right there.are all sorts of mechanisms by which you.can have an ownership interest in the.corporation uh-huh and I guess my.follow-on question be by what mechanism.and do you have that ownership interest.and I guess in the event that it was a.publicly traded corporation that issues.publicly traded securities we may can.have some relief by way of the 26:40.exemptions but again until we know right.we don't know right exactly so you can't.do an analysis until you know what the.structure of the of the actual farm is.so that's one of the first pieces of.information you're going to need now we.know that this and that's going to apply.to any business district so that so.that's why I've invoked that first.because I want for those of you out.there who don't deal with farms and.farms would never be a conflict for you.I don't want you to think that this that.this discussion is of no material.interest to you that's the same sort of.analysis you would do irrespective of.what the nature of the business was so.you'll be running a store or an IT firm.or a staffing company it doesn't really.matter what the business is we still.need to ask all those questions and.figure them out so that we can apply.exemptions appropriately or do our.analysis completely and we do need to.know what the nature of the business is.with the line of businesses if it's a.publicly traded company then you can.probably look it up yourself if it's.other than a publicly traded company you.do need to get you do need to find out.from the employee with that business.line or what the nature of the business.is as I have learned many times over.many times businesses have names that.are similar to other businesses if.there's any ambiguity make sure you know.what what the thing is that you're.looking at exactly so moving along.because we are dealing with a farm there.are additional interests and some more.specific interests that we would have to.be concerned about and make sure that if.we don't see them on the form that we.check with the employee to find out what.those interests are so for example what.does the farm produce there are there.are there crops are there is there a.livestock what exactly is the farm.engaged in what is the nature of the.business now for purposes of our farm.loan our farm loan officer it may or may.not be material because you know it may.it may not be that when she approves or.doesn't or recommends to approve or.doesn't recommend to approve a.particular loan that that necessarily is.going to have an effect on commodities.you know but we do need to know like we.do have to have a sensibility about what.the farm is what kind.business the farm is engaged in and then.particularly with our case where we have.a supplemental reg we need to know if.there are any leasing arrangements are.they leasing the farm for rent to anyone.and if they are make sure it's not a.program participant with whom they are.they have a leasing arrangement so this.is an example of where we're gonna have.to do probably significantly beyond the.information that is technically.disclosable longer on the form right in.order to ensure compliance with the.ethics laws and regulations but in.particular or supplemental regulations.exactly exactly.it's you know with respect to outside.positions we want to know whether or not.they are just a passive investor they.might just be a passive investor in the.farm so they really only have sort of.the the stock interest or the.partnership interest or the ownership.interest but they aren't actively.engaged in the management of the farm.but if they do hold a position and.they're actively engaged in the.management of the farm then we have to.be concerned about any kind of.interactions that they have on behalf of.the farm and seeking government.subsidies in seeking those types of.benefits because again even though the.subsidies government subsidies because.they are funded by the government are.not reportable in the form clearly if.you have an employee who holds a.position with a farm and they're the one.who are engaging in the negotiations or.whatever needs to be done in order to.get the the government benefits there's.a there's a possible 205 problem there.because they're representing the farm.they're not representing themselves.right so you know we have at least that.concern we want to make sure that our.employee is not representing the form.before the federal government we may.also have concerns about misuse of.non-public information right uh you know.we'd probably have to provide a full.outside activity analysis right and.that's something I would look for here.immediately is to find out if we have.indeed looked to this position before.and issued any advice because that might.be able to so that complete the picture.for us yes exactly and that's all the.more reason to have documentation of.things we got a very funny and comment.on the hangout that's how are you gonna.keep her down on the farm after she's.seen hurry.oh yes um the little camera goes a long.way that's for sure um and then of.course you're gonna need to know where.it's located because to the extent that.there are conflicts they may very well.be relational I mean like geographically.relative so you know if the farm is.located if she's in Oklahoma and the.farm is located in Georgia you know.maybe some of the concerns that you.would have if they were located in.Oklahoma will be different or will go.away altogether the perhaps is a remedy.we could send her to France to work so.anyway so um so I do I would do.recommend to you the the form 450.guidance document that we send to you.because it does contain information.about the things we just discussed in.addition it does talk about livestock.and farm interests as well and and it.talks about some of the things that we.mentioned about whether there's it's.participates in any federal programs.whether you look occation is etc etc so.let's go sit in the interest of time.let's keep let's keep moving on here so.our second interest that is disclosed is.Oklahoma AG credit and Oklahoma AG.credit is is I think probably clearly.some sort of a financial institution but.we would have to look it up and it and.it is and it's in it's a business in.Oklahoma that actually does provide farm.loans so we want to know what the.interest is here because the only thing.that shows us is that it's the spouses.okay so that could be an equity interest.loan could be an employment interest.uh-huh it could be some other kind of.ownership type interest mhm.it could be uh another source of income.and not an employment source of income.yes so we really don't know we don't and.I think it's gonna be important for us.to find out exactly exactly so we want.to find out what the nature of the.interest is and again think about it