278 SLC User Guide Release 5.0



Financial Disclosure Management (FDM) 278

Release 5.0

FDM 278 User Guide

for Senior Legal Counsel (SLC),

Ethics Counselors (ECs) & SLC Assistants

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Faster, Easier & More Accurate Financial Disclosure Reporting & Reviewing

February 2008

Table of Contents

1.0 FDM 5.0 Overview 4

1.1 Introduction 4

1.2 FDM Hierarchy 4

1.3 Using FDM Successfully 5

1.4 FDM Preview 6

1.5 Usage Conventions 6

1.6 User Comments & Feedback 6

2.0 Navigating FDM 7

2.1 Website 7

2.2 Inside FDM 7

2.2.1 Senior Legal Counsel (SLC) Tabs 7

2.2.2 Filer Tabs 8

2.2.3 Supervisor Tabs 8

2.2.4 My Info Tab 8

2.2.5 Review Filers Tab 8

2.2.6 Admin Tab 9

2.2.7 Resources Tab 10

2.2.8 Report Navigation 10

2.2.9 Save & Quit 11

3.0 FDM Technology 12

3.1 General 12

3.2 System Requirements: 12

3.3 Printing 12

3.4 Common Access Card Access to FDM 12

3.5 System Maintenance Outages 12

3.6 System Temporary “Lock Out” 12

4.0 Senior Legal Counsel (SLC)/SLC Ethics Counselors (SLC ECs) 13

4.1 Introduction. 13

4.2 SLC Registration 13

4.3 SLC Login 13

4.4 Registering other FDM users 13

4.4.1 Registering an SLC Ethics Counselor (EC) 14

4.4.2 Registering an SLC Assistant 15

4.4.3 Registering a Supervisor 15

4.4.4 Registering a Filer 16

4.5 Reviewing an SF 278 in FDM 18

4.6 Managing Filer Extensions 20

4.7 Comments 20

4.8 SF 278 Reviews 20

4.9 Electronically signing (eSigning) a reviewed report 20

4.9 Submit to DAEO 21

4.10 Amended Reports 21

4.11 Termination Reports 22

4.12 Combined Incumbent & Termination Reports 22

5.0 Filers 23

5.1 Registration 23

5.2 Filer Login 23

5.3 Adding a Filer’s Assistant 24

5.4 Starting a Report 26

5.4.1 Assets 30

5.4.2 Other Income 32

5.4.3 Transactions (for Incumbent and Termination Reports only) 33

5.4.4 Gifts (for Incumbent and Termination Reports) 34

5.4.5 Liabilities 35

5.4.6 Agreements or Arrangements 36

5.4.7 Positions 37

5.4.8 Comments 38

5.4.9 Termination Reports 38

5.4.10 Wrap Up & eSign 39

5.4.11 Amending a report 40

5.5 Log Out 41

6.0 Supervisors 42

6.1 Introduction 42

6.2 Registration 42

6.3 Login 42

6.4 Reviewing a report 42

6.4.1 Wizard View 42

6.4.2 View/Print Review 43

6.5 Electronically signing (eSigning) a reviewed report 43

6.6. eSigning an amended report 44

6.7. Log Out 44

Appendices

Appendix A – What’s New in FDM 278 Release 3.0 …………………………………….. 45

Appendix B – FDM Website Index …..…………………………………………………….. 47

Appendix C – FDM Preview ...…...…..…………………………………………………….. 49

Appendix D – Chart: SF 278 Schedules & Applicable Reporting Periods …..………... 50

Appendix E – Sample Notices to Filers to Use FDM …………………………………….. 51

Appendix F – Reporting Capacity Limits …..……………………………………………… 52

Appendix G – SLC Quick Start Checklist ...……………………………………………….. 53

Appendix H – FDM 278 Senior Legal Counsel(SLC)/

SLC Ethics Counselor (EC) Quick Start ...…………….……………….. 54

Appendix I – SF 278 Incumbent Filer Quick Start ..............…………….……………….. 59

1.0 FDM 5.0 Overview

1.1 Introduction

The Financial Disclosure Management (FDM) software program helps Filers accurately prepare and electronically file a Financial Disclosure Report (either the Standard Form (SF) 278, Public Financial Disclosure Report, or the Office of Government Ethics (OGE) Form 450, Confidential Financial Disclosure Report). It is a secure, online application accessed at that simplifies financial disclosure report preparation and review, eliminating many common errors and should save time.

FDM supports the DoD transformation of enterprise management and a specific DoD priority: “Improve Effectiveness and Efficiency Across the Board.” FDM is currently being considered for DoD Enterprise-wide use and is in use in OSD, JCS, the Air Force, Navy, Air National Guard, DISA, the Office of Government Ethics, and the Department of Veterans Affairs, among others.

FDM uses a “report wizard” to guide a filer through reporting required information. The wizard is tailored to the type of report (e.g., New Entrant, Incumbent, Termination) so that the information required for that type report is captured. See the Quick Reference, Key Features, for a quick look at FDM. The 5.0 Release Notes are available on the FDM website in Help & Support | Release Notes.

This Guide focuses on preparation of the SF 278, Public Financial Disclosure Report, using FDM. Since 2006 nearly 800 Army SF 278s were prepared annually using FDM.

This guide is intended primarily for local legal counsel who may share selected sections as appropriate. This Guide explains major FDM features that Filers, Supervisors, and legal advisors/staff use to prepare and electronically file, review, and manage the SF 278. It is best viewed online as it contains hyperlinks to assist easy movement to different topics. It is divided into these sections:

Navigating FDM – briefly explains how to navigate the FDM website and inside FDM to prepare and review financial disclosure reports.

FDM Technology – identifies the minimum system requirements users need to successfully use FDM. Direct any questions about a user’s computer to the user’s local technology support.

Senior Legal Counsel (SLC) or Legal Advisors – explains the basic information that SLCs (and legal staff) need to know to efficiently use FDM. In FDM the term “Senior Legal Counsel” indicates the senior legal advisor at a command, installation, organization, or other high level official responsible for Ethics at that location. In FDM, the Staff Judge Advocate (SJA) and General Counsel are FDM “SLCs”. SJAs may appoint Ethics Counselors (ECs) on their staff to review financial disclosure reports. SLCs may similarly appoint ECs in FDM.

Filers – explains the basic information that Filers (and Filers’ Assistants) need to know to efficiently use FDM.

Supervisors/Report Reviewers – explains the basic information that Supervisors (and Supervisors’ Assistants) need to know to efficiently use FDM.

Appendix A, What’s New in FDM 278 Release 5.0, briefly covers the most significant changes recently introduced to support SF 278 reporting and reviewing in 2008. Two additional minor releases are planned for March and early Summer.

1.2 FDM Hierarchy

FDM uses roles and relationships to group filers (“Org Units” to connect Filers, Supervisors (report reviewers), and Senior Legal Counsel (SLC) to limit who has access to a particular Filer’s report. Currently each 278 Filer must be a Filer in a particular organization. Each org unit has a Supervisor and an SLC assigned or acting.

FDM uses the roles and relationships to provide standard review notices to report reviewers. For example, as a Filer eSigns a report (s)he must indicate a notice to either (or both) the SLC or the Filer’s Supervisor. The FDM hierarchy also organizes reports under the respective responsible Deputy DAEO for final review and certification.

1.3 Using FDM Successfully

FDM is simple to use, much like TurboTax for electronic income tax filing. The graphic below illustrates the process flow for SF 278 submission:

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FDM has a Report Wizard with Common Questions & Answers and on screen report preparation instructions that guide a Filer through the report preparation and electronic filing process. If more assistance is needed, most Filers and Supervisors will find their Senior Legal Counsel (SLCs) or Ethics Counselor is the best resource, especially for substantive guidance on what must be reported. The FDM website Resources tab includes a summary chart of reportable items: . The FDM Learning Center | Documentation area includes a Quick Reference, Filing an SF 278, , as an introduction to FDM or a quick refresher for those Filers who haven’t used FDM recently.

SLCs should find this Guide covers most information needed to use and explain FDM to others.

Consult your local Information Technology (IT) Help Desk for technology related matters. For example, a user who experiences computer problems reading the Common Access Card (CAC) or does not have the minimum system requirements for using FDM should contact the local IT Help Desk. The FDM Technology section of this guide has useful information in this regard.

The FDM web site, , includes Help information and other resources (e.g., Video tutorials (). FDM tutorials are short videos on specific subjects. Each will self-play or use the control bar to pause (||) or rewind (>) at your pace.

FDM includes a [pic] symbol for more information on a particular task.

Most FDM screens include Common Questions and Answers tailored to that particular area of a report or on FDM use. See the entire set of FDM 278 Common Questions & Answers: .

An FDM Glossary covers terms used in FDM. A link to it is on the FDM web site (Help & Support | Resources) and on the Resources Tab inside FDM.

FDM Known Issues: all software has bugs or defects that may impede its overall effectiveness. Check FDM’s Known Issues area, , to see any reported known issues and suggested workarounds.

