April 4, 2019

The Honorable Charles Grassley
Chairman

Committee on Finance

United States Senate

Washington, DC 20510

Dear Mr. Cl?inirmnn:

By letter dated innunry l0} 201:3: the {lf?cc of Government lilthics (OGE) transmitted to
the Committee the ?nancial disclosure report of Steven Mnuchin in connection with his
tornination for the position of Secretary, Department of the Treasury. Enclosed are a letter horn
the Department of the ?Llh?easury and a letter from Secretary Mnuchin amending his ethics
agreement.

OGE is unable to certify Secretary Mnuchin?s 2018 annual public ?nancial disclosure
report because he has an imputed interest in Partners LLC, which he agreed to
divest. Although he divested this interest by selling it to his tlien?.lian.c?e, he subsequently
reacquired an imputed interest when he later married his ?ancee. According to the Department of
the Treasury, the Secretary sought advice from the Department of the Treasury?s Designated
Agency Ethics Of?cial. who advised him that he could retain his imputed interest in the entity
because the asset did not create a potential for a con?ict of interest. However, the Department of
the Treasury?s ethics officials did not inform OCEE of this advice, which had the effect of letting
the Secretary reacquire, without prior approval from OGE, a ?nancial interest in an asset he
agreed to divest.

Although OGE is unable, given these circumstances, to certify the Secretary?s Ni 8
annual ?nancial disclosure report, 0GB is satis?ed that commitments re?ected in the enclosed
modi?ed ethics agreement enable him, to continue to hold an imputed interest in Stormchaser
Partners LLC and be in compliance with his amended ethics agreement and the applicable
con?ict of interest laws. Speci?cally, Secretary Mnuchin has committed to additional recusals
and to consult with OGE if the nature of the Stormchaser Partners LLC business were to change.

Sincerely543? is? ix?zlgi a 1.5 
Emory A. Rounds, 
Director

Enclosures

.1201 NEW YORK AVE NW 500 DC '20005