in.terms of investment interests and non.investment interests and really try to.think outside the box about how many.different ways somebody could have a.have a.a financial interest here but you know.ask the employee and and and get a get a.get a handle on that obviously if it's.something like a stock ownership we.would handle that as we live with any.securities which is you know as long as.it's not a prohibited of holding.according to any supplemental regs.you would just simply decide whether or.not the employee was likely to work on a.matter that could directly and.particularly affect Ag credit and if so.you know whether or not it would fall.with them one of the de minimis.exemptions because if it's stock again.one of the reasons we need to know what.it is is because we may have some.exemptions that will help remediate.whatever the conflict is but but if it's.employment then we have to take a little.bit closer look at it because if it's.outside employment a there's a.difference 208 analysis we would be.doing it particularly if it's strictly.employment and B we still need to know.if it's an employment interest are there.other attendant financial interests.besides just salary and continued.employment and this is such a common.instance of underreporting yes where an.employee will report these are her.spouses employer and neglect to report.any attendant benefits such as.retirement retire on defined.contribution plans like a 401k or.something similar so anytime I see this.I always immediately ask you know does.your spouse have retirement or similar.benefits that need to go on the form a.lot that you neglected to to indicate.there and likewise if we found out that.this was not an employment interest of.the spouses that it was an equity.interest of some kind a good following.question B does your spouse have an.employer right because that's also.something that's chronically.underreported and again our goal here is.to provide his complete advice as.possible okay so the the more complete.our information the more complete our.advice can be exactly so you know once.we have a better and clearer picture of.what the of what the employer of the.employees spouses interest is in this.then we can actually do a conflicts.analysis and and again if it's something.if it's if it's an equity interest like.stock or if it's a retirement plan again.if it's a retirement plan if it's like a.401k your.need to know what's in it and they'll.have to disclose all the underlying.Holdings because that's where you're.gonna do your complex analysis excuse me.is in is looking at whatever the.underlying holdings of a retirement plan.would be likewise if they have some sort.of investment account with them with the.organization you would need to know.what's what the investments are in that.portfolio or in that account and you.would be doing your conflicts of.interest analysis against those discrete.investment portfolio items if it's only.outside employment I mentioned earlier.that if it's only outside employment.which is to say that the spouse works.there but the spouse doesn't have any.stock that's related to it and doesn't.have any other financial tie to the bank.other than as an employer that it's they.get a salary and and continued.employment again in the cut in the.financials closure reviewers guide we.talked about this but whenever you have.an employment relationship where there.is no attendant ownership interest the.2:08 conflict of interest analysis is.not quite as direct this is just for the.spouse this is just well this is just.for the spouse yes so if the spouse has.mere employment yes and nothing else yes.this is our analysis exactly so if the.file what the analysis for 208 when all.you have is a salary or continued.employment interest is is there anything.that Elizabeth Cornwell could do as a.loan officer that would so effect.Oklahoma AG credit that would it if it.that it would affect either her.husband's her spouse's salary or it.would affect his continued employment so.it has to more directly affect either.the spouses salary or the spouses.continued employment in order for there.to be to a wit conflict of interest.basically that's how we define the.spouses financial interest we say the.spouse has a financial interest in his.or her continued employment and his or.her level of compensation if we could.affect any of those things that would be.violative of 208 yes because those.interest then would beach would be.treated as if they were Elizabeth's own.interests exactly now but don't forget.the fact that we also have impartiality.considerations now under the.impartiality considerations Elizabeth.has a covered relationship with.Oklahoma AG credit so that means she.can't work on any like matters like a.job like a like a loan application if.Oklahoma AG credit is somehow a party to.that so you know this would obviously.very much have to depend on the facts of.the of the particular situation in any.case this is going to be an arrangement.that we're gonna want to manage.something.yes exactly regardless of whether or not.there's a financial interest if.Elizabeth was assigned to work on an.application that involve or affected and.credit huh we want to take a look at it.before she is able to proceed and if.possible it's probably best to keep.those matters away from Elizabeth yes.exactly so you know so it's it and it is.a matter of whether or not you know.maybe there are only certain.institutions that the farm loan agency.actually does business with so maybe.this this one is not it has no agreement.with the farm own you know agency to to.underwrite loans but in any event it.would be something you'd have to drill.down into and make sure that if you.thought there was any possibility that.she could bump up against her spouses.employer that would have to be.remediated okay so the next one on the.list is this farmland LP rei t-- mou SC.seems to be a very long title i'm in it.and it also has a ticker symbol FIP and.again the questions were the same what.is it what is the nature of the interest.so it looks like it's a limited.partnership it's got a ticker symbol.it's but also calls itself this rei t--.thing it's kind of confusing that's a.ticker symbol that looks like a stock.and it has two ticker symbol that looks.like a stock so what the heck is this.thing so this is one of those cases.where you absolutely have to look this.up we have a question from John Dudley.okay and I think this is uh this is a.good question okay and it says as the.term spouse is used but not other terms.is it correct that partners in spouse.like relationships and related.situations are not covered.and that's that's a good question John.for the purposes of the conflict of.interest statute.I need correct me if I get this wrong.Cheryl