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OGE Form 450 Review Exercise.Operator: (Audio starts mid-sentence) asking.a question. Oh, now I can turn that call over.to your first speaker today. Mr. Patrick Shepherd,.you may begin..Patrick Shepherd: All right, thanks very much,.Lori. Good afternoon, and welcome to the Ethics.Fundamental Series. My name is Patrick Shepherd..I'm pleased to be joined today by Cheryl Kane-Piasecki..Welcome, Cheryl..Cheryl Kane-Piasecki: Thanks very much, Patrick..Patrick Shepherd: What are we going to be.talking about today?.Cheryl Kane-Piasecki: 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 a 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 we're as you know, what we're planning.to do is to continue to build a library of.exercises that will be attendant to that MOOC.so that when folks watch it, we'll just continually.provide new opportunities to engage in some.sort of application-based learning..Patrick Shepherd: Excellent. And this is very.timely, because as we know, the deadline for.filing 450s is coming up in just a few days..Cheryl Kane-Piasecki: Yes, it is..Patrick Shepherd: So, hopefully this will.serve as a reminder or a refresher for those.of you who haven't looked at a 450 in a while..We'd 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..Cheryl Kane-Piasecki: Very quickly..Patrick Shepherd: 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,.D.C., do not fret a lot of the information.and the sessions will be available on our.YouTube channel, which is youtube.com/ogeinstitute..So Cheryl, should we pull up the slide deck?.Cheryl Kane-Piasecki: That would be wonderful,.and we can get started..Patrick Shepherd: Excellent..Cheryl Kane-Piasecki: For those of you who.I'm hoping those of you who are new to 450.review, had an opportunity to view the first.part of the MOOC, because in that I actually.walked you through the form itself and gave.you some some pointers as to what is required.to be reported, and some 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 a context.of of a mock 450..Patrick Shepherd: Excellent. So, we're assuming.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..Cheryl Kane-Piasecki: Exactly, exactly. So,.one thing I do want to do a little bit of.before we actually get started in the in debriefing.the 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 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.Patrick Shepherd: Right..Cheryl Kane-Piasecki: before we begin the.review. And clearly the the the the priority.for a 450 review is a is your substantive.review..Patrick Shepherd: 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?.Cheryl Kane-Piasecki: Exactly. So, one of.the primary things that we are looking for.with 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 U.S.C. § 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 going.to have to know what your employee does. So,.whether you get a position description, whether.you 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..Patrick Shepherd: And I think programmatically,.this is a an 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 OGE,.is because it puts you in a position to find.out and understand the work of your employees..Cheryl Kane-Piasecki: 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 interests does 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, they're 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.discloses, you need to have sufficient understanding.of what that thing is in order to be able.to do a robust conflicts 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 to.cause 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..Patrick Shepherd: 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 a conflict..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: Or that b) 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 enough.information to make one of those determinations,.I know I need more information..Cheryl Kane-Piasecki: Yes. That's and that's.a very nice way of of putting it, Patrick..That's a really nice 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.filer is 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 like to remind people; document, document,.document. So, we really strongly encourage.you to have reviewer's notes, when you're.asking questions of 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 determination, 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.the overall analysis was..Patrick Shepherd: 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.for advice, the outcome, the work product.that we should be producing, should be ethics.advice..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: And certainly any 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.Cheryl Kane-Piasecki: Right..Patrick Shepherd: so they understand the purpose.of the program, and receive the benefits of.the program, indeed..Cheryl Kane-Piasecki: Yeah, and 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 450, the.people who file the 450, 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 person who submitted.it, that there was a point to them having.submitted this information..Patrick Shepherd: Exactly..Cheryl Kane-Piasecki: 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 MAX. 