New Entrant Report U.S. Office of Government Ethics; 5 C.F.R. part 2634 Form Approved: OMB No. (3209-0001)(March 2014) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information DONNELLY, SALLY Senior Advisor to Secretary of Defense, OSD, Office of the Secretary of Defense Date of Appointment: 01/21/2017 Other Federal Government Positions Held During the Preceding 12 Months: Advisor, Defense Business Board, 1/2015 - 1/2016 Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge. eSigned in FDM by: SALLY DONNELLY User ID: 760E3EC284BE6251 05/17/2017 Agency Ethics Official's Opinion - On the basis of information contained in this report. I conclude that the filer is in compliance with applicable laws and regulations(Subject to any comments below). Other review conducted by U.S. Office of Government Ethics Certification 1. Filer Positions Held outside United States Government # NAME CITY, STATE OGE TYPE POSITION FROM 1 American Friends of the Black Stork New York, NY, USA Director 01/2013 06/2015 2 3 4 Donnelly Seaview LLC Imperatis SBD Advisors Columbia, SC, USA Arlington , VA, USA Washington, DC, USA Non-Profit Organiza tion Business Enterprise Business Enterprise Business Enterprise TO co-owner Director Officer 11/2012 Present 06/2014 12/2016 02/2012 01/2017 2. Filer's Employment Assets and Income # DESCRIPTION EIF VALUE 1 Time Warner Employee Savings Plan(401K) N/A $50,001 - $100,000 1.1 1.2 Time Warner Inc. Common Stock Time Warner Large Cap Value Fund No No $1,001 - $15,000 $1,001 - $15,000 INCOME TYPE INCOME AMOUNT Dividends None (or less than $201) $201 - $1,000 None (or less than $201) 1.3 Time Warner Growth Fund No $15,001 - $50,000 1.4 Capital Preservation Fund No $1,001 - $15,000 2 3 SBD Advisors LLC N/A Donnelly Seaview LLC - Columbia, SC (Residential Real N/A Estate) Calvert Balanced Portfolio Fund - A Yes $1,000,001 - $5,000,000 Partial sale/SBD $500,001 - $1,000,000 Rent and Royalties None (or less than $201) None (or less than $201) $390,000 $5,001 - $15,000 $1,001 - $15,000 $201 - $1,000 "TEGNA Common Stock (Sole Ownership)" TEGNA Common Stock (Joint Ownership) T. Rowe Price Diversified Mutual Funds (Joint Accoun t with Spouse) T. Rowe Price Capital Opportunity (PRCOX) (Joint Acco unt with Spouse) T. Rowe Price New Era Fund (PRNEX) (Joint Account wit h Spouse) T. Rowe Price Science & Technology Fund (PRSCX) (Join t Account with Spouse) T. Rowe Price TRP Capital Appreciation (Joint Account with Anna Rumer) T. Rowe Price TRP New Era (Joint Account with Anna Ru mer) Gannett Investments Common Stock (Joint Account with DC) Gannett Investments Common Stock (Individual Account) Gannett Investments Common Stock (Joint Account with Spouse) Wells Fargo Checking Account (Joint with Spouse) Wells Fargo Savings Account (Joint with Spouse) Personal Salary / Distributions (SBD Advisors) SBD Advisors Time Warner Pension Yes Yes N/A $100,001 - $250,000 $100,001 - $250,000 $250,001 - $500,000 Yes $15,001 - $50,000 Yes $15,001 - $50,000 Dividends, Capital Gains Dividends Dividends Dividends, Capital Gains Dividends, Capital Gains Dividends Yes $1,001 - $15,000 $201 - $1,000 Yes $15,001 - $50,000 Yes $15,001 - $50,000 Dividends, Capital Gains Dividends, Capital Gains Dividends No $15,001 - $50,000 Dividends $201 - $1,000 No No $15,001 - $50,000 $15,001 - $50,000 $1,001 - $2,500 $201 - $1,000 N/A N/A N/A N/A N/A $250,001 - $500,000 $500,001 - $1,000,000 Dividends Dividends, Capital Gains Interest Interest Salary Bonus Income Retirement Plan or Account 4 5 6 7 7.1 7.2 7.3 7.4 7.5 8 9 10 11 12 13 14 15 $2,501 - $5,000 $201 - $1,000 $1,001 - $2,500 $201 - $1,000 $201 - $1,000 $201 - $1,000 $201 - $1,000 $1,001 - $2,500 $1,001 - $2,500 $250000 $25000 $9745 3. Filer Employment Agreements and Arrangements # EMPLOYER OR OTHER PARTY TO AGREEMENT/ARRANGEMENT CITY/STATE STATUS AND TERMS 1 Time Warner Defined Benefit Pension New York, NY, USA 2 Time Warner Savings Plan (401K) New York, NY, USA Continuing participation in Employee Benefit Plan: I 04/2007 receive pension payments from my former employer. Th is information is also included under income. Continuing participation in Employee Benefit Plan: N 10/1985 either I nor my former employer continue to make cont ributions to this plan. DATE 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 2 3 Amazon Web Services Association of the US Army Bloomberg, LP Seattle, WA Arlington, VA New York, NY Consulting Consulting Consulting 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 C. Ham C5 ETO Group, LLC Foreign Policy General Motors LLC GeoPoll Human Rights First KnuEdge, Inc. M. Flynn Medecins Sans Frontiers USA, Inc MGM Consulting Palantir Technologies RCF Management LLC Sasakawa Peace Foundation USA SBD Advisors Skadden, Arps, Slate, Meagher & Flom LLP The Palm Center Uber World Wildlife Fund Washington, DC New York, NY Tampa , FL Washington, DC Detroit, MI Washington, DC Washington, DC San Diego, CA Washington, DC New York, NY Annapolis , MD Palo Alto, CA Escondido , CA Washington, DC Washington, DC Washington, DC San Francisco , CA San Francisco, CA Washington, DC Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Officer Consulting Consulting Consulting Consulting 5. Spouse's Employment Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Spouse Individual Retirement Account (IRA) N/A $250,001 - $500,000 Dividends, Capital