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Originally Processed With FOIA(s): FOIA Number: S FOIA MARKER This is not a textual record. This is used as an administrative marker by the George Bush Presidential Library Staff. Record Group/Collection: George H.W. Bush Presidential Records Collection/Office of Origin: Speechwriting, White House Office of Series: Snow, Tony, Files Subseries: Subject File, 1988-1993 OA/ID Number: 13894 Folder ID Number: 13894-011 Folder Title: [Executive Personnel Financial Disclosure Form] Stack: Row: Section: Shelf: Position: G 18 29 2 2 A basic premise of the statutory financial dis- II. Who Must File or Vice President or by May 15 of that calendar Executive Personnel closure requirements is that those having respon- a. Candidates for nomination or election to the office year, whichever is later, and on or before May 15 Financial Disclosure sibility for review of reports filed pursuant to the Act of President or Vice President. of each succeeding year that such an individual or permitted public access to reports, must be giv- continues to be a candidate on such date. Report en sufficient notice by reporting individuals in their b. Presidential nominees to positions requiring the ad- reports concerning the nature of their outside in- vice and consent of the Senate, other than those b. Within 5 days after the transmittal by the Presi- dent to the Senate of the nomination of an in- Instructions for Completing SF 278 terests and activities so that an informed judgment nominated for judicial office or for appointment to a rank in the uniformed services at a pay grade of 0-6 dividual referred to in section II(b) of these can be made with respect to the individuals' com- or below. instructions or, prior to that time, at any time af- pliance with applicable conflict of interest laws and ter the President or President-elect has publicly standards of conduct regulations. Therefore it is im- C. The following newly elected or appointed officials: announced his or her intention to nominate the Privacy Act Statement portant that you carefully complete the attached The President; individual. The Ethics in Government Act of 1978, as amend- form. This report is a safeguard for you as well as The Vice President; ed, 5 U.S.C. App. §201 et seq, requires the report- the Government in that it provides a mechanism for C. Within 30 days after assuming a position determining actual or potential conflicts between Officers and employees (including special Govern- described in section II(c) unless such an individual ing of this information. This information will be your public responsibilities and your private interests ment employees, as defined in 18 U.S.C. §202) has left another position described in section II(c) reviewed by Government officials to determine com- and activities and allows you and your agency to whose positions are classified at GS-16 or above within 30 days prior to assuming the new posi- pliance with applicable Federal laws and regulations, fashion appropriate protections against such con- of the General Schedule, or whose basic rate of tion, or has already filed a report with respect to and the report may be disclosed upon request to any requesting person pursuant to section 205 of the Act flicts when they first appear. pay (excluding "step" increases) under other pay nomination for the new position (section II(b)) or schedules is equal to or greater than the rate for as a candidate for the position (section II(a)). or as otherwise authorized by law. You may inspect Definitions and Terms GS-16 (step 1) (a group which includes all mem- d. No later than May 15 annually, in the case of applications for review of your own form upon re- quest. Knowing or willful failure to file or report in- Category of Amount bers of the Senior Executive Service); those in a position described in section II(C). In formation required to be reported by section 202 of Reportable financial interests are disclosed either Members of the uniformed services whose pay the event such an individual terminates employ- by exact amount or by category of amount, de- grade is 0-7 or above; ment, and does not accept another position the Act (or falsification) may subject you to a civil penalty of not more than $5,000 and to disciplinary pending on the interest as shown in the form. You Officers or employees in any other position de- described in section II(c), the report must be filed action by your employing agency or other appropri- may, but you are not required to, indicate an ex- termined by the Director of the Office of Govern- no later than the 30th day after termination. ate authority. Knowing or willful falsification of in- act amount where the form provides for a cate- ment Ethics to be of equal classification to GS-16; IV. Where to File formation required to be filed by section 202 of the gory of amount or value. Administrative law judges; Act may also subject you to criminal prosecution un- Dependent Child Employees in the excepted service in positions a. Candidates for President and Vice President, with der 18 U.S.C. $ 1001, leading to a fine of not more The term "dependent child" means your son, which are of a confidential or policy-making the Federal Election Commission. than $10,000 or imprisonment for not more than five daughter, stepson, or stepdaughter if such per- character, unless their positions have been exclud- b. The President and Vice President, with the Of- years or both. son is either: (i) unmarried, under age 21, and liv- ed by the Director of the Office of Government fice of Government Ethics. ing in your household, or (ii) a "dependent" of Ethics; C. Members of a uniformed service, with the Serv- I. Introduction yours within the meaning of section 152 of the In- The Postmaster General, the Deputy Postmaster ice Secretary concerned. ternal Revenue Code of 1954. General, each Governor of the Board of Gover- Scope of Disclosure Value d. All others, with the designated agency ethics offi- nors of the U.S. Postal Service and officers or em- The term "value" generally means a good faith cial at the agency in which the individual is em- The extent of the reporting requirement is noted ployees of the U.S. Postal Service or Postal Rate in each schedule. The applicable reporting periods estimate of the dollar value if the exact value is ployed or in which he or she will serve. Commission whose basic rate of pay is equal to and a description of who must complete each sched- neither known nor easily obtainable by you. When e. In the case of individuals appointed by or to be or greater than the minimum rate of basic pay ule and part are described on page 1 of the form. valuing assets, you may use a number of methods nominated by the President to positions requir- fixed for GS-16 (step 1); and In addition to your separate financial information, in addition to a good faith estimate. These are ing confirmation of the Senate, see 5 CFR The Director of the Office of Government Ethics you are required to report information concerning specifically set forth in the instructions under 734.604(c) for expedited procedure. your spouse and dependent children in several Schedule A. and each designated agency ethics official. schedules of the form. However, no report is re- d. Incumbent officials holding positions referred to in V. General Instructions Relative quired with respect to your spouse if he or she is The term "relative" means an individual who is section II(c) of these instructions if they have served a. This form consists of the front page and four living separate and apart from you with the inten- your father, mother, son, daughter, brother, sis- 61 days or more in the position during the preced- Schedules. You must complete each Part of all tion of terminating the marriage or providing for per- ter, uncle, aunt, great aunt, great uncle, first cous- ing calendar year. Schedules. If you