October 8, 2020 BY U.S. MAIL Phyllis K. Fong Inspector General U.S. Department of Agriculture Office of Inspector General PO Box 23399 Washington, DC 20026-3399 Re: Request for Investigation of Secretary Perdue’s Violations of His Ethical Commitments with Regard to His Trusts and Underlying Assets Dear Inspector General Fong: American Oversight respectfully requests that your Office conduct an investigation of Secretary Perdue’s apparent violations of the ethical commitments that he made in March 2017, shortly before being confirmed for the position of Secretary of the U.S. Department of Agriculture. Although he had promised to reorganize his existing trusts so as to create new trusts from which he would not benefit, Secretary Perdue nevertheless claimed nearly $650,000 in income from the underlying assets of one of the trusts in 2019. Furthermore, Secretary Perdue acts as cotrustee to the other trust, contrary to the terms of his 2017 ethics agreement. The Secretary’s numerous and labyrinthine financial interests in agribusiness and land development makes it essential that his ethical commitments be rigorously enforced so as to not create a conflict of interest. Accordingly, we ask that your Office ensure that Secretary Perdue not continue to violate the promises he made with respect to those interests. Secretary Perdue’s Trusts and Financial Interests Mr. Perdue was nominated to become the U.S. Secretary of Agriculture on January 18, 2017. At that time, Secretary Perdue and his wife, Mary Perdue, had two trusts: the couple served as “cotrustees and sole beneficiaries of the Perdue Family Revocable Management Trust,” and Mary Perdue was “the trustee and one of the beneficiaries of the Perdue Family Wealth Preservation Trust.”1 Secretary Perdue promised to reorganize these trusts and their financial interests shortly after confirmation so as to not benefit him or his wife: Within 90 days of my confirmation, I will cause these trusts to be restructured such that I will revoke the Perdue Family Revocable Management Trust and transfer all of its stock in Perdue Business Holdings, Inc. into a new, irrevocable trust (“New Family Management Trust”) that will not benefit me or my spouse. Neither I nor my wife will serve as trustee of the New Family Letter from George Ervin “Sonny” Perdue III to Designated Agency Ethics Officials Stuart Bender at 1, Mar. 7, 2017, https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/62146DAAA13D84E7852580E1002C8 262/$FILE/Perdue,%20George%20E.%20%20finalEA.pdf (“March 7, 2017 Letter”); see also Sonny Perdue, 2017 U.S. Office of Gov’t Ethics Form 278e at 6–7 (attached to this letter as Exhibit A). 1 1030 15th Street NW, Suite B255, Washington, DC 20005 AmericanOversight.org Management Trust. Until the steps outlined in this paragraph are completed, I will not participate personally and substantially in any particular matter that to my knowledge has a direct and predictable effect on the financial interests of the Perdue Family Revocable Management Trust or any of its underlying holdings. Within 90 days of my confirmation, the appointment committee for the Perdue Family Wealth Preservation Trust will appoint all of its stock in Perdue Business Holdings, Inc. to a new, irrevocable trust (“New Wealth Preservation Trust”) that will not benefit me or my spouse. Neither I nor my wife will serve as trustee of the New Wealth Preservation Trust, and the trust document for the New Wealth Preservation Trust will expressly prohibit its appointment committee from appointing trust assets to me or my spouse. I will not participate personally and substantially in any particular matter that to my knowledge has a direct and predictable effect on the financial interests of the Perdue Family Wealth Preservation Trust, or any of its underlying holdings, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(1), or qualify for a regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2).2 In short, Secretary Perdue promised that the new trusts would not benefit either him or his wife, and that neither would serve as a trustee of either new trust. Secretary Perdue did not keep these promises. In his 2018 ethics disclosure, Secretary Perdue listed neither the trusts that he promised to reorganize nor any new, reorganized trusts.3 In his 2019 disclosure, however, Secretary Perdue disclosed two new assets, the FALF Preservation Trust and the FALF Management Trust, the assets of which are nearly identical to the assets of the two conflicted trusts disclosed in Secretary Perdue’s original nominee disclosure in 2017.4 Despite writing that he would not “serve as trustee of the New Family Management Trust,” Secretary Perdue became a co-trustee of the FALF Management Trust in November 2018.5 Similarly, although Secretary Perdue wrote that the new preservation trust would “not benefit me or my spouse,”6 he received at least $649,997 in income from assets of the FALF Preservation Trust in 2019,7 as described in more detail below. The Secretary’s continued interest in the assets of the FALF Management Trust and the FALF Preservation Trust on his financial disclosures represent clear violations of his ethics agreement. Secretary Perdue has visibility into and control over the trusts and their underlying assets, and he continues to benefit from them despite the plain terms of his 2017 ethics agreement. Id. at 2. Sonny Perdue, 2018 U.S. Office of Gov’t Ethics Form 278e (attached to this letter as Exhibit B). 4 Sonny Perdue, 2019 U.S. Office of Gov’t Ethics Form 278e at 6–8 (“2019 Form 278e”) (attached to this letter as Exhibit C). 5 Id. at 3. 6 March 7, 2017 Letter at 2, supra note 1. 7 See 2019 Form 278e at 6–8, supra note 4. 