FDM Help Desk: (732) 532-5566, DSN 992-5566. This office is staffed from 7:00 AM to 5:00 PM Eastern Time. Voice mail available for other times. The email is: CELCMCFDMSupport@mail1.monmouth.army.mil.

Contact the FDM Webmaster by email at FDMWebmaster2@hqda.army.mil or by phone at 703.696.5512. Send comments or suggestions for improvements to the FDM Webmaster.

1.4 FDM Preview

SLCs and other legal staff may find the FDM Preview site helpful. In FDM Preview, legal staff may experience different roles e.g., as a Filer or Supervisor, to prepare for assisting FDM users in those roles on FDM production. It is an almost exact duplicate of FDM production except that it is not for real data or real financial disclosure report Filers. The FDM features work the same, but Preview is not for use in filing “real” reports. Appendix C has more information on FDM Preview.

1.5 Usage Conventions

In this guide, bold, italicized text indicates the FDM user should click on that item (e.g., Continue) or type that information in FDM in the area indicated.

Bolded or highlighted FDM location navigation tabs (e.g., My Info, Review Filers) indicate where an FDM user is at a particular time. FDM page or screen names are bolded and underlined.

1.6 User Comments & Feedback

Send comments or feedback on this Guide or about FDM to the FDM Webmaster, email address: FDMWebmaster2@hqda.army.mil.

2.0 Navigating FDM

FDM users start at the FDM website, , to login. The site contains general information on FDM, including the current system status (Important Information) and system requirements (see Help & Support).

2.1 Website

See Appendix B for more information about the FDM website, including a site index and screen shots.

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2.2 Inside FDM

FDM functions are always accessible through a tab menu in the banner at the top of each page. The tab menu provides a visual cue to a user’s location in FDM. Users may select tabs at any time to change location in FDM. The tab and sub-menu item (if any) corresponding to the user’s location are always highlighted or bolded. The Key Features Guide is a quick start guide to using FDM. It is a brief overview of the basic FDM functions.

2.2.1 Senior Legal Counsel (SLC) Tabs

The top tier menu for the SLC has these four tabs: My Info, Review Filers, Admin, and Resources:

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The Review Filers tab is the main FDM workspace for most legal personnel when reviewing or monitoring report processing.

2.2.2 Filer Tabs

The top tier main menu for Filers has three tabs: My Reports, My Info, & Resources

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The My Reports tab is the Filer’s main FDM workspace where the Filer will begin a new report or edit/view any previous report prepared in FDM.

2.2.3 Supervisor Tabs

The top tier menu for Supervisors is the same as for Senior Legal Counsel unless the Supervisor is also an FDM Filer. If so, it includes a My Reports tab to the left of My Info for the Supervisor’s report(s):

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2.2.4 My Info Tab

FDM uses the My Info tab to capture basic user information. It is also where a user appoints and manages assistants.

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The SLC’s My Info tab has the SLC contact information, is where the SLC may add any Ethics Counselors, Assistants, and register Filers, and view the SLC’s profile (summary page of roles and assistants).

The first time an SLC logs in to FDM the My Info | Contact Information screen displays so the SLC may review and update personal information.

2.2.5 Review Filers Tab

Legal personnel (SLC, SLC EC) and Supervisors have a Review Filers | Reports List tab that displays a list of their Filer(s) and report(s):

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See the Quick Reference, QRC Reviewing a SF 278 in the FDM Learning Center | Documentation for step-by-step instructions on reviewing a report.

This is the main FDM workspace for Supervisors and legal personnel. The Search box (Form Type, Year, Reporting Status, and Review Status) allows SLCs to display different combinations of reports. SLCs with only a few filers will find it most efficient to set the last two filters to All. For the SF 278 set the year to 2008 to see reports due in 2008 (covering Calendar Year 2007). Change to 2007 to see reports filed in CY 2007.

2.2.6 Admin Tab

The Admin tab is where SLCs, SLC ECs, and Org Unit Points of Contact (POC) group filers in “Org Units” associated with a specific Supervisor. Recall that the Joint Ethics Regulation (JER) requires Supervisors review the financial disclosure report. The Org Unit is how FDM organizes Filers for the responsible reviewing Supervisor.

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In addition, on other sub-tabs of the Admin tab, SLCs may add Points of Contact (POCs) to assist in managing Filers in particular organizations, register Supervisors for particular organizations, and assign 450 Certifiers (the approving authority for the OGE 450) to particular organizations.

Finally, the Users sub-tab is search tool for any FDM user showing a user’s FDM role(s) (and Org Unit location if a Filer).

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Here, a search using the AKO user name (for quickest result) returns:

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Select View to see the user profile page on this user, George Hancock:

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The underlined items are hyperlinks to additional information on the user. The Org Unit location is important for finding and moving the filer to another FDM organization.

2.2.7 Resources Tab

A Resources tab displays links to useful documents, the FDM Glossary, and ethics information sites.

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2.2.8 Report Navigation

Inside a financial disclosure report, on the Review Filers | Report Data page are Progress Bar buttons to move through the different report sections.

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For the New Entrant SF 278 Filer the Review Filers | Report Data page progress bar buttons are Getting Started, Assets, Other Income, Liabilities, Agreements, Positions, Compensation, and Wrap Up.

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For the Incumbent SF 278 Filer the Review Filers | Report Data page progress bar buttons are Getting Started, Assets, Other Income, Transactions, Gifts, Liabilities, Agreements, Positions, and Wrap Up.

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This diagram maps the different SF 278 Schedules or sections to the corresponding FDM Filer report type and the FDM progress bar.

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Most FDM report pages display a page title, tabs, tab menu items, report completion instructions, Common Questions (links open with answer in a separate window), and navigation buttons as shown here.

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2.2.9 Save & Quit

FDM saves information entered when a user selects Save or uses Continue to move to a different area. FDM users who Log Out and return will find the previous information available. Filers may stop and resume a report as many times as desired.

3.0 FDM Technology

3.1 General

FDM uses Army-wide standard computer settings (known as the Army Gold Master). In the unlikely event you encounter technology difficulties (e.g., your Common Access Card (CAC) does not work or FDM does not open an Adobe file) please check the FDM website, , Help & Support page, for information that your local IT Help Desk may need to check your computer settings.

3.2 System Requirements:

1. Operating System: Windows 2000 Pro (Service Pack (SP) 2) or XP Pro (SP1 or SP2)

2. Browser: Internet Explorer (IE) 6.0 (128 bit encryption)

3. Adobe Acrobat Reader 6.0 (or 7.0 IE plug-in)

4. JRE: Microsoft JVM or Sun JRE 1.5 or greater

5. CAC reader & any of this middleware:

o ActivCard 2.2 SP 2

o Activcard 3.0 (Recommended over 2.2)

o Litronic Inc. Netsign CAC 4.2

3.3 Printing

FDM relies on the user’s own computer printer settings to print. Users may need to check/adjust printer settings starting at the Internet Explorer File button, selecting Print to open the printer options.

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3.4 Common Access Card Access to FDM

FDM does not have its own user name and password generator or account manager. Instead, FDM uses DISA’s Global Directory Service (GDS) database of Common Access Card (CAC) holders and Army Knowledge Online (AKO) /Defense Knowledge Online (DKO) as FDM registration and access authorities. Information on GDS is available at . GDS is a DoD-wide database for identification. DISA compiles what the different CAC-issuing authorities send. FDM looks up users against GDS (or AKO/DKO). After a user surrenders his/her CAC FDM access is by AKO/DKO user name and password. Termination report filers must use the AKO user name/password access method. Note: AKO has strict password expiration at 150 days so users may first need to go to the AKO site, , and reset the expired password before logging in to FDM.

3.5 System Maintenance Outages

The Defense Information Systems Agency (DISA) began hosting FDM in late 2007. DISA regularly does system maintenance on Sunday afternoons or late evenings that may cause FDM to be temporarily unavailable. The FDM home page, , will usually reflect planned outages several days before they are scheduled. If a user is unable to access FDM please report that to the FDM Help Desk, CELCMCFDMSupport@mail1.monmouth.army.mil. It is staffed Monday – Friday 7:00 – 6:00 p.m. Eastern or phone: (732) 532-5566, DSN 992-5566.

3.6 System Temporary “Lock Out”

FDM users who enter the wrong PIN (or AKO password) three times within a few minutes will be temporarily locked out of FDM for about 30 minutes. Close the Internet Explorer window and login again. If that fails, contact the FDM Help Desk for assistance.

4.0 Senior Legal Counsel (SLC)/SLC Ethics Counselors (SLC ECs)

4.1 Introduction.

In FDM the term “Senior Legal Counsel” (SLC) indicates the senior legal advisor at a command, installation, organization, or other high level legal official responsible for financial disclosure reports (FDRs) at that location. The Staff Judge Advocate (SJA) and General Counsel are FDM “SLCs”. SJAs may appoint Ethics Counselors (ECs) on their staff to review FDRs. In FDM, SLCs may similarly appoint ECs. SLCs or their ECs or Assistants may perform many FDM functions including registering Filers and Supervisors, confirming pending self-registrants, and reviewing reports. This section explains selected features for SLCs, ECs, and SLC Assistants.

