June 12, 2019 Ms. Judith S. Kaleta Designated Agency Ethics Official U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Judy: This is to let you know that on June 3, 2019, I divested all shares of Vulcan Materials and Ingersoll Rand even though you advised me that holding these stocks did not create a conflict of interest. This also confirms that I no longer retain a financial interest in these two companies as indicated in my ethics agreement of January 5, 2017. Per your guidance, this information is also reported on my financial disclosure report for calendar year 2018 and corrects the inadvertent misstatement on my previous years' financial disclosure reports dated December 6, 2016 and May 15, 2018, and in my ethics agreement. Sincerely, June 10, 2019 Emory Rounds Director, Office of Government Ethics 1201 New York Avenue, N.W. Washington, D.C. 20005 Dear Mr. Rounds: This letter concerns the ethics agreement and Financial Disclosure Reports of Secretary of Transportation Elaine L. Chao. I am enclosing a letter from Secretary Chao. On January 6, 2017, I wrote to then Director Walter Shaub, Jr. that I reviewed the Financial Disclosure Report of then nominee Elaine L. Chao and found that her financial interests would not present a conflict of interest should she be confirmed as the Secretary of Transportation. I am writing to inform you that my letter contained inadvertent misstatements of fact based on inadvertent misstatements of fact reported on the nominee ' s Financial Disclosure Reports [based on information provided by the nominee' s accountant.] Nevertheless, my conclusion that these financial interests would not present a conflict of interest remains. In my letter, I stated that the nominee was a member of the Board of Directors of Ingersoll Rand and, pursuant to the terms of the company 's Directors' Retainer Stock Unit Plan, the nominee ' s unvested retainer stock units would vest upon separation from service on the Board, and she would receive a cash payout for all of the retainer stock units based on the closing price of the company ' s common stock on the date of her separation. I also stated that the nominee was a member of the Board of Directors of Vulcan Materials, that she held vested deferred stock units with Vulcan Materials and, pursuant to the terms of the company ' s Directors' Deferred Stock Unit Plan, the nominee would receive a cash payout for all of her vested deferred stock units in April of the year following the year of her separation from service based on the closing price of the company ' s common stock at the time payment is made that April. Furthermore, I stated that the nominee was a member of the Board of Directors of Wells Fargo & Company , that she held vested deferred stock compensation with Wells Fargo and, pursuant to the terms of the company's Directors Stock Compensation and Deferral Plan - Stock Award Deferrals, the nominee would receive a cash payout for her vested deferred stocked compensation based on various elections she had made each year of Board service. In fact, under the terms of the deferred compensation plans of each of the three companies, the payouts were made in stock. 2 During her tenure, Secretary Chao has not participated personall y and substantially in any particular matter that has a direct and predictable effect on the financial interests of Ingersoll Rand, Vulcan Materials , or Wells Fargo. Although I have advised Secretary Chao that the holding oflngerso ll Rand and Vulcan Material stock does not create a conflict of interest, Secretary Chao has divested all stock from those two companies. As stated in my January 6, 2017 letter, Secretary Chao retains a financial interest in Well Fargo. Therefore, for as long as Secretary Chao retains a financial interest in Wells Fargo, she will not participate personall y and substantially in any particular matter that has a direct and predictable effect on the financial interests of Wells Fargo, unless she first obtains a written waiver, pursuant to 18 U.S .C. § 208(b)(l) , or qualifies for a regulatory exemptio n, pursuant to 18 U.S.C. § 208(b)(2) . Sincerely , Judith S. Kaleta Deputy General Counsel Designated Agency Ethics Official Enclosure Annual Report 201 Qfor Calendar Year 2018 U.S. Office