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 Memon, Sean Deputy Chief of Staff, Securities and Exchange Commission Date of Appointment: 05/05/2017 Other Federal Government Positions Held During the Preceding 12 Months: None Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge. /s/ Memon, Sean [electronically signed on 06/05/2017 by Memon, Sean in Integrity.gov] 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). /s/ Minton, Shira, Certifying Official [electronically signed on 07/10/2017 by Minton, Shira in Integrity.gov] Other review conducted by /s/ Lacko, Michelle V, Ethics Official [electronically signed on 07/10/2017 by Lacko, Michelle V in Integrity.gov] U.S. Office of Government Ethics Certification Data Revised 07/10/2017 Data Revised 07/07/2017 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Sullivan & Cromwell LLP Washington, District of Columbia Law Firm Associate 9/2008 5/2017 VALUE INCOME TYPE INCOME AMOUNT Salary/Bonus $558,520 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF 1 Sullivan & Cromwell LLP (law firm) N/A 2 IRA No 2.1 Fidelity Government Cash Reserves Fund (FDRXX) Yes $1,001 - $15,000 None (or less than $201) 2.2 Fidelity Value Fund (FDVLX) Yes $15,001 $50,000 $201 - $1,000 2.3 Vanguard Value Index Fund Admiral Shares (VVIAX) Yes $1,001 - $15,000 $201 - $1,000 2.4 U.S. bank account (cash) N/A $1,001 - $15,000 None (or less than $201) 3 Roth IRA No 3.1 Fidelity Government Cash Reserves Fund (FDRXX) Yes $1,001 - $15,000 None (or less than $201) 3.2 Fidelity Value Fund (FDVLX) Yes $1,001 - $15,000 None (or less than $201) 3.3 Perkins Mid-Cap Value Fund (JMCVX) Yes $1,001 - $15,000 None (or less than $201) 3.4 SPDR S&P 500 ETF (SPY) Yes $15,001 $50,000 $201 - $1,000 4 Time Warner Inc. 401(k) No # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 4.1 Time Warner Inc. Stock Fund No 4.1.1 Time Warner Inc. common stock (TWX) N/A $15,001 $50,000 Dividends $201 - $1,000 4.2 Fidelity Growth Asset Allocation Fund Yes $15,001 $50,000 None (or less than $201) 4.3 Fidelity S&P 500 Index Fund Yes $1,001 - $15,000 None (or less than $201) 5 Sullivan & Cromwell LLP 401(k) No 5.1 Fidelity 500 Index Fund Institutional Class (FXSIX) Yes $250,001 $500,000 $5,001 - $15,000 3. Filer's Employment Agreements and Arrangements # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Time Warner Inc. 401(k) New York, New York I will continue to participate in this defined contribution plan but neither I nor the plan sponsor made any contributions after the date of my separation. All of the assets in the plan are reported on Part 2. 3/2001 2 Sullivan & Cromwell LLP 401(k) New York, New York I will continue to participate in this defined contribution plan but neither I nor the plan sponsor made any contributions after the date of my separation. All of the assets in the plan are reported on Part 2. 9/2008 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 Sullivan & Cromwell LLP Washington, District of Columbia Legal services # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 2 Ally Financial Inc. (client of Sullivan & Cromwell LLP) Detroit, Michigan Legal services 3 AMC Networks Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 4 American International Group, Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 5 The Bank of New York Mellon Corporation (client of Sullivan & Cromwell LLP) New York, New York Legal services 6 Barclays Capital Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 7 Cablevision Systems Corporation (client of Sullivan & Cromwell LLP) Bethpage, New York Legal services 8 Chubb Limited (client of Sullivan & Cromwell LLP) Warren Township, New Jersey Legal services 9 CIM Group LLC (client of Sullivan & Cromwell LLP) Los Angeles, California Legal services 10 CIT