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 are 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 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..We're 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 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 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 neither.our employees nor our spouses their spouses.or 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 then 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..Patrick Shepherd: So, in this case, the employee.is making the approve/disapprove recommendation..Cheryl Kane-Piasecki: Right..Patrick Shepherd: But we would have equal.concerns if they were a part of an advice-giving.process or something like that. The important.thing here is the employee's participating.in the substantive decision to issue the loan..Cheryl Kane-Piasecki: 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.Patrick Shepherd: Okay..Cheryl Kane-Piasecki: of a final decision..Patrick Shepherd: That's probably why Elizabeth.has to file..Cheryl Kane-Piasecki: That's why she's a confidential.filer..Okay. So, what I want what I want to encourage.you all to do, and maybe you do do this, but.I but I know that that when I review public.financial disclosure forms here, and when.we teach people within our GE 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 the.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 are 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.Patrick Shepherd: So, we might imagine the.kinds of entries that, if we were to see them.on the form, might give us pause..Cheryl Kane-Piasecki: Exactly..Patrick Shepherd: So that we are looking for.something, we're not just looking at the form..Cheryl Kane-Piasecki: 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 that could fall within each of these.broad categories. So clearly, we're 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..Patrick Shepherd: Right..Cheryl Kane-Piasecki: So, then you look at.investment interest; what kinds of investment.interest. Well, it could be a stock in a or.it could be a mutual fund that contains these.things, there 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.as on a board of directors, or a president,.or anything that's associated with a financial.institution..And then also we have to be thinking about.liabilities; do the 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 on 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 to 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 disclosable on.the form..Patrick Shepherd: Right. Some sometimes, you.know, the form is a balancing act. You know,.we try and collect just enough information.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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 problem.Cheryl Kane-Piasecki: Right..Patrick Shepherd: that requires 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 just kind of keep the broader.view in mind..Cheryl Kane-Piasecki: Yes. Exactly, exactly..There are 300,000, you know, plus confidential.filers in the government, and any regulation.that OGE would have hoped to have written.to require disclose was never going to be.a one size fits everybody, so..So so the other things, obviously, that's.sort of is an obvious thing would be any farming.or agriculture interests, because we are the.Department of Farming, and these are farmer.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 fund sorry, there should be a comma.between those two commodities futures. So,.if you've got somebody who is who is invested.in commodities..Partnerships, REITs, 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,.people own the farm, but they lease the farm.for somebody else to manage. And also like.crops and livestock..So, these are all sorts of things that that.you're going to want to you'd be prepared.to possibly see on the form..Patrick Shepherd: Right..Cheryl Kane-Piasecki: 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-backed 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.are you receiving any government subsidies,.are you 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?.Patrick Shepherd: And these are also questions.that you can ask in the context of a matter..Cheryl Kane-Piasecki: Right..Patrick Shepherd: So you could ask those in.the context of your annual review of the confidential.financial disclosure 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 a family member.or friend that she ought to seek advice before.participating..Cheryl Kane-Piasecki: Exactly..Patrick Shepherd: So, this fits into our our.sort of whole ethics program.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: because the pieces have.to work together..Cheryl Kane-Piasecki: Yes, that they're not.they're not unrelated to one another..Patrick Shepherd: Right..Cheryl Kane-Piasecki: And then finally again,.additional liabilities..So, if we look at our confidential financial.disclosure report, we we notice that she's.filled out everything and it appears to be.correctly. I 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 60 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.I, II and III, and she doesn't have anything.on IV and V. And then she's signed it, she's.dated it. It looks like she'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.going to 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 I,.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 I, 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 AgCredit;.that's a spousal thing. She's got Farmland.LP REIT 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, is 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 III,.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 an insight.before we ever get to Part I about what it.is we're looking at there, and that'll 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 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?.Patrick Shepherd: Okay..Cheryl Kane-Piasecki: So, let's look at the.first one, which is Cornwell Organics. We.know that she is a co-owner, and we know that.it's a farm. So, you've 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?.Patrick Shepherd: I think we're going to need.some more information here..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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 this poses a.potential conflict, or it will definitely.not pose a conflict. So, we're going to have.to ask some questions..Cheryl Kane-Piasecki: Yeah, we are going to.