4.2 SLC Registration

Unregistered SLCs needing FDM access should contact the MACOM Staff Judge Advocate, organization FDM POC, the FDM DAEO POC, or the FDM Webmaster, FDMWebmaster2@hqda.army.mil.

4.3 SLC Login

FDM-registered SLCs may login to FDM, , Login, using the Common Access Card (CAC) and Personal Identification Number (PIN). Army SLCs may also use the Army Knowledge Online (AKO) user name and password.

The first time an SLC logs in to FDM the Contact Information page displays for the SLC to review and complete. For Army SLCs some information is imported from AKO. For non-Army SLCs some information is imported from DISA’s Global Directory Service, an online data base of Common Access Card holders that FDM uses for registration purposes.

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Add any missing information and select Save.

4.4 Registering other FDM users

SLCs may register new FDM users – Filers, Supervisors, SLC Ethics Counselors (SLC ECs), and SLC Assistants. Once registered, SLC ECs and SLC Assistants also may register FDM Filers and Supervisors.

4.4.1 Registering an SLC Ethics Counselor (EC)

Many SLCs appoint an EC to review, and sometimes, to eSign the SF 278 (instead of the SLC). SLCs may appoint one or more SLC ECs in FDM on the My Info | My ECs tab.

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The My Info | My ECs tab displays the My Ethics Counselors page (above). Click on Add SLC EC. That opens the Add A New Ethics Counselor page (below) with the Search tool to find the EC to add:

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Tip: If you know the CAC-embedded email address (e.g., for Army personnel it is the AKO User Name) you may enter a few letters of the last name and then enter that in the email search box, then select Search.

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The result will be a list of names, Select the right one and Confirm to add the EC:

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The SLC EC can add new Org Units, register report Filers and Supervisors, and see the SLC's report list to monitor Filer progress and eSign a report for an SLC (when authorized).

4.4.2 Registering an SLC Assistant

SLCs may also appoint Assistants to monitor reports in FDM. To add an Assistant, use the My Info | My Assistants page and click on Add Assistant:

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The Add a SLC Assistant page (below) appears where you use the same search tool as for adding an EC:

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Select the correct name and Confirm to finish the Add SLC Assistant.

The SLC Assistant can register report Filers and Supervisors, act on pending self-registrants for the SLC, and see the SLC's report list to monitor Filer progress. An SLC Assistant cannot eSign a report for an SLC.

4.4.3 Registering a Supervisor

The Admin | Supervisors tab is where SLCs (or SLC ECs or SLC Assistants) assign a Supervisor to a particular Org Unit (group of filers).

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Select Next Level Down to the appropriate Org Unit where you assign the Supervisor. FDM’s construct is to use the next higher Org Unit Supervisor as “acting” until a specific assignment at a given Org Unit.

See the short video, Managing FDM Roles, or the QRC, QRC Managing FDM Roles.

4.4.4 Registering a Filer

The My Info | My Filers tab displays the My Filers – Senior Legal Counsel View page where SLCs see and register their Filer(s) in a specific Org Unit associated with the Filer’s Supervisor. A short video tutorial, Managing FDM Filers, and a Quick Reference Card (QRC), QRC My Filers, are available to explain the filer registration process. Other videos and QRCs are available on these topics: Managing FDM Org Units and Managing FDM Roles.

In the Army several Deputy Designated Agency Ethics Officials (DDAEOs) are responsible for the financial disclosure reporting program and process for specific areas generally along command lines. (See Army General Counsel Memorandum, Subj: Designation of Deputy Designated Ethics Officials (DAEOs) & Delegation of Authority UP JER, DOD 5500.7-R, January 03, 2007 .)

FDM Release 4.1 introduced an Organizational Unit (“Org Unit”) tool to group and organize Filers by supervisor for visibility to the respective, responsible DDAEO. There were over 1,000 Filers and “supervisors” already using FDM when Release 4.1 went live in November 2007. To keep those Filers grouped together by their reviewing Supervisor, FDM named that grouping an Org Unit name using this naming convention:

Org Unit Supervisor’s Last Name (e.g., OrgUnit Hancock, G).

SLCs may change the Org Unit name to one based on the Supervisor’s title or position or use the office symbol. This is especially important where the former Supervisor departed and a new one will review reports of the employees who remained in that organization (and are still grouped in FDM under the named OrgUnit). See Enclosure 10 to the FDM 278 SOP for more on Org Units. The FDM Learning Center also has a short video tutorial, Managing FDM Org Units, and a Quick Reference Card, QRC Managing Org Units.

Before you add a Filer you need to have an Org Unit for the Filer. That process begins on the Admin | Org Units tab, or if you are ready to add both a new Supervisor and the Org Unit, use the Admin | Supervisor tab.

Admin | Org Units tab method:

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The SLC (or SLC EC) sees a “Role” (SLC/ SLC EC) and an opportunity to change (if the SLC has other FDM roles). Below the Role display is an “Org Unit: My Orgs” “breadcrumb trail” display showing existing organizations with which you have an association in FDM. Most SLCs (SLC ECs) will start with an organization corresponding to the supported SF 278 Filer (e.g., CG of the organization) and may see other Org Units where there is an SLC relationship. SLCs and SLC ECs may add a new Org Unit. See the video on adding org units, , or the Quick Reference, .

After the new Org Unit is added, the SLC may assign a Supervisor (Admin | Supervisor tab) a POC (Admin | POC tab) and/or a 450 Certifier, to register and manage Filers for that organization online in FDM. See the video tutorial on assigning a Supervisor, Managing FDM Roles, , or the Quick Reference, Managing FDM Roles, .

Admin | Supervisor tab method (benefit – combines adding Supervisor and new org unit in same FDM area, starting with the Supervisor first):

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FDM includes a [pic] symbol for more information on the particular task.

Under the Role box, in the Org Unit breadcrumb trail, be sure to “Select Next Level Down” to add subordinate org units.

To change a Supervisor for an org unit, select next level down, find the Supervisor’s name, Delete, then Assign the successor. Immediately after deleting, FDM inserts the next higher Supervisor as acting until the new Supervisor is Assigned.

An SLC (or SLC EC, POC) adds Filers to particular Org Units on the My Info | My Filers tab. See the Quick Reference, My Filers, (FDM Learning Center | Documentation) for specific instructions or watch the short video tutorial, Managing FDM Filers (FDM Learning Center | Tutorials).

Note: registering a Filer generates an automatic notice of registration to the Filer, the Filer’s Supervisor, and SLC. You should confirm the org unit has an assigned supervisor or the next higher level FDM Supervisor (Vacancy, acting name) will receive the email notice.

Note: FDM uses a hierarchy construct. Once an SLC, or SLC EC (or any role) is filled at a particular level that person may act in that role for all subordinate organizations/levels, even if another person is assigned to that role for a particular organization. It is not necessary to assign a person in a role at the higher level to the same role at the subordinate level (Select Next Level Down) and FDM simply shows “Vacancy, . . . acting” at the subordinate levels. That way, when the person vacates that role and a successor is assigned that carries through as well, saving time on replacing at each subordinate level.

Note: Delete/Assign successor supervisors for org units on the Admin | Supervisor tab.

Assign Requirement to File & Notify Filers to File:

FDM includes a Required Activity tool to assign Filers the requirement to file and an optional notify Filers to file using FDM, see Appendix A, para A-3, for information, link to a short video, and a sample email notice. In addition, Appendix D is a template of instructions you could adapt and send to filers.

Note: assigning the required activity to file will help quickly identify delinquent/non filers, notify them of their lateness, and compile a report for higher headquarters. An additional benefit is the ability to quickly obtain the Filer numbers for the annual Office of Government Ethics questionnaire. Assign the requirement to file at any time, even after the Filer has filed and FDM will update the list of delinquent Filers for the assigned requirement whenever the Filer has eSigned that report.

Note about FDM email notices: FDM will email notify up to 100 Filers at a time, however, some local commands limit the number of “email addressees” in a single email to 20 – 30. If you don’t know your local activity limits, consider FDM notifying only 20 at one time.

The My Info | My Profile page shows a summary of your FDM roles and any Assistants in that role on a single page:

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The screen above shows an SLC EC to Ms. Stockel, an FDM EC.

4.5 Reviewing an SF 278 in FDM

SLCs (and SLC ECs) review a report starting on the Review Filers | Reports List tab. Be sure to check your Role and Org Unit “breadcrumb” trail (use “Show My Filer’s Reports to see all filers where you are named as SLC (or other role)) as well as the “Search box” (Filer’s Reports filters to display reports):

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Recommendation: SLCs/SLC ECs with only a few Filers will save time by using “Show My Filer’s Reports to see all reports where you are named as SLC/SLC EC and setting the Search box Reporting Status and Review Status filters to All to display all reports in Draft, Under Review, and Completed.

Selecting View opens the report and displays the Review Filers | Report Data Report Progress Bar wizard (below) that lets you click through or use Continue to advance through the report sections.