2 3 2 Secretary Perdue Received At Least $648,997 in Income Through the FALF Preservation Trust in 2019 Secretary Perdue promised in his 2017 ethics agreement that the new preservation trust, presumably the FALF Preservation Trust, would “not benefit me or my spouse.”8 Nevertheless, he received at least $649,997 in income from assets underlying the FALF Preservation Trust in 2019.9 Specifically, the FALF Preservation Trust owns FALF, LLC, which is a holding company for Soque River Conservation LLC,10 as well as “100% of the non-voting stock in Perdue Business Holdings Inc.”1112 Perdue Business Holdings, in turn, owns Perdue, Inc., StarPort Logistics LLC, and Houston Fertilizer and Grain Co., Inc., among other companies.13 According to his 2019 filing with the Office of Government Ethics, Secretary Perdue claimed income from Perdue, Inc., StarPort Logistics, Houston Fertilizer and Grain, and Soque River Conservation in 2019: $320,473 from Perdue, Inc.,14 $99,587 from StarPort Logistics,15 $91,738 from Houston Fertilizer and Grain,16 and $138,179 from Soque River Conservation.17 The receipt of this income appears contrary to the agreement that Secretary Perdue signed in 2017. American Oversight therefore respectfully requests that your Office investigate Secretary Perdue’s receipt of income from these assets underlying the FALF Preservation Trust as a violation of his 2017 ethics agreement. Secretary Perdue Significantly Benefited from a 2018 U.S. Army Corps of Engineers Decision Regarding Assets Owned by Soque River Conservation LLC The $138,179 in 2019 income that Secretary Perdue claimed from Soque River Conservation LLC—owned under the FALF Preservation Trust—was generated in part through the “sale of conservation mitigation bank credits” to offset the adverse environmental impacts of land development.18 These mitigation credits were created under a formal agreement with and regulated by the U.S. Army Corps of Engineers (USACE).19 March 7, 2017 Letter at 2, supra note 1. See 2019 Form 278e at 6–8, supra note 4. 10 Id. at 6, 9. 11 Id. at 9. 12 Although Secretary Perdue only reported income from Perdue Business Holdings under the FALF Preservation Trust, id. at 7–8, his disclosures also state that "FALF Management Trust owns . . . 100% of the voting stock of Perdue Business Holdings, Inc.," id. at 11. The income of companies owned by Perdue Business Holdings therefore relates to both of Secretary Perdue's trusts. 13 Id. at 9–11. 14 Id. at 8. 15 Id. 16 Id. 17 Id. at 6. 18 Id. 19 Public Notice, Savannah District, Project Number SAS-2010-00442, U.S. Army Corps of Engineers, July 9, 2018, https://www.sas.usace.army.mil/Portals/61/docs/Regulatory/publicnotices/Final_PN_SoqueRi ver_9July2018.pdf?ver=2018-07-09-174751-933. 8 9 3 Wetland mitigation bank credits are granted by the federal government for the “restoration, creation, or enhancement of wetlands for the purpose of compensating for unavoidable impacts to wetlands at another location.”20 Wetland mitigation banking, which uses grants to mitigation bankers who have bought and restored agricultural property that includes damaged wetlands, “is commonly used to compensate for wetland impacts from development, but it also used for impacts from agriculture.”21 As credits are sold to offset development impacts, “they are subtracted from the bank until all the available credits are purchased.”22 The price of each credit in subsequent transactions is “negotiated between the buyer and seller.”23 In 2009, "[Secretary] Perdue and a partner, Aaron McWhorter, bought a 157-acre parcel of agricultural property in Habersham County along the Soque River for $3.7 million.”24 By 2014, the conversion of the property from a “sod farm along the Soque River in Clarkesville . . . into a [m]itigation [b]ank” was underway.25 The Soque River Conservation land is in the Savannah District, and its granted credits include both wetland credits and stream credits, which are valued at different prices.26 As of 2019, according to a Georgia Department of Transportation interoffice memo, in the Upper Chattahoochee Watershed, which includes Perdue’s Soque River property, stream credits were valued at $38 per credit and wetland credits were valued at $50,000 per credit.27 In 2018, during Secretary Perdue’s tenure as Secretary of Agriculture, Soque River Conservation asked USACE to increase its held wetland credits and decrease its stream credits, thus dramatically increasing the value of the credits associated with the property.28 Specifically, the requested modification was for a "59.12 wetland credit increase" and a "616.01 stream credit decrease."29 If the values given by the 2019 Georgia Department of Transportation interoffice memo are correct, that modification would have amounted to a $2,956,000 increase in value from wetland credits for a $23,408.38 decrease in stream credits, a net gain of more than $2.9 million. USACE enjoys “a long-term working relationship” with USDA “to improve the management of water and related natural resources,” and “work[s] together” with USDA’s Natural Resource Conservation Service on “wetlands creation, restoration and enhancement.”30 Secretary Perdue, for his part, stood to significantly benefit from USACE's decision regarding the requested Soque U.S. Dept. of Agriculture, Conservation Compliance and Wetland Mitigation Banking, https://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/programs/farmbill/?cid=nrcsepr d362686 21 Id. 22 Id. 23 Id. 24 Jay Bookman, Perdue Seeks Opportunity in Wetlands Bank, Atlanta J. Cons., Dec. 17, 2010, available at https://www.pressreader.com/usa/the-atlanta-journalconstitution/20101217/281895884664400. 25 Soque River Watershed Association News, Georgia Foothills, Sept. 11, 2014, http://www.georgiafoothills.org/2014/09/soque-river-watershed-association-news.html. 26 Public Notice, supra note 18. 27 Georgia Dep't of Transport., Interoffice Memo, P.I. # 001757, Jul. 16, 2019 (excerpt attached to this letter as Exhibit D). 28 Public Notice, supra note 18. 29 Id. at 2. 30 U.S. Dep’t of Agriculture, Nat. Res. Conservation Serv., NRCS and US Army Corps of Engineers (USACE) National Partnership, https://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/nwmc/?cid=nrcs143_014960. 