have no information to report manent separation. In addition, no report is required in, nephew, niece, husband, wife, grandfather, e. Certain individuals who perform staff functions in sup- in any Part of a Schedule, you should indicate with respect to any income or obligations of an in- grandmother, grandson, granddaughter, father- port of an advisory committee composed in whole "None". A report is considered incomplete if any dividual arising from the dissolution of a marriage in-law, mother-in-law, son-in-law, daughter-in-law, or in part of special Government employees (see 5 Part of any Schedule is left blank. Schedule A or the permanent separation from a spouse. There brother-in-law, sister-in-law, stepfather, step- C.F.R. §734.202(h). combines a report of income items (other than are other exceptions to the reporting of assets and mother, stepson, stepdaughter, stepbrother, step- income, transactions, and liabilities of a spouse or III. When to File from current employment by the United States sister, half brother, half sister, your spouse's Government) with the disclosure of property in- dependent child which are discussed in the instruc- grandfather or grandmother or your fiance or a. Within 30 days after becoming a candidate for terests (generally referred to here as assets). tions applicable to those subjects. fiancee. nomination or election to the office of President Schedule B deals with transactions in real prop- OFFICE OF PERSONNEL MANAGEMENT erty or certain other assets, as well as gifts and have to report the day-to-day transactions of the line to the right. However, when you have a num- A personal residence from which no income is de- reimbursements. Schedules C and D relate to lia- pool services business nor such things as the nor- ber of different kinds of financial arrangements and rived should not be reported as a property interest bilities and employment relationships. After com- mal and customary temporary liabilities it incurs transactions involving one entity, a full disclosure because it is not held for investment or production pleting the first page and each part of the with its suppliers. of all the required information for that entity may re- of income. However, if you hold residential proper- Schedules (including extra sheets of any Sched- f. If you need assistance in completing this form, quire more than one line. You may always use more ty which is used for investment or income purposes, ule where continuation pages are required for any contact the designated agency ethics official of than one line for clarification if you choose. such as a summer home rented during parts of the part), consecutively number all pages. the agency in which you serve, will serve or have Note: Specific regulations for the reporting of inter- year, you must report that interest. b. The information to be disclosed is only that which served. ests in property and income are found in In the case of personal property such as antique the Ethics in Government Act of 1978, as amend- 5 CFR 734.301(a) and (d). collections and related holdings, the Office of ed, and 5 CFR Part 734 specifically require. You Government Ethics deems intermittent sales from may, however, include in any section of the form Schedule A such additional information, beyond the Act's re- II. Property Interests and Assets such a collection or holdings to demonstrate that they are held for investment or the production of quirements, as you may wish to disclose for pur- poses of clarification. I. General Instructions (BLOCKS A and B) income. Two of the general disclosure requirements of the A. Items to Report C. Combine on one form the information applicable Valuation Method to yourself, your spouse and dependent children; Act concern certain interests in property (generally Report the identity and category of valuation of any interest in property (real or personal) held by The statute provides several methods you may use or if more convenient, use separate schedules to referred to here as assets) and items of income. report the required information applicable to fa- Schedule A is designed to enable you to meet both you, your spouse or a dependent child, in a trade for determining valuation: or business, or for investment or the production Option 1-any good faith estimate of the value of mily members. You may, if you desire, distinguish of these reporting requirements. Generally a de- of income which has a fair market value which ex- the property if the exact value is unknown any entry for a family member by preceding the scription of your, your spouse's or dependent child's entry with an (S) if it is for a spouse or a (DC) if assets and sources of income is required to be list- ceeds $1,000 as of the close of the reporting peri- or not easily obtainable; od. These interests include, but are not limited to, Option 2-value based upon a recent appraisal of it pertains to a dependent child. ed in BLOCK A of the Schedule. Reading from left stocks, bonds, pension interests and annuities, fu- the property interest; d. Definitions of the various terms used in these in- to right across the page from each description of the asset or income source, you will be able to report tures contracts, mutual funds, IRA assets, tax Option 3-the date of purchase and the purchase structions and detailed information as to what is in BLOCK B the value of each asset, and in BLOCK shelters, beneficial interests in trusts, income- price of your interest; required to be disclosed are contained in 5 CFR C the type and amount of income generated by that producing bank accounts, real estate, commercial Option 4-the assessed value of the property for tax Part 734. asset or received from the non-asset source. BLOCK animals, crops and collectibles held for the produc- purposes adjusted to reflect current e. In the case of references to entities which do not D is a question designed to lead incumbents and tion of income. Exceptions: Exclude your personal market value if the tax assessment is have listed securities or are not described in stan- termination filers to Schedule B for certain of the residence and any personal liability owed to you, computed at less than 100% of current dard reference materials (such as Moody's Manu- items they have listed in BLOCK A. your spouse or dependent child by a relative. Ex- value (if Option 4 is used, describe the als)-whether such entities are operating trades clude also any deposits aggregating $5,000 or less manner in which you adjusted the as- or businesses, or private investment pools or oth- On Schedule A are two examples which are rep- in a personal savings account in a single financial sessed value); er private vehicles (such as IRA's) which are resentative of the reporting scheme of this Sched- institution. A personal savings account includes a ule. The first example represents the proper meth- Option 5-the year-end book value of non-publicly themselves the media for indirect financial in- certificate of deposit or any other form of deposit in terests in trades or businesses attributable to you od of reporting a stock of the XYZ Company held traded stock, or the year-end exchange a bank, savings and loan association, credit union for purposes of the application of Federal law- by the reporting individual at the end of the report- value of corporate stocks, or the face or similar institution. With respect to assets of a ing period which then had a value of $40,000. The value of corporate bonds, or comparable you must provide sufficient information about spouse or a dependent child, do not report items: these private entities to give reviewers of dis- individual had also received dividends of $1,500 and securities; (i) which represents your spouse's or dependent had purchased the stock during the reporting peri- Option 6-the net worth of your interest (as in a busi- closure reports an adequate basis for the conflicts child's