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Notice that the Review Filers sub-menu may contain up to eight items that appear when needed:

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• Reports List - shows Filer’s previous report(s) (if any). This is where you can begin a new report and edit/view all previously prepared reports.

• Report Data – main area used for preparing (or reviewing a report with FDM’s report wizard).

• Attachments – add/replace/view attachments associated with a report.

• Comments – area for recording Reviewer comments on a report.

• Flags – identifies missing or incomplete information that must be provided before the report is filed.

• Audit Trail – tracks all changes made to the report).

• View/Print – provides the user a view and print function for the report.

• Review Status – shows who has reviewed/approved a Filer’s report.

Most SLCs and SLC ECs check the Comments, Flags, Audit Trail, View/Print, and Review Status tabs before reviewing the substance of a report. These help quickly identify missing or explanatory report information as well as display who else has reviewed the report (Review Status tab). Office of Government Ethics (OGE) financial disclosure report review guides are available on the FDM website Resources tab. In addition, a “Quick Reference,” Reviewing a SF 278, , is available. Some SLCs prefer to print the report and review in on paper. Go to the View/Print tab and print the report. Return to the wizard view to add any section/line item comments.

4.6 Managing Filer Extensions

Visit the FDM Learning Center, , for a short video tutorial on Managing FDM Extensions, and a Quick Reference Card, QRC Granting Extensions. A future FDM feature will enable a 278 Filer to request an extension inside FDM. For now, however, Filers request an extension outside FDM. FDM has a tool for a DAEO/DAEO EC to record extensions granted for the Filer as shown in the items in the FDM Learning Center.

Notes:

• Filers in a combat zone (CZ) when a report is due (e.g., 15 May for the Incumbent (Annual)) have up to 180 days after leaving the CZ to submit the report.

• Army DDAEOs may have delegated authority to approve filing extensions to SLCs. FDM, however, does not yet have a tool for SLCs to record such extensions. Instead, SLCs who approve extensions should add a comment to the report to that effect and request the DDAEO FDM POC or the FDM Webmaster record the extension in FDM for the affected 278 Filer(s).

4.7 Comments

SLCs (and other FDM users) may use the Comments tab for supplemental or explanatory information. For example, if a Filer had an extension not otherwise record in FDM, the SLC may use the Comment tab to explain and record that extension.

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4.8 SF 278 Reviews

Reviewers are checking the reported financial interests for completeness and to identify those financial interests that may conflict with the Filer’s official duties and that the report is administratively accurate and complete. Before signing off on the report the reviewer must take appropriate steps to resolve any apparent conflicts of interest.

The in-depth, systematic agency review of financial disclosure reports is called the certification process. It entails:

• A technical review (is the report completed accurately)

• A conflict of interest analysis (focal point of the certification process; your analysis whether a filer is/is not complying with the conflict of interest statutes, standards of conduct, and any agency-specific laws and regulations.)

• Recommending remedies to resolve a conflict, if one is found on the report, and

• A certifying signature by the DDAEO, the responsible approving authority.

See the FDM 278 SOP for detailed guidance/checklists for reviewing an SF 278.

4.9 Electronically signing (eSigning) a reviewed report

An SLC ready to eSign a report sees the “eSign” option on the Review Filers | Reports List page. The SLC (or SLC EC) may End Review, View the report, or eSign by selecting the appropriate choice in the far right column of the row for the desired report.

Note: Some SLCs direct the SLC EC to use End Review to signal to the SLC that the legal staff review is complete and ready for the SLC to eSign the report.

Selecting eSign displays the eSign effect pop up (shown below). Click OK to proceed.

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The eSign Report page appears:

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After selecting eSign, the Review Filers | Reports List Welcome name page displays the report as Under Review (the SLC has eSigned and can View the report).

4.9 Submit to DAEO

The “Submit to DAEO” option appears (on Review Filers | Reports List or inside a report on the Review Status tab). After a Supervisor has eSigned, SLCs click on Submit to DAEO to inform the report certifying authority that this Filer’s SF 278 is ready for review.

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Click OK to finish the Submit to DAEO.

In some cases the report certifying authority will direct changes by the Filer or another reviewer. To do so, that certifying authority must return the report to Under Review status before others may act on that report.

Use the Reports List tab and Filer filters to display other reports for SLC review or Log Out of FDM (top right).

4.10 Amended Reports

A Filer may amend an SF 278 report at any time until it is “Submitted to DAEO” for certification or has been completed by the certifying authority. The DAEO/DAEO EC can undo the “Submit to DAEO” status and make the report available for Filer amendment. Once the Filer has amended the Filer and all reviewers need to eSign the report again. The SLC (or SLC EC) usually “Submits to DAEO” after those eSignatures.

4.11 Termination Reports

SLCs of SF 278 termination report Filers are the only local reviewing official as the Filer’s Supervisor is not required to review the report (JER 7-206a). Once the SLC (or SLC EC) has reviewed and eSigned the report “Submit to DAEO” for final action. Army SF 278 Filers may eSign a termination report using the AKO user name and password access to FDM. Termination reports may not be submitted until the last day of active duty or the Filer is no longer in the Army (e.g., retired military on the Retired Rolls, SES has left the Army, including using all leave). The Filer section contains special guidance for Filers on Termination reports.

4.12 Combined Incumbent & Termination Reports

Reporting individuals who anticipate leaving a covered position on or within 90 days after the May 15 annual deadline may file a combined Incumbent (annual)/Termination report if they request and receive an extension of the annual filing deadline. An official leaving before May 15 who has not yet filed an annual SF 278, however, would file a Termination SF 278, not a combined report. Note: This termination report will cover a period slightly longer than one year, including both the previous year and the current year up to the date of termination.

5.0 Filers

5.1 Registration

Certain FDM users (e.g., an agency legal advisor (a Senior Legal Counsel (SLC) or SLC Ethics Counselor), a Point of Contact (POC) or administrator, or supervisor) may register a Filer. Supervisors or Filers may ask their FDM-registered Senior Legal Counsel (SLC), Supervisor, Supervisor Assistant, or organization FDM point of contact (POC) to register them. They may need to provide the email address on their Common Access Card (CAC) and the name(s) of the legal advisor and supervisor to the agency FDM POC. In addition, the FDM Webmaster, FDMWebmaster2@hqda.army.mil, can assist with Filer registration.

5.2 Filer Login

Appendix E is a sample email to notify Filers to eFile. Filers login by selecting Login at the FDM website, .

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The FDM Login page displays with the User Notice pop up. Click OK to proceed to login to FDM.

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Use your CAC/PIN (or, if you have an Army Knowledge Online (AKO) account you may use your AKO User Name and password). [AKO policy requires password reset about every 150 days. Your AKO password must be reset if AKO expired it. Visit AKO, , to reset your password, then return to FDM.]

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The first time a Filer logs in FDM prompts to update contact information on the “My Info” tab:

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Notice that Filers must use the drop down list under Filer Category to indicate a Filer Category. This is used to report statistics of types of filers to the Office of Government Ethics annually. Review the other information, update as necessary, and click on Continue to proceed.

5.3 Adding a Filer’s Assistant

Some Filers take advantage of a feature to appoint one or more Filer Assistants to draft the report for the Filer. Assistants may create, view, edit, delete reports in Draft state, and only view other reports. Assistants may not submit a report nor make any changes after a Filer has submitted a report. Only Filers may amend reports (those a Filer first eSigned, then amended).

To add a Filer’s Assistant click on the My Info| My Assistant tab to open the My Assistants page:

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Select Add Assistant to open the Add an SF 278 Filer Assistant page:

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Enter your assistant’s name and Search. Your assistant must have a DoD CAC or an Army Knowledge Online (guest) account.

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Select and Confirm your Assistant.

The My Info| My Assistant tab displays the My Assistants page (below) with your assistant listed:

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Filers may remove an Assistant by clicking Remove.

5.4 Starting a Report

The top tier main menu for Filers has three tabs: My Reports, My Info, & Resources.

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The My Reports tab is the Filer’s main FDM workspace where the Filer will begin a new report or edit/view any previous report prepared in FDM. A Quick Reference, Filing a SF 278, , is also available.

After logging in to FDM, Filers (or a Filer Assistant) should go to the My Reports page to start a report. Select Add New Report as shown below:

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Repeat FDM Filers will find a list of their prior FDM report(s):

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Repeat FDM Filers also start a report by selecting Add New Report.

FDM displays the Getting Started screen shown below that identifies information helpful in preparing a report:

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Click Continue to advance in the report wizard.

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The Reporting Status choice affects what the Filer reports and what parts of the SF 278 must be completed. Appendix D summarizes this information.

When Incumbent is selected, FDM prompts for the year the report is due.

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Be sure to check the correct year if doing a report for other than the current year (e.g., a report prepared after returning from a combat zone period covering an earlier time period).

FDM prompts to use the information in a prior report to “prepopulate” a new report if the Filer used FDM previously. [pic]

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The Checkpoint page (below) displays cautioning the Filer to review the prior report information that was carried forward and indicates that the incumbent report is due by May 15, 2007 (in this case).

