Congressional Ethics and Disclosure
Instructions
We read the public ethics record of Congress the way an ethics counsel’s compliance team does: what the rules require, what the filings show, whether the filings were on time, and whether a matter is ready to put in front of an ethics office. Everything here is done from public filings, without compulsion. We report facts of the filing; we do not infer motive.
This skill owns the rule text for the House and Senate ethics codes, the STOCK Act PTR regime and the 18 U.S.C. 207 post-employment restrictions. Other skills apply that text.
Use a different skill when:
- the question is what OGE, the House or Senate ethics committees or the Office of
Congressional Conduct are as institutions (mandate, history, powers) — use government-oversight-mechanisms;
- the task is a whole-dais, per-hearing member profile (statements, votes, donors and holdings
for every member) — use member-intel-profile, which consumes this skill’s PTR method for its holdings field. This skill does not profile members;
- the person is the subject of a durable published profile — use
accountability-profile-builder; - the question is a former official’s lobbying registrations or FARA filings —
lobbying-fara-disclosure-analyst
applies §207 (this skill’s text, §3) to the lobbying record;
- the question is campaign contributions and their timing —
campaign-finance-transparency.
Method, in order: the rules (§1–§3), the filings and where their indexes live (§4), the PTR timing test (§5), the symmetry rule (§6), the complaint process (§7), and language (§8).
1. The ethics codes: what the manuals govern
Each chamber writes its own code; each chamber’s ethics committee interprets it in a manual and in advisory guidance. We cite the chamber’s own text, never a summary of it.
| Topic | House | Senate | What to check in the record |
|---|---|---|---|
| Gifts | Code of Official Conduct (House Rule XXIII) and the gift rule (House Rule XXV); House Ethics Manual, gifts chapter | Senate Rule 35 (the Gifts Rule); Senate Ethics Manual and the Committee’s gift guidance | Gifts and reimbursements reported on the annual disclosure; whether an exception is claimed |
| Privately sponsored travel | House Ethics Manual, travel chapter; Committee pre-approval | Senate Rule 35 and the Committee’s privately sponsored travel regulations (updated February 2025): prior written approval, never retroactive | Sponsor, dates and approval on the travel disclosure; the trip against the filer’s committee work |
| Outside earned income | House Rule XXV and the manual’s outside-income chapter | Senate Rules 36 and 37 (outside earned income, honoraria, conflicts) | Positions and earned income on the annual disclosure |
| Staff rules | Manual chapters on staff, campaign work and official resources | Senate Code of Official Conduct, Rules 34–43 | Whether a staffer is a “senior staff” filer (PTR duty applies) |
Dollar thresholds (gift limits, outside-income caps) change by rule and by year. Quote the threshold from the current manual or the committee’s current guidance with its date; never from memory and never from an older guide.
2. The STOCK Act PTR rule
The STOCK Act (Pub. L. 112-105, 2012) added the periodic transaction report to the Ethics in Government Act. Its current text is 5 U.S.C. 13105(l):
“Not later than 30 days after receiving notification of any transaction required to be reported … but in no case later than 45 days after such transaction”
- Who files. Members of Congress, and legislative-branch staff who meet the senior-staff
pay threshold, along with the President, Vice President and senior executive-branch officials (§13105(l)(1)–(9)).
- Whose trades. The filer’s, the filer’s spouse’s and dependent children’s purchases, sales
and exchanges of stocks, bonds, commodities futures and other securities over $1,000 (House Committee on Ethics PTR instructions).
- Exclusion. Widely held, publicly traded or diversified investment funds the filer does
not control (Pub. L. 112-105 §14, noted at 5 U.S.C. 13105).
- The due date is the earlier of the two. Notification date + 30 days, or transaction date
+ 45 days. The House instruction guide’s worked example: a trade on July 9 that the filer learned of on July 15 is due August 14 (30 days after notice, earlier than 45 days after the trade).
- Late but no fee; late with a fee. The House guide gives a 30-day grace period after the
due date: filed inside it, the report is late but no late fee is owed; filed after it, a late fee is due unless the Committee waives it. Older House guides state the fee as $200; the current guide tells filers to contact the Committee for the amount. Quote the guide in force for the year of the trade.
Days-late arithmetic is exact; it uses only dates the filing states. If the filing does not state the notification date, compute against the 45-day outer limit and say so in the row.