sole financial interest or responsibility analysis required by the Act. Thus, except in the od. The second example represents the proper and of which you have no knowledge; ness partnership or other jointly held method of reporting the source of $50,000 of earned business interest); case of private investment vehicles (for which full (ii) which are not in any way, past or present, de- disclosure of holdings is required), you must dis- income from private law practice as well as the Option 7-the equity value of your interest (as in a close the primary trade or business of private en- $12,500 the reporting individual maintained in the rived from your income, assets, or activities; solely owned business or commercial capital account in the law firm at the end of the and tities, as well as attributed interests and activities enterprise); and not solely incidental to such a primary trade or reporting period. If, in the first example, the XYZ (iii) from which you neither derive, nor expect to Option 8-actual value (e.g., savings accounts) or business. For instance, if your family swimming stock had been sold rather than purchased, there derive, any financial or economic benefit. any recognized indication of value (such pool services corporation incurs a liability to pur- would be no entry in BLOCK B because the individu- Note: It is very difficult for most individuals to meet as last sale on a stock exchange). chase an apartment house for investment in ad- al no longer owned the stock at the end of the report- all three parts of this test, especially (iii). For ing period, but there would be an entry for capital You need not disclose which methods you chose un- dition to its pool services business, you will have instance, if you file a joint tax return with your to report your indirectly allocable share of the cor- gains as well as dividends in BLOCK C if they were less you wish. This is a change from prior forms. spouse, you derive a financial or economic poration's liability, the apartment house invest- realized during the period. benefit from the items involved and you are ment, and its purchase, in addition to the items Normally you will have to list an item only once charged with knowledge of those items. B. What to Show on the Form you are required to report about your interest in in BLOCK A with all other value and income infor- Therefore, those asset and income items do Enter the identity of the asset in BLOCK A and the family corporation. You would not, of course, mation associated with that item shown on the same not fit the test. then show the applicable value in BLOCK B. Only the category of value, rather than the actual val- out further disclosure of what financial interests are disclose the assets unless it is an "excepted trust" "Honoraria"; under ACTUAL AMOUNT ue of the property interest or asset, must be attributable to the individual by virtue of the IRA, it discussed immediately above. "$1,000", and under DATE "3/19/84". If the shown. is not possible to evaluate the individual's compli- Except for one of the three trusts described above, same item of income was received under the For assets such as stocks, bonds, and securi- ance with applicable laws and regulations. If the IRA you must identify each individual investment hold- same circumstances by your spouse, who is self- ties, report any holdings by you, your spouse or were invested solely in a mutual fund such as "Tem- ing of a trust which had a value in excess of $1,000. employed as a marketing consultant, you would dependent child from one source totaling more than pleton World Fund, Inc." and the investment was For example, in BLOCK A an entry such as "trust enter in BLOCK A "S" Chicago Civic $1,000 in value. Identify the holding and show the disclosed in Schedule A, that would be sufficient, held by First National Bank (Boston, MA) consist- Club, 18 Lakeshore Dr., Chicago, IL"; in BLOCK category of value. When identifying shares of pub- as that fund's portfolio is detailed in Moody's Bank ing of ITT stock, U.S. Treasury certificates, and Dal- C under OTHER specify "Honoraria"; under licly traded stocks, the common abbreviation of the and Finance Manual and could be evaluated. If, las Municipal Bonds" might be made. In BLOCK B ACTUAL AMOUNT leave a blank or fill in N/A; and name of the corporation may be used. If you have however, the IRA was privately invested, detailed the applicable value of each trust asset would be under date "3/19/84". Honoraria received and stock interests through an investment trust or mutual disclosure of the investment would be required on entered. (And, as described under IV B 5. Trust In- donated to charity must be reported, but a nota- fund, and the holdings of the trust or fund are a mat- Schedule A in the same amount of detail as if the come, below, the income from each asset would be tion explaining that fact may be included in report- ter of public record, you may-instead of identify- investment were directly held. entered in BLOCK C as well as income from assets ing such items. ing the fund's share holdings-identify your interest of the trust sold during the reporting period.) 2. OTHER INCOME-Means all income, exclusive by simply giving the name of the trust or mutual fund. b. Trusts of honoraria, received from non-investment If you hold different types of securities of the same With respect to trusts in which a beneficial in- III. Earned and Other sources including fees, commissions, salaries, in- corporation (e.g., bonds and stocks of "X" Corpo- terest in principal or income is held, report trust come from personal services, pensions, etc. Re- ration), these holdings should be considered as be- interests and trust assets which had a value in Non-Investment Income port the identity of the source and give the ing from the same source for purposes of excess of $1,000. You need not report the identity (BLOCKS A and C) actual amount of such income. For example, determining whether the aggregate value of the in- of assets of a trust of which you are the beneficiary A. Items to Report if you earned $450 teaching at a law school, en- terest is below or above the $1,000 value. if the interest is: For yourself, report the identity of the source in ter in BLOCK A John Jones Law School, To report interersts in a business, a partner- i. a "qualified blind trust" or "qualified diversi- BLOCK A and amount in BLOCK C of non- Rockville, MD"; in BLOCK C under OTH- ship, or joint venture, or the ownership of prop- fied trust", which has been certified by the Of- investment income exceeding $100, from any one ER "Salary"; and under ACTUAL AMOUNT erty held for investment or the production of fice of Government Ethics, or source, other than income from the United States "$450". Exclude income totaling less than income, identify the character of your ownership ii. an "excepted trust", that is, one which- Government for current Government services. Such $100 from any one source. For example, if you interest, and, unless a publicly traded security, income includes fees, salaries, commissions, com- earned $75 for teaching in one law school and A. was not created by you, or your spouse or the nature and location of the business or in- dependent children, and pensation for personal services, pension payments, $150 from teaching at another school, report only the $150 amount. terest. Thus, in the case of non-publicly traded secu- B. the holding or sources of income of which honoraria, etc. Report these items on the same line rities, show the nature and address of the business you, your spouse and dependent children as any related interest in property (if any). If your spouse has earned income in excess (in addition to its name). For example, the entry for have had no knowledge. For your spouse, report the source, but not the of $1,000 from any one source identify the a holding of farm land might show, under BLOCK