it's my understanding that you.have to be married yes it has to be a.legal spousal relationship in order for.the imputation under 208 and that's.inclusive of anyone who is a spouse.under under state law so that includes.our same gendered spouses right but does.not extend to things like you know.partners or no significant live with or.you know some of these other kinds of.arrangements right though in those cases.we would still be concerned with the.appearance issues yes exactly the.impartiality provisions we would still.be very concerned about irrespective of.whether or not they had a formal spousal.relationship right so for the purpose of.the statute yep marriage is the the key.element offer appearance concerns we're.always going to be concerned uh-huh yes.thank you John yes thank you that was an.excellent question.okay so if you look up farmland partners.prospectus and I've given you the URL.here you will see that they have what.they say their offerings are they say.they have offer common stock preferred.stock Depositary Shares warrants and.rights and so that seems sounds to me.like a corporate structure like a.publicly traded company to me yeah it.looks like a publicly traded company.okay so if you look at their debt their.description of themselves they're an.internally managed real estate company.they own and seek to acquire primary.crop front farm land etc throughout.North America they tell you where they.own farmland which is really nice.because they own it in a bunch of.different places Illinois Colorado.Nebraska Arkansas South Carolina.Louisiana Kansas and Mississippi so.they're not in Oklahoma so that you know.that might give us at least a little bit.of ease about whether or not in to what.extent this is going to at least.immediately be a conflict of interest.for our person their principal source of.revenue is rent from tenants that.conduct farming operations on their.farmland so I mean this gives us a nice.profile of what this is the the employee.would not be required to disclose all.this on the form because this is a.publicly traded company so really for.you to find out all this you could.probably go to the.employee and ask them if they know but.it you know you it's just as easy for.you to go pull up the ticker symbol look.it up and find its prospectus and this.kind of lays it out for you fairly.clearly what what you're dealing with.right now yeah I think the question I'd.have immediately for the employee is you.know do you own the publicly traded.shares of this company is that the way.that you have an ownership interest.mm-hmm can you click on that yeah now.what's ooh what's with this rei t--.thing that that the file are listed on.the on the form and I have to say when I.looked at this top because this is an.actual obviously this is an actual.entity when I looked up their website.they described themselves as being.something like an REI T but an REI T it.is typically we typically see them they.look different than than a corporation.they usually are a portfolio of real.estate holdings they're publicly traded.but they're more kind of like mutual.funds because they're like a fund of it.so in the financial schools reviewers.guide we have a description of REI T's.in there and it's based upon what our.common experience of them has been and.when I looked further at FBI I found.that while they're structured as a.corporation the corporation basically.owns a general partnership and then in.addition to that they said that for tax.purposes they were taxed as an REI T so.I don't know what all of that means for.purposes of tax or even for purposes of.any other thing what I do know is you.just need to concentrate on what is the.nature of the financial interests that.this employee can have in this entity.and it appears that the financial.interests that this employee would have.in this entity would likely be through.common stock right and because we have a.ticker symbol it's gonna be publicly.traded common stock so if we're looking.for an exemption we would look in the.area of exemptions for publicly traded.securities right if I something like the.mutual fund exemption exactly exactly.but it's useful for us to know where.they're doing business because we can I.can certainly inves.there being a potential conflict of.interest if they were to move into the.Oklahoma area and start buying up.properties in the Oklahoma area I could.see that being a potential for conflict.so so anyway the lesson in all of that.folks is you need to drill down into.this sometimes and you need to go.independently and look for information.because sometimes you'll get these mixed.messages from things like websites and.it's not until you actually go to see.formally what they have to file and you.see how they describe themselves for.those purposes that you can kind of you.know get down to the bottom of what.you're looking at and I think it always.comes back to those two questions do I.have enough information to say I don't.need to worry about this or enough.information it's definitely concerned.and if we're somewhere in the middle.well we don't know what this thing is so.we can't determine one way or the other.we're always going to need more.information right so in this case we're.we just need to find out what is it that.this person really holds right and.through what mechanism might that pose a.conflict if at all right right exactly.um so our next entry is Mutual Financial.Services fund and again they give us a.ticker symbol which is always really.nice when you get the ticker then you.can pull that up and then it's.unambiguous hopefully but the question.is once there anytime you see a find.it's like okay is it a diversified.mutual fund is it a sector mutual fund.is it an exchange-traded fund or is it.some other kind of animal and then once.you figure out what it is then you get.to decide whether or not there are any.ethics concerns so we did though we did.the heavy lifting for you here and we we.looked up the ticker symbol and and we.found it and it gives us a description.which is says the investment seeks.capital appreciation which may.occasionally be short-term the fund.invests at least eighty percent of its.net assets and securities of financial.services companies that invest that if.the investment manager believes are.available at market prices etc etc it.looks like it looks like it's a it's a.sector fund right because it has a.stated policy of investing in one sector.within the economy so yes I would judge.this to be a sector fund yes.but if you have any questions about it.again you can dig further and if you.look at the bottom of the paragraph.where the description is listed you'll.see it says fund filings.and if you go to that page and you click.on that it pulls up a page which where.you can