Nominee 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 Wilson, Christine Smith Commissioner, Federal Trade Commission Other Federal Government Positions Held During the Preceding 12 Months: None Names of Congressional Committees Considering Nomination: ● Committee on Commerce, Science, and Transportation 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/ Wilson, Christine Smith [electronically signed on 01/23/2018 by Wilson, Christine Smith 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/ White, Christian S., Certifying Official [electronically signed on 01/31/2018 by White, Christian S. in Integrity.gov] Other review conducted by /s/ Pankey, Lorielle L, Ethics Official [electronically signed on 01/31/2018 by Pankey, Lorielle L in Integrity.gov] Wilson, Christine Smith - Page 1 U.S. Office of Government Ethics Certification /s/ Apol, David, Certifying Official [electronically signed on 01/31/2018 by Apol, David in Integrity.gov] Wilson, Christine Smith - Page 2 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Delta Air Lines Washington, DC, District of Columbia Corporation Senior Vice President -Legal, Regulatory & International 8/2016 Present 2 Kirkland & Ellis LLP Washington, DC, District of Columbia Law Firm Partner 3/2011 4/2016 EIF VALUE INCOME TYPE INCOME AMOUNT Yes $50,001 $100,000 None (or less than $201) 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION 1 IRA 1 1.1 Hennessy Focus Fund Investor Class 2 IRA 2 2.1 Fidelity 500 Index Premium Class Yes $250,001 $500,000 $5,001 - $15,000 2.2 Oppenheimer Intl Growth Class A Yes $50,001 $100,000 $201 - $1,000 2.3 Oppenheimer Intl Small Mid Company Class A Yes $100,001 $250,000 $2,501 - $5,000 3 IRA 3 3.1 Fidelity 500 Index Premium Class Yes $250,001 $500,000 $5,001 - $15,000 Wilson, Christine Smith - Page 3 # DESCRIPTION EIF VALUE 3.2 Fidelity OTC Portfolio Yes $100,001 $250,000 $5,001 - $15,000 4 Delta 401k 4.1 S&P 500 Index Yes $100,001 $250,000 None (or less than $201) 5 Delta Air Lines, common stock N/A None (or less than $1,001) 6 Delta Air Lines, unvested restricted stock N/A $1,000,001 $5,000,000 None (or less than $201) 7 Delta Air Lines, unvested stock options N/A $50,001 $100,000 None (or less than $201) 8 Delta Air Lines N/A Salary $390,625 9 Delta Air Lines, Management Incentive Plan See Endnote N/A Cash award $135,955 10 Kirkland & Ellis (law firm) See Endnote N/A LLC Distribution $521,086 11 Delta Air Lines, non cash travel benefit N/A Imputed income for travel benefit $7,500 12 Delta Air Lines, anticipated severance, cash N/A $1,000,001 $5,000,000 None (or less than $201) 13 Delta Air Lines, Management Incentive Plan (anticipated cash award) N/A $250,001 $500,000 None (or less than $201) 14 Delta Air Lines, vested stock award N/A None (or less than $1,001) 15 Delta Air Lines, tax allowance travel benefit N/A See Endnote INCOME TYPE Dividends INCOME AMOUNT $5,001 - $15,000 Ordinary income $878,600 Ordinary income to cover taxes on non cash travel benefit $6,840 Wilson, Christine Smith - Page 4 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 16 Delta Air Lines, anticipated travel benefit N/A $1,001 - $15,000 None (or less than $201) 17 Compensation owed by filer's former employer, Kirkland & Ellis (law firm) N/A $15,001 $50,000 None (or less than $201) 3. Filer's Employment Agreements and Arrangements # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Delta Air Lines, 401k Washington, District of Columbia I will continue to participate in this defined contribution plan. The plan sponsor will not make further contributions after my separation. 8/2016 2 Delta Air Lines, unvested restricted stock Washington, District of Columbia I received restricted stock awards at 3 different times (initial equity award, 2016 Long Term Incentive Plan, and 2017, Long Term Incentive Plan). Under the LTIP, a portion of the award vests each year. The Delta Air Lines, Inc. Officer and Director Severance Plan provides for the pro rata vesting of restricted stock at separation. I will receive that vested share and will forfeit the portion that remains unvested. 8/2016 3 Delta Air Lines, unvested stock options Washington, District of Columbia I received unvested stock options under the 2017 Long Term Incentive Plan. Under the LTIP, a portion of the award vests each year. The Delta Air Lines, Inc. Officer and Director Severance Plan provides for the pro rata vesting of stock options at separation. I will receive that vested share and will forfeit the portion that remains unvested. 2/2017 Wilson, Christine Smith - Page 5 # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 4 Delta Air Lines, travel benefit Washington, District of Columbia Pursuant to Delta's travel benefit plan and Officer and Director Severance Plan, for up to 15 months after February 1, 2018, I will continue to receive the same travel benefit I received as an employee. During my appointment, I will not exercise my entitlement to these Delta travel benefits. In addition, in December 2018, Delta will calculate the travel I took from November 1, 2017 to January 31, 2018 and impute the income into my W2 and pay my income taxes up to the maximum of my tax allowance. For travel after January 31, 2018, Delta will impute the income but not pay my income taxes. 