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The Honorable Gene Dodaro Comptroller General of the United States U.S.

Government Accountability Office 441 G Street, NW Washington, DC 20548 October 13, 2011 Dear Mr. Dodaro: We are writing to urge the GAO to meet its statutory obligation to review the personal financial disclosure system created under the Ethics in Government Act. Specifically, GAO should evaluate whether the executive, legislative, and judicial branches are meeting their obligations to publicly release personal financial disclosure information, whether the systems put in place could be improved, and whether the law itself should be updated. In the 1970s and '80s, GAO often evaluated how government carried out its reporting and disclosure responsibilities.1 In 1989, the Ethics Reform Act formalized that obligation by requiring GAO to "regularly ... conduct a study to determine whether the provisions of this title [Financial Disclosure Requirement of Federal Personnel] are being carried out effectively."2 Between 1989 and 1994, GAO carried out nine studies. In the 17 years since, GAO has released only a single report on this topic, and that was at Congress's request.3 GAO oversight is essential to preserving an effective disclosure system for personal assets. Federal personal financial disclosure requirements were created to promote accountability in high-level officials in all three branches of government. The law requires officials to publicly report financial interests and activities in order to avoid conflicts of interest and promote trust in government. There is much for GAO to evaluate. Do personal financial disclosure reports ask the right questions to permit identification of potential conflicts of interest? Are reports submitted in appropriate formats that permit computer analysis, promote quick identification of data quality problems, and allow real-time release to the public on the Internet? Can the burden on filers and ethics officers be reduced? Should the law be updated to bring the personal financial disclosure system into the 21st century? We welcome the opportunity to discuss this with you further. Please do not hesitate to contact Sunlight policy director, John Wonderlich, at 202-742-1520- x 234 or With best regards, Ellen Miller

1 2 3 See 5 App. U.S.C. 108. "Federal Judiciary: Assessing and Formally Documenting Financial Disclosure Procedures Could Help Ensure Balance between Judges' Safety and Timely Public Access," June 30, 2004, GAO-04-696NI, unavailable from GAO but available at