of Government Ethics; 5 C.F.R. part 2634 Form Approved: OMB No. (3209-0001) (Updated jan. 2019) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information Chao, Elaine Secretary, Department of Transportation Report Year: 2019 Other Federal Government Positions Held During the Preceding 12 Months: None Electronic Signature - I certify that the statements have made in this form are true, complete and correct to the best of my knowledge. ls/ Chao, Elaine [electronically signed on 05/15/19 by Chao, Elaine in Integrity.gov] Agency Ethics Official?s Opinion - 0n 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). ls/ Kaleta,Judith, Certifying Official [electronically signed on 06/13/19 by Kaleta,Judith in lntegritygov] Other review conducted by Carlson, Terence W, Ethics Of?cial [electronically signed on 06/12/19 by Carlson, Terence in Integrity.gov] US. Office of Government Ethics Certification Data Revised 06/13/2019 Data Revised 06/12/2019 Data Revised 06/11/2019 Comments of Reviewing Officials {public annotations): PART REFERENCE COMMENT General (06/13/19, Kaleta,Judith): Endnote to Part 2, Line 10; endnote to Part 2, Line 11; endnote to Part 3, Line 1; and endnote to Part 3, Line 6 correct financial disclosure reports filed on 12/6/2016 and 5/15/2018. The prior reports referred to "cash payouts" that would have resulted in no further financial interests in those companies. In fact, payouts were made in stock consistent with the plans of these companies, Part 2 of the report filed on 5/15/2018 disclosed these continued equity interests in the companies, and the filer was recused. 1. Filer's Positions Held Outside United States Government ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Firebird International LLC See Endnote Louisville, Limited Liability Sole Member 5/2009 Present Kentucky Company 2 Elaine Chao Revocable Trust Louisville, Trust Trustee 9/2012 Present Kentucky 2. Filer's Employment Assets Income and Retirement Accounts DESCRIPTION VALUE INCOME TYPE INCOME AMOUNT 1 Firebird International LLC See Endnote 1.1 Firebird International LLC, SunTrust Business $250,001 - $500,000 None (or less than Checking $201) 1.2 Firebird International LLC, SunTrust Business Money $50,001 - $100,000 Interest $201 - $1,000 Market Performance 1.3 Firebird International LLC, defined benefit plan - Yes $1,000,001 - None (or less than VUSXX - Vanguard $5,000,000 $201) 1.4 Wells Fargo Company DSU Vesting $432,347 1.5 Vulcan Materials DSU Vesting $344,936 2 Wells Fargo Company, common stock $500,001 - Dividends $15,001 - $50,000 $1,000,000 3 Wells Fargo Company, Deferred Stock $250,001 - $500,000 None (or less than Compensation $201) 4 UBS Pension Trust (Personal Retirement Account) No 4.1 UBS Brokerage Account (Cash) None (or less than None (or less than $1,001) $201) 4.2 WGIFX - American Funds Capital World Gr Inc F2 Yes $15,001 . $50,000 None (or less than $201) 4.3 - Dreyfus/The Boston Co Sm/Md Cp Gr 1 Yes $1,001 - $15,000 None (or less than $201) 4.4 FEGIX First Eagle Gold I Yes $1 ,001 - $15,000 None (or less than $201) 4.5 PEQPX - Principal Equity Income Yes $15,001 - $50,000 None (or less than $201) 4.6 - American Funds Growth Fund of Amer F2 Yes $15,001 - $50,000 None (or less than $201) 4.7 - Delaware Diversified Income Yes $15,001 - $50,000 None (or less than $201) 4.8 TGBAX - Templeton Global Bond Adv Yes $1 ,001 - $15,000 None (or less than $201) 4.9 - Principal Global Div Yes $1 ,001 - $15,000 None (or less than 5 Mutual ofAmerica Tax Deferred Annuity No $201) DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 5.1 Deutsch VSI Capital Growth Yes $100,001 - $250,000 None (or less than $201) 6 UBS PSP (Personal Retirement Account) No 6.1 UBS Brokerage Account (cash) $1,001 - $15,000 None (or less than $201) 6.2 JHIGX .JHancock International Growth Fund Class R2 Yes $15,001 - $50,000 None (or less than $201) 6.3 -JHancock Disciplined Value Fund Class R2 Yes $15,001 - $50,000 None (or less than $201) 7 The Heritage Foundation 403(b) 7.1 - Schwab Government Money Fund Yes $100,001 - $250,000 None (or less than $201) 7.2 VFIAX - Vanguard 500 Index Admiral Yes $15,001 - $50,000 None (or less than $201) 7.3 PREIX - T. Rowe Price Equity Index 500 Yes $100,001 - $250,000 None (or less than $201) 8 The