Gains $1,001 - $2,500 1.1 Avenue Credit Strategies Investor Yes $1,001 - $15,000 1.2 Baron Emerging Markets Fund Retail Yes $1,001 - $15,000 1.3 Columbia Dividend Opportunity Class A Yes $1,001 - $15,000 1.4 Columbia Select LRG Cap Growth Class A Yes $15,001 - $50,000 1.5 Delaware Value FD CL A Yes $15,001 - $50,000 1.6 Doubleline Low DURTN EMERG MKTS FX INC Yes $1,001 - $15,000 1.7 Dreyfus Bond Market Index INVS Yes $15,001 - $50,000 1.8 Driehaus Micro CAP Growth Fund Yes $1,001 - $15,000 1.9 Driehaus Event Driven Fund Yes $1,001 - $15,000 1.10 Driehaus Active Income Fund Yes $1,001 - $15,000 1.11 Fidelity 500 Index Premium Class Yes $15,001 - $50,000 1.12 Fidelity Government Cash Reserves Yes $1,001 - $15,000 1.13 JP Morgan Strategic Income Opportunity A Yes $1,001 - $15,000 1.14 LM BW Absolute RTRN Opportunities CL A Yes $1,001 - $15,000 Dividends, Capital Gains Dividends, Gains Dividends, Gains Dividends, Gains Dividends, Gains Dividends, Gains None (or less than $201) $2,501 - $5,000 Capital None (or less than $201) None (or less than $201) $2,501 - $5,000 Capital $2,501 - $5,000 Capital $2,501 - $5,000 Capital $2,501 - $5,000 Capital $1,001 - $2,500 Dividends, Capital Gains Dividends, Capital Gains None (or less than $201) $2,501 - $5,000 $1,001 - $2,500 None (or less than $201) None (or less than $201) 1.15 MFS International Value Fund CL A Yes $1,001 - $15,000 1.16 T Rowe Price Growth Stock Advisor CL Yes $15,001 - $50,000 1.17 Ridgeworth Ceredex Mid-Cap VAL EQ I Yes $15,001 - $50,000 1.18 Rivernorth Core Opportunities FD CL R Yes $1,001 - $15,000 1.19 Riverpark Short Term Hi Yield Yes $1,001 - $15,000 1.20 Riverpark Strategic Income Yes $1,001 - $15,000 1.21 Double Line Total Return Bond Fund Yes $15,001 - $50,000 1.22 Victory Global Natural Resources Fund Yes $1,001 - $15,000 1.23 Touchstone Small Cap Value Fund Yes $1,001 - $15,000 1.24 Touchstone Focused Fund Yes $1,001 - $15,000 1.25 Wasatch Frontier Emerging Small Fund Yes $1,001 - $15,000 1.26 Wasatch International Opportunities Fund Yes $1,001 - $15,000 1.27 T Rowe Price International Stock Yes $1,001 - $15,000 1.28 TCW Relative Value Dividend Fund Yes $15,001 - $50,000 2 3 Carnegie Endowment for International Peace College of Charleston N/A N/A 4 Cowen Services Company LLC N/A 5 Dartmouth College N/A 6 Gerson Lehrman Group, 60 East 42d Street, NY N/A 7 8 Massachusetts Institute of Technology SAIC, 151 Lafayette Dr., Oak Ridge, TN N/A N/A Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Salary Income from personal services Income from personal services Income from personal services Income from personal services Royalties Income from personal services None (or less than $201) $2,501 - $5,000 $5,001 - $15,000 None (or $201) None (or $201) None (or $201) None (or $201) None (or $201) None (or $201) $1,001 - less than less than less than less than less than less than $2,500 None (or less than $201) $1,001 - $2,500 $1,001 - $2,500 $5,001 - $15,000 6. Other Assets and Income # DESCRIPTION EIF VALUE 1 Time Warner Cable stock(IRA) N/A $15,001 - $50,000 2 AOL stock(IRA) N/A $50,001 - $100,000 7. Transactions This report has no reported Transactions INCOME TYPE INCOME AMOUNT None (or less than $201) None (or less than $201) 8. Liabilities # CREDITOR NAME TYPE OF LIABILITY AMOUNT 1 Wells Fargo Bank Mortgage, Washington , DC, USA $250,001 $500,000 YEAR INCURRED INTEREST RATE TERM 2016 3.0% 15 years 9. Gifts and Travel Reimbursements This report has no reported Gifts and Reimbursements Summary of Contents 1. Filer's Positions Held Outside the United States Government Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the filer did not receive compensation. This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an honorary nature; (3) positions held as part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests as a limited partner or nonmanaging member of a limited liability company. 2. Filer's Employment Assets and Income Part 2 discloses the following: • Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria, scholarships, and prizes) • Assets related to the filer's business, employment, or other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or other incomegenerating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 3. Filer's Employment Agreements and Arrangements Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as the following: • Future employment • Leave of absence • Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer) • Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan • Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a company's profits, etc.) 4. Filer's Sources of Compensation Exceeding $5,000 in a Year Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period. The filer discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its payment to the filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client is paying. 5. Spouse's Employment Assets and Income Part 5 discloses the following: • Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership share) • Sources of honoraria for the filer's spouse greater than $200 during the reporting period • Assets related to the filer's spouse's employment, business activities, other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria). 