8/2016 5 Delta Air Lines, anticipated cash severance Washington, District of Columbia Pursuant to the Delta Air Lines, Inc. Officer and Director Severance Plan, I am entitled to receive a severance payment calculated according to a formula, payment of 15 months of COBRA expenses, and the Management Incentive Plan payment for my work in January 2018. Under the Long Term Incentive Plan, I am entitled to receive a pro rata share of my cash performance award granted in 2016 and 2017. 1/2018 6 Delta Air Lines, career transition services Washington, District of Columbia Pursuant to the Delta Air Lines, Inc. Officer and Director Severance Plan, I am eligible to receive career transition services valued at up to $5,000 at a career transition services firm chosen and paid by Delta. The eligibility will expire upon my becoming employed. 1/2018 7 Delta Air Lines, Management Incentive Plan, anticipated 2017 payment Washington, District of Columbia Under the Management Incentive Plan I will receive the 2017 payment. 8/2016 8 Delta Air Lines, cash signing bonus Washington, District of Columbia Delta has agreed to waive the contractual requirement that I repay 50% of my cash signing bonus. 1/2018 Wilson, Christine Smith - Page 6 # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 9 Kirkland & Ellis (law firm) Washington, District of Columbia Prior to confirmation, I will receive $16,313.00 from my former employer. This sum represents ordinary course income that I earned as a partner in the firm, but have yet to receive either because the matters that resulted in the income were recently settled or are ongoing. The method for calculation of accrued income at a discounted rate is identical to the method the firm uses for any other Kirkland & Ellis partner who has left the firm and asked to have their payments accelerated for any reason. Apart from this payment, I have no further payments of any kind coming from my former firm. 1/2018 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 Delta Air Lines Washington, DC, District of Columbia Legal services 2 Kirkland & Ellis LLP Washington, DC, District of Columbia Legal services 3 Boehringer Ingelheim USA Ridgefield, Connecticut Legal services 4 Bristol-Myers Squibb Company New York, New York Legal services 5 Fortiline, Inc. Concord, North Carolina Legal services 6 Fortune Brands Home & Security, Inc. Deerfield, Illinois Legal services 7 New Mountain Capital New York, New York Legal services 8 Reddy Ice Corporation Dallas, Texas Legal services Wilson, Christine Smith - Page 7 # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 9 Sage Products, LLC Cary, Illinois Legal services 10 Teva Pharmaceuticals North America North Wales, Pennsylvania Legal services 11 The Blackstone Group New York, New York Legal services 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE INCOME TYPE 1 Ramsey J Wilson, attorney at law (Law firm (solo legal practice)) N/A $1,001 - $15,000 Legal fees 2 ZFO Consulting LLC (personal finance and small business consulting firm (solo practice)) N/A $1,001 - $15,000 EIF VALUE INCOME AMOUNT None (or less than $201) 6. Other Assets and Income # DESCRIPTION INCOME TYPE INCOME AMOUNT 1 Brokerage 1 1.1 Fidelity 500 Index Premium Class Yes $50,001 $100,000 $1,001 - $2,500 1.2 Fidelity Government Money Market Yes $15,001 $50,000 $201 - $1,000 1.3 Delta Air Lines common stock N/A None (or less than $1,001) $201 - $1,000 2 Brokerage 2 Wilson, Christine Smith - Page 8 # DESCRIPTION EIF VALUE 2.1 Fidelity 500 Index Premium Class Yes $100,001 $250,000 $2,501 - $5,000 3 Virginia 529 College Savings Plan Account 3.1 Stable Value Portfolio Yes $100,001 $250,000 None (or less than $201) 4 U.S. bank savings account 1 (cash) N/A $250,001 $500,000 Interest $201 - $1,000 5 U.S. bank savings account 2 (cash) N/A $100,001 $250,000 Interest $201 - $1,000 6 U.S. bank certificate of deposit N/A $100,001 $250,000 Interest $201 - $1,000 7 U.S. bank personal checking account (cash) N/A $1,001 - $15,000 None (or less than $201) 8 U.S. bank savings account 3 UTMA (cash) N/A $1,001 - $15,000 None (or less than $201) 9 Farm land (Berkeley Springs, WV) N/A $250,001 $500,000 None (or less than $201) See Endnote INCOME TYPE INCOME AMOUNT 7. Transactions (N/A) - Not required for this type of report 8. Liabilities Wilson, Christine Smith - Page 9 # CREDITOR NAME 1 Barclays See Endnote TYPE AMOUNT YEAR INCURRED RATE TERM Kirkland & Ellis partnership capital loan $100,001 $250,000 2011 2.29% Paid upon closing of partnership capital account in April 2017 9. Gifts and Travel Reimbursements (N/A) - Not required for this type of report Endnotes PART # ENDNOTE 2. 9 Payment for 2016 made in 2017 2. 10 I have disclosed the total income amount received (the amount of interest income received is not readily ascertainable). 2. 13 Cash award on Feb 1, 2018 pursuant to the Management Incentive Plan 6. 9 Not an active farming operation. 8. 1 Interest rate calculated based on 2016 interest paid Wilson, Christine Smith - Page 10 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.) Wilson, Christine Smith - Page 11 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 Wilson, Christine Smith - Page 12 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. Wilson, Christine Smith - Page 13 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). Wilson, Christine Smith - Page 14