amount, of your spouse's non-investment income source but show nothing under amount. If your A "sole ownership of 100 acres of unimproved In such cases, in lieu of disclosing the source and assets of the trust, you should show in BLOCK A exceeding $1,000 from any one source. No report spouse is self-employed in a business or profes- dairy farm land on Rural Route # at Pine Bluff, of the earned or non-investment income of your de- sion, for example as a practicing psychologist who Madison County, Wisconsin". the identity of the trust including the date the trust pendent children is required. earned $10,500 during the year, you need only was created, and the classification of the trust in- show under BLOCK A In the case of holdings that are essentially non- practicing psycholo- terest as a "qualified blind trust", a "qualified diver- public such as private trades or businesses, invest- sified trust", or an "excepted trust". Although you B. What to Show on the Form gist". ment pools or other private investment vehicles, need not report the identity of the assets of a 1. HONORARIA-Means payment of money or any- 3. UPDATE-A Presidential nominee to a position sufficient disclosure must be made to give review- qualified or excepted trust, the category of thing of value to you or your spouse, for an ap- requiring the advice and consent of the Senate ers an adequate basis for the conflicts analysis re- amount of the trust income, if it exceeded $100, pearance, speech, or article. (See 2 U.S.C. 444i shall file with the Senate committee considering quired by the Act. Therefore, you must disclose the must be reported in BLOCK C. for full definition.) For each honorarium you his or her nomination a report which shall update primary trade or business of private entities, as well received in excess of $100 show the identity of all items of his or her earned income and honorar- as interests and activities not solely incidental to Note: You are not permitted by the statute to "create" an excepted trust by avoiding pre- the source in BLOCK A, the date and net ia through the period ending no earlier than 5 days such a trade or business. For example, if your fa- amount in BLOCK C. For your spouse, you must before the scheduled date of the Senate commit- mily is involved in a private real estate investment vious sources of knowledge upon entering Government service. See subpart D of 5 CFR show only the source of any honorarium over tee hearing on the nomination. This update shall business but as a side interest buys stock through Part 734. $1,000 and the date of the event for which it was be provided in the manner requested by the the business in a bank, you must disclose in addi- received. List each honorarium separately. For ex- Senate committee considering the nomination. tion to real estate, (by type and general location), It is not necessary to identify those assets of a ample, if you received $1,400 for a speech be- that the family business holds an interest in a bank. trust of which a spouse or dependent child is a ben- fore the Chicago Civic Club on March 19, 1984, IV. Investment Income In addition, while under the general rules of Sched- eficiary if the trust meets the same three part test of which $200 was actually spent for round-trip (BLOCK C) ule A an individual who directly holds an IRA (In- set forth in the first paragraph under II.A. above. travel, and $200 went to the agent who made the Report items of investment income on the same dividual Retirement Account) would have to indicate However, in applying the test, if the trust is one set speaking arrangement, enter in BLOCK A line of Schedule A as the related property interest its value and the income derived from it (even though up for the education of your minor children, you do "Chicago Civic Club, 18 Lakeshore Dr., Chica- or other asset from which such income is derived. non-taxable for Federal income tax purposes), with- receive a financial benefit from such a trust and must go, IL"; in BLOCK C under OTHER specify Note that some property interests or other assets will not have a related item of realized income. In example, if you received $2,000 as rental income the trust is a qualified trust or an excepted trust, or exchange of any real property, stocks, bonds, such a case, check "None (or less than $101)" in from an apartment building in Miami, Florida, in BLOCK A show only the identity of the trust in- commodities futures and other securities by you, BLOCK C under category of amount. enter in BLOCK A "apartment building, at cluding the date the trust was created, and in your spouse or dependent child when the amount 5802 Biscayne Blvd., Miami, FL", and in BLOCK BLOCK C check the classification of the trust in- involved in the transaction exceeded $1,000. This A. Items to Report C check that rental income was received and terest as a "qualified blind trust", "qualified diver- will include the transaction for any asset for which Report the identity in BLOCK A and category of check the appropriate category of amount. sified trust", or "excepted trust", and check you answered "Yes" in BLOCK D of Schedule A. value in BLOCK C of any investment income over 3. INTEREST-Identify the source and the category of amount of the income realized. It also includes reporting any sale or exchange of $100 from any one source received by you, your category of amount of any interest earned or 6. OTHER INVESTMENT INCOME-Report any an asset involving an amount exceeding $1,000 spouse or dependent child, or which accrued to the received by you, your spouse or dependent items of investment income exceeding $100 when the sold or exchanged asset did not yield in- benefit of any one of you during the reporting peri- child as income from investment holdings includ- which are not described above, such as income come of more than $100 (and therefore was not od. For purposes of determining whether you meet ing: bills and notes, loans, promissory notes, an- from business interests, property dealings, annui- reported on Schedule A), or reporting the purchase the over $100 threshold from any one source, you nuity funds, bonds, and other securities. For ties, an estate, or a distributive share of a part- of an asset involving an amount exceeding $1,000 must aggregate all types of investment income from example, if you earned $300 in interest during the nership or joint business venture's income. To but at the end of the reporting period having a value that same source. calendar year on a Savings Certificate with Fed- identify the sources of other investment income, less than $1,000 and earning income of $100 or less Investment income includes, but is not limited to: eral Savings and Loan, enter in BLOCK A "Fed- either for yourself, your spouse, or a dependent during the reporting period (and therefore not ap- income derived from dealings in property, interest, eral Savings and Loan (Baltimore, MD)-Savings child, briefly characterize, in BLOCK A, the na- pearing on Schedule A). The example on the form rents, royalties, dividends, annuities, income from Certificate", and in BLOCK C check that interest ture of the business or investment interest, and shows the proper way to disclose the XYZ common endowment contracts, income from discharge (for- income was received and check the appropriate when applicable, the location: for exam- stock the reporting individual purchased for $35,000 giveness) of debts owed to you, your distributive category of amount. ple "one-third ownership in a retail furniture on 2/1/83. Note on Schedule A, that there is an en- share of partnership or joint venture income, and in- store at 1010 Grand Ave., Chicago, IL". In BLOCK try for the stock as well since it was still held at the 4. CAPITAL GAINS-Report income from capital come from an interest in an estate or trust. You need C, under OTHER specify the applicable type of end of the reporting period and that the