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About Financial Disclosure


Notice: Effective October 30, 2015, amendments to the County's Public Ethics Law changed financial disclosure requirements to meet State of Maryland requirements.  Most significantly, all filed disclosure statements will be publicly available.  There are a number of changes to the financial disclosure form and the electronic filing system to accommodate the changes to the law.  In terms of content of required disclosures, the amended law, in general, requires an increased level of detail from elected officials, but a decreased level from other filers.  Filers will be guided by prompts regarding the information that must be provided.  Due to the changes to the form and online disclosure system, there will be no "copy data" function available for filing 2015 annual financial disclosure reports (so automatic copying of data from a previously filed statement will not be possible).

What is the Financial Disclosure Statement?

When do I file the Financial Disclosure Statement?

General Filing Instructions

Filing Tips

Important Information for Final Filers


What is the Financial Disclosure Statement?

The County's Ethics Law (Chapter 19A of the Montgomery County Code) requires certain County employees, certain members of Boards, Committees, and Commissions, and certain employees of the Housing Opportunities Commission to file financial disclosure statements.  All financial disclosure statements are publicly available.  If you are designated to file a financial disclosure statement, you will be notified of your obligation to do so by the Ethics Commission.

When do I file the Financial Disclosure Statement?

Commencement of Employment Within 15 days after the employee or volunteer is notified by the Ethics Commission of the obligation to file an Initial financial disclosure statement
Annual Disclosures The first business day in January through April 15 for the previous calendar year
Termination of Employment Before the employee or volunteer who is in a position required to file terminates employment or service.  A final paycheck will not be issued until the employee has filed the required financial disclosure statement.

When entering a position, the filer submits an "Initial" financial disclosure, which covers the prior calendar year as well as the portion of the current year up to the date of filing.  Every year after filing the "Initial" financial disclosure, filers must submit "Annual" disclosures that cover the previous calendar year.  And when leaving a filing position, filers submit a "Final" financial disclosure, which covers the time period from the end of the last filing period up to the date of separation from the filing position.

General Filing Instructions

For all filers, once you have successfully logged in, you will be taken directly to the Main Menu page.  Select the appropriate filing type ("Initial", "Annual" or "Final"); filers will also be asked to select the Filing Year.  The FDS will not permit you to file an incorrect type of financial disclosure.  If you are required to file a "Final" disclosure, for instance, and you select "Annual" by mistake, you will receive an error message in red indicating that the FDS does not require that type of filing from you at that particular time.

It is possible to complete the form in separate sessions, logging out in between.  The FDS has a timeout feature, where each session will expire after 30 minutes, regardless of activity.  All information saved within that session will still be in the system when the filer accesses the FDS again.  The form contains nine sections. In order to submit the form electronically, the filer must access each of the nine sections, regardless of whether there is information to report in each section.  This is accomplished by clicking on the hyperlinked name of the section in the sections list, reading the instructions, and clicking on Yes if you have something to report or No if you do not have anything to report.  If you click on No, you will be returned to the sections list, and the words Not Applicable will appear in green in the row for the section you have just completed.  If you click on Yes, you will see a blank form in which you must answer questions pertaining to that particular section.

If you have a new item to report in the section, fill out the data input fields, and then click Save at the bottom of the screen.  The information you added will become a line item at the top of the page.  This process can be repeated for as many line items as is needed to comply with reporting requirements.

After completing each section, click Section Complete at the top of the page.  This will return you to the sections list page, so that you may move on to the next section of the report.  You will see that the section in which you just added reportable information now shows the word Complete in green in the row for the section you have just completed.  This process should be completed for all nine sections.

Once all nine sections have been addressed, at the bottom of the sections list, click the certification box and then click Submit Finalized Form.  You will not be able to submit the form to your reviewer unless all nine sections are listed as either Complete or Not Applicable.  If the word Incomplete appears in red in the right hand column in the sections list for any section, you must re-enter that section and complete it prior to submitting your statement for review.  After clicking Submit Finalized Form, a popup will appear reminding the filer that each section must be completed and that all submitted disclosures are publicly available after submission. After reading the popup, if you are sure you properly and fully completed all nine sections, click OK to submit the financial disclosure statement to your reviewer.  If you feel the need to review your work again before committing to the filing, click Cancel to remove the popup and go through each section before submitting the statement to your reviewer.

When you submit your finalized form, it is sent to your departmental reviewer.  After your reviewer approves it, the disclosure is sent to the Ethics Commission for final acceptance.  Both the departmental reviewer and the Ethics Commission reviewer must accept the filing in order for the process to be completed.  If either the departmental reviewer or the Ethics Commission reviewer returns the filing to you, please read any notes located on the History tab inside your FDS account.  Filers may access any reviewer notes by clicking on the hyperlinked word Returned in the status column for the returned disclosure, which will open a separate dialog box containing the reviewer's notes to the filer.  After reading any notes regarding the returned disclosure, please make adjustments to the disclosure statement as needed prior to resubmitting the statement to your departmental reviewer.  This form must be resubmitted within a week of receiving the returned statement.

NOTE:  If your filing is returned to you, in order to access the editable version of your disclosure statement, click History on the Main Menu page after logging in.  Then, on the History screen, click the radio button to the left of the appropriate line for the filing that was returned (any financial disclosure still in Returned or Filing status will have a radio button on this screen; the radio button is a circle that you click with your cursor).  After clicking the radio button, scroll down and click Continue Filing at the bottom of the screen.  This will take you back to the sections list for the filing you selected on the History screen.  Then, continue filing as outlined above.

Filing Tips

1.  In the real property section, the cost of the property is no longer required (except for elected officials who will continue to provide that information).  Also, all real estate interests held, including leases, regardless of location must now be listed.

2.   In the section on ownership of corporations, partnerships, or other business interests, while stocks and the like still need to be disclosed, the value of holdings and how much was paid for them is no longer required to be disclosed (except for elected officials.)

3.  The income section now excludes unearned income and also excludes income from County employment.  

4.  The threshold for reportable gifts from “restricted sources” has changed to gifts worth more than $20.  Gifts to employees from restricted sources worth more than $20 must be disclosed regardless of whether they have been accepted pursuant to an exception under the gift law (19A-16(d)).

5.  Indebtedness to and positions with persons “doing business with” the County is required to be reported.  Also, if a source of income of an employee (or immediate family member) is “doing business with the County” that fact is required to be disclosed.  For purposes of reporting, doing business means entering contracts, grants or other agreements involving the exchange of at least $1,000 for goods and/or services.  It does not include routine payments of fees, taxes, or use of County provided programs or services, even where payments may be involved, such as through an application for a permit.  For example, a bank holds a mortgage on an employee’s house; the bank submits tax payments on behalf of the employee to the County, and itself pays taxes on property it owns in Montgomery County.  These activities do not constitute “doing business with” the County for purposes of the financial disclosure reporting requirements. Some insight to banks "doing business with" the County may be obtained through use of the County's contract search function at http://www2.montgomerycountymd.gov/ICCS/.

6.  In the indebtedness section, the interest rate is no longer required (except for elected officials.)

Important Information for Final Filers

If an employee is leaving a filing position as a result of separating from County employment, failure to file a "Final" disclosure will result in a hold being placed on the employee's final paycheck until the disclosure is completed.

READ THE INSTRUCTIONS FOR EACH SEPARATE SECTION!!!
 

 

Montgomery County Ethics Commission · 100 Maryland Avenue · Room 204 · Rockville, Maryland 20850
Ethics.Commission@montgomerycountymd.gov · Telephone: 240-777-6670 · Fax: 240-777-6672
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