New Entrant Report] US. Office ofGovemmenl Ethics; 5 part 2634 I Form Approved: OM13 No. 2014) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information DONNELLY, SALLY Senior Advisor to Secretary of Defense, OSD, Office ofthc 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 ofmy knowledge. eSigned in FDM by: SALLY DONNELLY User ID: 05/17/2017 Agency Ethics Official's Opinion On the basis ofinformation contained in this report. I conclude that the filer is in compliance with applicable laws and regulations(Subject to any comments below). eSigned in FDM by: KURT T. GERLACH User ID: A362E5D13AC976AA 08/30/2017 Other review conducted by Supervisor: eSigned in FDM by: KEVIN M. SWEENEY User ID: 4C72DC3B5E257D4D 07/27/2017 US. Of?ce of Government Ethics Certification Comments of Reviewing Of?cials (public annotations): PART REFERENCE COMMENT 2. 2 SBD Advisers LLC (08/30/17, GERLACH, KURT T.): Confirmed that this asset actually has 0 value to filer as she no longer has any stake in the company. ADAEO Clarification: Filer confirmed this was total sale of filer's partial interest. 2. 13 Personal Salary Distributions (SBD Advisors) (08/30/17, GERLACH, KURT T.): Filer earned an additional $20,833 for ork in CY 2017. ADAEO Clarification: Filer confirmed that income received in 2017 was for work performed in 2016. 1. Filer's Positions Held Outside United States Government NAME CITY, STATE OGE TYPE POSITION FROM TO 1 American Friends of the Black Stork New York, NY, USA Non-Profit Organiza Director 01/2013 06/2015 tion 2 Donnelly Seaview LLC Columbia, SC, USA Business Enterprise co-owner 11/2012 Present 3 Imperatis Arlington VA, USA Business Enterprise Director 06/2014 12/2016 4 SBD Advisors Washington, DC, USA Business Enterprise Officer 02/2012 01/2017 2. Filer's Employment Assets Income and Retirement Accounts DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Time Warner Employee Savings Plan(401K) $50,001 $100,000 None (or less than $201) 1.1 Time Warner Inc. Common Stock No $1,001 $15,000 Dividends $201 $1,000 1.2 Time Warner Large Cap Value Fund No $1,001 - $15,000 None (or less than $201) 1.3 Time Warner Growth Fund No $15,001 $50,000 None (or less than $201) 1.4 Capital Preservation Fund No $1,001 $15,000 None (or less than $201) 2 SBD Advisors LLC $1,000,001 $5,000,000 Partial sale/SBD $390,000 3 Donnelly Seaview LLC Columbia, SC (Residential Real $500,001 $1,000,000 Rent and Royalties $5,001 $15,000 Estate) 4 Calvert Balanced Portfolio Fund A Yes $1,001 $15,000 Dividends, Capital $201 - $1,000 Gains 5 Common Stock (Sole Ownership)" Yes $100,001 $250,000 Dividends $2,501 $5,000 6 TEGNA Common Stock (Joint Ownership) Yes $100,001 1 $250,000 Dividends $201 - $1,000 7 T. Rowe Price Diversified Mutual Funds (Joint Accoun $250,001 $500,000 Dividends, Capital $1,001 - $2,500 with Spouse) Gains 7.1 T. Rowe Price Capital Opportunity (PRCOX) (Joint Acco Yes $15,001 - $50,000 Dividends, Capital $201 $1,000 unt with Spouse) Gains 7.2 T. Rowe Price New Era Fund (PRNEX) (Joint Account wit Yes $15,001 $50,000 Dividends $201 - $1,000 Spouse) 7.3 T. Rowe Price Science Technology Fund (Join Yes $1,001 - $15,000 Dividends, Capital $201 $1,000 Account with Spouse) Gains 7.4 T. Rowe Price TRP Capital Appreciation (Joint Account Yes $15,001 $50,000 Dividends, Capital $201 $1,000 with Anna Rumer) Gains 7.5 T. Rowe Price TRP New Era (Joint Account with Anna Ru'Yes $15,001 $50,000 Dividends $201 - $1,000 mer) 8 Gannett Investments Common Stock (Joint Account with No $15,001 - $50,000 Dividends $201 - $1,000 DC) 9 Gannett Investments COmmon Stock (Individual Account) No $15,001 $50,000 Dividends $1,001 $2,500 10 Gannett Investments Common Stock (Joint Account with No $15,001 $50,000 Dividends, Capital $201 - $1,000 Spouse) Gains 11 Wells Fargo Checking Account (Joint with Spouse) $250,001 - $500,000 Interest $1,001 - $2,500 12 Wells Fargo Savings Account (Joint with Spouse) $500,001 - $1,000,000 Interest $1,001 $2,500 13 Personal Salary Distributions (SBD Advisors) Salary $250000 14 SBD Advisors 15 Time Warner Pension 3. Filer's Employment Agreements and Arrangements EMPLOYER OR OTHER PARTY TO 1 Time Warner Defined Benefit Pension 2 Time Warner Savings Plan New York, NY, USA New York, NY, USA 4. Filer's Sources of Compensation Exceeding $5,000 in a Year SOURCE NAME CITY, STATE 1 Amazon Web Services Seattle, WA 2 Association of the US Army Arlington, VA 3 Bloomberg, LP New York, NY 4 C. Ham Washington, DC 5 C5 New York, NY 6 ETO Group, LLC Tampa FL 7 Foreign Policy Washington, DC 8 General Motors LLC Detroit, MI 9 GeoPoll Washington, DC 10 Human Rights First Washington, DC 11 KnuEdge, Inc. San