access the prospectus and you.know when you look at the prospectus the.prospectus provides you with language.that's a little less which is a little.less ambiguous is even more kind of.dead-on with respect to what we would.look for to decide whether or not this.was a diversified mutual fund as opposed.to a sector fund and it basically says.the fund concentrates its investments in.companies operating in the financial.services industry which means the fund.is less diversified than a fund.investing in a broader range of.industries the language in 2640 about.what makes something diversified is.whether there's no stated policy of.concentrating investments here we have.is a policy of concentrating investments.exactly so we know dead-on that this is.a sector mutual fund so then we have to.look at it from a conflict standpoint.and you know quite often you know it.could be that that this would be.absolutely dead on a potential problem.for anybody who's engaging in providing.loans you know any government employee.who's engaged in in in approving loans.and who's engaged in in dealing with the.financial services sector there is the.de minimis exemption for sector mutual.funds unless unless your agency has a.prohibitive Holdings restriction and.you're prohibited Holdings restriction.would trump our sector mutual fund.exemptions so what we've learned here is.it's not a diversified mutual fund so.that massive mechanism of not worrying.about it is unavailable to us so now we.have to determine affirmatively either.this poses a potential conflict and we.have relief through an exemption or.maybe we can make a determination that.this actually isn't it concern given the.situation of Elizabeth right but we have.to answer both of those questions yes.yes we do.okay so our final thing on part one is.this thing called USAG and again we'll.is it is it a is it a fund is it and if.it is what kind of fund is it and what.are our ethics concerns um we provided.you with the fact sheet for us AG.because I think it's an interesting.example of where you could start looking.at something and think you're looking at.one thing but actually be looking at.something categorically different this.is where I think you have to be really.careful about reading the bottom line.and reading the the you know the small.print it says it's an agricultural index.fund and whenever I think index fund my.inclination shorthand which is always.the wrong thing to do is to jump to the.conclusion oh it's an index fund oh it's.probably a diversified mutual fund I'm.like that was true ten years ago yes and.I'm absolutely wrong and I would be.absolutely wrong first this is an.exchange-traded product so and then they.are very careful to say product and they.don't say fund notice they avoid the the.use of in the you know actual.explanation of what it is they say it's.a product and that should always raise.some concern because it suggests that.maybe the thing you're looking at isn't.a fund or a fund equivalent right and.it's following the performance of this.other index return okay and it talks.about it's designed to be a way for.investors to access the returns of a.portfolio of agricultural commodities.futures contracts so we're not in the.SEC world here no we're not in the SEC.world commodities futures trading.commission world yes.so the minute you see anything that.talks about commodities or commodities.futures you should almost just decide.right there and then you're probably not.dealing with a mutual fund so we're not.going to have available our sector.mutual fund exemptions who are we going.to have diversify their bond exemptions.of.because frankly this thing isn't a fund.it's not a fund it is not a fund and.they even tell you so so if you get to.the bottom of this little fact sheet.well first of all the one nice thing.about it is it gives you a more.portfolio of it like typically what.they're what futures contracts they're.invested in so if you for example do.work in an area of the department of.farming or USDA where it is material.consideration to conflicts that you know.that you understand what types of.commodities are likely to be affected or.that are involved in this in this.portfolio they give you a nice break out.of the portfolio but the most important.thing they do at the end is tell you.explicitly USAG is not a mutual fund or.any other type of investment or other.type of investment company within the.meaning of the investment company Act of.1940 and how is it that what is the what.is the relevance of the investment.company Act of 1940 Patrick it's.registration under the Act is a.necessary condition for using the.exemptions for mutual funds yes so here.because it's not an investment company.under the Act of 1940 uh-huh we know.that we cannot use those exemptions yeah.so if you can keep that in mind that.that by definition a mutual fund has to.be registered under the Investment.Company Act of 1940 then you know.anytime you see language that suggests.that something either is you'll know.you're a mutual fund land but if it says.that it's not you know you are not.dealing with a mutual fund and you're.not going to be able to avail yourself.of those exemptions that's very nice of.them to tell us that it is very nice.work a little harder to figure that out.yes yes okay and so just for you just.for your your your welfare as well I did.find these two commodity funds site that.they basically are listings of commodity.funds so if you have it if you if you.run across something and you're not.quite sure here at least two websites.you can go to that list.a lot of it may be it may not be.entirely comprehensive but I think there.were fairly comprehensive list of.commodity funds with a place to start.it's a place to start yes exactly.okay so we're done with part 1 now.though actually I want to go back to the.to the to this one first again what what.you need to do to make sure I mean and I.don't I don't want to shortchange the.analysis here again once you've decided.and figured out what it is you do still.have to do the conflicts analysis so I.don't want to say that well it because.it's not a mutual fund you can't use the.exemption so this is gonna be a problem.you still have to determine that it is a.problem it's just that if you determine.that it is a potential conflict you just.don't have the same tools to work with.to remediate it that you would if it.were actually in so your options are.basically recusal or divestiture.right ok so now like we move on to part.2 and on part 2 elizabeth is listed Farm.Credit of Central Oklahoma and it looks.like they have an equity line of credit.from Farm Credit of Central Oklahoma.it's a line of credit the quote one of.the big questions I have is hmm this is.listed on this form but if you look at.the