I Until recently, the DOT Departmental Ethics U?'rce has not had adequate resources to accomplish its legally required compliance functions,
including its responsibilities relating to the ?nancial disclosure report program-

I A (35-14 non?attorney ethics specialist, while experienced and conscientious, was essentially the only employee charged with reriewing hundreds of
ETEs for DDT headquarters employees- This employee also had the responsibility of advising thousands of employees on very speci?c ?nancial
disclosure report obligations {when you include the con?dential ?lers Form 4-3 and administering the electronic ?nancial disclosure system
{FDonlinej-

I This lack of quali?ed staf?ng dedicated to 2T3 retiews for non-PAS o?icials {the senior ethics attorneys retiewed EJSs for Pill-S of?cials)= contributed
to a situation where many reports {including the 4 subject reports) were not retiewed and certi?ed properly.

I This situation with the ?nancial disclosure program and other aspects of the ethics program had been developing for many years and certainly predated
the current administration.

I Senior DDT management in this administration= including the Deputy Secretary and the Acting Solicitor, recognised the urgent need to overhaul the
ethics program. The Deputy Secretary came on board in August and by I[Illctober EDIT, ordered the recruitment ofa new career Senior Executive
Service ethics attorney to talre control ofthe situation and correct the de?ciencies ofthe DECI-

I In addition to senior management in the current administration recognising the problems with the the U-3- l[llf?ce of Government Ethics 
recognized the severity ofthe problem when they conducted an audit ofthe DIED during the last year ofthe past administration in 21316 and protided
extensive criticism of the program. This audit report is publicly ayailable on the USE website.

I Just nine weel-rs ago, in mid-April DDT senior management brought on board a new team of career professional ethics attorneys to run the
DEG. See the attached announcement. 1When ProPublica's inquiry regarding "six blanl: was brought to their attention in May EDIE they
immediately requested that a senior career ethics attorney with the DEC) investigate the matter. The attorney was directed to personally inter-Liew
each ?ler and go through each section ofthe 2J3 with them. This process revealed that some ofthe ?lers were confused about what in?c-rmation was
supposed to be reported on their New Entrant ETEs when they came on board in 2017' and that some ?lers thought they had ?lled out the form
correctly when, in fact they had not. There appeared to be no case where any ?ler intended to not disclose information that they lcnew or should have
lcnown was required to be reported-

I ?Mrile ?lers are ultimately responsible ?x the accurate submission of their own forms, the DEC) is culpable in certifying forms that appeared "blanl-r"
without conducting a certain level of due diligence to ensure that the ?lers submitted correct forms. a minimum, ethics o?'rcials should have
contacted ?lers of these forms and con?rmed ifthe information {or lack of information] on the ?rms was correct-

I The new DIED management team has decades of experience running ?nancial disclosure programs and recognizes the shortcomings ofthe program
and is moving to address the situation. IZine of the ?rst concrete actions it has taken to improve the submission of the E?l? reports is
requiring ethics of?cials to contact ?lers and actively inteniew them about each section of the report if the reports don't appear adequate or
accurate. For example, ifthey see that a ?ler has work-ed ?x years at various companies and has not listed a single E3. or 401(k), then that is a
red ?ag and they should be contacting that ?ler to con?rm that they in fact do not have any de?ned contribution plans to report Another concrete
action talcen this ?ling season is that all of the ethics o?icials must reyiew some ETEs and a single inditidual is not responsible for all the
reviews- These two actions were taken, in fact, prior to the new management even learning of the ProPublica inquiry and was communicated in the
?rst week of their employment at DUI in mid-April.

I In addition to ProPublica's inquiry, the Government Accountability ICilf?ce (GAD) is currently conducting an audit of certain aspects of the ethics o?'rces
of various Federal of?ces (in, how political appointees were processed}. 'The time period being examined is January 2131? to January EDI E- The
results of the audit for DDT will lilrely highlight some of the problems discussed here.

I Finally, the new and ADA-ED are fully aware of the problems, issues, and shortcomings of the DUI ethics program and are diligently and
steadfastly working to address them as quickly as possible- The has been reorganized in the last several weeks and new senior attorneys will be
hired this summer to lead the ?nancial disclosure program and the ethics training and education program. Tn addition. the Deputy Secretary and
Acting Solicitor are the new ethics team at every turn and all DUI senior management is supporting the Deputy Secretary's urgent new
initiative to hire dozens more ethics o?'rcials throughout the Department-

I The new DEED welcomes ProPublica's interest in the DUT's ethic-s program and appreciates the role of government watchdog groups and the media in
ensuring that the Federal government functions properly for all Americans-