Diego, CA 12 M. Washington, DC 13 Medecins Sans Frontiers USA, Inc New York, NY 14 MGM Consulting Annapolis MD 15 Palantir Technologies Palo Alto, CA 16 RCF Management LLC Escondido CA 17 Sasakawa Peace Foundation USA Washington, DC 18 SBD Advisors Washington, DC 19 Skadden, Arps, Slate, Meagher Flom LLP Washington, DC 20 The Palm Center San Francisco 21 Uber San Francisco, 22 World Wildlife Fund Washington, DC I STATUS AND TERMS Continuing participation in Employee Benefit Plan: Bonus Income Retirement Plan or $25000 $9745 Account DATE I 04/2007 receive pension payments from my former employer. Th is information is also included under income. Continuing participation in Employee Benefit Plan: 10/1985 either I nor my former employer continue to make cont ributions to this plan. CA CA 5. Spouse's Employment Assets Income and Retirement Accounts DESCRIPTION 1 Spouse Individual Retirement Account (IRA) 1.1 Avenue Credit Strategies Investor 1.2 Baron Emerging Markets Fund Retail 1.3 Columbia Dividend Opportunity Class A EIF Yes Yes YES VALUE $250,001 $1,001 $1.001 $1,001 - $500,000 $15,000 $15,000 $15,000 BRIEF DESCRIPTION OF DUTIES Consulting Consulting Censulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Consulting Officer Consulting Consulting Consulting Consulting INCOME TYPE Dividends, Capital Gains INCOME AMOUNT $1,001 - $2,500 None (or less than $201) Dividends, Capital $2,501 - $5,000 Gains None (or less than $201] Columbia Select LRG Cap Growth Class A Delaware Value FD CL A Doubleline Low DURTN EMERG MKTS FX INC Dreyfus Bond Market Index INVS Driehaus Micro CAP Growth Fund Driehaus Event Driven Fund Driehaus Active Income Fund Fidelity 500 Index Premium Class Fidelity Government Cash Reserves JP Morgan Strategic Income Opportunity A LM BW Absolute RTRN Opportunities CL A MFS International Value Fund CL A Rowe Price Growth Stock Advisor CL Ridgeworth Ceredex Mid-Cap VAL EQ I Rivernorth Core Opportunities FD CL Riverpark Short Term Hi Yield Riverpark Strategic Income Double Line Total Return Bond Fund Victory Global Natural Resources Fund Touchstone Small Cap Value Fund Touchstone Focused Fund Wasatch Frontier Emerging Small Fund Wasatch International Opportunities Fund Rowe Price International Stock TCW Relative Value Dividend Fund Carnegie Endowment for International Peace College of Charleston Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes $15,001 $15,001 $1,001 - $15,001 $1,001 - $1,001 - $1,001 - $15,001 $1,001 - $1,001 - $1,001 $1,001 $15,001 $15,001 $1,001 - $1,001 - $1,001 - $15,001 $1,001 - $1,001 - $1,001 - $1,001 $1,001 - $1,001 - $15,001 - $50,000 - $50,000 $15,000 - $50,000 $15,000 $15,000 $15,000 - $50,000 $15,000 $15,000 $15,000 $15,000 - $50,000 - $50,000 $15,000 $15,000 $15,000 - $50,000 $15,000 $15,000 $15,000 $15,000 $15,000 $15,000 - $50,000 Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Dividends, Capital Gains Salary Income from personal services None (or $201) $2,501 - $2,501 - $2,501 - $2,501 - $1,001 - None (or $201) $2,501 - $1,001 - None (or $201) None (or $201) None (or $201) $2,501 - $5,001 None (or $201) None (or $201) None (or $201) None (or $201) None (or $201) None (or $201) $1,001 - None (or $201) $1,001 - $1,001 - $5,001 - less than $5,000 $5,000 $5,000 $5,000 $2,500 less than $5,000 $2,500 less than less than less than $5,000 $15,000 less than less than less than less than less than less than $2,500 less than $2,500 $2,500 $15,000 4 Cowen Services Company LLC Income from personal services 5 Dartmouth College Income from personal services 6 Gerson Lehrman Group, 60 East 42d Street, NY Income from personal services 7 Massachusetts Institute of Technology Royalties 8 SAIC, 151 Lafayette Dr., Oak Ridge, TN Income from personal services 6. Other Assets and Income DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 Time Warner Cable stocktIRA) $15,001 $50,000 None (or less than $201l 2 AOL stocktIRA) $50, 001 - $100, 000 None (or less than $201) 7. Transactions This report has no reported Transactions 8. Liabilities YEAR INTEREST CREDITOR NAME TYPE OF LIABILITY AMOUNT INCURRED RATE TERM 1 Wells Fargo Bank Mortgage, Washington DC, USA $250,001 - 2016 3.0% 15 years $500,000 9. Gifts and Travel Reimbursements This report has no reported Gifts and Reimbursements Summary of Contents 1. Filer?s Positions Held Outside United States Government Part 1 discloses positions that the ?ler held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even it? 