Group Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 11 The Clearing House Association LLC (client of Sullivan & Cromwell LLP) New York, New York Legal services 12 Deutsche Bank AG (client of Sullivan & Cromwell LLP) Frankfurt, Germany, Outside U.S. Legal Services 13 First Republic Bank (client of Sullivan & Cromwell LLP) San Francisco, California Legal services 14 GCT Global Container Terminals Inc. (client of Sullivan & Cromwell LLP) Vancouver, Canada, Outside U.S. Legal services 15 General Electric Capital Corporation (client of Sullivan & Cromwell LLP) Norwalk, Connecticut Legal services 16 General Electric Company (client of Sullivan & Cromwell LLP) Boston, Massachusetts Legal services # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 17 Great-West Lifeco, Inc. (client of Sullivan & Cromwell LLP) Winnipeg, Canada, Outside U.S. Legal services 18 The Goldman Sachs Group, Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 19 J.C. Flowers & Co. LLC (client of Sullivan & Cromwell LLP) New York, New York Legal services 20 JPMorgan Chase & Co. (client of Sullivan & Cromwell LLP) New York, New York Legal services 21 LendingClub Corporation (client of Sullivan & Cromwell LLP) San Francisco, California Legal services 22 MetLife Inc. (client of Sullivan & Cromwell LLP) New York, New York Legal services 23 Mitsui & Co. Financial Services (U.S.A.) (client of Sullivan & Cromwell LLP) New York, New York Legal services 24 Moody's Corporation (client of Sullivan & Cromwell LLP) New York, New York Legal services 25 MSG Networks (client of Sullivan & Cromwell LLP) New York, New York Legal services 26 Nomura Securities Co., Ltd (client of Sullivan & Cromwell LLP) Tokyo, Japan, Outside U.S. Legal services 27 NorthStar Realty Finance Corp. (client of Sullivan & Cromwell LLP) New York, New York Legal services 28 UBS Group AG and its subsidiaries (client of Sullivan & Cromwell LLP) Zurich, Switzerland, Outside U.S. Legal services 29 Wells Fargo & Company (client of Sullivan & Cromwell LLP) San Francisco, California Legal services 30 Note: 1 confidential corporate client is not disclosed because the disclosure of the representation is the subject of attorneyclient privilege and other confidentiality obligations, including Rule 1.6 of the New York Rules of Professional Conduct and Rule 1.6 of the Washington, D.C. Rules of Professional Conduct. 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF 1 Financial Industry Regulatory Authority (SelfRegulatory Organization) N/A 2 Roth IRA No 2.1 Vanguard 500 Index Fund Admiral Shares (VFIAX) Yes 3 FINRA 401(k) No 3.1 Vanguard Institutional Index Fund Institutional Plus Shares (VIIIX) VALUE INCOME TYPE INCOME AMOUNT salary, bonus $15,001 $50,000 $201 - $1,000 Yes $100,001 $250,000 $5,001 - $15,000 6. Other Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Fidelity Government Money Market Fund (SPAXX) Yes $100,001 $250,000 2 Stamford, CT, bonds N/A $50,001 $100,000 3 Fidelity Tax-Exempt Money Market Fund (FMOXX) Yes $1,001 - $15,000 4 State of Illinois, bonds N/A $100,001 $250,000 Interest $5,001 - $15,000 5 North Carolina Medical Care Commission, bonds N/A None (or less than $1,001) Interest $5,001 - $15,000 6 Fairfax County, VA , bonds N/A $15,001 $50,000 Interest $1,001 - $2,500 7 Fairfax County, VA , bonds N/A $15,001 $50,000 Interest $1,001 - $2,500 None (or less than $201) Interest $1,001 - $2,500 None (or less than $201) # DESCRIPTION EIF VALUE INCOME TYPE 8 U.S. bank account #1 (cash) N/A $100,001 $250,000 None (or less than $201) 9 U.S. bank account #2 (cash) N/A $15,001 $50,000 None (or less than $201) 10 U.S. bank account #3 (cash) N/A $15,001 $50,000 None (or less than $201) 11 Richmond, VA, bonds N/A $15,001 $50,000 Interest $201 - $1,000 12 Suffolk, VA, bonds