20 4 River Conservation credit modification. Given the Secretary’s commitment to “not participate personally and substantially in any particular matter that to [his] knowledge has a direct and predictable effect on the financial interests” of the assets underlying his trusts,31 American Oversight requests that your Office investigate whether Secretary Perdue improperly participated in any USACE decision to alter the composition of Soque River Conservation’s mitigation credits during his tenure as Secretary. Conclusion Secretary Perdue has continued to benefit from the assets of the FALF Preservation Trust, despite the terms of the 2017 ethics agreement that he signed before his confirmation as Secretary. Furthermore, he acts as co-trustee of the FALF Management Trust against the terms of that same agreement. American Oversight requests that your Office ensure that Secretary Perdue is held to strict compliance with his ethical agreements by investigating whether he properly claimed income from FALF Preservation Trust assets, whether he may serve as cotrustee of the FALF Management Trust, and whether he has had any improper involvement in any USACE decision regarding Soque River Conservation LLC’s mitigation bank credits. If you have any questions or require additional information, please contact Hart Wood at (202) 873-1743 or hart.wood@americanoversight.org. Thank you for your consideration of this important matter. Respectfully, Austin Evers Executive Director American Oversight 31 March 7, 2017 Letter at 2, supra note 1. 5 EXHIBIT A 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 Perdue, George Ervin Secretary, Department of Agriculture Other Federal Government Positions Held During the Preceding 12 Months: None Names of Congressional Committees Considering Nomination: ● Committee on Agriculture, Nutrition, and Forestry 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/ Perdue, George Ervin [electronically signed on 02/01/2017 by Perdue, George Ervin 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/ Bender, Stuart, Certifying Official [electronically signed on 03/10/2017 by Bender, Stuart in Integrity.gov] Other review conducted by U.S. Office of Government Ethics Certification /s/ Shaub, Walter M, Certifying Official [electronically signed on 03/10/2017 by Shaub, Walter M in Integrity.gov] 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Perdue Management Holdings LLC Bonaire, Georgia Limited Liability Company Manager 10/2010 Present 2 Perdue Family Revocable Management Trust Bonaire, Georgia Trust Trustee 12/2010 Present 3 Bipartisan Policy Center Governor's Council Washington, District of Columbia Non-Profit Council Member 8/2012 Present 4 Georgia Agribusiness Council Commerce, Georgia State Agriculture Industry Organization Secretary 1/2015 Present 5 National Grain and Feed Association Arlington, Virginia Industry Association Member, Board of Directors 1/2015 Present 6 Perdue Business Holdings, Inc. Bonaire, Georgia Corporation Member, Board of Directors 12/2010 Present 7 Perdue Properties LLC See Endnote Bonaire, Georgia Limited Liability Company Sole Owner 11/2010 Present 8 Perdue Real Estate Holdings LLLP See Endnote Bonaire, Georgia Limited Liability Limited Partnership Sole Owner 11/2010 Present VALUE INCOME TYPE INCOME AMOUNT 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF 1 Roth IRA No 1.1 Fidelity Government Cash Reserves (FDRXX) Yes $1,001 - $15,000 None (or less than $201) 1.2 Fidelity 500 Index Premium Class (FUSVX) Yes $15,001 $50,000 $201 - $1,000 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.3 Baron Emerging Markets Fund Retail (BEXFX) Yes $1,001 - $15,000 None (or less than $201) 1.4 Columbia Dividend Opportunity CL A (INUTX) Yes $1,001 - $15,000 None (or less than $201) 1.5 Columbia Select Lrg Cap Growth CL A (ELGAX) Yes $15,001 $50,000 None (or less than $201) 1.6 Delaware Value Fund CL A (DDVAX) Yes $15,001 $50,000 $201 - $1,000 1.7 Driehaus Micro Cap Growth Fund (DMCRX) Yes $1,001 - $15,000 None (or less than $201) 1.8 MFS International Value Fund CL A (MGIAX) Yes $15,001 $50,000 $201 - $1,000 1.9 T Rowe Price Growth Stock Advisor CL (TRSAX) Yes $15,001 $50,000 None (or less than $201) 1.10 Ridgeworth Ceredex Mid Cap Value EQ I (SMVTX) Yes $15,001 $50,000 $201 - $1,000 1.11 T Rowe Price Intl Stock Advisor CL (PAITX) Yes $15,001 $50,000 None (or less than $201) 1.12 TCW Relative Value Dividend Apprec CL N (TGIGX) Yes $15,001 $50,000 $201 - $1,000 1.13 Touchstone Focused CL A (TFOAX) Yes $1,001 - $15,000 None (or less than $201) 1.14 Touchstone Small Cap Value CL A (TVOAX) Yes $1,001 - $15,000 None (or less than $201) 1.15 Victory Global Natural Resources A (RSNRX) Yes $1,001 - $15,000 None (or less than $201) 1.16 Wasatch International Opportunities Fund (WAIOX) Yes $1,001 - $15,000 None (or less than $201) 1.17 Wasatch Frontier Emerging Small CO's (WAFMX) Yes $1,001 - $15,000 None (or less than $201) 1.18 Avenue Credit Strategies Investor (ACSAX) Yes $1,001 - $15,000 $201 - $1,000 1.19 Doubleline Total RT Bond FD CL N (DLTNX) Yes $1,001 - $15,000 $201 - $1,000 # DESCRIPTION EIF VALUE 1.20 Doubleline Low Durtn Emerg Mkts FIX Inc N (DELNX) Yes $1,001 - $15,000 None (or less than $201) 1.21 Dreyfus Bond Market Index Invs (DBMIX) Yes $1,001 - $15,000 $201 - $1,000 1.22 Driehaus Event Driven Fund (DEVDX Yes $1,001 - $15,000 None (or less than $201) 1.23 Driehaus Active Income Fund (LCMAX) Yes $1,001 - $15,000 $201 - $1,000 1.24 JP Morgan Strategic Income Opport A (JSOAX) Yes $1,001 - $15,000 None (or less than $201) 1.25 Riverpark Strategic Income Fund Retail (RSIVX) Yes $1,001 - $15,000 None (or less than $201) 1.26 Riverpark Short Term High Yield Retail (RPHYX) Yes $1,001 - $15,000 None (or less than $201) 1.27 Rivernorth Core Opportunity FD L R (RNCOX) Yes $1,001 - $15,000 $201 - $1,000 2 Georgia Legislative Retirement System (Defined Benefit Pension - Value not Readily Ascertainable) N/A State retirement payments. Filer receives $326.71 per month. 3 Bipartisan Policy Center, Inc. N/A Compensation for service as a Member of the Governor's Council. $30,000 4 Bipartisan Policy Center, Inc. - 7/26/16 N/A Honorarium $10,000 5 Poplar Springs North Baptist Church 2/17/16 N/A Honorarium $300 3. Filer's Employment Agreements and Arrangements INCOME TYPE INCOME AMOUNT # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Georgia Legislative Retirement System Atlanta, Georgia I have a defined benefit pension from the State of Georgia. I receive $326.71 per month. I will continue to participate in this plan. 1/1992 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 Bipartisan Policy Center, Inc. Washington, District of Columbia Service as member of the Governor's Council to help formulate bipartisan policy as well as honorarium. 