directions for liabilities it may.not be an actual reportable liability.because we exempt from reporting.requirements those liabilities offered.on a looked on terms generally available.to the public from a financial.institution yes so what would you jump.to any conclusions with this Patrick or.how would you what would you do in this.situation for the fact that it's been.reported I think need to be at least.have to consider it it's reportable or.not and also because it's from Farm.Credit of Central Oklahoma and we're in.the business of issuing farm loans in.concert with financial institutions to.people in the farming industry right I.may have some questions yes yes indeed.so I think we first of all we want we.want to satisfy ourselves that this was.in fact reportable or not reportable.which is to say was this on terms that.are available to the general public or.was this sort of a sweetheart loan and.maybe not even in a malign kind of way.but just that for whatever reason they.were long-standing relationship with.with the with this particular.lender and you know familial ties or who.knows what and so they were given a line.of credit on or more favorable terms I.mean we just have to ascertain first of.all what why this is reported and.whether or not it's there's anything.there that that we need to be concerned.by but also I think that you know that.whenever you're engaged in in financial.transactions or in you know whether you.regulate financial institutions or.you're responsible for initiating loans.or whatever where you are heavily.engaged in the financial services.industry loans and liabilities can be.problematic for your employees in the.way that they're not for let's say.somebody who works at oh gee right.exactly because Elizabeth could have.direct interaction with these people or.is it for duties which could raise some.appearance concerns she may have the.capacity in her role to affect the.continued willingness of this.organization to extend credit to her or.her business or whoever the recipient of.the crane is there there may be some.possibility for concern that maybe.wouldn't be existent with people in.other lines of work right and I want to.point out something which I thought was.really interesting because in preparing.this this presentation I was trying to.look at some other people's supplemental.rags like organizations that that do are.involved with financial institutions and.services and I noticed that CFPB.actually has a supplemental regulation.where they prohibit acceptance of credit.on preferential terms from an entity.that is supervised by the bureau so this.notion of that there could be some sort.of preferential type of thing is not is.obviously not purely hypothetical I know.this is a real concern I mean so much so.that at CFPB how it actually has it put.as part of their supplemental regulation.so you know I do think that that I guess.the the learning point here is don't.blow off the liability section simply.because by regulation we have made very.little reportable right you know that.anything that's coming from a financial.institution and I think this is another.area where when you think about the.breadth of employees that have to come.the 450s the reporting requirements make.a lot of sense.you know if you're a contracting officer.or you know someone engaged in Purchase.card work liabilities from banks are.very unlikely to pose problems for you.right it's in these minority of cases.where someone's involved in the banking.industry or an extending credit or.making decisions about the extension of.credit or the supervising of financial.institutions where they pose potential.concerns so this would be an area where.you might want to ask this question or.indeed some agencies might have.supplemental instructions for the form.that require disclosure of liabilities.so that we can get to those issues.exactly um in the interest of time.because we're bumping up against three.o'clock here we're gonna move on to part.three the first thing is the Cornwell.organics which we we did discuss as part.of part one but again if you if you.didn't have the part one disclosure.whenever you see something where there's.a business you're gonna want to know.you're going to want to check part one.and make sure that any investment or.earned income or other types of entries.are on part one again we want to know.what type of position the employee holds.with this organization because depending.upon the nature of their activities with.the organization they be may be more or.less likely to not only have 208.concerns but also other representational.concerns and restrictions we if there's.prior approval required that obviously.is a flag to make sure that they.actually got prior approval I don't want.to belabor this because we did talk a.lot about this with respect to what we.saw in part one did you have anything.that you wanted to add a pattern no just.that I would I would start with looking.for the prior approval for the outside.activity right possible to be very.advice completely and if we haven't we.know we have to go through that process.and we have a number of courses we have.a whole MOOC dedicated to doing that.analysis right if you don't know how to.do it I'd encourage you to take a look.at that yes and then the second thing.that's on the form is this Oklahoma.small business development and the.employee.it's a mentoring organization and the.employee appears to be a volunteer now.this probably technically doesn't have.to be a reported Patrick right right.because they're a volunteer which.probably doesn't raise to the.of position right however since they.provided this information where we have.concerns we should address them.yeah and I think the other thing too.with volunteer that just means you're.not compensated so I also would want to.look into what services are they.providing to the organization because if.they're providing personal services to.the organization other than like you.know you know filling envelopes and.doing you know ministerial stuff if they.are really providing like consulting.services or something like that to the.organization then just because they're.not paid for it I would not be inclined.to say that that wouldn't be something.I'd encourage people to disclose right.you know some of the things we look at.are you know whether the organization.make sure its control over the employee.and their capacity as a volunteer so if.they're being directed and if they have.a fiduciary responsibility of the.organization's certainly then we have a.concern so you're right the compensation.isn't as positive and again I agree with.Patrick if there's prior approval.required and this is one of the beauties.of requiring prior approval and if this.is the type of activity that