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Continue opens the Appointment Date page:

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Continue opens the Contact Information page of the Draft report. Be sure to check/indicate your Filer Category using the drop down list:

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The Filer category information, required for SF 278 Filers, is used for statistical reporting purposes in annual DoD reports to the Office of Government Ethics (OGE).

Continue opens the Position History page that indicates the Filer’s position Title, e.g., Commander:

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The Filer reviews the information and updates as necessary, then selects Continue to display the Job Description page where the Filer’s Job Description is attached (like attaching a document to an email):

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Then Continue to move into the report itself.

The My Reports sub-menu may contain up to eight items that appear when appropriate:

• Reports List - shows Filer’s previous report(s) (if any). This is where a Filer (or Filer Assistant) can begin a new report and edit/view all previously prepared reports.

• Report Data – main area used for preparing a report.

• Attachments – add/replace/view attachments associated with a report.

• Comments – area for recording Reviewer comments on a report.

• Flags – identifies missing or incomplete information that must be provided before the report is filed.

• Audit Trail – tracks all changes made to the report).

• View/Print – provides the user a view and print function for the report.

• Review Status – shows who has reviewed/approved a Filer’s report.

Inside the report, Filers will find these navigational tools to assist report preparation:

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5.4.1 Assets

Any previously reported Assets from the prior FDM-prepared report are listed (if pre-population feature used):

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Filer (or Filer’s Assistant) may Edit, Delete, Add Underlying Asset, or Add Comment for any items listed.

Select Add Asset to display the Add Asset page or Continue to proceed to the next section of the report (if no other assets to add). An Asset Name may be up to 256 characters.

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FDM now includes a feature to identify underlying assets of other reported assets, connecting them for review purposes. Check the “This is an underlying asset” and click Save to open the Select Parent Asset page:

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Select the appropriate parent and proceed. Continue editing prior reported assets, add any new assets, or advance to the Other Income section.

Note: on Incumbent (annual) reports, when reporting assets for the first time, FDM prompts to also report a Transaction where the asset was acquired. Doing so “populates” the Transaction section of the report for that asset and means minimal editing in that section.

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5.4.2 Other Income

Yes/No questions are used to enable Add pages for report sections that do not have any information pre-populated. Below you see the Report Data | Other Income section, Other Earned or Non-Investment Income page. A Yes answer opens the Add page for this section. A No answer moves to the next section of the SF 278 (e.g., Transactions).

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A Yes opens the Add Other Earned or Non-Investment Income page:

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5.4.3 Transactions (for Incumbent and Termination Reports only)

Transactions never pre-populate from a prior report but may pre-populate if the Filer “creates” a transaction when reporting an Asset in the Asset section. That feature is explained earlier. Below is the default Transactions page.

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A Yes answer opens this Add Transaction page:

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Note: Filers are encouraged to first report Assets in the Asset section and “create” transactions during the Add Asset process. That will fill in much of the required transaction information and save time. There is no “reverse” feature that will create an Asset if the Filer (or Filer Assistant) reports the transaction information before adding the Asset.

5.4.4 Gifts (for Incumbent and Termination Reports)

Like Transactions (5.4.3), gifts never pre-populate. The default Gift page with Yes/No answer option:

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Yes opens this Add Gifts, Reimbursements, or Travel Expenses page:

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5.4.5 Liabilities

The default Liabilities page:

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A Yes answer opens this Add Liability page:

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5.4.6 Agreements or Arrangements

The default Agreements or Arrangements page:

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A Yes answer above opens this Add Agreement or Arrangement page:

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5.4.7 Positions

The default Positions Held Outside U.S. Government page:

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A Yes answer opens this Add Position Held Outside US Government page:

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5.4.8 Comments

Filers (and other FDM users) may use the Comments tab for supplemental or explanatory information. For example, a Filer who had a Combat Zone or other extension who is now completing an SF 278 should add a comment to that effect indicating the date returned from the CZ. FDM does not currently recalculate the report due date for such an extension so the comment explains and documents it.

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5.4.9 Termination Reports

Army FDM users who are filing a Termination report may do so with the AKO user name and password without a Common Access Card (CAC). The report may not be submitted until the Filer’s last day of service in the Army or has retired or left the service (not while on transition or other leave).

Supervisors do not review Termination reports so Filers need only notify the SLC when eSigning the Termination report.

5.4.10 Wrap Up & eSign

When ready to electronically sign and submit the SF 278 proceed to the Wrap Up page.

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FDM will display a Report Ready for Submission page (with any Red Flags requiring further action by the Filer).

If there are no red flags the options are Submit Now or Submit Later.

Continue opens the eSign Report page (below):

[pic]Filers may click on View this report to display the report in a separate browser window as a multipage PDF.

Filers also should click on the link to the Annual Post-Employment Certification and Notification to Senior Officials on Post-Government Employment Restrictions (circled in red above), a 5-page notice that Filers should read before proceeding. A Filer’s signature on the SF 278 certifies awareness and compliance with the notice. This notice is a DoD Joint Ethics Regulation 8-400 requirement incorporated in FDM concurrent with eSigning the SF 278. FDM does not generate a separate document. (The annual notice is also on the FDM Resources tab. The notice content changes slightly each year (top of page 3, the dollar amount increases).)

Next, complete Step 2 indicating who FDM will notify in the Filer’s report review chain (e.g., SLC and/or Supervisor). That enables an eSign button at the bottom to electronically sign and submit the report.

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Selecting eSign results in a Submit Confirmed page and a link to the Filer survey:

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5.4.11 Amending a report

When necessary, a Filer may amend a report by starting on the My Reports | Reports List page. There will be an “Amend” option in the far right column of any report that may be amended:

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Reports in a Review Status of “Complete” may not be amended. The DAEO may allow amendment of reports “Submitted to DAEO” in FDM. Contact the SLC or DAEO for assistance.

Filers use the Report Data page navigation buttons to go to the specific reports section(s) to amend.

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Note: Filers must complete the Wrap Up eSign process again after amending a report before a reviewer may act on that report.

5.5 Log Out

Filers may then exit FDM using Log Out (upper right).

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6.0 Supervisors

6.1 Introduction

Supervisors of SF 278 Filers use FDM to review the Filer’s financial disclosure report online. As a Filer eSigns a report the Filer may cause FDM to email the Supervisor (and or SLC) a notice that the report is ready for review. The email includes the Filer’s name and a link to FDM, . The report will appear on the Supervisor’s Review Filers tab depending on the filter settings (see 6.7 below).

The FDM Learning Center | Documentation has a Quick Reference, QRC Reviewing a SF 278, that illustrates the steps in FDM to review a report.

6.2 Registration

Like a Filer, a Supervisor must be registered in FDM to use it. Certain FDM users (e.g., an agency administrator, supervisor, or agency legal advisor (SLC)) may register a Supervisor.

6.3 Login

After registration, Supervisors login at , just like Filers as explained earlier (see 5.2).

6.4 Reviewing a report

The Joint Ethics Regulation (JER) 7-206 requires Supervisors review SF 278s (except for Termination reports). Supervisors use FDM to review financial disclosure reports online. Reviewers are checking the reported financial interests for completeness, to identify any financial interests that may conflict with the Filer’s official duties, and that the report is administratively accurate and complete.

Supervisors generally start on the Review Filers tab with Role of Supervisor. In the Org Unit box, select “Show My Filer’s Reports” and Check the “Include . . . “ checkbox. Then set the Search criteria as shown below (or use Review Status: Under Review to limit to only those reports ready for Supervisor review. Use the Last Name field to Search for a particular Filer’s report.

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Reviewing a SF 278, , a Quick Reference, is available to explain reviewing a report. FDM offers two ways to review a report: Wizard View or View/Print View.

6.4.1 Wizard View

The Wizard View provides the same view the Filer uses when creating the report, answering questions and providing report information. The same FDM Report Data progress bar navigation buttons allow the Supervisor to move section by section through the report.

The Wizard view allows the Supervisor to add comments tied to a specific item by using the Add Comment feature (in the far right column of each reported item). Comments are a way of clarifying reported information, alerting the Filer to missing information, over reporting, or other information that the agency report certifying official may need.

In addition, Supervisors may find the Review Filers tab Comments, Flags, and Audit Trail items useful.

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6.4.2 View/Print Review

Some Supervisors prefer to view the SF 278 in the traditional paper view. On the Review Filers | Reports List tab, select the Report you want to View, then select View/Print to open the report.

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An Adobe PDF of the report will appear in a separate browser window for viewing or printing.

Note: depending on the length of the report it may take several minutes to appear completely.

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At the bottom of the screen are the page advance buttons to page through the report on screen. Print the report as you would any PDF file.

6.5 Electronically signing (eSigning) a reviewed report

The Supervisor may View the report or proceed direct to eSign by selecting the appropriate choice in the far right column on the Review Filers | Reports List Welcome page.