3. 18 U.S.C. 207 post-employment rules
We state the window; lobbying-fara-disclosure-analyst applies it to the lobbying record.
| Former position | Window | Who they may not lobby | Provision |
|---|---|---|---|
| Senator | 2 years | Any Member, officer or employee of either House, or any legislative office | §207(e)(1)(A) |
| Member or elected officer of the House | 1 year | Members, officers and employees of either House (a former elected officer: the House only) | §207(e)(1)(B) |
| Senate officer, or Senate employee above the pay threshold | 1 year | Senators, and Senate officers and employees | §207(e)(2) |
| House personal staff above the pay threshold | 1 year | The former employing Member and that Member’s staff | §207(e)(3) |
| House committee staff above the pay threshold | 1 year | The committee’s Members and staff | §207(e)(4) |
| Senior executive-branch personnel | 1 year | Their former department or agency | §207(c) |
| Very senior executive-branch personnel | 2 years | Their former agency and listed senior officials | §207(d) |
| Any executive-branch employee | Permanent / 2 years | Particular matters they worked on / were responsible for | §207(a)(1), (a)(2) |
The staff rows apply only to a former employee paid at least 75 percent of a Member’s pay for 60 days or more in the final year (§207(e)(7)). Pay records are not always public: when the threshold cannot be confirmed from the House or Senate disbursement reports, say “threshold not confirmed” rather than applying the rule.
4. The filings and their indexes
The clients return index records only. None downloads or parses a PDF; a human reads the filing itself and transcribes the fields the timing table needs.
| Filing | Who files | Index | Notes |
|---|---|---|---|
| House annual disclosure and PTR | Members, candidates, senior staff | api.house_disclosures (scripts/lib/osint_api/fin_disclosures.py, host disclosures-clerk.house.gov) |
PTRs are rows with filing type P in the same annual index as annual (O) and amended (A) reports. The bulk-index URL and schema are still awaiting a human check against a live document (see Verify) |
| Senate annual disclosure and PTR | Senators, candidates, senior staff | api.senate_efd — disabled by default (CA_ENABLE_SENATE_EFD) |
eFD’s search sits behind a terms-of-use agreement that bars automated use, so the client makes no request unless the flag is set. Pull Senate PTRs by hand from efdsearch.senate.gov, record the URL and access date |
| Executive-branch OGE 278e and 278-T | PAS nominees and officials | api.oge (scripts/lib/osint_api/oge.py, host extapps2.oge.gov) |
OGE’s online collection is mostly presidential appointees confirmed by the Senate. Many appointees’ 278e is held by the employing agency, not OGE, so zero hits is an expected answer; request it from the agency (OGE Form 201) through records-request-drafting |
Run every client through scripts/ca_research.py api , never directly, so the call is cached and in the run ledger. Executive-branch filers are subject to the same 13105(l) PTR rule (the 278-T is their PTR); apply §5 to them unchanged.
5. The PTR timing test
For one filer, or for every member of one committee (§6):
- Collect every PTR for the window from §4’s indexes; a human reads each filing.
- Transcribe per transaction: transaction date, notification date (if stated), filed date,
asset, type (purchase/sale/exchange), amount range, and owner (self, spouse, dependent).
- Compute the due date (§2) and days late (filed date minus due date; zero or negative is
on time). Mark “inside grace period” or “fee period”.
- Jurisdiction overlap. Map the asset’s issuer or sector to the committee and subcommittee
jurisdictions in House Rule X or Senate Rule XXV. Write the clause that creates the overlap; “same industry” is not an overlap.
- Nearest event. For each overlapping trade, find the nearest hearing, markup or roll-call
vote on that jurisdiction before and after the trade: hearings from the committee’s own hearing page or api.congress; votes through api.house_votes or api.senate_votes. Record the gap in days, both directions.
- Fill the timing table (Appendix A). Every row carries the filing’s source URL.
Report what the table shows: late filings as facts, and timing coincidences as coincidences (§8). A trade that precedes a hearing is not evidence the filer knew anything the public did not.
6. Partisan symmetry: test the whole committee
MANDATORY. When a timing test touches a committee, run §5 on every member of that committee, majority and minority, for the same window and the same assets or sector. Publish the denominator: “N of M members filed late in the window”, never one member’s late filings alone. A one-party table is not an output of this skill.