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE 1 Roth IRA No 1.1 JP Morgan Income Builder Fund Cl C (JNBCX) Yes $15,001 $50,000 INCOME TYPE INCOME AMOUNT $201 - $1,000 6. Other Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 U.S.bank account #1 (cash) N/A $50,001 $100,000 Interest $201 - $1,000 2 Residential real estate, Butts County, Georgia N/A $500,001 $1,000,000 None (or less than $201) 3 Undeveloped land, Osceola County, Florida N/A $250,001 $500,000 None (or less than $201) 4 Undeveloped land, Houston County, Georgia N/A $250,001 $500,000 None (or less than $201) # DESCRIPTION EIF VALUE 5 Undeveloped land, Houston County, Georgia N/A $100,001 $250,000 None (or less than $201) 6 TIAA Path2College 529 Plan Yes $50,001 $100,000 None (or less than $201) 7 Note Receivable from AGrowStar, LLC N/A $500,001 $1,000,000 Interest $50,001 $100,000 8 Perdue Family Wealth Preservation Trust See Endnote No 8.1 FALF LLC See Endnote No 8.1.1 Soque River Conservation LLC See Endnote N/A $500,001 $1,000,000 Land rent and sale of conservation mitigation bank credits. $35,617 8.2 Perdue Business Holdings Inc. See Endnote No 8.2.1 Legacy 13:22 LLC See Endnote N/A 8.2.1.1 TW Rocky Mount Real Estate LLC See Endnote N/A $500,001 $1,000,000 None (or less than $201) 8.2.1.2 TWAS Rocky Mount LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 8.2.1.3 U.S. bank account #3 N/A $15,001 $50,000 8.2.2 Perdue Partners LLC See Endnote No None (or less than $1,001) None (or less than $201) 8.2.2.1 Perdue Consulting Group LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 8.2.2.2 Benton Global LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 8.2.2.3 Benton Logistics LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 8.2.3 U.S. bank account #2 (cash) N/A $250,001 $500,000 See Endnote INCOME TYPE Interest Interest INCOME AMOUNT None (or less than $201) $2,501 - $5,000 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 8.2.4 AGrowStar LLC See Endnote N/A $5,000,001 $25,000,000 Passive business ownership income. $15,326 8.2.5 Perdue, Inc. See Endnote N/A $1,000,001 $5,000,000 Passive business ownership income. $598,591 8.2.6 Houston Fertilizer and Grain Co., Inc. See Endnote N/A $1,000,001 $5,000,000 Passive business ownership income. $28,305 8.2.7 ProAg Products LLC See Endnote N/A $50,001 $100,000 Passive business ownership income. $50,307 8.2.8 StarPort Logistics LLC See Endnote N/A $100,001 $250,000 Passive business ownership income. $99,587 9 Perdue Family Revocable Management Trust See Endnote No 9.1 Perdue Management Holdings LLC See Endnote N/A 9.2 Perdue Business Holdings, Inc. See Endnote No 10 Note receivable from the Perdue Family Wealth Preservation Trust 7. Transactions (N/A) - Not required for this type of report N/A None (or less than $1,001) None (or less than $201) None (or less than $201) $1,000,001 $5,000,000 Interest $15,001 $50,000 8. Liabilities # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 1 Citizens Bank of the South Personal Loan $15,001 $50,000 2016 2.250% 12/2017 2 CB&T Loan Guarantor 50% $500,001 $1,000,000 2013 3.25% 12/2021 3 CB&T Loan Guarantor 50% $500,001 $1,000,000 2013 3.25% 12/2021 4 Morris Bank Loan Guarantor $250,001 $500,000 2016 4.45% 192 Months 9. Gifts and Travel Reimbursements (N/A) - Not required for this type of report Endnotes PART # ENDNOTE 1. 7 Perdue Properties LLC is an empty company which has never held any assets nor engaged in any business. 1. 8 Perdue Real Estate Holdings LLLP is an empty company which has never held assets nor engaged in any business. 6. 6 This investment, the 100% EQUITY option, tracks the TIAA-CREF Equity Index Fund Institutional Class (TIEIX) 6. 8 Perdue Family Wealth Preservation Trust owns FALF and 100% of the non-voting stock in Perdue Business Holdings Inc. 6. 8.1 FALF LLC is a single member Limited Liability Company owned by Perdue Family Wealth Preservation Trust. FALF LLC is a holding company for Soque River Conservation LLC. PART # ENDNOTE 6. 8.1.1 Soque River Conservation LLC is owned by FALF LLC. Soque River Conservation LLC is a passive landholding partnership on the Soque River in Georgia. 6. 8.2 Perdue Business Holdings Inc. is owned by the Perdue Family Wealth Preservation Trust and the Perdue Family Revocable Trust. Underlying assets of Perdue Business Holdings are shown in Lines 8.2 through 8.2.8, and the value shown for the underlying assets is the full value for each holding. 6. 8.2.1 Legacy 13:22 LLC is a single member LLC owned by Perdue Business Holdings Inc. Legacy 13:22 is a holding company for TW Rocky Mount Real Estate LLC and TWAS Rocky Mount LLC. 6. 8.2.1.1 TW Rocky Mount Real Estate LLC is majority owned by Legacy 13:22 LLC. TW Rocky Mount Real Estate LLC owns the real estate in Rocky Mount, North Carolina, upon which the car wash owned by TWAS Rocky Mount LLC is being constructed. 6. 8.2.1.2 TWAS Rocky Mount LLC is majority owned by Legacy 13:22 LLC. TWAS Rocky Mount LLC is an operating business that owns a car wash that is currently under construction. 6. 8.2.2 Perdue Partners LLC is 25% owned by Perdue Business Holdings Inc. This consulting company is dormant. 6. 8.2.2.1 Perdue Consulting Group LLC is owned by Perdue Partners LLC. This business consulting company is not currently operating and has no current clients. 6. 8.2.2.2 Benton Global LLC is owned by Perdue Partners LLC. This is a trucking company that is not currently operating. 6. 8.2.2.3 Benton Logistics LLC is owned by Perdue Partners LLC. This is a logistics company that is not currently operating. 6. 8.2.4 AGrowStar LLC is a Qualified Subchapter S Subsidiary owned by Perdue Business Holdings Inc. AGrowStar LLC is a grain merchandising company. 6. 8.2.5 Perdue Inc. is a Qualified Subchapter S Subsidiary owned by Perdue Business Holdings Inc. Perdue Inc is a trucking company. 6. 