Heritage Foundation Retirement Plan (defined contribution plan) 8.1 - Schwab Government Money Fund Yes None (or less than None (or less than $201) 8.2 ARTKX - Artisan International Value Investor Yes $1,001 - $15,000 None (or less than $201) 8.3 BARAX - Baron Asset Retail Yes $1,001 - $15,000 None (or less than $201) 8.4 FAIRX - Fairholme Yes $15,001 - $50,000 None (or less than $201) 8.5 - Loomis Sayles Bond Instl Yes $1,001 - $15,000 None (or less than $201) 8.6 OAKMX - Oakmark I Yes $15,001 - $50,000 None (or less than $201) 8.7 RSEIX - Royce Special Equity Instl Yes $1,001 - $15,000 None (or less than $201) 8.8 SLASX - Selected American Shares 5 Yes $15,001 $50,000 None (or less than $201) 8.9 - T.Rowe Price Emerging Markets Stock Yes $1,001 - $15,000 None (or less than $201) 8.10 - Vanguard REIT Index Adm Yes $1 ,001 - $15,000 None (or less than $201) 811 WIIBX - Segall Bryant Hamil Plus Bond Instl See Endnote Yes $1,001 - $15,000 None (or less than $201) 9 UBS IRA 9.1 WGIFX - American Funds Capital World Gr Inc F2 Yes $50,001 - $100,000 None (or less than (UBS) $20? 9.2 FEGIX - First Eagle Gold I (UBS) Yes $15,001 - $50,000 None (or less than $201) 9.3 PEQPX - Principal Equity Income (UBS) Yes $50,001 - $100,000 None (or less than $201) 9.4 - RS Partners (UBS) Yes $15,001 - $50,000 None (or less than $201) 9.5 American Funds Growth Fund of Amer F2 Yes $50,001 - $100,000 None (or less than (UBS) $201) DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 9.6 - Delaware Diversified Income (UBS) Yes $50,001 - $100,000 None (or less than $201) 9.7 TGBAX - Templeton Global Bond Adv (UBS) Yes $15,001 - $50,000 None (or less than $201) 10 VMC - Vulcan Materials, Common Stock See Endnote WA $250,001 - $500,000 Dividends $2,501 - $5,000 11 lR- Ingersoll Rand (CSSP) See Endnote WA $100,001 - $250,000 Dividends $2,501 - $5,000 12 Vanguard IRA Account( Personal Retirement Account) 12.1 VFIAX - Vanguard 500 Index Admiral Yes $100,001 - $250,000 None (or less than $201) 3. Filer's Employment Agreements and Arrangements EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Wells Fargo Company See Endnote San Francisco, Pursuant to the terms of the company's Directors Stock 6/201 1 California Compensation and Deferral Plan Stock Award Deferrals, I will receive a stock payout for my deferred stock compensation (all of which is fully vested at the time of grant) based on various elections I have made each year that I have served on the Board. I will continue to receive deferred stock compensation equivalents, which track dividends on the company's common stock until I receive the stock payout. The approximate portion of my remaining deferred stock compensation to be paid out as of December 31, 2018 is as follows: March 2019 68%; March 2020 16%; and March 2021 16%. 2 The Heritage Foundation 403(b) Washington, District I will continue to participate in this defined contribution plan. 6/2016 of Columbia The sponsor has not made any further contributions since my separation from the company. 3 Firebird international LLC, Defined Benefit Plan Louisville, Kentucky I will continue to participate in this defined benefit plan. 5/2009 Delta Airlines Atlanta, Georgia As a former director of Northwest Airlines, which merged with 10/2008 Delta Airlines in 2009, I receive discounted travel on Delta Airlines. I have never been a director of Delta Airlines, and this benefit is taxable on such discounted airfare at rates established by the Internal Revenue Service. I will forgo this benefit while in office per my ethics agreement. 5 The Heritage Foundation Retirement Plan Washington, District I will continue to participate in this defined contribution plan. 6/2016 of Columbia The sponsor has not made any further contributions since my separation from the company. 6 Vulcan Materials See Endnote Birmingham, Pursuant to the terms of the company's Directors? Deferred 2/2015 Alabama Stock Unit Plan, I received a stock payout for all of my vested 4. Filer's Sources of Compensation Exceeding $5,000 in a Year - Not required for this type of report deferred stock units in April 2018. 