6. Other Assets and Income Part 6 discloses each asset, not already reported, that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in investment income during the reporting period. For purposes of the value and income thresholds, the filer aggregates the filer's interests with those of the filer's spouse and dependent children. This section does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits associated with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial institution with a value of $5,000 or less (unless more than $200 of income was produced). Additional exceptions apply. Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 7. Transactions Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during reporting period. This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money market accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions apply. 8. Liabilities Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period. This section does not include the following types of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a personal motor vehicle, household furniture, or appliances, unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances, if the outstanding liability did not exceed $10,000 at the end of the reporting period. Additional exceptions apply. 9. Gifts and Travel Reimbursements This section discloses: • Gifts totaling more than $375 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. • Travel reimbursements totaling more than $375 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $150 or less. Regardless of the value, this section does not include the following items: (1) anything received from relatives; (2) anything received from the United States Government or from the District of Columbia, state, or local governments; (3) bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food, lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their relationship to the filer. Additional exceptions apply. Privacy Act Statement Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. app. § 101 et seq., as amended by the Stop Trading on Congressional Knowledge Act of 2012 (Pub. L. 112-105) (STOCK Act), and 5 C.F.R. Part 2634 of the U. S. Office of Government Ethics regulations require the reporting of this information. The primary use of the information on this report is for review by Government officials to determine compliance with applicable Federal laws and regulations. This report may also be disclosed upon request to any requesting person in accordance with sections 105 and 402(b)(1) of the Act or as otherwise authorized by law. You may inspect applications for public access of your own form upon request. Additional disclosures of the information on this report may be made: (1) to any requesting person, subject to the limitation contained in section 208(d)(1) of title 18, any determination granting an exemption pursuant to sections 208(b)(1) and 208(b)(3) of title 18; (2) to a Federal, State, or local law enforcement agency if the disclosing agency becomes aware of violations or potential violations of law or regulation; (3) to another Federal agency, court or party in a court or Federal administrative proceeding when the Government is a party or in order to comply with a judge-issued subpoena; (4) to a source when necessary to obtain information relevant to a conflict of interest investigation or determination; (5) to the National Archives and Records Administration or the General Services Administration in records management inspections; (6) to the Office of Management and Budget during legislative coordination on private relief legislation; (7) to the Department of Justice or in certain legal proceedings when the disclosing agency, an employee of the disclosing agency, or the United States is a party to litigation or has an interest in the litigation and the use of such records is deemed relevant and necessary to the litigation; (8) to reviewing officials in a new office, department or agency when an employee transfers or is detailed from one covered position to another; (9) to a Member of Congress or a congressional office in response to an inquiry made on behalf of an individual who is the subject of the record; (10) to contractors and other non-Government employees working on a contract, service or assignment for the Federal Government when necessary to accomplish a function related to an OGE Government-wide system of records; and (11) on the OGE Website and to any person, department or agency, any written ethics agreement filed with OGE by an individual nominated by the President to a position requiring Senate confirmation. See also the OGE/GOVT-1 executive branch-wide Privacy Act system of records. Public Burden Information This collection of information is estimated to take an average of three hours per response, including time for reviewing the instructions, gathering the data needed, and completing the form. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Program Counsel, U.S. Office of Government Ethics (OGE), Suite 500, 1201 New York Avenue, NW., Washington, DC 20005-3917. Pursuant to the Paperwork Reduction Act, as amended, an agency may not conduct or sponsor, and no person is required to respond to, a collection of information unless it displays a currently valid OMB control number (that number, 3209-0001, is displayed here and at the top of the first page of this OGE Form 278e).