8.2.6 Houston Fertilizer and Grain Co., Inc. is a Qualified Subchapter S Subsidiary owned by Perdue Business Holdings Inc. Houston Fertilizer and Grain Co, Inc. does not engage in agribusiness, it simply holds, manages and rents commercial real estate in Bonaire, Fort Valley, and Calhoun, Georgia. 6. 8.2.7 ProAg Products LLC is a single member Limited Liability Company owned by Perdue Business Holdings Inc. ProAg Products is a grain market trading business. 6. 8.2.8 StarPort Logistics LLC is a single member Limited Liability Company owned by Perdue Business Holdings Inc. StarPort Logistics LLC is an operating logistics company. 6. 9 Perdue Family Revocable Management Trust owns Perdue Management Holding LLC and 100% of voting stock of Perdue Business Holdings Inc. PART # ENDNOTE 6. 9.1 Perdue Management Holdings LLC is 100% owned by the Perdue Family Revocable Management Trust. Perdue Management Holdings LLC is a holding company that is dormant and has no assets or holdings. 6. 9.2 Underlying assets of Perdue Business Holdings is shown in Lines 8.2 through 8.2.8. 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.) 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 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. 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). EXHIBIT Annual Report 2018 U.S. Office of Government Ethics; 5 C.F.R. part 2634 Form Approved: OMB No. (3209-0001) (January 2018) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information Perdue, George Ervin Secretary, Department of Agriculture Report Year: 2018 Other Federal Government Positions Held During the Preceding 12 Months: None 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/ Perdue, George Ervin [electronically signed on 06/01/2018 by Perdue, George Ervin in Integrity.gov] - Filer received a 45 day filing extension. 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/ Bender, Stuart, Certifying Official [electronically signed on 07/16/2018 by Bender, Stuart in Integrity.gov] Other review conducted by U.S. Office of Government Ethics Certification /s/ Skalla, Daniel L, Certifying Official [electronically signed on 07/20/2018 by Skalla, Daniel L in Integrity.gov] Perdue, George Ervin - Page 1 Data Revised 07/03/2018 Data Revised 06/01/2018 Perdue, George Ervin - Page 2 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 Perdue Management Holdings LLC Bonaire, Georgia Limited Liability Company Manager 10/2010 4/2017 2 Perdue Family Revocable Management Trust Bonaire, Georgia Trust Trustee 12/2010 7/2017 3 Bipartisan Policy Center Governor's Council Washington, District of Columbia Non-Profit Council Member 8/2012 4/2017 4 Georgia Agribusiness Council Commerce, Georgia State Agriculture Industry Organization Secretary 1/2015 4/2017 5 National Grain and Feed Association Arlington, Virginia Industry Association Member, Board of Directors 1/2015 4/2017 6 Perdue Business Holdings, Inc. Bonaire, Georgia Corporation Member, Board of Directors 12/2010 4/2017 7 Perdue Properties LLC See Endnote Bonaire, Georgia Limited Liability Company Sole Owner 11/2010 Present 8 Perdue Real Estate Holdings LLLP See Endnote Bonaire, Georgia Limited Liability Limited Partnership Sole Owner 11/2010 Present VALUE INCOME TYPE INCOME AMOUNT 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF 1 Roth IRA No Perdue, George Ervin - Page 3 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.1 Fidelity Government Cash Reserves (FDRXX) Yes $1,001 - $15,000 None (or less than $201) 1.2 Fidelity 500 Index Premium Class (FUSVX) Yes $15,001 $50,000 $201 - $1,000 1.3 Baron Emerging Markets Fund Retail (BEXFX) Yes $1,001 - $15,000 None (or less than $201) 1.4 Columbia Dividend Opportunity CL A (INUTX) Yes $1,001 - $15,000 None (or less than $201) 1.5 Columbia Select Lrg Cap Growth CL A (ELGAX) Yes $15,001 $50,000 None (or less than $201) 1.6 Delaware Value Fund CL A (DDVAX) Yes $15,001 $50,000 $201 - $1,000 1.7 Driehaus Micro Cap Growth Fund (DMCRX) Yes $1,001 - $15,000 None (or less than $201) 1.8 MFS International Value Fund CL A (MGIAX) Yes $15,001 $50,000 $201 - $1,000 1.9 T Rowe Price Growth Stock Advisor CL (TRSAX) Yes $15,001 $50,000 None (or less than $201) 1.10 Ridgeworth Ceredex Mid Cap Value EQ I (SMVTX) Yes $15,001 $50,000 $201 - $1,000 1.11 T Rowe Price Intl Stock Advisor CL (PAITX) Yes $15,001 $50,000 None (or less than $201) 1.12 TCW Relative Value Dividend Apprec CL N (TGIGX) Yes $15,001 $50,000 $201 - $1,000 1.13 Touchstone Focused CL A (TFOAX) Yes $1,001 - $15,000 None (or less than $201) 1.14 Touchstone Small Cap Value CL A (TVOAX) Yes $1,001 - $15,000 None (or less than $201) Perdue, George Ervin - Page 4 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.15 Victory Global Natural Resources A (RSNRX) Yes $1,001 - $15,000 None (or less than $201) 1.16 Wasatch International Opportunities Fund (WAIOX) Yes $1,001 - $15,000 None (or less than $201) 1.17 Wasatch Frontier Emerging Small CO's (WAFMX) Yes $1,001 - $15,000 None (or less than $201) 1.18 Avenue Credit Strategies Investor (ACSAX) Yes $1,001 - $15,000 $201 - $1,000 1.19 Doubleline Total RT Bond FD CL N (DLTNX) Yes $1,001 - $15,000 $201 - $1,000 1.20 Doubleline Low Durtn Emerg Mkts FIX Inc N (DELNX) Yes $1,001 - $15,000 None (or less than $201) 1.21 Dreyfus Bond Market Index Invs (DBMIX) Yes $1,001 - $15,000 $201 - $1,000 1.22 Driehaus Event Driven Fund (DEVDX Yes $1,001 - $15,000 None (or less than $201) 1.23 Driehaus Active Income Fund (LCMAX) Yes $1,001 - $15,000 $201 - $1,000 1.24 JP Morgan Strategic Income Opport A (JSOAX) Yes $1,001 - $15,000 None (or less than $201) 1.25 Riverpark Strategic Income Fund Retail (RSIVX) Yes $1,001 - $15,000 None (or less than $201) 1.26 Riverpark Short Term High Yield Retail (RPHYX) Yes $1,001 - $15,000 None (or less than $201) 1.27 Rivernorth Core Opportunity FD L R (RNCOX) Yes $1,001 - $15,000 $201 - $1,000 2 Georgia Legislative Retirement System (Defined Benefit Pension - Value not Readily Ascertainable) N/A State retirement payments. Filer receives $326.71 per month. Perdue, George Ervin - Page 5 3. Filer's Employment Agreements and Arrangements # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Georgia Legislative Retirement System Atlanta, Georgia I have a defined benefit pension from the State of Georgia. I receive $326.71 per month. I