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.how the business is structured. And we gave.you the OGE 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 farm a sole proprietorship?.Because if it's a sole proprietorship, then.that basically means that the farm and the.employee are kind of co-extensive; they are.one in the same thing..Patrick Shepherd: Right..Cheryl Kane-Piasecki: Okay? So, then anything.that can affect the farm is going to be deemed.to affect our employee..Is it a partnership? Is it a general partnership?.Because if it's if it's founded as a general.partnership, then our employee's going to.have a financial interest, not only in the.partnership itself, but in what else?.Patrick Shepherd: Also, in the general partner..Cheryl Kane-Piasecki: In the general partners..Patrick Shepherd: The confidential statute.tells us that to the financial interest, and.that's the personal financial interest of.the general partner, or imputed to us.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: as their general partner,.or as their partner..Cheryl Kane-Piasecki: 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, that there's a.great likelihood that our employee is going.to know what the financial interests of the.other general partners are..Patrick Shepherd: Absolutely, it could be.a you know, it could be a family relation,.or a, you know a close friend, or someone.that they grew up with..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: But that's probably a fairly.close business relationship..Cheryl Kane-Piasecki: And it's going to 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 partners..Patrick Shepherd: In the general partners..Cheryl Kane-Piasecki: Now, there are some.limited exemptions in 2640 for the general.partner interests, and that's not the partnership.itself, that's the general partners' interests..Patrick Shepherd: That's right..Cheryl Kane-Piasecki: But it it is a limited.exemption. But again, if you know that that's.what you're dealing with, then you know you're.going to 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 stock..Patrick Shepherd: Right. And there's all sorts.of mechanisms by which you can have an ownership.interest in a corporation..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: And I guess my follow-on.question would be by what mechanism do you.have that ownership interest..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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 2640.exemptions..But again, until we know.Cheryl Kane-Piasecki: Right..Patrick Shepherd: we don't know..Cheryl Kane-Piasecki: 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 interest, so that's.why I I 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..Patrick Shepherd: So, if you're 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 of those questions.and figure them out so that we can apply exemptions.appropriately or do our analysis completely..Cheryl Kane-Piasecki: And we do need to know.what the nature of the business is, what the.line of business is. 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 what the business.line, or what the nature of the business is..Patrick Shepherd: And as I have learned many.times over, many times businesses have names.that are similar to other businesses..Cheryl Kane-Piasecki: Right..Patrick Shepherd: Well, if there's any ambiguity,.make sure you know what what the thing is.that you're looking at..Cheryl Kane-Piasecki: 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?.Are there are there crops, are there is there.livestock? What exactly is the is the farm.engaged in that's 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 of 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..Patrick Shepherd: So, this is an example of.where we're going to have to go, probably.significantly beyond the information that.is technically disclosable on the on the form.Cheryl Kane-Piasecki: Right..Patrick Shepherd: in order to ensure compliance.with the ethics laws and regulations, but.in particular, our supplemental regulation..Cheryl Kane-Piasecki: Exactly, exactly. It's.you know, and 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 in 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 on the form,.clearly if you have an employee who holds.a position with a farm, and they are 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..Patrick Shepherd: Right. So, you know, we.have at least that concern. We want to make.sure that our employee is not representing.the farm before the federal government.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: and we may also have concerns.about misuse of non public information..Cheryl Kane-Piasecki: Right..Patrick Shepherd: We'd probably have to provide.a full outside-activity analysis..Cheryl Kane-Piasecki: Right..Patrick Shepherd: 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.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: because that might be able.to sort of complete the picture for us..Cheryl Kane-Piasecki: Yes, exactly. And that's.all the more reason to have documentation.of things..We got a very funny comment on the Hangout..It says how are you going to keep her down.on the farm after she's seen Perry (phonetic)?.Oh yes, a little humor goes a long way, that's.for sure..And then of course you're going to 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 it were located in.Oklahoma will be different or will go away.altogether..Patrick Shepherd: And perhaps as a remedy,.we could send her to France to work..Cheryl Kane-Piasecki: So, anyway, so so I.do I do recommend to you the Form 450 guidance.document that we sent 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.it and it talks about some of the things that.we mentioned about whether there's it participates.in any federal programs, what the geographic.location is, et cetera, et cetera..So let's so, in the interest of time, let's.keep let's keep moving on here..So, our second interest that is disclosed.is Oklahoma AgCredit. And Oklahoma AgCredit.is is, I think, probably clearly some sort.of financial institution, but we would have.to look it up. And it is, and it's a and 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 it shows us is that.it's the spouse's..Patrick Shepherd: Okay. So, that could be.it could be an equity interest..