5. Spouse's Employment Assets Income and Retirement Accounts DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT Merrill - IRA Mitch IRA - Required $8,480 Minimum Distribution 2 Mitch IRA MLPA 2.1 Bank of America - IRA Cash Account $1,001 - $15,000 Interest None (or less than $201) 2.2 SCPB - SPDR Barclays Short Term Corp Bd ETF Yes $15,001 - $50,000 None (or less than $201) 2.3 VCSH - Vanguard Short-Term Corporate Bond ETF Yes $15,001 - $50,000 None (or less than $201) 2.4 IWM - iShares Russell 2000 Yes $15,001 - $50,000 None (or less than $201) 2.5 V0 - Vanguard Mid-Cap ETF Yes $15,001 - $50,000 None (or less than $201) 2.6 SPY - SPDR 500 ETF Yes $50,001 - $100,000 None (or less than $201) 6. Other Assets and Income DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT - Vanguard Money Market Reserves Yes None (or less than None (or less than $1,001) $201) 2 - Vanguard Municipal Money Market Yes $1,000,001 - $15,001 - $50,000 $5,000,000 3 VFIAX Vanguard 500 Index Admiral Yes $5,000,001 $100,001 - $25,000,000 $1,000,000 4 US bank Money Market Account 1 (Cash) WA $250,001 - $500,000 Interest $201 - $1,000 5 Real Property with Carriage House Rental - $1 ,000,001 - Rent or Royalties $15,001 - $50,000 Washington, DC $5,000,000 6 US bank Account 1 (Cash) $1,001 - $15,000 None (or less than $201) 7 US bank Account 2 (Cash) $1,001 - $15,000 None (or less than $201) 8 - T. Rowe Price Blue Chip Growth Yes $250,001 - $500,000 $5,001 - $15,000 9 PRITX - T.Rowe Price International Stock Fd Yes $50,001 - $100,000 $2,501 - $5,000 10 - T. Rowe Price Mid-Cap Growth Yes $250,001 - $500,000 $15,001 . $50,000 11 - T. Rowe Price Science Tech Yes $15,001 - $50,000 $5,001 - $15,000 12 OTCFX - T. Rowe Price Small - Cap Stock Yes $50,001 - $100,000 $5,001 - $15,000 13 VGIAX Vanguard Growth Income Adm Yes $250,001 - $500,000 $5,001 - $15,000 14 - Vanguard Municipal Money Market Yes $100,001 - $250,000 $5,001 - $15,000 15 VFIAX - Vanguard 500 Index Admiral Yes $1,000,001 - $15,001 - $50,000 $5,000,000 DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 16 HaneLChaoRewxameTnst 17 USbankAccount3(Cash) $15001-$50000 $201) 18 MNNAX - Victory Munder Multi-Cap A Yes $15,001 - $50,000 $5,001 - $15,000 19 Yes $250001-$500000 $15001-$50000 20 Yes $250001-$500000 $5001-$15000 21 VHAX-Vanguanj500 ndexAdnmal Yes $250001-$500000 $5001-$15000 22 A. Mitchell McConnell,Jr. Revocable Trust 22.1 US Brokerage Money Market Account (Cash) WA $15,001 - $50,000 Dividends $201 - $1,000 23 Vanguard 529 College Savings Plan 23.1 Vanguard Aggressive Growth Portfolio (Age Based) Yes $50,001 - $100,000 None (or less than $201) 24 Vanguard 529 College Savings Plan 24.1 Vanguard Aggressive Growth Portfolio (Age Based) Yes $50,001 - $100,000 None (or less than $201) 25 MNNAX - Victory Munder Multi-Cap Fund CIA Yes $15,001 - $50,000 $201 - $1,000 7. Transactions DESCRIPTION TYPE DATE AMOUNT 1 WFC - Wells Fargo Co See Endnote Purchase 09/06/18 $1,001 - $15,000 2 WFC - Wells Fargo Co See Endnote Purchase 03/05/18 $1,001 - $15,000 3 WFC - Wells Fargo Co See Endnote Purchase 06/01/18 $1 ,001 - $15,000 4 WFC - Wells Fargo Co See Endnote Purchase 12/05/18 $1 .001 - $15,000 5 - T. Rowe Price Blue Chip Growth See Endnote Purchase 12/13/18 $1 .001 - $15,000 6 PRITX - T. Rowe Price International Stock See Endnote Purchase 12/17/18 $1,001 - $15,000 7 - T. Rowe Price Mid-Cap Growth See Endnote Purchase 12/13/18 $15,001 - $50,000 8 - T. Rowe Price Science Technology See Endnote Purchase 12/14/18 $1,001 - $15,000 9 OTCFX - T. Rowe Price Small - Cap Stock See Endnote Purchase 12/13/18 $1 .001 - $15,000 10 VFIAX - Vanguard 500 Index Fund See Endnote Purchase 03/23/18 $15,001 - $50,000 11 VFIAX - Vanguard 500 Index Adm See Endnote Purchase 06/27/18 $15,001 - $50,000 12 VFIAX - Vanguard 500 Index Adm See Endnote Purchase 09/25/18 $15,001 - $50,000 13 VFIAX - Vanguard 500 Index Adm See Endnote Purchase 12/14/18 $15,001 - $50,000 14 VGIAX Vanguard Growth Income See Endnote Purchase 06/15/18 $1,001 - $15,000 15 VGIAX - Vanguard Growth Income See Endnote Purchase 12/18/18 $15,001 - $50,000 16 MNNAX - Victory Munder Multi - Cap Fund Class A See Endnote Purchase 12/19/18 $1 ,001 - $15,000 (Spouse) 17 Vanguard Aggressive Growth Portfolio (Age Based) Purchase 12/03/18 $1 .001 - $15,000 (Spouse) 18 VHCAX - Vanguard Capital Opportunity Fund Admiral See Endnote Purchase 12/18/18 $1,001 - $15,000 Shares(Spouse) 19 Vanguard Aggressive Growth