7. Complaints: who may file, what is public, what a referral means
| House | Senate | |
|---|---|---|
| Office that takes information from the public | Office of Congressional Conduct (OCC) — named the Office of Congressional Ethics (OCE) through the 118th Congress. Independent, non-partisan; reviews allegations against House Members, officers and staff; accepts submissions; the OCC Board alone decides whether to open a preliminary review | Select Committee on Ethics. Its Supplementary Procedural Rule 2: a Committee member or staffer “shall report”, and any other person may report, a sworn complaint or other allegation |
| Committee | House Committee on Ethics. A complaint is filed by a Member, or by a non-Member whose information a Member certifies in writing as submitted in good faith | Same committee; it must promptly begin a preliminary inquiry on a sworn complaint or other allegation |
| What becomes public | On an OCC referral, the Committee must announce its course of action within the time House Rule XI clause 3(b)(8)(A) and Committee Rule 17A set | The Committee never comments on whether it has received a complaint |
| What a referral means | An OCC referral says the Board found grounds for further review. It is not a finding of a violation | A preliminary inquiry is not a finding |
The PTR fee itself is administered by the committee: a late filing is often resolved by fee or waiver, not a complaint. Before drafting anything, run the readiness checklist (Appendix B). A human files every complaint; this skill prepares the record, it never submits.
8. Language discipline
| Write | Never write (absent an adjudication) |
|---|---|
| “The trade’s timing coincided with the committee’s [date] hearing on X” | “insider trading”, “traded on inside information”, “profited from” |
| “The report was filed [N] days after the statutory due date” | “hid the trade”, “concealed”, or any motive for the lateness |
| “The OCC referred the matter to the Committee on Ethics” | “was found to have violated”, “was charged” |
| “The asset falls within the jurisdiction of [committee] under [rule clause]” | “conflict of interest” as a conclusion, unless an ethics body found one |
| “No PTR was located in the index for [window]” | “failed to disclose” (the filing may be held elsewhere or not yet indexed) |
“Late filing” is a fact; its motive is not. A violation exists when an ethics committee, OCE/OCC report or court says so, and we quote that body.
Sources
Primary:
- 5 U.S.C. 13105(l), periodic transaction reports (Ethics in Government Act as amended by the
STOCK Act; text and the Pub. L. 112-105 §14 fund note) — https://www.law.cornell.edu/uscode/text/5/13105 — confirmed 2026-10-31.
- 18 U.S.C. 207, post-employment restrictions — https://www.law.cornell.edu/uscode/text/18/207 —
confirmed 2026-10-31 (covers (c), (d), (e)(1)–(4), (e)(7)).
- House Committee on Ethics, *Financial Disclosure Reports for Calendar Year 2025: Instruction
Guide* (due-date examples, 30-day grace period, spouse and dependent-child examples) — https://ethics.house.gov/wp-content/uploads/2026/04/2025-Published-Instruction-Guide-4-15-2026-1.pdf — confirmed 2026-10-31.
- House Committee on Ethics, PTR instructions ($1,000 threshold, spouse and dependent child) —
https://ethics.house.gov/wp-content/uploads/2023/12/FINAL-PTR-Form-CY-2021_0.pdf; earlier guide stating the $200 late fee — https://ethics.house.gov/wp-content/uploads/2023/12/CY-2017-Instruction-Guide-for-Financial-Disclosure-Statements-and-PTRs_0_0.pdf — confirmed 2026-10-31.
- House Code of Official Conduct — https://ethics.house.gov/publications/code-official-conduct —
confirmed 2026-10-31.
- Office of Congressional Conduct, home page (mandate, submissions, Board decides) —
https://occ.house.gov/ — confirmed 2026-10-31.
- House Committee on Ethics, statement of 2026 citing an OCC referral of December 2, 2025, House
Rule XI cl. 3(b)(8)(A) and Committee Rule 17A — https://ethics.house.gov/press-releases/statement-of-the-chairman-and-ranking-member-of-the-committee-on-ethics-regarding-representative-nancy-mace-2 ; and the Committee’s 118th Congress activity report (“OCE referred 15 matters”) — https://ethics.house.gov/wp-content/uploads/2025/01/Committee-Report.pdf — confirmed 2026-10-31.
- House Rule XI cl. 3(b)(2), Member filing and certified non-Member complaints —
https://ethics.house.gov/wp-content/uploads/2019/01/Appendix-I.pdf — confirmed 2026-10-31.