reporting gains received or realized by you, your spouse not show the exact dollar amount of dividends, rents income, for example 'distributive share" from individual properly noted "Yes" in BLOCK D. or dependent child from sales or exchanges of and royalties, interest, capital gains, and certain trust a partnership or "gross income" from a property, business interests, partnership interests You need not report a transaction involving (1) income. For these specific types of income you need proprietorship, and under ACTUAL AMOUNT the or shared ownership investment interests. Iden- your personal residence(s); (2) a money market only check the category of amount of the item report- actual amount of such income which was realized ed. For all "other investment income" as described tify the source and check the category of mutual fund or personal bank account; (3) an asset during the reporting period. amount of the gain. An example of an entry in of your spouse or dependent child if the asset meets in item 6 below, you will have to report the exact BLOCK A might be "sale of one-third interest in V. Transactions Test the three-part test set forth under the instructions dollar amount of income from each source. 100-acre farm in Hamilton County, lowa" and in for Schedule A, at II.A.; and (4) a holding of a "quali- (BLOCK D) B. What to Show on the Form BLOCK C check that capital gains were received fied blind trust", a "qualified diversified trust" or an and check the appropriate category of amount. BLOCK D is to be completed by incumbent and "excepted trust". You will need to report any trans- 1. DIVIDENDS-Show in BLOCK C the category of termination filers only. It is designed to assist you actions of a business or commercial enterprise in the amount you, your spouse or dependent 5. TRUST INCOME-Report the category of in determining which assets in BLOCK A will also which you, your spouse or dependent child have a child received as dividends from investment amount and the type of any income of $100 or have to be reported in Part I of Schedule B as be- direct proprietary or general partnership interest. sources including: common and preferred secu- more received from any trust. You need not iden- ing purchased, sold or exchanged during the report- rities, endowment contracts, and pension and an- tify the source from which the trust received the ing period. You will need to check "YES" or "NO" You are required to report any covered transac- nuity funds. Identify the source of such income income when the trust is: (i) a "qualified blind in BLOCK D for any real property or stocks, bonds, tion of any company, investment pool, or other en- and check the category of amount. When iden- trust" or "qualified diversified trust", which has commodities futures, and other forms of securities tity, in which you, your spouse or dependent child tifying the source of a corporate stock dividend, been certified by the Office of Government Ethics; listed in BLOCK A. You need not answer the ques- have an interest if (i) the entity is not described in you may abbreviate the corporate name. For ex- or (ii) an "excepted trust", one which was not tions for any other kinds of items listed in BLOCK standard reference materials, or (ii) the transaction ample, if cash dividends of $950 were received created directly by, and about which no knowl- A. If you answer "Yes" for any such item, you must is not incidental to the primary trade or business of for shares of common stock of International Busi- edge of holdings or source of income of the trust also report the details of the purchase, sale or ex- the entity as indicated by you on Schedule A. (See ness Machines, enter in BLOCK A "IBM com- is possessed by you, your spouse or dependent change in Part I of Schedule B. also section V(e) of the General Instructions preced- mon", and in BLOCK c check that dividend in- child. Note, you are not permitted by the statute ing those for Schedule A.) come was received and check the appropriate to "create" an excepted trust by avoiding previ- B. What to Show on the Form category of amount. ous sources of knowledge upon entering Govern- Schedule B Under identification of assets, identify the property 2. RENTS AND ROYALTIES-Show income re- ment service. See subpart D of 5 CFR Part 734. or securities involved in the purchase, sale or ex- ceived by you, your spouse or dependent child Whenever you are required to identify the I. Part I-Transactions change, and give the date of the transaction. For as rental or lease payments for occupancy or use source of trust income, either for yourself or for example, under IDENTIFICATION OF ASSETS of personal or real property in which any one of a spouse or child, it is not enough simply to say A. General Instructions and "GMC common stock"; under TYPE OF TRANS- you have an interest. In addition, show payments "John Jones Trust". Generally, the investment ACTION received from such interests as copyrights, royal- holdings of the trust, discussed above under Items to Report check type; under DATE enter date transaction occurred; under AMOUNT OF TRANS- ties, inventions, patents, and mineral leases or "Property Interests and Assets", and the income This part is to be completed by incumbents and ACTION check the category of value of the sale other interests. Identify the source of such in- derived from each holding must be identified to termination filers only. Give a description, the date, price, purchase price, or exchange value of the come and check the category of amount. For the same extent as if held directly. However, if and the category of amount of any purchase, sale, property involved in the transaction. II. Part II-Gifts and in value received from any one source (for ue from any one source, other than excluded gifts must disclose the highest amount owed on any lia- Reimbursements purposes of the $100 aggregation in this ex- which you or your spouse received during the bility held during the reporting period, not just at clusion, you need not count any items with calendar year. Thus, if you and your spouse each the end of the period. If the liability was completely A. General Instructions a fair market value of $35 or less, nor any item receive a $60 figurine from the same donor, the paid during the period, you may also note that on for which, in an unusual case, a publicly avail- gift has a value of more than $100, and it must This Part is to be completed by incumbents and the form if you wish. able request for waiver was granted); termination filers only. The Act requires you to dis- be reported. To report the gift, identify the source, briefly describe the items, and show the value. B. Items to Report close the receipt of gifts, in-kind travel expenses, ix. Gifts given to a spouse totally independent and cash reimbursements by you or your spouse of his or her relationship to you; In the case of the figurines, report on the form un- Identify and give the category of amount of the X. Gift items in the nature of communications to der SOURCE "Artifact Co., 153 Utah St., liabilities which you, your spouse or dependent from any one source other than the U.S. Govern- your office, such as subscriptions to news- Omaha, NE"; and under BRIEF DESCRIPTION child owed to any creditor, other than a relative, ment. Generally, these are (1) gifts of in kind serv- ices of transportation, lodging, food or entertainment papers and periodicals; 'two porcelain figurines". Under VALUE which exceeded $10,000 at any time during the $120 would be shown. reportable period, except: aggregating $250 or more from any one source, (2) xi. Gifts of hospitality on the donor's personal or family premises, as defined in 5 CFR 3. REIMBURSEMENTS-Report the source and i. a mortgage secured by real property which is cash reimbursements aggregating $250 or more from any one source for any kind of expense, and the approximate value of any cash reimburse- the