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: It could be an employment.interest..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: It could be some other kind.of ownership-type interest..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: It could be another source.of income, a non-employment source of income..Cheryl Kane-Piasecki: Yes..Patrick Shepherd: So, we really don't know..Cheryl Kane-Piasecki: We don't..Patrick Shepherd: And I think it's going to.be important for us to find out..Cheryl Kane-Piasecki: 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 handle on that. Obviously, if.it's something like a stock ownership, we.would handle that as we would with any securities,.which is, you know, as long as it's not a.prohibited 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 predictably.affect AgCredit. And if so, you know, whether.or not it would fall within one of the de.minimis exemptions. Because if it's stock,.again, one of the reason we need to know what.it is is because we may have some exemptions.that will help remediate whatever the conflict.is..Patrick Shepherd: Right..Cheryl Kane-Piasecki: But but if it is employment,.then we have to take a little bit closer look.at it, because if it's outside employment,.a) there's a different 208 analysis we would.be doing, particularly if it's strictly employment..Patrick Shepherd: Right..Cheryl Kane-Piasecki: 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?.Patrick Shepherd: And this is such a common.instance of underreporting.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: where an employee will report.his or her spouse's employer, and neglect.to report any attendant benefits such as retirement,.defined contribution plans like a 401(k).Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: or something similar..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: that you neglected to to.indicate there? And likewise, if we found.out that this was not an employment interest.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: of the spouse's, that it.was an equity interest of some kind, a good.following question would be does your spouse.have an employer?.Cheryl Kane-Piasecki: Right..Patrick Shepherd: Because that's also something.that's chronically underreported. And again,.our goal here is to provide as complete advice.as possible..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, the more complete our.information, the more complete our advice.can be..Cheryl Kane-Piasecki: Exactly. So, you know,.once we have a better and clearer picture.of what the of what the employee the employee's.spouse's 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 401(k), you're going.to need to know what's in it. And they'll.have to disclose all the underlying holdings,.because that's where you're going to do your.conflicts 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 with the organization, you would.need to know what 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 if 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 in the financial disclosure.reviewer's guide, we talk about this, but.whenever you have an employment relationship.where there is no attendant ownership interest,.the 208 conflict of interest analysis is not.quite as direct..Patrick Shepherd: And this is just for the.spouse..Cheryl Kane-Piasecki: This is well; this is.just for the spouse, yes..Patrick Shepherd: Yes. So, if the spouse has.mere employment.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: and nothing else.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: this is our analysis..Cheryl Kane-Piasecki: Exactly. So, if the.filer 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 affect Oklahoma AgCredit, 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.spouse's salary, or the spouse's continued.employment in order for there to be a 208.conflict of interest..Patrick Shepherd: Basically, that's how we.define the spouse's financial interest..Cheryl Kane-Piasecki: Right..Patrick Shepherd: We say the spouse has a.financial interest in his or her continued.employment, and his or her level of compensation..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, if we could affect any.of those things that would be violative of.208..Cheryl Kane-Piasecki: Yes, because those interests.then would be would be treated as if they.were Elizabeth's own interests..Patrick Shepherd: Right..Cheryl Kane-Piasecki: 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 AgCredit. So that means she can't.work on any, like, matters like a job like.a like a loan application if Oklahoma AgCredit.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..Patrick Shepherd: But this is in any case,.this is going to be an arrangement that we're.going to want to manage somehow..Cheryl Kane-Piasecki: Yes, exactly..Patrick Shepherd: So, regardless of whether.or not there's a financial interest if Elizabeth.was assigned to work on an application that.involved or effected AgCredit.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: we'd want to take a look.at it before she's able to proceed. And if.possible, it's probably best to keep those.matters away from Elizabeth..Cheryl Kane-Piasecki: Yes, exactly. So, you.know, so it's 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 Loan,.