N/A None (or less than $1,001) Interest $1,001 - $2,500 13 Suffolk, VA, bonds N/A None (or less than $1,001) Interest $201 - $1,000 14 iShares Core S&P Mid-Cap ETF (IJH) Yes $1,001 - $15,000 $201 - $1,000 15 iShares Core S&P 500 ETF (IVV) Yes $500,001 $1,000,000 $5,001 - $15,000 16 SPDR S&P 500 ETF (SPY) Yes $500,001 $1,000,000 $15,001 $50,000 17 U.S. bank account #4 (cash) N/A $500,001 $1,000,000 18 Yahoo Inc. (YHOO) N/A $15,001 $50,000 None (or less than $201) 19 Family Trust #1 No 19.1 Fidelity Govt. Money Market Fund (SPAXX) Yes $100,001 $250,000 None (or less than $201) 19.2 New York City, NY, Municipal Water Finance Authority, bonds N/A None (or less than $1,001) Interest $201 - $1,000 19.3 New York City, NY, Municipal Water Finance Authority, bonds N/A None (or less than $1,001) Interest $1,001 - $2,500 19.4 Clark County, NV, Water Reclamation District, bonds N/A $100,001 $250,000 Interest $5,001 - $15,000 19.5 Fidelity Real Estate Investment Fund (FRESX) Yes $15,001 $50,000 Interest INCOME AMOUNT $15,001 $50,000 $1,001 - $2,500 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 19.6 Fidelity Municipal Money Market Fund (FTEXX) Yes $1,001 - $15,000 None (or less than $201) 19.7 Fidelity 500 Index Premium Class (FUSVX) Yes $500,001 $1,000,000 $15,001 $50,000 19.8 SPDR S&P 500 ETF (SPY) Yes $250,001 $500,000 $5,001 - $15,000 19.9 Vanguard FTSE Developed Market ETF (VEA) Yes $100,001 $250,000 $2,501 - $5,000 20 Commonwealth of Puerto Rico, bonds N/A $1,001 - $15,000 Interest $201 - $1,000 21 Puerto Rico Electric Power Authority, bonds N/A $1,001 - $15,000 Interest $201 - $1,000 22 Puerto Rico Electric Power Authority, bonds N/A $15,001 $50,000 Interest $1,001 - $2,500 23 Motorola Solutions Inc. (MSI) N/A $1,001 - $15,000 24 U.S. bank account #5 (cash) N/A $500,001 $1,000,000 Interest $5,001 - $15,000 25 Family Trust #2 No 25.1 Connecticut State Housing Finance Authority, bonds N/A $100,001 $250,000 Interest $5,001 - $15,000 25.2 Howard County, MD, bonds N/A $100,001 $250,000 Interest $5,001 - $15,000 25.3 Massachusetts Bay Transit Authority, bonds N/A $15,001 $50,000 Interest $1,001 - $2,500 25.4 Virginia State Resource Authority, bonds N/A $100,001 $250,000 Interest $5,001 - $15,000 25.5 iShares Core U.S. Aggregate Bond ETF (AGG) Yes $15,001 $50,000 $1,001 - $2,500 25.6 Fidelity Overseas Fund (FOSFX) Yes $100,001 $250,000 $2,501 - $5,000 25.7 iShares Cohen and Steers REIT (ICF) Yes $15,001 $50,000 $1,001 - $2,500 None (or less than $201) # DESCRIPTION EIF VALUE 25.8 Vanguard FTSE Developed Market ETF (VEA) Yes $50,001 $100,000 $2,501 - $5,000 25.9 Vanguard 500 Index ETF (VOO) Yes $250,001 $500,000 $5,001 - $15,000 25.10 Vanguard Extended Market ETF (VXF) Yes $100,001 $250,000 $1,001 - $2,500 25.11 Virginia State Housing Development Authority, bonds N/A None (or less than $1,001) 25.12 U.S. brokerage account #1 (cash) N/A $50,001 $100,000 None (or less than $201) 26 U.S brokerage account #2 (cash) N/A $100,001 $250,000 None (or less than $201) 27 U.S. brokerage account #3 (cash) N/A $1,001 - $15,000 None (or less than $201) 7. Transactions (N/A) - Not required for this type of report 8. Liabilities None 9. Gifts and Travel Reimbursements (N/A) - Not required for this type of report INCOME TYPE Interest INCOME AMOUNT $2,501 - $5,000 Endnotes Summary of Contents 1. Filer's Positions Held Outside 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 non-managing member of a limited liability company. 2. Filer's Employment Assets & Income and Retirement Accounts 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 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). 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 & Income and Retirement Accounts 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).