personal residence (or a second residence 734.105(i); (3) other gifts, whether tangible or intangible, ag- ments (except those from the United States not used for producing income) of you or your xii. Gifts and reimbursements received during gregating $100 or more from any one source. This non-Federal employment periods; and Government) aggregating $250 or more which spouse; reporting requirement applies to gifts and reimburse- you or your spouse received from any one ii. a loan secured by a personal motor vehicle, xiii. Reimbursements you received for political ments received by your spouse to the extent the gift source. For example, if you were reimbursed $400 household furniture, or appliances, where the trips which were required to be reported un- was not given to him or her totally independent of for travel and lodging expenses in connection with loan does not exceed the purchase price of the der section 304 of the Federal Election Cam- his or her relationship to you. a speech you made for the State Realtors Associ- item; paign Act of 1971 (2 U.S.C. 434). ation, you would report this item on the form by iii. a revolving charge account where the out- B. Items to Report showing under SOURCE State Realtors As- C. What to Show on the Form standing liability did not exceed $10,000 as of Report gifts received by you, your spouse or de- soc., 45 Bridge St., Denver, CO"; under BRIEF the close of the preceding calendar year; and pendent child during the reporting period. A "gift" 1. TRANSPORTATION, LODGING, FOOD, ENTER- DESCRIPTION 'travel expenses for speech iv. any liability of your spouse or dependent child means any payment, forbearance, advance, render- TAINMENT-Report the identity of the source, made in Denver"; and under VALUE "$400" which represents the sole financial interest or ing or deposit of money, or anything of value, un- a brief description, and the approximate val- would be shown. If your spouse made this speech responsibility of the spouse or child, and about less consideration of equal or greater value is ue of in-kind gifts of transportation, lodging, food and received the reimbursement totally indepen- which you have no knowledge, and which is received by the donor. In determining which gifts or entertainment aggregating $250 or more from dent of his or her relationship to you, no informa- not related to your income, assets, or activi- and reimbursements must be reported or aggregat- any one source which were received by you or tion for this item need be reported. ties, and concerning which you neither derive ed for purposes of meeting the threshold disclosure your spouse and which do not fall within any of Note: If you receive in-kind services of transporta- nor expect to derive any financial or econom- amounts, exclude these items: the categories of exclusions enumerated above. tion, lodging, food and entertainment or a ic benefit. To reach a $250 aggregation, you determine i. Gifts having a value less than $35; reimbursement of official travel expenses from whether any one or combination of the compo- ii. Gifts received from "relatives" (see definition a non-profit tax-exempt institution categorized You are required to report any liability of any com- nents within this gift category received from one in Introduction); by the IRS as one falling within the terms of pany, investment pool, or other entity, in which you, source (transportation, lodging, food and enter- your spouse or dependent child have an interest, 26 U.S.C. 501(c)(3), you must report the name iii. Bequests and other forms of inheritance; tainment) amounts to $250 or more in value. For if (i) the entity is not described in standard reference of the organization, a brief description of the iv. Suitable mementos of a function honoring the example, if you spent a weekend at a hunting in-kind services or the reimbursement and the materials, or (ii) the liability is not incidental to the reporting individual; lodge owned by AmCoal Corporation, and you value. If known, you may also wish to note the primary trade or business of the entity as indicated V. Food, lodging, transportation, and entertain- received lodging fairly valued at $150, food val- date you received the required written ap- by you on Schedule A. (See also section V(e) of the ment provided by a foreign government with- ued at $100, and entertainment valued at $125, proval from your agency to accept such items. General Instructions preceding those for Schedule the aggregate value of the gift is $375. A gift of A). in a foreign country or by the United States Government; this nature-hospitality at a lodge owned by a cor- C. What to Show on the Form poration rather than an individual-would not Schedule C vi. Food and beverages consumed at banquets, Under NAME AND ADDRESS OF CREDITOR qualify as a "personal hospitality" exclusion. To receptions or similar events; the name and address of the actual creditor must report this gift you would show, under SOURCE I. Part I-Liabilities vii. Gifts in-kind of food, lodging, transportation 'AmCoal Corp., 1210 North St., Chicago, IL"; be shown unless the reporting individual is only able and entertainment aggregating less than under BRIEF DESCRIPTION "lodging, food, A. General Instructions to identify a fiduciary and certifies in the report that $250 in value received from any one source he has made a good faith effort to determine who and entertainment as a guest at hunting lodge The Act requires you to disclose certain of your during the preceding calendar year (for pur- the actual creditor is and was unable to do so, or owned by AmCoal"; and under VALUE financial liabilities. The examples on the form show upon his certification that such determination is poses of the $250 aggregation in this exclu- "$375". how to report a mortgage on real estate the report- sion, items with a fair market value of $35 or otherwise impracticable. Under TYPE OF LIABILI- 2. OTHER GIFTS-Report the identity of the ing individual held for the production of income and TY less need not be counted); briefly indicate the nature of the liability. Un- source, a brief description, and the value of a promissory note made to an individual. Note that der DATE enter date loan incurred; under IN- viii. Gifts (other than transportation, lodging, food gifts other than transportation, lodging, food or you will need to disclose the date, interest rate and TEREST RATE note the set rate or, if a variable or entertainment) aggregating less than $100 entertainment aggregating $100 or more in val- term (if applicable) of each liability. Also note you one, the formula used to vary the rate, i.e. prime 2%; and under TERM the duration of the loan. pects to receive a lump sum payment from the law nature. No report is required regarding any posi- brief description of the services you provided. When Check the category of value. firm he has left in order to enter the Government. tions held by your spouse or a dependent child. a source has paid you directly, you should have a B. What to Show on the Form Be sure to report on Schedule A any income you corresponding entry on Schedule A. A client who II. Part II-Agreements or received from acting in any of these positions. paid your business affiliation $5,000 or more for your Under DESCRIPTION OF TERMS describe Arrangements the agreement or arrangement with appropriate B. What to Show on the Form services will appear only in this Part. specificity. Under PARTIES show the name of the Give the name, address and brief description of B. Items to Report A. General Instructions and organization, or entity, and (if applicable) the name the organization, the title or other brief functional Report the nature of the duties performed or serv- Items to Report and title of the official, corporate officer, or principal description of the position, and the dates you held ices rendered for any person (other than the United Provide