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 spouse's employer.that would have to be remediated..Okay. So, the next one on the list is this.Farmland LP REIT, M-O-U-S-E it seems to be.a very long title and it and it also has a.a a ticker symbol, FIP. And again, the questions.are the same. What is it? What is the nature.of the interest?.So, it it looks like it's a limited partnership..It's got a ticker symbol. It's but also calls.itself this REIT thing. It's kind of confusing..Patrick Shepherd: And that's a ticker symbol.that looks like a stock..Cheryl Kane-Piasecki: And it has a 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..Patrick Shepherd: Actually, we have a question.from John Dudley (phonetic)..Cheryl Kane-Piasecki: Okay..Patrick Shepherd: And I think this is this.is a good question..Cheryl Kane-Piasecki: Okay..Patrick Shepherd: 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..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: For the purposes of the.conflict of interest statute.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: and you can correct me if.I get this wrong, Cheryl..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: It's my understanding that.you have to be married..Cheryl Kane-Piasecki: Yes, it has to be a.a legal spousal relationship in order for.the imputation under 208 to.Patrick Shepherd: And that's inclusive of.anyone who is is is a.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: is a spouse under under.state law..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, that includes same-gendered.spouses..Cheryl Kane-Piasecki: Right..Patrick Shepherd: But does not extend to things.like, you know, partners or.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: you know, a significant.other that you live with, or, you know, some.of these other kinds of arrangements..Cheryl Kane-Piasecki: Right..Patrick Shepherd: Though in those cases we.would still be concerned with the appearance.issues..Cheryl Kane-Piasecki: Yes, exactly. The impartiality.provisions we would still be very concerned.about irrespective of whether or not they.had a formal spousal relationship..Patrick Shepherd: Right. So, for the purpose.of the statute, yeah, marriage is the key.element.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: for appearance concerns,.we're always going to be concerned..Cheryl Kane-Piasecki: Mm-hmm, yes..Patrick Shepherd: But thank you, John..Cheryl Kane-Piasecki: 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 offer common stock, preferred.stock, depositary shares, warrants and rights..And so, that seems sounds to me like a corporate.structure, and what do I.Patrick Shepherd: That looks like a publicly.traded company to me..Cheryl Kane-Piasecki: Yeah, it looks like.a publicly traded company, okay. So, if you.look at their their description of themselves,.they're an internally managed real estate.company. They own and seek to acquire primary.crop farmland, et cetera, 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, and 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 give 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 of this,.you could probably go to the the employee.and ask them if they know, but it you know,.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..Patrick Shepherd: Right. And I yeah, I think.the question I'd have immediately for the.employee is do you own the publicly traded.shares of this company; is that the way that.you have an ownership interest?.Cheryl Kane-Piasecki: Mm-hmm. Can you click.me back on? Okay. Yeah..Now, the so what's with this REIT thing that.that the filer listed on the on the form?.And I have to say, when I looked this up because.this is an actual obviously, this is an actual.entity. When I looked up their website, they.described themselves as being some like an.REIT. But, an REIT is typically we typically.see them and 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 a fund of it..So, in the financial disclosure reviewer's.guide we have a description of REITs in there,.and it's based upon what our common experience.of them has been..Patrick Shepherd: Right..Cheryl Kane-Piasecki: And when I looked further.at FPI, 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 REIT..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 interest that this employee can.have in this entity. And it appears that the.financial interest that this employee would.have in this entity would likely be through.common stock..Patrick Shepherd: Right. And because we have.a ticker symbol, it's going to 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.Cheryl Kane-Piasecki: Right..Patrick Shepherd: to find something like the.mutual fund exemption..Cheryl Kane-Piasecki: Exactly, exactly. But.it's useful for us to know where they're doing.business, because we can I can certainly envision.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 of what you're looking.at..Patrick Shepherd: And I think it always comes.back to those two questions..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: Do I have enough information.to say I don't need to worry about this, or.enough information to say it's definitely.a concern? And if we're somewhere in the middle.where 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..Cheryl Kane-Piasecki: Right..Patrick Shepherd: So, in this case, we're.we just need to find out what is it that this.person really holds.Cheryl Kane-Piasecki: Right..Patrick Shepherd: and through what mechanism.might that pose a conflict, if at all?.Cheryl Kane-Piasecki: Right, right, exactly..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 at any time you.see a fund, 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 the we did the 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 80.percent of its net assets in securities of.financial services companies that invest that.the investment manager believes are available.at market prices, et cetera, et cetera..It looks like it looks like it's a it's a.sector fund, right?.Patrick Shepherd: Because it has the stated.policy of investing in one sector within the.economy. So yes, so I I would judge this to.be a sector fund..Cheryl Kane-Piasecki: 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..Patrick Shepherd: And here we have.Cheryl Kane-Piasecki: It's.Patrick Shepherd: a stated policy of concentrating.investments..Cheryl Kane-Piasecki: 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 a a a potential problem for anybody.who is engaging in providing loans; you know,.any government employee who is engaged in.in in approving loans, and who is engaged.in in dealing with the financial services.sector..There is the de minimis exemption for sector.mutual funds..Patrick Shepherd: Right..Cheryl Kane-Piasecki: Unless unless your agency.has a prohibited-holdings restriction, and.your prohibited-holdings restriction would.trump our sector mutual fund exemptions..Patrick Shepherd: Well, what we've learned.here is it's not a diversified mutual fund,.so that.