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The eSign choice displays the eSign Report page where the Supervisor may View the report or click eSign (bottom):

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After clicking eSign, FDM records the Supervisor’s electronic signature and displays the Review Filer | Reports List tab showing the Supervisor may only View the report now.

Supervisors may review and eSign other reports or Log Out.

6.6. eSigning an amended report

A Supervisor must eSign again if a Filer amends a report after the Supervisor eSigned it. The eSign process for an amended report is the same as eSigning a report (6.5). The Supervisor may want to use the FDM Audit Trail tab for that report to quickly see what the Filer changed or amended.

6.7. Log Out

Use the Reports List tab to move to other reports or Log Out of FDM (upper right corner).

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Appendix A

What is New in FDM 278 Release 5.0

FDM Release Notes, , provide details on features added in earlier releases (e.g., 3.x, 4.1, and 5.0). Here are a few highlights and additional FDM resources on specific topics.

A.1 Prior Reports

To conserve limited development funds, SF 278 reports prepared before December 2006 can only be viewed as PDF documents.

A.2 “Org Unit”

FDM introduced an “Org Unit” construct to group filers by reviewing Supervisor. See the QRC, QRC Managing Org Units, or the short video tutorial, Managing FDM Org Units, and FDM 278 SOP, Enclosure 10, for more on this new tool.

A.3 Global Directory Service

FDM connects to the Defense Information Systems Agency (DISA) Global Directory Service (GDS) for FDM access and use. GDS provides a DoD-wide service for identification from any place at any time. This means that any DoD Common Access Card holder may use FDM (if the Agency is using FDM). This also allows non-Army reviewers to be FDM users to review reports of Army Filers in FDM.

For further information or assistance contact the FDM Webmaster, email at FDMWebmaster2@hqda.army.mil, or by phone at 703.696.5512.

A.4 Notifying Filers to File – Required Activity

One of the new FDM features is "Required Activity." DAEOs, DAEO ECs, SLCs, SLC ECs, & POCs, use it to notify registered filers to do their report in FDM. Using this feature will enable FDM to generate the statistical information on Filers for the annual OGE report. This feature is explained in the Quick Reference Card: Managing Filer Activities. In addition, the FDM Learning Center | Tutorials, includes a short video tutorial: Managing FDM Required Activities.

To assign a required activity go to the My Info | Required Activity screen. In the Org Unit filter box are several combination settings:

• Show Required Activities for My Orgs – shows at that particular current level

• Show My Required Activities – shows all where you are responsible (role dependent)

• Show My Required Activities and Include Required Activities for Org Units assigned to other SLCs – shows all at your level and below, regardless that another person has the same role as you in subordinate organizations (this allows a higher headquarters user to assign the required activity for an entire organization/agency).

After you assign the required activity, you may email “notify” all selected Filers. A sample email is in the FDM 278 SOP.

Note: Do not use special characters such as , =, &, :, or quotes in FDM notices.

A.5 “?How Do I . . . “

Many FDM screens now include a link to context-sensitive, topical Quick References – click on the

[pic] for information.

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A.6 Role & Change Role

FDM includes a Role button for all users and the “Change” feature for those users with multiple roles.

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A.7 Revised FDM Glossary

With OGE staff assistance the FDM Glossary, , was substantially revised.

A.8 Revised FDM 278 Common Questions & Answers

With OGE staff assistance, the FDM 278 Common Questions & Answers, , were substantially improved.

Coming in March . . . an FDM “compare report” feature that will highlight changes in reports between two FDM reports.

Appendix B

FDM Website Index

FDM Home page:

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What is FDM

• Introduction to FDM

• Why Use FDM

• Get FDM

• Security

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Learning Center

• Getting Started

• Tutorials

• Documentation (including Quick Reference Cards)

• Glossary

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Help & Support (732) 532-5566, DSN 992-5566

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• FAQs

• Knowledge Center

• Resources (includes links to Financial Disclosure resources and references)

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Agency Contact & Information

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Appendix C

Financial Disclosure Management (FDM) Preview

An FDM Preview instance is available for agency ethics staff to experience and evaluate FDM. FDM Preview is an almost exact duplicate of FDM production except that it is not for real data or real financial disclosure report Filers.

The FDM features work the same. In FDM Preview, legal staff may experience different roles e.g., as a Filer or Supervisor, to prepare for assisting FDM users in those roles on FDM production.

Access to FDM Preview is by special approval. Contact your Agency FDM POC or the FDM Webmaster to request access. Most legal advisors request access as an SF 278 Filer initially. Email: FDMWebmaster2@hqda.army.mil or telephone 703.696.5512.

FDM Preview:

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Appendix D

SF 278 Schedules and Applicable Reporting Periods

FDM automatically helps the Filer correctly report based on the report type and Filer status (e.g., New Entrant, Incumbent).

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This chart is available on the FDM website, , Help & Support | Resources tab.

Appendix E

Sample Notices to Filers to Use FDM

New Entrant Filers:

Financial Disclosure Management (FDM), a secure, online software program, is available to electronically file and process your required SF 278, Public Financial Disclosure Report. The FDM web site is . Your report is due 30 days after you were promoted to Brigadier General or attained Senior Executive Service status. Contact your legal advisor if you have questions about the report, using FDM, or need an extension to file.

Incumbent Filers:

As you recall, your annual SF 278, Public Financial Disclosure Report, is due by 15 May. Use Financial Disclosure Management (FDM), a secure, online software program. The FDM web site is . One of FDM’s advantages for returning users is the “prepopulate” feature. After you login and are on the My Reports | Reports List tab, select “Add New Report” to start your 2008 report. You will be asked if you want to “pre-populate” your report with the information from your last report.

Filers who use FDM also complete the Annual Post-Employment Certification and Notification to Senior Officials on Post-Government Employment Restrictions concurrent with eSigning the SF 278. This is a DoD Joint Ethics Regulation 8-400 requirement incorporated in FDM concurrent with eSigning the SF 278. FDM does not generate a separate document.

A Quick Reference, Filing an SF 278 is available: .

Note: If your Supervisor or legal advisor reflected in FDM has not been updated please notify me.

Contact your legal advisor if you have questions about the report, using FDM, or will need an extension to file.

Announcement:

Subject: Use Financial Disclosure Management (FDM); SF 278, Public Financial Disclosure Report, Preparation and Electronic Filing

1. Annually by 15 May, Presidential Appointees, active duty General Officers, reserve General Officers who served over 60 days active duty during 2007, and Senior Executive Service personnel must complete an Annual Post-Government Employment Restrictions Notification and Acknowledgement and Standard Form (SF) 278, Public Financial Disclosure Report. Using the Army FDM secure, web-based program () is the way to complete and maintain these important documents. In addition, report reviewers and ethics officials use FDM’s online review and approval features to complete electronic processing of the report. FDM’s digital signature technology works with your Common Access Card (CAC) and Personal Identification Number (PIN).

2. Filers who use FDM also complete the Annual Post-Employment Certification and Notification to Senior Officials on Post-Government Employment Restrictions concurrent with eSigning the SF 278. This is a DoD Joint Ethics Regulation 8-400 requirement incorporated in FDM concurrent with eSigning the SF 278. FDM does not generate a separate document.

3. Consult your legal advisor for assistance.

4. The Office of the General Counsel (OGC) is responsible for the development and operation of FDM. Within the OGC, the Deputy General Counsel (Ethics and Fiscal) is responsible for the execution and management of FDM. The point of contact is Mr. George Hancock, George.Hancock2@hqda.army.mil, or 703-696-5512.

Appendix I is a Quick Start for the Incumbent SF 278 Filer that you might attach to an email.

Appendix F

Reporting Capacity Limits

FDM has some limits on the amount of information it can contain. For example, an asset name is limited to 256 characters.

This table lists the current FDM System maximum capacity by report section. FDM will warn the filer when they have entered the maximum number in a section. These limits were established using current disclosure line item counts but can be adjusted if required. Successful viewing the PDF rendering of a SF 278 is highly dependent on the memory configuration of the viewer's workstation. Vewing of the SF 278 in PDF format is not required to complete the eSigning.

|Disclosure Section |Limit – maximum number of items |

|SF 278 | |

|Assets & Other Income (combined) |501 (going to 1,000) |

|Transactions |501 (going to 1,000) |

|Liabilities |55 |

|Gifts |55 |

|Agreements |66 |

|Compensation |66 |

|Positions |66 |

| | |

|FDM-450 | |

|Non-Investment Income and Assets and Investment Income |282 |

|(combined) | |

|Liabilities |51 |

|Outside Positions |68 |

|Agreements or Arrangements |51 |

|Gifts and Travel Reimbursements |68 |

For example, an SF 278 Filer may report up to 55 different Gifts or 66 agreements in the same report.

If you encounter Filers needing to report more than these limits please contact the FDM Webmaster (mailto:FDMWebmaster) ASAP.

Appendix G

SLC FDM Quick Start Checklist

• Am I registered as an FDM SLC?

– Try to access FDM, , or contact your Deputy DAEO FDM POC. Only SLCs appointed as Ethics Counselors with financial disclosure report responsibilities are registered as SLCs in FDM.