will continue to participate in this plan. 1/1992 4. Filer's Sources of Compensation Exceeding $5,000 in a Year (N/A) - Not required for this type of report 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE 1 Roth IRA No 1.1 JP Morgan Income Builder Fund Cl C (JNBCX) Yes $15,001 $50,000 INCOME TYPE INCOME AMOUNT $201 - $1,000 6. Other Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 U.S.bank account #1 (cash) N/A $50,001 $100,000 Interest $201 - $1,000 2 Residential real estate, Butts County, Georgia N/A $500,001 $1,000,000 None (or less than $201) 3 Undeveloped land, Osceola County, Florida N/A $250,001 $500,000 None (or less than $201) Perdue, George Ervin - Page 6 # DESCRIPTION EIF VALUE 4 Undeveloped land, Houston County, Georgia N/A $250,001 $500,000 None (or less than $201) 5 Undeveloped land, Houston County, Georgia N/A $100,001 $250,000 None (or less than $201) 6 TIAA Path2College 529 Plan Yes $50,001 $100,000 None (or less than $201) 7 Note Receivable from AGrowStar, LLC N/A $500,001 $1,000,000 Interest 8 U.S. bank account #3 N/A $15,001 $50,000 Interest 9 U.S. bank account #2 (cash) N/A $250,001 $500,000 Interest $2,501 - $5,000 See Endnote INCOME TYPE INCOME AMOUNT $50,001 $100,000 7. Transactions None 8. Liabilities # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 1 CB&T Loan Guarantor 50% $500,001 $1,000,000 2013 3.25% 12/2021 2 CB&T Loan Guarantor 50% $500,001 $1,000,000 2013 3.25% 12/2021 3 Morris Bank Loan Guarantor $1,000,001 $5,000,000 2016 4.45% 192 Months Perdue, George Ervin - Page 7 # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 4 LoanCare Mortgage on Personal Residence $500,001 $1,000,000 2017 3.0% 07/2047 9. Gifts and Travel Reimbursements None Endnotes PART # ENDNOTE 1. 7 Perdue Properties LLC is an empty company which has never held any assets nor engaged in any business. 1. 8 Perdue Real Estate Holdings LLLP is an empty company which has never held assets nor engaged in any business. 6. 6 This investment, the 100% EQUITY option, tracks the TIAA-CREF Equity Index Fund Institutional Class (TIEIX) Perdue, George Ervin - Page 8 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.) Perdue, George Ervin - Page 9 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 Perdue, George Ervin - Page 10 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 $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. Perdue, George Ervin - Page 11 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). Perdue, George Ervin - Page 12 EXHIBIT Annual Report 2019 for 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 Perdue, George Ervin Secretary, Department of Agriculture Report Year: 2019 Other Federal Government Positions Held During the Preceding 12 Months: None 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/ Perdue, George Ervin [electronically signed on 06/07/2019 by Perdue, George Ervin in Integrity.gov] - Filer received a 47 day filing extension. 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/ Bender, Stuart, Certifying Official [electronically signed on 07/17/2019 by Bender, Stuart in Integrity.gov] Other review conducted by U.S. Office of Government Ethics Certification /s/ Granahan, Megan, Certifying Official [electronically signed on 09/13/2019 by Granahan, Megan in Integrity.gov] Perdue, George Ervin - Page 1 Data Revised 07/17/2019 Data Revised 07/08/2019 Data Revised 07/03/2019 Data Revised 07/02/2019 Data Revised 06/13/2019 Perdue, George Ervin - Page 2 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 The FALF Management Trust Bonaire, Georgia Trust Co-Trustee 11/2018 Present 2 Perdue Properties LLC See Endnote Bonaire, Georgia Limited Liability Company Sole Owner 11/2010 Present 3 Perdue Real Estate Holdings LLLP See Endnote Bonaire, Georgia Limited Liability Limited Partnership Sole Owner 11/2010 Present EIF VALUE INCOME TYPE INCOME AMOUNT 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION 1 Roth IRA 1.1 Fidelity Government Cash Reserves (FDRXX) Yes $1,001 - $15,000 None (or less than $201) 1.2 Fidelity 500 Index Premium Class (FUSVX) Yes $15,001 $50,000 $201 - $1,000 1.3 Baron Emerging Markets Fund Retail (BEXFX) Yes $1,001 - $15,000 None (or less than $201) 1.4 Columbia Dividend Opportunity CL A (INUTX) Yes $1,001 - $15,000 None (or less than $201) 1.5 Columbia Select Lrg Cap Growth CL A (ELGAX) Yes $15,001 $50,000 None (or less than $201) 1.6 Delaware Value Fund CL A (DDVAX) Yes $15,001 $50,000 $201 - $1,000 Perdue, George Ervin - Page 3 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.7 Driehaus Micro Cap Growth Fund (DMCRX) Yes $1,001 - $15,000 None (or less than $201) 1.8 MFS International Value Fund CL A (MGIAX) Yes $15,001 $50,000 $201 - $1,000 1.9 T Rowe Price Growth Stock Advisor CL (TRSAX) Yes $15,001 $50,000 None (or less than $201) 1.10 Ridgeworth Ceredex Mid Cap Value EQ I (SMVTX) Yes $15,001 $50,000 $201 - $1,000 1.11 T Rowe Price Intl Stock Advisor CL (PAITX) Yes $15,001 $50,000 None (or less than $201) 1.12 TCW Relative Value Dividend Apprec CL N (TGIGX) Yes $15,001 $50,000 $201 - $1,000 1.13 Touchstone Focused CL A (TFOAX) Yes $1,001 - $15,000 None (or less than $201) 1.14 Touchstone Small Cap Value CL A (TVOAX) Yes $1,001 - $15,000 None (or less than $201) 1.15 Victory Global Natural Resources A (RSNRX) Yes $1,001 - $15,000 None (or less than $201) 1.16 Wasatch International Opportunities Fund (WAIOX) Yes $1,001 - $15,000 None (or less than $201) 1.17 Wasatch Frontier Emerging Small CO's (WAFMX) Yes $1,001 - $15,000 None (or less than $201) 1.18 Avenue Credit Strategies Investor (ACSAX) Yes $1,001 - $15,000 $201 - $1,000 1.19 Doubleline Total RT Bond FD CL N (DLTNX) Yes $1,001 - $15,000 $201 - $1,000 1.20 Doubleline Low Durtn Emerg Mkts FIX Inc N (DELNX) Yes $1,001 - $15,000 None (or less than $201) 1.21 Dreyfus Bond Market Index Invs (DBMIX) Yes $1,001 - $15,000 $201 - $1,000 Perdue, George Ervin - Page 4 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1.22 Driehaus Event Driven Fund (DEVDX Yes $1,001 - $15,000 None (or less than $201) 1.23 Driehaus Active Income Fund (LCMAX) Yes $1,001 - $15,000 $201 - $1,000 1.24 JP Morgan Strategic Income Opport A (JSOAX) Yes $1,001 - $15,000 None (or less than $201) 1.25 Riverpark Strategic Income Fund Retail (RSIVX) Yes $1,001 - $15,000 None (or less than $201) 1.26 Riverpark Short Term High Yield Retail (RPHYX) Yes $1,001 - $15,000 None (or less than $201) 1.27 Rivernorth Core Opportunity FD L R (RNCOX) Yes $1,001 - $15,000 $201 - $1,000 2 Georgia Legislative Retirement System (Defined Benefit Pension - Value not Readily Ascertainable) N/A State retirement payments. Filer receives $326.71 per month. 