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: or maybe we can make a determination.that this actually isn't a concern given the.situation of Elizabeth..Cheryl Kane-Piasecki: Right..Patrick Shepherd: But we have to answer both.of those questions..Cheryl Kane-Piasecki: Yes; yes, we do. Okay..So, our final thing on Part I is this thing.called USAG. And again, is it is it is it.a fund? Is it and if it is, what kind of fund.is it, and what are our ethics concerns?.We provided you with the fact sheet for USAG,.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 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..Patrick Shepherd: And that that was true ten.years ago..Cheryl Kane-Piasecki: 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..Patrick Shepherd: And that should always raise.some concern..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: It because it suggests that.maybe the thing you're looking at isn't a.fund or a fund equivalent..Cheryl Kane-Piasecki: 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..Patrick Shepherd: And also, we're not in the.SEC world here..Cheryl Kane-Piasecki: No, we're not in the.SEC world..Patrick Shepherd: We're in the Commodities.Futures Trading Commission world..Cheryl Kane-Piasecki: 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..Patrick Shepherd: So, we're not going to have.available our sector mutual fund exemptions..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: Nor are we going to have.diversified mutual fund exemptions available,.because frankly, this thing isn't a fund..Cheryl Kane-Piasecki: 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 portfolio.of it; like typically what their 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 breakout 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 invest 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?.Patrick Shepherd: It's registration under.the act is a necessary condition for using.the exemptions for mutual funds..Cheryl Kane-Piasecki: Yes..Patrick Shepherd: So here, because it's not.an investment company under the Act of 1940.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: we know that we cannot use.those those de minimis exemptions..Cheryl Kane-Piasecki: Yeah, so if you can.keep that in mind 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 in 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..Patrick Shepherd: That's very nice of them.to tell us that..Cheryl Kane-Piasecki: It is very nice for.them to tell us that..Patrick Shepherd: Sometimes you have to work.a little harder to figure that out..Cheryl Kane-Piasecki: Yes..Patrick Shepherd: Yeah..Cheryl Kane-Piasecki: Yes. Okay. And so just.for your just for your your your welfare as.well, I did find these two commodity fund.sites they they basically are listings of.commodity funds, so if you have if you run.across something and you're not quite sure,.here are at least two websites you can go.to that list a lot of it may not be entirely.comprehensive, but I think it they were a.fairly comprehensive list of commodity funds..Patrick Shepherd: So, it's a place to start..Cheryl Kane-Piasecki: It's a place to start..Yes, exactly. Okay..So, we're done with Part I. 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, because it's not a.mutual fund, you can't use the exemption,.so this is going to 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 a mutual fund..Patrick Shepherd: Right, so your options are.basically recusal or divestiture..Cheryl Kane-Piasecki: Right. Okay. So, now.like we move on to Part II. And on Part II,.Elizabeth has 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. 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..Patrick Shepherd: Right, because we we exempt.from reporting requirements those liabilities.offered on terms generally available to the.public from financial institutions..Cheryl Kane-Piasecki: Yes. So, what would.you jump to any conclusions with this Patrick,.or how would you what would you do in this.situation?.Patrick Shepherd: Well, the fact that it's.being reported.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: I think means we at least.have to consider it..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: Whether it's reportable.or not..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: And also because it's from.Farm Credit of Central Oklahoma.Cheryl Kane-Piasecki: Yes..Patrick Shepherd: and we're in the business.of issuing farm loans in concert with financial.institutions.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: two people in the farming.industry.Cheryl Kane-Piasecki: Right..Patrick Shepherd: I may have some questions..Cheryl Kane-Piasecki: 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?.Patrick Shepherd: Right..Cheryl Kane-Piasecki: Or was this sort of.a sweetheart loan, and maybe not even in a.malign kind of way, but just, for whatever.reason, they were longstanding relationship.with the with the with this particular lender,.and, you know, familial ties, or who knows.what, and so they were given a a line of credit.Patrick Shepherd: Right..Cheryl Kane-Piasecki: 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 you know, whether you regulate financial.institutions or you're responsible for initiating.loans or or whatever, where you are heavily.engaged in 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 OGE..Patrick Shepherd: Right, exactly, because.Elizabeth could have direct interaction with.these people in the course of her duties.