• What FDM 278 resources should I have available?

– The FDM 278 SOP and this FDM 278 SLC User Guide

• How do I add an Ethics Counselor or Assistant to screen and manage Filers/reports for me?

– See 4.4.1, Registering an Ethics Counselor, or 4.4.2, Registering an Assistant, or Managing Assistants,

• Have I alerted my SF 278 Filer(s) to file?

– If not, do so as reports are due not later than 15 May unless an extension is requested and obtained from the Deputy DAEO. See Appendix E for a sample.

• How do I register SF 278 Filers I support?

– See 4.4.4, Registering a Filer or Quick Reference, Managing Filer Registration: .

• Have I tried FDM Preview, the FDM training site, , for legal community users?

– The FDM Training Site is a special version of FDM for training. Many SLCs are registered as SF 278 filer to gain experience with FDM. Contact the FDM Webmaster if you want to use the FDM Preview site.

• If my AKO user name and password does not work with FDM have I visited AKO to reset my AKO password?

– If not do so as AKO expires passwords every 150 days.

For assistance with Financial Disclosure Report policy and substantive matters contact the Deputy DAEO/FDM Point of Contact for your organization.

The FDM website, , includes Help information and other resources. (Appendix B has more information on the FDM website.)

For questions on FDM performance or error notices call (732) 532-5566, DSN 992-5566 (available Monday – Friday 7:00 a.m. – 6:00 p.m. Eastern). Messages recorded at other hours. The FDM User Service Center email is: CELCMCFDMSupport@mail1.monmouth.army.mil for similar issues.

Contact the FDM Webmaster by email at FDMWebmaster2@hqda.army.mil or by phone at 703.695.5512.

Appendix H

FDM 278 Senior Legal Counsel(SLC)/

SLC Ethics Counselor (EC) Quick Start

Introduction:

Welcome to the Financial Disclosure Management (FDM) software program that helps Filers accurately prepare and electronically file a Financial Disclosure Report (either the Standard Form (SF) 278, Public Financial Disclosure Report, or the Office of Government Ethics (OGE) Form 450, Confidential Financial Disclosure Report). FDM is a secure, online application that simplifies financial disclosure report preparation and review saving time and eliminating common errors.

FDM supports the DoD transformation of enterprise management and a specific DoD priority: “Improve Effectiveness and Efficiency Across the Board.” In 2008, FDM is being considered for DoD Enterprise-wide use and is in use in OSD, JCS, the Air Force, Navy, Air National Guard, DISA, the Office of Government Ethics, and the Department of Veterans Affairs, among others.

The purpose of the SF 278 is to help employees avoid conflicts between their official government duties and their private financial interests or affiliations. It also helps them avoid conflicts that result from the financial interests and affiliations of their spouses and dependent children.

Agency review of the SF 278 helps employees avoid conflicts of interests. It also protects the agency by giving the agency a chance to deal with conflicts of interest internally instead of publicly. The review also provides an in-depth, methodical review process to identify conflicts (or potential ones) that employees may overlook and to take appropriate preventive or corrective action.

SLCs have very important responsibilities in the processing of the SF 278, Public Financial Disclosure Reports, for your organization. Deputy Designated Agency Ethics Officials (DDAEOs) usually appoint the senior legal counsel/advisor at an activity, organization, or installation, as an FDM SLC. In FDM the SLC is the legal advisor to the 278 Filer or the Supervisor of that Filer. You may appoint one or more ECs to assist you. Any SLC EC you appoint (on the My Info | My ECs tab) will see the same reports that you see as FDM is role-based and access to information depends on what role(s) a user has. SLCs manage any appointed ECs (add/remove upon departure).

This Quick Start guide introduces the most likely FDM features and resources you will need in your role. Please share this information with any ECs and assistants you appoint. In addition to this guide, you may find the FDM 278 SOP, Enclosure 9, Reviewing an SF 278, with its checklist for reviews, helpful.

Getting Started in FDM: Browse the FDM web site, , especially the Learning Center and the Help & Support tabs. The FDM Learning Center, , includes short video tutorials () (e.g., Managing Required Activities, Managing Extensions), and topical Quick Reference Cards (QRCs) () that are often two to six pages of screen shots and step-by-step explanations of select FDM features or functions including:

|Filing an SF 278 |Managing Filer Activities |

|Reviewing an SF 278 |Managing Org Units |

|Managing My Filers (including how to add Filers) |Granting Extensions |

You may find it helpful to scan the FDM 278 SOP and the FDM 278 SLC User Guide (check the FDM Resources page, , for the latest versions). The SOP includes suggestions for migrating from paper report processing, a timeline for identifying Filers, and a checklist for reviewing an SF 278.

Login to FDM: FDM is simple to use, much like TurboTax. The first time a new FDM user logs in the Contact Info screen appears. Complete any missing information and Save to proceed to the standard FDM navigation tabs:

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Note: You will not have a “My Reports” tab or an “Assist Filers” tab unless you are a report Filer or have been appointed as a Filer assistant.

The Admin tab, sub-tabs Org Units, POCs, and Supervisors are the locations where you create new org units (or edit the existing org unit name/description), register org unit POCs (who assist/manage their Filer lists), register Supervisors (Delete old/Assign new Supervisors who leave/arrive at the Org Unit).

The Admin | Users tab is an online directory of all registered FDM users and their profile (roles) in FDM. This is very useful when seeking a user’s FDM org unit location, an email address, or phone number.

Seeing Your 278 Filers: Go to My Info | My Filers (check your role – SLC or SLC EC) to see your Filers. Use “SELECT Next Level Down” to display Filers in a particular org unit at subordinate levels.

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You may want to mark the “Show My Filers” (instead of “Show Filers for My Orgs”) to see all Filers in org units at the current level and below where you are named as SLC. Check “Include Filers for Org Units assigned to other SLCs” to see 278 Filers where another SLC is registered in FDM for those 278 Filers at levels subordinate to the Filer/org unit where you are the SLC.

Checking on FDM Users: The Admin | Users tab is search tool for any FDM user showing a user’s FDM role(s) (and Org Unit location if a Filer).

Adding New Filers: Most Army 278 Filers are already registered in FDM in an “Org Unit” that has one or more Filers, a Supervisor, an SLC, and a Deputy DAEO (278 certifying authority). Contact the FDM Webmaster or your DDAEO’s FDM POC to register newly promoted Brigadier Generals and new SES employees. When doing so, provide the Supervisor’s name. (SLCs/SLC ECs may register Filers in FDM on the My Info | My Filers tab in an existing Org Unit associated with the Filer’s Supervisor (or, add a new org unit if needed).) A short video tutorial, Managing FDM Filers, and a Quick Reference Card (QRC), QRC My Filers, explain the Filer registration process.

Updating FDM 278 Supervisors: If an exisiting FDM org unit should have a new Supervisor go to Admin | Supervisor tab and select next level down until you reach the level where you want to replace the Supervisor. There, use Delete, then Assign the successor.

Moving 278 Filers: If an FDM-registered Filer (or Supervisor) changed assignments since last using FDM (e.g., PCS, new Supervisor), (s)he may need to be moved in FDM’s org unit hierarchy. SLCs/SLC ECs may request the FDM Webmaster or Help Desk assist, especially if the 278 Filer to be moved was under a different Deputy DAEO authority for the last report in FDM.

After Filers are registered/moved to the current organization, consider using one of the new FDM features: "Required Activity" (My Info | Required Activity tab). When you want to notify your filers that they should do their report in FDM, go to the My Info | Required Activity screen where you assign the filing requirement for any/all of your filers, then select Notify. FDM will open a partially completed email that you may edit before sending. See the Quick Reference: Managing Filer Activities, . In addition, the FDM Learning Center, , includes a video tutorial on it: Managing FDM Required Activities. The FDM 278 SLC User Guide has a sample email for notifying SF 278 Filers to file.

Notes:

1. One of the future advantages of FDM 450 is to eliminate the requirement to report numbers of filers, categories, etc., for the annual OGE report. FDM will compile that information once all the Army is using FDM. (All Army SF 278 Filers already use FDM. All Army OGE 450 Filers will be using FDM by the February 2009 filing season.)

2. Some offices are reporting that the local IMO has blocked emails with multiple to addressees of more than 20 or 30 people at one time.

In your "notice to file using FDM" email, you may want to add a sentence about a Quick Reference, Filing an SF 278:

You may find the short Quick Reference Card, Filing an SF 278, , useful as an introduction to FDM or a quick refresher if you haven’t used FDM recently. SF 278 Filers with prior reports in FDM may prepopulate the next report using information from the last one to save time. A chart summarizing what to report is at .

A sample email notice is in the FDM 278 SLC User Guide.

Filer Departed?

If your list of 278 Filers (My Info | My Filers tab) shows a 278 Filer who departed your AOR notify the FDM Webmaster or Help Desk to move the Filer to another FDM location.