3. Filer's Employment Agreements and Arrangements # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 Georgia Legislative Retirement System Atlanta, Georgia I have a defined benefit pension from the State of Georgia. I receive $326.71 per month. I will continue to participate in this plan. 1/1992 4. Filer's Sources of Compensation Exceeding $5,000 in a Year (N/A) - Not required for this type of report Perdue, George Ervin - Page 5 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION 1 Roth IRA 1.1 JP Morgan Income Builder Fund Cl C (JNBCX) EIF VALUE Yes $15,001 $50,000 INCOME TYPE INCOME AMOUNT $201 - $1,000 6. Other Assets and Income # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 U.S.bank account #1 (cash) N/A $50,001 $100,000 Interest $201 - $1,000 2 Residential real estate, Butts County, Georgia N/A $500,001 $1,000,000 None (or less than $201) 3 Undeveloped land, Osceola County, Florida N/A $250,001 $500,000 None (or less than $201) 4 Undeveloped land, Houston County, Georgia N/A $250,001 $500,000 None (or less than $201) 5 Undeveloped land, Houston County, Georgia N/A $100,001 $250,000 None (or less than $201) 6 TIAA Path2College 529 Plan See Endnote Yes $50,001 $100,000 None (or less than $201) 7 The FALF Preservation Trust See Endnote No 7.1 FALF LLC See Endnote No 7.1.1 Soque River Conservation LLC See Endnote N/A $500,001 $1,000,000 Land rent and sale of conservation mitigation bank credits. $138,179 Perdue, George Ervin - Page 6 # DESCRIPTION EIF VALUE INCOME TYPE 7.2 Perdue Business Holdings Inc. See Endnote No 7.2.1 Legacy 13:22 LLC See Endnote N/A 7.2.1.1 TW Rocky Mount Real Estate LLC See Endnote N/A $500,001 $1,000,000 None (or less than $201) 7.2.1.2 TWAS Rocky Mount LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 7.2.1.3 U.S. bank account #2 (cash) N/A $15,001 $50,000 7.2.1.4 TW Apex Real Estate LLC See Endnote N/A $500,001 $1,000,000 None (or less than $201) 7.2.1.5 TWAS Apex LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 7.2.1.6 TWAS Camden LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 7.2.1.7 TW Camden Real Estate LLC See Endnote N/A $500,001 $1,000,000 None (or less than $201) 7.2.1.8 TW Pinehurst Real Estate LLC See Endnote N/A $1,000,001 $5,000,000 None (or less than $201) 7.2.1.9 TWAS Pinehurst LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 7.2.2 Perdue Partners LLC (dormant) See Endnote No None (or less than $1,001) None (or less than $201) 7.2.2.1 Perdue Consulting Group LLC (dormant) See Endnote N/A None (or less than $1,001) None (or less than $201) 7.2.3 U.S. bank account #3 (cash) N/A $250,001 $500,000 Interest $2,501 - $5,000 7.2.4 U.S. bank account #4 (cash) N/A $5,000,001 $25,000,000 Interest $100,001 $1,000,000 Interest INCOME AMOUNT $2,501 - $5,000 Perdue, George Ervin - Page 7 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 7.2.5 Perdue, Inc. See Endnote N/A $1,000,001 $5,000,000 Passive business ownership income $320,473 7.2.6 Houston Fertilizer and Grain Co., Inc. See Endnote N/A $1,000,001 $5,000,000 Passive Business Ownership Income $91,738 7.2.7 StarPort Logistics LLC See Endnote N/A $100,001 $250,000 Passive business ownership income. $99,587 8 FALF Management Trust See Endnote No 8.1 Perdue Management Holdings LLC See Endnote N/A None (or less than $1,001) None (or less than $201) 7. Transactions None 8. Liabilities # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 1 Morris Bank Loan Guarantor $1,000,001 $5,000,000 2016 4.45% 192 Months 2 Synovus Loan Guarantor $15,001 $50,000 2018 5.19% 120 Months Perdue, George Ervin - Page 8 # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 3 LoanCare Mortgage on Personal Residence $500,001 $1,000,000 2017 3.00% 07/2047 9. Gifts and Travel Reimbursements None Endnotes PART # ENDNOTE 1. 2 Perdue Properties LLC is an empty company which has never held any assets nor engaged in any business. 1. 3 Perdue Real Estate Holdings LLLP is an empty company which has never held assets nor engaged in any business. 6. 6 This investment, the 100% EQUITY option, tracks the TIAA-CREF Equity Index Fund Institutional Class (TIEIX) 6. 7 The FALF Preservation Trust owns FALF LLC and 100% of the non-voting stock in Perdue Business Holdings Inc. 6. 7.1 FALF LLC is a single member Limited Liability Company owned by FALF Preservation Trust. FALF LLC is a holding company for Soque River Conservation LLC. 6. 7.1.1 Soque River Conservation LLC is owned by FALF LLC. Soque River Conservation LLC is a passive landholding partnership on the Soque River in Georgia. 6. 7.2 Perdue Business Holdings Inc. is owned by the FALF Preservation Trust and the FALF Management Trust. Underlying assets of Perdue Business Holdings are shown in Lines 7.2.1 through 7.2.6, and the value shown for the underlying assets is the full value for each holding. Perdue, George Ervin - Page 9 PART # ENDNOTE 6. 7.2.1 Legacy 13:22 LLC is a single member LLC owned by Perdue Business Holdings Inc. Legacy 13:22 is a holding company for TW Rocky Mount Real Estate LLC, TWAS Rocky Mount LLC, TW Apex Real Estate LLC, TWAS Apex LLC, TW Camden Real Estate LLC, TWAS Camden LLC, TW Pinehurst Real Estate LLC, and TWAS Pinehurst LLC. 6. 7.2.1.1 TW Rocky Mount Real Estate LLC is majority owned by Legacy 13:22 LLC. TW Rocky Mount Real Estate LLC owns the real estate in Rocky Mount, North Carolina, upon which the car wash owned by TWAS Rocky Mount LLC is located. 6. 7.2.1.2 TWAS Rocky Mount LLC is majority owned by Legacy 13:22 LLC. TWAS Rocky Mount LLC is an operating business that owns a car wash in Rocky Mount, NC. 6. 7.2.1.4 TW Apex Real Estate LLC is majority owned by Legacy 13:22 LLC. TW Apex Real Estate LLC owns the real estate in Apex, NC, upon which the car wash owned by TWAS Apex LLC is constructed. 