would fall.within that's and that you know that's.kind of the avenue to go make sure it's.already been approved if it hasn't been.approved then you go through that whole.process which is a much more rigorous.process but just as kind of a quick and.dirty or in terms of this one I based.this entry on something that I found.with one of the usda's of the Farm.Service Agency where it appeared that.they have certain relationships with.mentoring organizations to help like.small farmers who are trying to open a.business that can give them some.mentoring skills on how you operate a.small business so this this type of.service is actually something that could.might very well be part of the services.that are provided by the government and.you know if you have an employee who is.engaging on the side in doing it for.another entity you are doing it you know.like even particularly if they're doing.it for compensation there may be some.relatedness things to the job that.they're doing or you may not want them.to be in the business of trying to you.know counsel their own clients on you.know attending this particular mentoring.service as opposed to you know.attending another yeah so you know it's.something we just want to go through the.process for the outside activity review.right yeah that makes a lot of sense.okay so they haven't reported anything.on parts four and five and I just.strongly encourage you that even though.they're left blank to go back to the.file read and confirm that there aren't.any reportable agreements arrangements.or gifts and I think particularly if you.have anything on the form that would.lead you to believe that there could be.a possibility of either of those things.but in any event just out of a set you.know the sake of being complete I would.always just confirm that eat that there.was nothing to report on parts four and.five excellent and that brings us right.to the top of the hour so we were.successful at getting through the.exercise within the time all right up.for a question or two yeah sure I guess.we have something on the phone and again.if those folks on the Hangout have any.questions you can put those in the lower.right hand corner of the screen and.while we wait for the first question to.come in it's a good idea to remind folks.that this presentation like all of our.presentations will be available.immediately after the end of the.broadcast on the YouTube channel which.is youtube.com slash oh gee Institute so.if you want to go back and listen to.something you can do that uh if you have.to take off right now and don't have.time to hang on for the questions you.can come back and find those two and.Patrick we're really gonna house that in.the milk section correct that's right.yeah so we'll be adding this to the 450.MOOC okay I don't show any questions on.the Hangout isn't actually we do it we.have a question that's come in on the.Hangout ah so the question is Cheryl if.we know the filer is married but has.more to know on everything can we assume.that that's correct or follow up that's.a good question that's an excellent.question um my my advice would be that.you always follow up if you know that.the.has a spouse there is every possibility.that there's some sort of spousal.employment at the very least so I would.always go back and confirm that there's.nothing to report on the form and I.think you know this is a case where good.notes can help so if I saw this on a new.entrant report I would absolutely every.time follow up to make sure that the.employee understood yes if we had it.back and forth and we had clearly.communicated to the employee that any.spousal employment would certainly be.reportable I knew have confidence in.that discussion and the employees.ability to understand that information.any in subsequent years I'd be less.concerned certainly the first time that.would be a concern yeah but yeah I think.that's a good question mm-hmm one thing.I did want to let people know too and I.don't mean to admit be heavy-handed with.this because and I always tried a little.lightly when we're talking about.enforcement type of things but one thing.that you do need to know and it would be.useful to look at the prosecution's.survey that we put out every year is.that 1001 violations 18 USC 1001.violations which is kind of like a.falsification is it isn't is a tool of.choice for the Department of Justice.when they have found some sort of.misconduct by someone and they maybe.can't prove all of the elements of.another violation but the person was a.filer and they failed to disclose on the.report something that was material to.whatever the the the misconduct was and.they'll go after them one Oh 1001 so I.always like to let filers know you know.you do run a risk if you fail to.willfully fail to disclose information.on your form because you are subject to.criminal penalties for a willful you.know falsification I think this is an.area where employees should understand.this that there are benefits to filing.both on the enforcement side and also on.the prevention side yes absolutely we.can't help you manage conflicts that we.can't identify right so the more.completely information that we as ethics.officials receive the more complete our.advice can be so that's one area where.an employee receives a benefit from.filing and also if they willfully failed.to disclose they incur liability.personally so there are lots of good.reasons for completing these reports and.yes the Lord do we have any questions on.the phone.welcome Sheila okay could you repeat.highway can receive information get how.you can receive the information yeah.with which information oh you'd be like.enough to find out where you can watch.the broadcast again sure uh the the URL.is youtube.com slash OGE.institute there will also be a link to.the presentation from the max page where.you registered so if you have bookmarked.the max registration page you can find.the link there you can also find an.index of all of the previous courses on.max and that is searchable and sortable.by topic as well as the title of the.presentation of the series it belongs to.so if you're looking for prior.broadcasts that's a good place to start.well and the max.gov site where you.registered that's where all of the.materials are as well so the slide deck.is there and all of the materials that.we cover today are there and after the.broadcast a direct link to the youtube.channel will be there as well so you'll.have the whole package right there on.the max gov site where you registered.and I'm showing none on the Hangout so.thank you all very much for joining us.everything sure for being here.absolutely and we look forward to seeing.you next week for the advanced.practitioner search yes and good luck.with your 450s yes enjoy 450 season.