Portfolio (Age Based) Purchase 12/03/18 $1 .001 - $15,000 (Spouse) DESCRIPTION VHCAX - Vanguard Capital Opportunity Fund Admiral See Endnote Shares (Spouse) VSIAX - Vanguard Small Cap Value Index Fund Admiral Shares (Spouse) VSIAX - Vanguard Small Cap Value Index Fund Admiral Shares (Spouse) VSIAX - Vanguard Small Cap Value Index Fund Admiral Shares (Spouse) VSIAX - Vanguard Small Cap Value Index Fund Admiral Shares (Spouse) VFIAX - Vanguard 500 Index Fund Admiral Shares (Spouse) VFIAX Vanguard 500 Index Fund Admiral Shares (Spouse) VFIAX - Vanguard 500 Index Fund Admiral Shares (Spouse) VFIAX - Vanguard 500 Index Fund Admiral Shares (Spouse) VFIAX - Vanguard 500 Index Fund Admiral Shares (Defined Benefit Plan) MNNAX - Victory Munder Multi-Cap Fund Class A MNNAX - Victory Munder Multi-Cap Fund Class A VFAIX - Vanguard 500 Index Admiral (IRA) VFAIX - Vanguard 500 Index Admiral (IRA) VFAIX - Vanguard 500 Index Admiral (IRA) VFAIX - Vanguard 500 Index Admiral (IRA) -John Hancock Funds Disciplined Value Funds Class R2 (UBS PSP) WGIFX - American Funds Capital World Gr&lnc F2 - American Funds The Growth Fund of America Class F2 (UBS Pension Trust) PEQPX - Principal Equity Income (UBS Pension Trust) PEQPX - Principal Equity Income (UBS IRA) WGIFX - American Funds Capital World Gr&lnc F2 (UBS IRA) - Victory RS Partners Fund Class (UBS IRA) - American Funds The Growth Fund of America Class F2 (UBS IRA) MNNAX - Victory Munder Multi-Cap Fund Class A (Spouse) 8. Liabilities None See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote See Endnote TYPE Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Sale Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase DATE 12/18/18 03/21/18 06/21/18 09/27/18 12/21/18 03/23/18 06/27/18 09/25/18 12/14/18 04/02/18 12/19/18 12/19/18 03/23/18 06/27/18 09/25/18 12/14/18 12/17/18 12/19/18 12/24/18 12/20/18 12/20/18 12/19/18 12/20/18 12/24/18 12/19/18 AMOUNT $15,001 - $50,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001- $15,000 $1,000,001 - $5,000,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1.001- $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 $1,001 - $15,000 9. Gifts and Travel Reimbursements SOURCE NAME CITY, STATE BRIEF DESCRIPTION VALUE 1 Waterways Council Washington, District 17th Annual Waterways Council Inc. Leadership Award plaque - 469 of Columbia Spouse 2 The Veterans of Foreign Wars of the United States Kansas City, Veterans of Foreign Wars (VFW) Gold Medal of Merit - Spouse 398 Missouri 3 Minor League Baseball St. Petersburg, Plaque from Minor League Baseball in recognition of leadership 826 Florida and public service - Spouse Endnotes PART ENDNOTE 1. 1 This is a single-member pass-through entity whose sole source of income is from my director fees and speaking fees, as separately disclosed herein. The only income in 2018 in Firebird international LLC is from director fees that were earned in a prior year, but deferred until 2018. 2. 1 This is a single-member passethrough entity whose sole source of income is from my director fees and speaking fees, as separately disclosed herein. The only income in 2018 in Firebird international LLC is from director fees that were earned in a prior year, but deferred until 2018. 8.11 Security name change in 2018; formerly Westcore Plus Bond institutional 10 Although advised by the DAEO that the holding of Vulcan Materials stock does not create a conflict of interest, the flier divested all of the Vulcan Materials stock that is reported in Part 2, Line 10 on 6/3/2019, thus no longer retaining a financial interest in the company, as indicated in the filer's ethics agreement. 2. 11 This corrects the financial disclosure report filed on 12/6/2016. On that report, the status and terms of Part 3, Line 8 referred to a "cash payout" that would be received under the Directors' Retainer Stock Unit Plan. Part 3, Line 8 of that report should have referred to a "stock payout." Although advised by the DAEO that the holding of lngersoil Rand stock does not create a conflict of interest, the filer divested all of the lngersoil Rand stock that is reported in Part 2, Line 11 on 6/3/2019, thus no longer retaining a financial interest in the company, as indicated in the filer's ethics agreement. 3. 