information regarding any agreements or person responsible for carrying out the terms of the the position. If you currently hold the position, in the States Government) from which compensation in ex- agreement or arrangement. Under DATE show arrangements you have concerning (i) future em- entry block under TO note "Present". cess of $5,000 in any of the two preceding calen- ployment; (ii) a leave of absence during your period the date of any such arrangement. No report is re- of Government service; (iii) continuation of payments II. Part II-Compensation in dar years, or the present calendar year was received quired regarding any agreement or arrangement by you or an entity which billed for your services by a former employer other than the United States entered into by a spouse or dependent child. Excess of $5,000 (business affiliation). Exclude: (i) information to the Government; and (iv) continuing participation in an Paid by One Source extent that it is considered confidential as a result employee welfare or benefit plan maintained by a of a privileged relationship established by law, or (ii) former employer. This includes any arrangements A. General Instructions information about persons for whom services were or negotiations with a future employer entered into Schedule D This Part is to be completed by nominees and new provided by a business affiliation of which you were by a termination filer. For purposes of public dis- entrants only. This Act requires that you disclose a member, partner or employee unless you were closure only, you must disclose any negotiations for I. Part I-Positions Held your sources of compensation in excess of $5,000 directly involved in the provision of the services. The future employment from the point you and a poten- and the nature of the duties you provided. This in- name of a client of a law firm is not generally con- tial private sector employer have agreed to your fu- A. Items to Report cludes not only the source of your salary or other sidered confidential. No report is required regard- ture employment by that employer whether or not Report all positions held at any time during the fees, but the disclosure of clients for whom you per- ing compensation paid to your spouse or a you have settled all of the terms, such as salary, ti- reporting period, as well as those positions you cur- sonally provided $5,000 in services even though the dependent child. tle, benefits, and date employment is to begin. Your rently hold as an officer, director, trustee, partner, clients' payment was made to your employer, firm agency may require internal disclosure of negotia- proprietor, representative, employee or consultant or other business affiliation. The example on the C. What to Show on the Form tions much earlier and you should seek guidance of (i) any corporation, company, firm, partnership, form shows the proper way to disclose the business Under SOURCE give the name and address before conducting any negotiations with persons trust, or other business enterprise; (ii) any non-profit affiliation which paid the reporting individual's com- of the person to whom services were provided, for with whom you do business. A criminal statute, 18 organization; (iii) any labor organization; (iv) any pensation, in this case a law firm, and a client of the example, "Newark Real Estate Co. (Newark, NJ)"; U.S.C. §208, applies to actions you may take while educational institution; or (v) other institution other firm for whom the reporting individual personally and under BRIEF DESCRIPTION the title or other negotiating future private sector employment. than the United States Government. Exclude posi- provided over $5,000 worth of services. This Part brief functional description of the services rendered, The example on the form shows the severance tions held in any religious, social, fraternal, or polit- does not require you to disclose the value of the for example: "tax matters researched for above firm agreement under which the reporting individual ex- ical entity, and any positions solely of an honorary compensation for these services; it does require a while an associate with Quinn and Ouspensky". SF 278 (Rev. 1/85) Financial Disclosure Report Form Approved FPM Chapter 734 OMB No. 3206-0092 Page 1 U.S. Office of Personnel Management Reporting Status (Check Appropriate Box) Agency Use Only OGE Use Only Date of Appointment, Candidacy, Termination Date (If Applicable) Election or Nomination (Mo., Day, Yr.) (Month, Day, Year) New Entrant, Nominee, Termination Incumbent or Candidate Filer Last Name First Name and Middle Initial Reporting Individual's Name Title of Position Department or Agency (If Applicable) Position for Which Filing Reporting Periods Incumbents: Complete Schedules A, B, C, and Part I of D. The Address (Number, Street, City, State and ZIP Code) Telephone No. (Include Area Code) reporting period is the preceding calendar year except for Part Location of Present Office II of Schedule C and Part I of Schedule D where you must also include any positions held or agreements or arrangements made Position(s) Held With the Federal Title of Position(s) and Date(s) Held from the beginning of the filing year until the date you file. Government During the Preceding 12 Termination Filers: Complete Schedules A, B, C, and Part I Months (If Not Same as Above) of D. The reporting period begins at the end of the period cov- ered by your previous filing and ends at the date of termination. Presidential Nominees Name of Congressional Committee Considering Nomination Do You Intend to Create a Qualified Diversified Trust? Nominees, New Entrants and Candidates for President and Subject to Senate Confirmation Vice President: Complete Schedules A, C, and D. (Candidates Yes No do not file Part II of Schedule D.) Certification Signature of Reporting Individual Date (Month, Day, Year) Schedule A-The reporting period for Income (BLOCK C) and I CERTIFY that the statements I have Transactions Test (BLOCK D) is the preceding calendar year made on this form and all attached and the current calendar year up to the date of filing. Value schedules are true, complete and correct to the best of my knowledge assets in BLOCK B as of any date you choose that is within and belief. 31 days of the date of filing. Signature of Other Reviewer Date (Month, Day, Year) Other Review Schedule C, Part I (Liabilities)-The reporting period is the (If desired by agency) preceding calendar year and the current calendar year up to any date you choose that is within 31 days of the date of filing. Agency Ethics Official's Opinion Signature of Designated Agency Ethics Official/Reviewing Official Date (Month, Day, Year) Schedule C, Part II (Agreements and Arrangements)-Show any agreements or arrangements as of the date of filing. The information contained in this report discloses no conflict of interest Schedule D-The reporting period is the preceding two under applicable laws and regulations. calendar years and the current calendar year up to the date Signature Date (Month, Day, Year) of filing. Office of Government Ethics Use Only Comments of Reviewing Officials (If additional space is required, use the reverse side of this sheet) (Check box if comments are continued on the reverse side) PREVIOUS EDITION USABLE 278-109 NSN 7540-01-070-8444 SF 278 (Rev. 1/85) Form Approved FPM Chapter 734 OMB No. 3206-0092 U.S. Office of Personnel Management Reporting Individual's Name Page Schedule Assets and Income Number A All Filers: In BLOCK A report (a) the identity of each asset held for the produc- tion of income at the close of the reporting All Filers: In BLOCK B report All Filers: In BLOCK C report the type and amount of income exceeding $100 or more period which had a fair market value ex- the value of each asset listed in received from the assets and other sources of income listed in BLOCK A. You must re- Incumbents and Termination ceeding $1000 