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How to create an electronic signature for the Oge 450 Fillable Form in Chrome

Chrome has been more and more popular as a convenient browser due to its comprehensive features, useful tools, and extensions. In this way, you can keep all your tools on your home screen in front of you. You just need to choose the form that fulfill your need without searching for it in a long time.

Using this useful extension feature offered by Chrome, you can add CocoSign extension to your browser and use it whenever you need to write eSignatures in your documents. With CocoSign extension, you will also get other features like merge PDFs, add multiple eSignatures, share your document, etc.

Here are the basic key elements you need to follow:

  1. Note the CocoSign extension on Chrome Webstore and choose the option 'Add'.
  2. Log in to your account if registered before, otherwise choose signup and register with us.
  3. On your Oge 450 Fillable Form, right-click on it and go to open with option. From there, choose CocoSign reader to open the document.
  4. Choose 'My Signature' and write your own signatures.
  5. Place it on the page where you require it.
  6. Choose 'Done'.
  7. Once you are done, save it. You can also fax it with other people.

How to create an electronic signature for the Oge 450 Fillable Form in Gmail?

Mailing documents is so useful that majority of businesses have gone paperless. Therefore, it will be a great selection if one can esign form online from Gmail in a straight line. You can do it by adding a CocoSign extension on your Chrome. Here is what you need to do:

  1. Add the CocoSign extension to your browser from the Chrome Webstore.
  2. Log in to your pre-registered account or quickly 'Sign up'.
  3. Open the email with the document you need to sign.
  4. From the sidebar, choose 'Sign'.
  5. Draw your electronic signatures.
  6. Generate them in the document where you need to.
  7. Choose 'Done'.

The signed file is in the draft folder. You can easily share it to your required mailing address.

Working with electronic signatures in Gmail is such a quick and cheap tool. It is specifically designed for people who work from anywhere. By CocoSign, and you will surely be among our hundreds of happy users.