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: which could raise some appearance.concerns..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: She may have the capacity.in her role to affect the continued willingness.of this organization to extend credit.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: to her or her business or.whoever the recipient of the credit is. So,.there may be some possibility for concern.that maybe wouldn't be existent with people.in other lines of work..Cheryl Kane-Piasecki: 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 regs, 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 mean,.this is.Patrick Shepherd: No, this isn't a theoretical.concern..Cheryl Kane-Piasecki: Yeah..Patrick Shepherd: This is a real concern..Cheryl Kane-Piasecki: This is a real concern;.I mean, so much so, that CFPB had actually.has it 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.Patrick Shepherd: Right..Cheryl Kane-Piasecki: You know, that anything.that's coming from a financial institution.Patrick Shepherd: And I think this is another.area where when you think about the breadth.of employees that have to complete the 450,.the reporting requirements make a lot of sense..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: 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..Cheryl Kane-Piasecki: Right..Patrick Shepherd: It's in these minority of.cases where someone's involved in the banking.industry or in extending credit or making.decisions about the extension of credit.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: or the supervising of financial.institutions where they pose potential concerns..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, this would be an area.where you might want to ask this question;.or indeed, some agencies might have some supplemental.instructions for the forms that require disclosure.of liabilities so that we can get to those.issues..Cheryl Kane-Piasecki: Exactly. In the interest.of time, because we're bumping up against.3 o'clock here, we're going to move on to.Part III..The first thing is the Cornwell Organics,.which we we did discuss this part of Part.I. But again, if you if you didn't have the.Part I disclosure, whenever you see something.where there's a business, you're going to.want to know..You're going to want to check Part I and make.sure that any investment or earned income.or other types of entries are on Part I. 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 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 I. Did you have anything that.you wanted to add, Patrick?.Patrick Shepherd: No, just that I would I.would start with looking for the prior approval.for the outside activity..Cheryl Kane-Piasecki: Right..Patrick Shepherd: Because it's possible that.we've already advised completely, and if we.haven't, we know we have to go through that.process..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: And we have a number of.courses we have a whole MOOC dedicated to.doing that analysis..Cheryl Kane-Piasecki: Right..Patrick Shepherd: So, if you don't know how.to do it, I'd encourage you to take a look.at that..Cheryl Kane-Piasecki: Yes. And then the 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 reported, Patrick, right?.Patrick Shepherd: Right, because they're a.volunteer, which probably doesn't raise to.the to the definition of position..Cheryl Kane-Piasecki: Right..Patrick Shepherd: However.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: since they've provided this.information, where we have concerns, we should.address them..Cheryl Kane-Piasecki: 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..Patrick Shepherd: Right. And, you know, some.of the things we look at are, you know, whether.the organization exerts control over the employee.in their capacity as a volunteer. So, if they're.being directed.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: and if they have a fiduciary.responsibility to the organization, certainly.then we have a concern..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, you're right, you know,.if the compensation isn't dispositive..Cheryl Kane-Piasecki: Mm-hmm. And again, I.agree with Patrick. If there's prior approval.required, and this is one the beauties of.requiring prior approval, and if this is the.type of activity that would fall within that.ambit, 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 a a quick and dirty,.in terms of this one. I based this entry on.something that I found with one of USDA's.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, or doing it you know, like even particularly.if they're doing it for compensation, there.may be some relatedness things to the.Patrick Shepherd: Right..Cheryl Kane-Piasecki: job that they're doing..Or you may not want them to be in the business.of of trying to, you know, counsel their own.clients on, you know, attending this particular.mentoring service, as opposed to, you know,.attending another..Patrick Shepherd: Yeah, so, you know, it's.it's something that we just wanted to go through.the process for the outside activity review..Cheryl Kane-Piasecki: Right..Patrick Shepherd: Yeah, that makes a lot of.sense..Cheryl Kane-Piasecki: Okay. So, they haven't.reported anything on Parts IV and V. And I.just strongly encourage you that even though.they're left blank, to go back to the filer.and 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 the sake you.know, the sake of being complete, I would.always just confirm that that there was nothing.to report on Parts IV and V..Patrick Shepherd: Excellent. And that brings.us right to the top of the hour..