and (b) any other asset BLOCK A which had a fair mar- port the actual amount of any income not of a type specifically noted below. You need Filers only: In BLOCK D, for or source of income which generated over ket value exceeding $1000 at the not report the actual amount of your spouse's earned income, only the source in BLOCK any real property, stocks, bonds, $100 in income during the reporting period. close of the reporting period. commodities futures and other This includes but is not limited to em- A. You may not check "qualified trust" unless you have a blind trust which has been securities listed in BLOCK A, ployers, stocks, bonds, tax shelters, bank specifically approved by the Office of Government Ethics. If you, your spouse or depen- accounts, real property, mutual funds, did you pensions, IRA assets, assets of certain dent child are the beneficiary of a trust which no one of you created and has no knowl- purchase, sell, or exchange the trusts, commodities futures, personal busi- edge of the assets, refer to the instructions to see if it qualifies as an "excepted trust." item during the reporting period nesses and partnership interests. Exclude If "none" (or less than $101) is checked under Category of Amount of Income, no other for a value that exceeds $1000? your personal residence unless you rent it entries need be made in BLOCK C for that item. out. See instructions for rules on bank accounts and complex holdings. BLOCK A BLOCK B BLOCK C BLOCK D Assets & Income Sources Valuation of Assets Income Transactions Test Category of Value (X) Type of Income (X) Category of Amount of Income (X) Identify each asset and income source Actual If yes, complete Other Date Schd. B Part for of yours, your spouse(S) and your Amount None (or less than $1001) those assets dependent child (DC). $1,001- $5,000 $5,001 $15,000 $15,001- $50,000 $50,001 $100,000 $100,001- $250,000 Over $250,000 Dividends Rent Interest Capital Gains Excepted Trust Qualified (Specify None (or less than $101) (Mo., Day, Yr.) Trust $101- $1,000 $1,001- $2,500 $2,501- $5,000 $5,001- $15,000 $15,001- $50,000 $50,001 $100,000 $100,000 Only if Type) Over "Other" Only if including those sold for a loss. Honoraria NONE Specified YES NO S Exam- X Y Z Common X X X x or DC ples: Doe Jones & Smith, Hometown, USA X ptnrshp income $50,000 1 2 3 4 5 6 7 8 9 10 PREVIOUS EDITION USABLE 278-209 SF 278 (Rev. 1/85) Form Approved FPM Chapter 734 OMB No. 3206-0092 U.S. Office of Personnel Management Reporting Individual's Name Page Schedule Number B Part I Transactions Incumbents and Termination Filers only: Report any pur- actions that resulted in a loss. Do not report a transaction chase, sale or exchange by you, your spouse or dependent involving property used solely as your personal residence, Type of Transaction (X) Amount of Transaction (X) child during the reporting period of any real property, stocks, or a transaction between you, your spouse or your depen- bonds, commodities futures, and other securities when the dent child. amount of the transaction exceeded $1,000. Include trans- NONE Purchase Sale Exchange Date (Mo., Day, Yr.) $1,001- $5,000 $5,001- $15,000 $15,001- $50,000 $50,001- $100,000 $100,001- $250,000 Over $250,000 S Exam- Identification of Assets or ple: DC X Y Z Common X 2/1/83 X 1 2 3 4 5 6 Part II received from one source totaling $250 or more unless tally independent of their relationship to you. Exclude trans- Gifts, Reimbursements and Travel Expenses received as personal hospitality at the donor's personal or portation, lodging, food and reimbursements from the U.S. family residence; (2) other gifts received from one source Government. For (1) and (2), exclude gifts from relatives and Incumbents and Termination Filers only: totaling $100 or more in value; and (3) cash reimbursements exclude gifts of $35 or less when aggregating them for the Report the source, a brief description and the value of: (1) of $250 or more received from one source. Exclude gifts and total from one source. See instructions for in-kind gifts of transportation, lodging, food or entertainment reimbursements received by your spouse that were given to- further exclusions. NONE Source (Name and Address) Brief Description Value S Exam- Nat'l Assn. of Rock Collectors, NY, NY Airline ticket, hotel room & meals incident to national conference 6/15/83 $500 ples: Nat'l Assn. of Rock Collectors, NY, NY Leather briefcase for retiring president $125 1 2 3 4 5 6 PREVIOUS EDITION USABLE 278-108 SF 278 (Rev. 1/85) Form Approved FPM Chapter 734 OMB No. 3206-0092 U.S. Office of Personnel Management Reporting Individual's Name Page Schedule Number C Part I Liabilities spouse or dependent child. Check the highest amount owed automobiles, household furniture or appliances, and liabili- All Filers: Report liabilities over $10,000 owed to any one during the reporting period. Exclude a mortgage on your per- ties owed to relatives. See instructions for creditor at any time during the reporting period by you, your sonal residence unless it is rented out, loans secured by revolving charge accounts. NONE Category of Amount or Value (X) Term Creditor (Name and Address) Date Interest if Type of Liability $10,001 $15,001 $50,001 $100,001 Incurred Rate applic- Over to to to to able $15,000 $50,000 $100,000 $250,000 $250,000 S Exam- First District Bank, Washington, DC Mortgage on rental property, Rehoboth Beach, Delaware 1981 13% 25 yrs. X or DC ples: John Jones, 123 J St., Washington, DC Promissory note 1979 10% on demand X 1 2 3 4 5 6 Part II Agreements Or Arrangements All Filers: Report your agreements or arrangements for or continuing participation in an employee benefit plan. See future employment, leaves of absence, continuation of pay- instructions regarding the reporting of negotiations for any of ment by a former employer (including severance payments), these arrangements or benefits. NONE Status and Terms of any Agreement or Arrangement Parties Date (Mo., Yr.) Example: Pursuant to partnership agreement, will receive capital account & 7/75 partnership share calculated on service performed through 11/83 Doe Jones & Smith, Home town, USA ptnership agmnt. PREVIOUS EDITION USABLE 278-108 SF 278 (Rev. 1/85) Form Approved FPM Chapter 734 OMB No. 3206-0092 U.S. Office of Personnel Management Reporting Individual's Name Page Schedule Number D Part I Positions Held Outside U.S. Government All Filers: Report any positions held during the applicable prietor, representative, employee or consultant of any cor- Exclude positions with religious, social, fraternal, or political reporting period. Positions include but are not limited to poration, firm, partnership, or other business enterprise entities or those solely of an honorary nature. those of an officer, director, trustee, general partner, pro- or any non-profit organization or educational institution. NONE Organization (Name and Address) Type of Organization Position Held From (Mo., Yr.) To (Mo., Yr.) Nat'l Assn. of Rock Collectors, NY, NY Non-profit education President 6/82 6/83 Examples: Doe Jones & Smith, Hometown, USA Law firm Partner 7/75 11/83 Part II Compensation In Excess Of $5000 Paid by One Source Nominees and New Entrants only: Report sources of such This includes the names of clients and customers of any cor- services generating a fee or payment of more than $5,000. compensation received by you or your business affiliation for poration, firm, partnership or other business enterprise, or You need not report the U.S. Government services directly provided by you during the reporting period. any nonprofit organization, when you directly provided the as a source. NONE Source (Name and Address) Brief Description of Duties Doe Jones & Smith, Hometown, USA Legal services Examples: Metro University (client of Doe Jones & Smith) Hometown, USA Legal services in connection with university construction PREVIOUS EDITION USABLE 278-108