6. 7.2.1.5 TWAS Apex LLC is majority owned by Legacy 13:22 LLC. TWAS Apex LLC is an operating business that owns a car wash in Apex, NC. 6. 7.2.1.6 TWAS Camden LLC is majority owned by Legacy 13:22 LLC. TWAS Camden LLC is an operating business that is in the process of building a car wash in Camden, SC. 6. 7.2.1.7 TW Camden Real Estate LLC is majority owned by Legacy 13:22 LLC. TW Camden Real Estate LLC owns the real estate in Camden, South Carolina upon which the car wash owned by TWAS Camden LLC is being constructed. 6. 7.2.1.8 TW Pinehurst Real Estate LLC is majority owned by Legacy 13:22 LLC. TW Pinehurst Real Estate LLC owns the real estate in Pinehurst, North Carolina, upon which the car wash owned by TWAS Pinehurst LLC is being constructed. 6. 7.2.1.9 TWAS Pinehurst LLC is majority owned by Legacy 13:22 LLC. TWAS Pinehurst LLC is an operating business that is in the process of building a car wash in Pinehurst, NC. 6. 7.2.2 Perdue Partners LLC is 40% owned by Perdue Business Holdings Inc. This consulting company is dormant. 6. 7.2.2.1 Perdue Consulting Group LLC is owned by Perdue Partners LLC. This business consulting company is not currently operating and has no current clients. 6. 7.2.5 Perdue Inc. is a Qualified Subchapter S Subsidiary owned by Perdue Business Holdings Inc. Perdue Inc. is a trucking company. 6. 7.2.6 Houston Fertilizer and Grain Co., Inc. is a Qualified Subchapter S Subsidiary owned by Perdue Business Holdings Inc. Houston Fertilizer and Grain Co, Inc. does not engage in agribusiness, it simply holds and manages commercial real estate in Bonaire, Georgia. Perdue, George Ervin - Page 10 PART # ENDNOTE 6. 7.2.7 StarPort Logistics LLC is a single member Limited Liability Company owned by Perdue Business Holdings Inc. StarPort Logistics LLC is an operating logistics company. 6. 8 FALF Management Trust owns Perdue Management Holding LLC and 100% of voting stock of Perdue Business Holdings Inc. 6. 8.1 Perdue Management Holdings LLC is 100% owned by the FALF Management Trust. Perdue Management Holdings LLC is a holding company that is dormant and has no assets or holdings. Perdue, George Ervin - Page 11 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 (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 (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.) Perdue, George Ervin - Page 12 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 (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 (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, (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 (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 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). Perdue, George Ervin - Page 13 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 (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 $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. Perdue, George Ervin - Page 14 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 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 278e). Perdue, George Ervin - Page 15 EXHIBIT i? lnteroffice Memo Georgia DeportmeniofTransportation Office Of POIICV support DATE: 7/16/2019 FILE: 0001757 Fulton County GDOT District 1 Gainesville 7 Metro Atlanta SR400 Express Lanes from MARTA North Springs Station to McFarlane Pkwy ?v?ck FROM: fur? Brent Story, State Design Policy Engineer TO: SEE DISTRIBUTION SUBJECT: APPROVED CONCEPT REPORT Attached is the approved Concept Report for the above subject project. Attachment Distribution: Hiral Patel, Director of Engineering Joe Carpenter, Director of P3 Albert Shelby, Director of Program Delivery Carol Comer, Director, Division of Intermodal Darryl VanMeter, Assistant Director of PS/State Innovative Delivery Administrator Kim Nesbitt, Program Delivery Administrator Bobby Hilliard, Program Control Administrator Paul Tanner, State Transportation Planning Administrator Eric Duff, State Environmental Administrator Bill DuVaIl, State Bridge Engineer Andrew Heath, State Traffic Engineer Angela Robinson, Financial Management Administrator Erik Rohde, State Project Review Engineer Monica Flournoy, State Materials Engineer Patrick Allen, State Utilities Engineer Eric Conklin, State Transportation Data Administrator Attn: Systems Classification Branch Benny Walden, Statewide Location Bureau Chief Brandon Kirby, District Engineer Sue Anne Decker, District Preconstruotion Engineer Palmer, District Utilities Manager Kathy Zahul, District Engineer Paul DeNard, District Preconstruction Engineer Shun Pringle, District Utilities Manager Dustin O?Quinn, Project Manager BOARD MEMBER 6th 7th Congressional Districts FHWA attn: Moises Marrero, Georgia Division Administrator Sova, Anton From: Sent: To: Cc: Subject: Tsang, Byron Thursday, October 18, 2018 12:24 PM Njie, Marie; Sova, Anton Dawood, Laura RE: SR 400 PI 0001757 - Mitigation cost for Concept Rpt All – see below estimated mitigation credit costs. NOTE: these are based on current prices for UPPER CHATTAHOOCHEE watershed, for GRANDFATHERED credits. The new 2018 SOP credits don’t apply yet, as the mitigation banks haven’t been released for these credits. Summary of Stream Credits Owed Length/Area of Impact Water Resource Intermittent/Ephemeral Perennial Streams (less than 3) Perennial Streams (more than 3) Total Stream Credits 2018 Credits Grandfathered Credits COST @ $38.00 /stream credit 27249 $1,035,462 4205 2271 9605 8644 103735 3472 3125 37498 $3,941,930 $1,424,924 168482 $6,402,316 14040 Summary of Wetland Credits Owed Water Resource Riverine/Lacustrine Fringe WLs Open Water Total Wetland Credits Length/Area of Impact 2018 Credits Grandfathered Credits 12.35 12.36 98.9 0.02 0.02 12.38 COST @ $50,000 /WL credit $4,945,000 0.16 $8,000 99.06 $4,953,000 Byron Tsang D +1-404-965-9656 Byron.Tsang@aecom.com From: Njie, Marie Sent: Tuesday, October 16, 2018 23:11 To: Sova, Anton Cc: Dawood, Laura; Tsang, Byron Subject: FW: SR 400 PI 0001757 - Mitigation cost for Concept Rpt Anton, The mitigation estimates for SR 400 are provided in the email below. We’ll coordinate with Ecology for the estimated mitigation costs you need for the Concept Report. 1