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, we we were successful.at getting through the exercise within the.time..Should we open it up for a question or two.Cheryl Kane-Piasecki: Yeah, sure..Patrick Shepherd: in case we have somebody.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 we'll address a couple with the.time we have remaining..Cheryl Kane-Piasecki: Mm-hmm..Operator: Thank you. At this time if you'd.like to ask a question, please press star,.followed by 1, on your touchtone phone. Questions.will be taken in the order they are received..Again, that is star followed by 1 on your.touchtone phone. You will be prompted to record.your name prior to asking your question. One.moment for your first question..Patrick Shepherd: 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/ogeinstitute..So, if you want to go back and listen to something,.you could do that..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: If you have to take off.right now and don't have time to hang around.for the questions, you can come back and find.those, too..Cheryl Kane-Piasecki: And Patrick, we're probably.going to house that in the MOOC section, correct?.Patrick Shepherd: That's right, yes. And we'll.be adding this to the 450 MOOC..Cheryl Kane-Piasecki: Okay..Patrick Shepherd: I don't show any questions.on the Hangout..Operator: I'm showing no questions on the.phones..Patrick Shepherd: Yes, and actually we we.do. We have a question that's come in on the.Hangout..So the question is, Cheryl, if we know the.filer's married, but has marked no on everything,.can we assume that that's correct, or follow.up? I think that's a good question..Cheryl Kane-Piasecki: That's an excellent.question. My my advice would be that you always.follow up..If you know that the filer has a spouse, there.is every possibility that there is 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..Patrick Shepherd: And I think, you know, this.is a case where good notes can help..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, if I saw this on a new.entrant report.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: I would absolutely, every.time, follow up to make sure that the employee.understood..Cheryl Kane-Piasecki: Yes..Patrick Shepherd: If we had had a back and.forth, and we had clearly communicated to.the employee that any spousal employment would.certainly be reportable.Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: and you have confidence.in that discussion, and the employee's ability.to understand that information, maybe in subsequent.years I'd be less concerned..Cheryl Kane-Piasecki: Right..Patrick Shepherd: But certainly the first.time, that would be a concern..Cheryl Kane-Piasecki: Yeah..Patrick Shepherd: But yeah, thanks, that's.a great question..Cheryl Kane-Piasecki: Mm-hmm. One thing I.did want to let people know too, and I don't.mean to be heavy handed with this, because.and I always try it a little lightly when.we're talking about enforcement type of things..But one thing that you do need to to know,.and it would be useful to look at the prosecution.survey that we put out every year, is that.1001 violations, 18 U.S.C. 1001 violations,.which is kind of like a falsification, is.a is a 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 their report something that.was material to whatever the the miss the.the misconduct was..Patrick Shepherd: Right..Cheryl Kane-Piasecki: And they'll go after.one on 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 willful, you know.Patrick Shepherd: Yep..Cheryl Kane-Piasecki: you know, falsification..Patrick Shepherd: Anyhow, I think this is.in the area where employees should understand.this, that there are benefits to filing, both.on the enforcement side, and also on the prevention.side..Cheryl Kane-Piasecki: Yes, absolutely..Patrick Shepherd: We can't help you manage.conflicts that we can't identify..Cheryl Kane-Piasecki: Right..Patrick Shepherd: So, the more complete the.information that we as ethics officials receive,.the more complete our advice can be..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, that's one area where.an employee receives a benefit from filing,.and also if they willfully fail to disclose.Cheryl Kane-Piasecki: Right..Patrick Shepherd: they incur liability personally..So, there are lots of good reasons for completing.these reports..Cheryl Kane-Piasecki: Yes..Patrick Shepherd: Lori, do we have any questions.on the phone?.Operator: We do have one question. Sheila.Gordon (phonetic); your line is open..Patrick Shepherd: Excellent. Welcome, Sheila..Sheila Gordon: Okay, could you repeat how.we can receive this information again, please?.Patrick Shepherd: How you can receive the.information?.Sheila Gordon: Yes..Patrick Shepherd: Which information?.Sheila Gordon: Like the whole website where.the program that we just finished with now..Patrick Shepherd: Oh, oh, you you'd like to.to find out where you can watch the the broadcast.again? Sure. The the URL is youtube.com/ogeinstitute..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 and the series it belongs.to..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: So, if you're looking for.prior broadcasts, that's a good place to start..Sheila Gordon: Thanks..Cheryl Kane-Piasecki: 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.covered 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..Patrick Shepherd: Well, thanks, Sheila..Sheila Gordon: All right..Patrick Shepherd: And I'm.Operator: Thank you. At this time, I'm showing.no further questions..Patrick Shepherd: And I'm showing none on.the Hangout. So, thank you all very much for.joining us..Cheryl Kane-Piasecki: Mm-hmm..Patrick Shepherd: And thanks, Cheryl, for.being here..Cheryl Kane-Piasecki: Absolutely..Patrick Shepherd: And we look forward to seeing.you next week for the Advanced Practitioner.Series..Cheryl Kane-Piasecki: Yes, and good luck with.your 450s..Patrick Shepherd: Yes, enjoy 450 season..

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Form 450 FAQs

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