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 ofthc filer's of?cial duties with the United States Government; (4) more membership in an organization; and (S) 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 Part2 discloses the following: - Sources ofearncd and other non-investment income ofthe ?ler totaling more than S200 during the reporting period salary, fees, partnership share, honoraria, scholarships, and prizes) - Assets related to the ?ler?s business, employment, or other income-generating activities that (I) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period 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 ?ler's business, employment, or other income- generating activities 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 quali?es as an excepted investment fund (EIF). 3. Filer's Employment Agreements and Arrangements Part 3 discloses agreements or arrangements that the ?ler had during the reporting period with an employer or former employer (except the United States Government), such as the following: 0 Future employment 0 Leave of absence 0 Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer) 0 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 pro?ts or carried interests vested and unvested stock options, restricted stock, future share of a company's pro?ts, 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 ?ler's services during any year of the reporting period. The ?ler discloses payments both from employers and from any clients to whom the ?ler personally provided services. The ?ler discloses a source even if the source made its payment to the ?ler's employer and not to the ?ler. The ?ler does not disclose a client's payment to the ?ler's employer if the ?ler 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 ?ler's spouse totaling more than $1,000 during the reporting period salary, consulting fees, and partnership share) Sources of honoraria for the ?ler's spouse greater than $200 during the reporting period - Assets related to the ?ler'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 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 ?ler's spouse's business, employment, or other income-generating activities 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 quali?es 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 (I) 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 ?ler aggregates the ?ler's interests with those of the ?ler?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 bene?ts associated with United States Government employment Thrift Savings Plan); and (3) cash accounts checking, savings, money market accounts) at a single ?nancial 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 quali?es 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 ?ler, the ?ler'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 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 ?ler, the ?ler?s spouse or dependent child owed at any time during the reporting period. This section does not include the following types of liabilities: mortgages on a personal residence, unless rented out (limitations apply for PAS ?lers); (2) loans secured by a personal motor vehicle, household fumiture, 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 ?ler, the ?ler's spouse, and dependent children received from any one source during the reporting period. 0 Travel reimbursements totaling more than $375 that the ?ler, the ?ler?s spouse, and dependent children received from any one source during the reporting period. For purposes of this section, the ?ler 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 ?'om 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 ?ler's agency in connection with the ?ler's of?cial travel; (5) gifts of hospitality (food, lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the ?ler?s spouse or dependent children totally independent of their relationship to the ?ler. 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. Of?ce of Government Ethics regulations require the reporting of this information. The primary use of the information on this report is for review by Government of?cials 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 Govemment 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 Of?ce 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 of?cials in a new of?ce, 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 of?ce 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 (l l) on the OGE Website and to any person, department or agency, any written ethics agreement ?led with OGE by an individual nominated by the President to a position requiring Senate con?rmation. See also the 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, US. Of?ce 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 ?rst page of this OGE Form 278a).