How to create an e-signature for the Oge 450 Fillable Form straight from your smartphone?

mobiles are the most useful electronic devices used nowadays. You must be interested in using e-signature from this most used electronic device.

What's more, with eSignature capability on your mobile phone, you can e-sign your document anytime, anywhere, away from your laptop or desktop. You can work with CocoSign electronic signature on your mobile phones by following these key elements:

  1. Direct to the CocoSign website from your mobile browser. Login to your CocoSign account or sign up with us if you don't have registered before.
  2. Click the document you need to e-sign from your mobile folder.
  3. Open the document and choose the page where you want to put the electronic signatures.
  4. Choose 'My Signatures'.
  5. Write your electronic signature and insert it to the page.
  6. Choose 'Done'.
  7. Print the document or directly share through email.

That's it. You will be done signing your Oge 450 Fillable Form on your mobile phones within minutes. With CocoSign's remote signature tool, you no longer need to worry about the usage of your electronic signatures and use our app of your choice.

How to create an e-signature for the Oge 450 Fillable Form on iOS?

Many apps have a more complex setup when you start using them on an iOS device like the iPhone or iPad. However, you can esign form online safely with CocoSign, either using the iOS or Android operating system.

Below instructions will help you to e-sign your Oge 450 Fillable Form from your iPad or iPhone:

  1. Add the CocoSign app on your iOS device.
  2. Write your CocoSign account or login if you have a previous one.
  3. You can also sign in through Google and Facebook.
  4. From your internal storage, click the document you need to e-sign.
  5. Open the document and choose the space you want to place your signatures.
  6. Write your electronic signatures and save them in your desired folder.
  7. Save the changes and send your Oge 450 Fillable Form.
  8. You can also share it to other people or upload it to the cloud for future use.

Select CocoSign electronic signature solutions and enjoy effectively working on your iOS devices.

How to create an electronic signature for the Oge 450 Fillable Form on Android?

These days, Android gadgets are commonly used. Therefore, to assist its customers, CocoSign has developed the app for Android users. You can use the following intstructions to e-sign your Oge 450 Fillable Form from Android:

  1. Add the CocoSign app from Google Play Store.
  2. Login to your CocoSign account from your device or signup if you have not been pre-registered.
  3. Choose on the '+' option and add the document in which you want to place your electronic signatures.
  4. Select the area you want to put your signatures.
  5. Generate your e-signature in another pop-up window.
  6. Place it on the page and choose '✓'.
  7. Save changes and send the file.
  8. You can also share this signed Oge 450 Fillable Form with other people or upload it on the cloud.

CocoSign helps you to write lots of electronic signatures at anytime. Connect with us now to automate your document signing.

Oge 450 Fillable Form FAQs

Note answers to questions about Oge 450 Fillable Form. View the most useful topics and more.

Need help? Contact support

I'm trying to fill out a free fillable tax form. It won't let me click "done with this form" or "efile" which?

It’s can be aggravating! Like Gevin mentioned the “done with this form” button is disabled for form 1040 ONLY. To continue, you have to click the step 2 tab to the right of step 1 . The tab says “E File your tax forms”

How do I make a PDF a fillable form?

How to create fillable PDF files: Open Acrobat: Click on the “Tools” tab and select “Prepare Form.” Select a file or scan a document: Acrobat will automatically analyze your document and add form fields. Add new form fields: Use the top toolbar and adjust the layout using tools in the right pane. Save your fillable PDF:

Is there a service that will allow me to create a fillable form on a webpage, and then  email a PDF copy of each form filled out?

Many times while browsing the internet we feel like reading full article,due to many constraints like time, we fail to read so its better get convert the website,article or the facts to PDF file. Usually we use Google Chrome ,for browsing the web.Its most used Web-browser in the world.While you browsing the web using Google Chrome its easy to save the website or article as PDF. Read Full Article on How to convert any web-page as PDF without any software?

Do military members have to pay any fee for leave or fiancee forms?

First off there are no fees for leaves or requests for leave in any branch of the United States military. Second there is no such thing as a fiancée form in the U.S. military. There is however a form for applying for a fiancée visa (K-1 Visa)that is available from the Immigration and Customs Service (Fiancé(e) Visas ) which would be processed by the U.S. State Department at a U.S. Consulate or Embassy overseas. However these fiancée visas are for foreigners wishing to enter the United States for the purpose of marriage and are valid for 90 days. They have nothing to do with the military and are Continue Reading

How do I transfer data from Google Sheets cells to a PDF fillable form?

I am not sure I totally understand the question. Do you need a pdf of one page for every row in your spreadsheet? For this you might have to use Google app script

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