1 This corrects the financial disclosure report filed on 12/6/2016. On that report, the status and terms of Part 3, Line 2 referred to a "cash payout" that would be received under the Directors Stock Compensation and Deferral Plan - Stock Award Deferrals. Part 3, Line 2 of that report should have referred to a "stock payout." 3. 6 This corrects the financial disclosure reports filed on 12/6/2016 and 5/15/2018. On these reports, the status and terms of Part 3, Line 7 referred to a "cash payout" that would be received under the Directors? Deferred Stock Unit Plan. Part 3, Line 7 of both reports should have referred to a "stock payout" in April 2018. 7. 1 Dividend Reinvestment 7. 2 Dividend Reinvestment 7. 3 Dividend reinvestment 7. 4 Dividend Reinvestment 7. Dividend Reinvestment 7. 6 Dividend Reinvestment 7. 7 Dividend Reinvestment 7. 8 Dividend Reinvestment 7. 9 Dividend Reinvestment 7. 10 Dividend Reinvestment 7. 11 Dividend Reinvestment 7. 12 Dividend Reinvestment 7. 13 Dividend Reinvestment 7. 14 Dividend Reinvestment 7. 15 Dividend Reinvestment 7. 16 Capital Gains Reinvestment PART ENDNOTE 7. 18 Dividend Reinvestment 7. 20 Capital Gains Reinvestment 7. 21 Dividend Reinvestment 7. 22 Dividend Reinvestment 7. 23 Dividend Reinvestment 7. 24 Dividend Reinvestment 7. 25 Dividend Reinvestment 7. 26 Dividend Reinvestment 7. 27 Dividend Reinvestment 7. 28 Dividend Reinvestment 7. 29 Conversion of entire defined benefit plan holdings to VUSXX - Vanguard Treasury Money Market 7. 30 Dividend Reinvestment 7. 31 Capital Gain Reinvestment 7. 32 Dividend Reinvestment 7. 33 Dividend Reinvestment 7. 34 Dividend Reinvestment 7. 35 Dividend Reinvestment 7. 36 Dividend Reinvestment 7. 37 Dividend Reinvestment 7. 38 Dividend Reinvestment 7. 39 Dividend Reinvestment 7. 40 Dividend Reinvestment 7. 4i Dividend Reinvestment 7. 42 Dividend Reinvestment 7. 43 Dividend Reinvestment 7. 44 Dividend Reinvestment 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 ifthe 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 8: 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 salary, fees, partnership share, honoraria, scholarships, and prizes) . Assets related to the filer's business, employment, or other income-generating activities (1 that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in income was received 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 filer'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 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 vested and unvested stock options, restricted stock. future share of a company's profits, etc.) 0 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 flier 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 flier did not provide the services for which the client is paying. 5. Spouse's Employment Assets 8: 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 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 (1)that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in income was received 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 filer'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 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) that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in investment income was received 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 Thrift Savings Plan); and (3) cash accounts checking, savings, money market accounts) at a single financial institution with a value of $5,000 or less (unless more than $200 in income was received). 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 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. L1ab111t1es 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 $390 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. . Travel reimbursements totaling more than $390 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 $156 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) oftitle 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 ofJustice 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 (1 1) 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 executive branch-wide Privacy Act system of records. Public Burden Information This collection of information is estimated to take an average of ten 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 278a).