- Senate Select Committee on Ethics, Contacting the Committee (Supplementary Procedural Rule 2) —
https://www.ethics.senate.gov/public/index.cfm/contacting-the-committee; Rules of Procedure — https://www.ethics.senate.gov/public/index.cfm/rules-of-procedure-of-the-select-committee-on-ethics — confirmed 2026-10-31.
- Senate Code of Official Conduct, Rules 34–43 — https://www.ethics.senate.gov/public/index.cfm/ethicsrules;
privately sponsored travel regulations (February 2025) — https://www.ethics.senate.gov/public/index.cfm/regulations-and-guidelines-for-privately-sponsored-travel; Senate Ethics Manual (2003 edition) — https://www.ethics.senate.gov/public/index.cfm/senate-ethics-manual — confirmed 2026-10-31.
- CRS R47320, Financial Disclosure in the U.S. Government: Frequently Asked Questions —
https://www.congress.gov/crs-product/R47320 — [V] (reused from member-intel-profile).
Verify (not stated as fact in the body):
- House Ethics Manual: current edition and URL not fetched in this build [U]. Cite the edition
by year from ethics.house.gov when quoting a chapter.
api.house_disclosuresbulk-index URL and XML schema [U] — the client’s own docstring holds
this open until a human checks a live document.
- Current House PTR late-fee amount [U] — the 2025 guide says to contact the Committee.
Cross-references
government-oversight-mechanisms— OGE, the ethics committees and the OCC as institutions.member-intel-profile— the whole-dais member profile; consumes §5 for its holdings field.patriot-private-citizen-inclusion-gate— spouses and dependants named on a filing.hearing-prep-and-analysis— where a timing table feeds a hearing memo.congressional-oversight-procedure— committee jurisdiction and procedure.accountability-profile-builder— durable published profiles.records-request-drafting— the OGE Form 201 or agency request for a 278e that OGE does not hold.public-corruption-ombudsman— corruption statutes beyond the ethics codes.quote-integrity-audit— any quoted committee or OCC finding.lobbying-fara-disclosure-analyst— lobbying and FARA; applies §3.campaign-finance-transparency— campaign finance and donation timing.
Safety
- Not legal advice. Whether a filing violates a rule is for the ethics committees and
courts; route a reader’s own exposure question to qualified counsel.
- No impersonation of government authority. We never present ourselves as an ethics office,
a committee or OGE; a complaint is filed by a named human in their own name.
- Allegation vs. finding vs. charge. An OCC referral, a sworn complaint and a preliminary
inquiry are not findings; a finding is not a charge. Name which one each source is.
- Trade timing is not insider trading. Use §8’s table; absent an
adjudication, “coincided with” is the strongest verb.
- Late filing is a fact; motive is not. Report days late; never characterize why.
- Partisan symmetry (mandatory). §6: the same test on every member of the committee, both
parties, with the denominator published.
- Private persons. Spouses and dependent children named on a filing are private persons.
Their names do not appear in our output unless they pass patriot-private-citizen-inclusion-gate; otherwise write “spouse” or “dependent child” in the owner column.
- Index only. The clients never fetch PDFs; Senate eFD is read by hand under its terms of use.
Appendix A: PTR timing table
| Filer | Owner (self / spouse / dependent) | Transaction date | Notification date | Filed date | Due date | Days late | Grace / fee period | Asset | Type, amount range | Committee jurisdiction overlap (rule clause) | Nearest hearing or vote (date, gap in days) | Source URL |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
Summary line, required: “N of M committee members (majority a of x, minority b of y) filed one or more PTRs late between [start] and [end].” Owner names never appear; see Safety.
Appendix B: ethics-complaint readiness checklist
- [ ] The conduct is described by a specific rule or statute clause (§1–§3), quoted.
- [ ] Every fact rests on a public filing or record with a URL and access date.
- [ ] The right forum is chosen: OCC (House Members, officers, staff), House Committee on Ethics
(needs a Member or a Member’s certification), or Senate Select Committee on Ethics.
- [ ] Days-late figures are recomputed from the filing’s own dates, against the guide in force.
- [ ] §6 symmetry run is complete, and the comparison is included.
- [ ] Language passes §8; no motive is alleged.
- [ ] Private persons pass the inclusion gate or are removed.
- [ ] The fee-or-waiver path has been checked; the matter is more than an unpaid late fee.
- [ ] A named human reviews and files; the filer’s name and role are disclosed in any story.
- [ ] Counsel has been offered the draft where the filer seeks advice on their own exposure.