Filer Assistant: Many SLCs/SLC ECs serve as Filer Assistants to the 278 Filer and draft the report for the Filer. Some 278 Filers also appoint an Aide or Executive Assistant as a Filer Assistant (My Info | My Assistants tab). The FDM Webmaster or the DDAEO FDM POC may add you as a Filer Assistant.

Extensions: See the Quick Reference: QRC Granting Extensions, or the short video tutorial, Managing FDM Extensions. DDAEOs have authority to grant extensions. Some DDAEOs further delegated this authority to subordinate Ethics Counselors. FDM allows recording of any extension granted to a 278 Filer until the DDAEO completes the report. Extension requests are still processed outside FDM, but may be added as an attachment (Attachment tab in a Report). Currently, only DAEOs or DAEO ECs may record the extension in FDM. A future release will extend this ability to SLCs & SLC ECs.

Reviewing an SF 278 in FDM: The FDM Learning Center | Documentation includes a Quick Reference, QRC Reviewing a SF 278, that covers the FDM mechanics for moving through a report (either in Report Wizard view, section-by-section, or the View/Print method (displays the 278 in printable PDF)). The FDM 278 SOP has a detailed checklist for reviewing an SF 278 substantively.

On the Review Filers | Reports List tab, set your role as SLC (or SLC EC) and the Org Unit to the level you desire (Select Next Level Down).

Mark the “Show My Filers Reports” to see all your Filers where you are the Filer’s SLC. (Do not check the “_Include . . .” unless you want to see reports assigned to other SLCs at subordinate levels in addition to those where you are the SLC.)

In the Search box, set the form type to SF 278, year: 2008 (unless looking for reports for an earlier year), Reporting Status: ALL, and Review Status: Under Review (or ALL or draft). (Once a 278 Filer eSigns the report status changes from Draft to Under Review.) A table of available reports will display. You will have several options: View, End Review, eSign, & Submit to DAEO. Many SLCs who appoint SLC ECs have the SLC EC use “End Review” to indicate the report is ready for the SLC’s eSign.

When finished checking the report contents and you are ready to End Review or eSign go to Wrap Up and follow the on-screen instructions.

After the Filer’s SLC and Supervisor have eSigned the report is ready to “Submit to DAEO” so the DAEO (certifying authority) may complete the report. Any reviewer, including the DAEO’s FDM POC may advance a report to that status. While in Submitted to DAEO status the Filer may not amend the report.

Helping Supervisors Find Reports to Review: Supervisors needing to review SF 278s do so on the Review Filers | Reports List tab, using the settings shown below:

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In the Search box, use the Last Name and First Name fields to find the specific 2008 report to review.

FDM Preview: is a duplicate of the FDM Production site reserved strictly for legal community users to experience FDM as a “pretend” SF 278 or OGE 450 Filer. Contact the FDM Webmaster if interested in test driving FDM as a pretend Filer.

FDM Usage Cautions:

• Use FDM’s buttons (e.g., “back”) when available instead of the Internet Explorer (IE) Back/Forward)

• Repeated unsuccessful login (due to expired password or wrong PIN entry) will temporarily “lock” the user out after three wrong tries. After the 30-minute “lock out” open a new IE window and login.

Using FDM Successfully:

1. When changing screens in FDM watch the upper right corner of your Internet Explorer Window for the “flying Windows flag icon” [pic] or the status bar at the bottom of the screen for an indication

[pic] that FDM is accomplishing your action. If both “stop” completely you may need to click on the action again. At times FDM may appear to stall or go slower than you expect. Opening a very large PDF of an SF 278 will take a few seconds to a minute or more depending on the size of the file. Avoid double clicking whenever possible.

2. Keep 278 Filers and Supervisors informed. For example, email your Filer(s) a reminder to efile and include links to the Quick Reference, Filing an SF 278. When 278s are ready for Supervisor review, email the Supervisor to review using the suggested notice in the FDM 278 SOP and mention the Quick Reference, Reviewing an SF 278, as well as the suggestions at the bottom of page 4 for finding a report.

3. Check the FDM Learning Center | Tutorials tab, , for short videos on specific subjects. Each will self-play or use the control bar to pause (||),

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rewind (>) at your pace.

4. FDM includes a [pic] symbol for more information on a particular task.

5. Most FDM screens include Common Questions and Answers tailored to that particular area of a report or on FDM use. See the entire set of FDM 278 Common Questions & Answers: .

6. FDM’s Glossary: .

7. FDM Known Issues: all software has bugs or defects that may impede its effectiveness. Check FDM’s Known Issues area, , to see any reported known issues and suggested workarounds.

8. FDM Help Desk: (732) 532-5566, DSN 992-5566, Staffed 7:00 AM to 5:00 PM Eastern Time. Voice mail available for other times. The email is: CELCMCFDMSupport@mail1.monmouth.army.mil.

9. Contact the FDM Webmaster by email at FDMWebmaster2@hqda.army.mil or by phone at 703.696.5512. Send comments or suggestions for improvements to the FDM Webmaster.

FDM: Faster, Easier & More Accurate Financial Disclosure Reporting & Reviewing

Appendix I

Quick Start: Financial Disclosure Management (FDM)

S: Annual Report due NLT 15 May

What is FDM?

Financial Disclosure Management (FDM) is a SECARMY-approved, secure, web-based program to help you (your Assistant) prepare your SF 278, Public Financial Disclosure Report.

Using several “TurboTax®”-like screens, questions, and “flags,” FDM simplifies your report preparation, eliminating common errors and saving time.

• FDM enables you to (optionally) appoint an Assistant(s) to help you prepare your report.

• You, any assistant(s) you appoint, and your reviewers have access to your report.

• You are the only one who can submit your report online or amend it.

• FDM eliminates reentering information that is carried forward from year to year by enabling you to “pre-populate” a new report from a previous report’s data.

How do I access FDM?

Login at using the Common Access Card (CAC) and Personal Identification Number. (Army users may also use the AKO user name/password.)

How do I use FDM to prepare and electronically file my report?

1. Gather your reportable financial information (e.g., asset information, income tax statements). Note: You will need an electronic version of your current job description to attach to your Report (e.g., a Microsoft Word document or a scanned paper document). If you don’t have one readily available, you may want to ask your assistant to prepare one while you are filling out/verifying your financial information.

2. You may appoint an assistant(s) to help you draft your report (My Info | My Assistants, Add Assistant).

3. After login, FDM presents a set of clickable tabs and “sub-menu” items to aid you navigate through the steps to prepare your report. Most filers will see tabs named My Reports, My Info, and Resources arranged across the top of the FDM screen, as shown in this screen shot. (Filers who are also Supervisors will have a Review Filers tab.)

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4. Click Add New Report then Continue. On the Reporting Status page, select the appropriate report (probably Incumbent (the default) if you previously filed an SF 278 (even if you did not use FDM).

Hint: FDM provides Continue and Back buttons at the bottom of the FDM page to “navigate through” the steps to prepare your SF 278. Please use these buttons not your Internet Explorer browser’s Forward and Back buttons.

5. Select the year report due (2008), Continue until you see “Your new report is ready . . .” After setting up your report with this administrative information you may stop and return later to finish it.

6. Once you have entered all your data and have cleared any red flags, the Wrap Up enables you to electronically file your report online.

7. Before eSigning your report select who FDM should notify that your report is ready for review: your named supervisor and/or legal advisor. If the information shown needs changing please contact your legal advisor for assistance. FDM will e-mail a notification that you signed your report and it is ready for review.

How do I pick up where I left off?

Each time you log back into FDM, go to your My Reports tab to see a list of your reports. Pick the report you want to Edit then use the navigation tabs to move directly to the desired section. For example, to add a Transaction, simply click Edit on the desired report and then click Transactions (in the report progress bar row of tabs or buttons that appears just above the Getting Organized title on the page).

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Is that all there is?

Yes, to start just click Add a New Report, and click Continue to move forward through the process after providing any requested information. Most FDM pages have explicit instructions and handy reference material (Common Questions -- on the right hand side of the screen).

What if I need further assistance?

The FDM website has a Quick Reference with step-by-step instructions and screen shots: . Contact your Senior Legal Counsel (e.g., Staff Judge Advocate, General Counsel, Ethics Counselor). You may also send suggestions and comments to the FDM Web Master by email at FDMWebmaster2@hqda.army.mil, or by phone at 703.696.5512.

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Overarching goal for FDM:

“Make the preparation and review of the SF 278 easier and less time consuming, especially for Incumbent filers with few annual changes.”

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Use to move to different report section

Report Data | Add Asset

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Filers are encouraged to take the Filer survey and provide feedback about FDM.

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Use to move to different report section

Report Data | Add Asset

Page Title

Common Questions

Click to display

Log Out

Click to exit FDM

Instructions

Provide directions on how to enter data

Tab Menu Items

Click to display

Common Questions

Click to display

Log Out

Click to exit FDM

Instructions

Provide directions on how to enter data

Tab Menu Items

Click to display

Tabs

Click to display the first page for the tab and any tab menu items

Tabs

Click to display the first page for the tab and any tab menu items

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