Today, Sunlight is sending the following letter (see below) to the Government Accountability Office, or GAO.

We are urging them to review the personal financial disclosure system, that requires top officials throughout the federal government to publicly disclose their assets. A comprehensive GAO review is important to ensuring the effectiveness of our system, is long overdue, and is actually already required by law.

For those unfamiliar, this may seem to be an abstract or wonky subject.  But if you've news stories about Justice Thomas, or Rep. Rangel (or many, many others) then you've heard about the importance of financial disclosure. Our laws requiring our top officials to publicly declare their assets are an essential safeguard against corruption and conflicts of interest, and are a bulwark for accountability in government service.

The GAO should review our financial disclosure system, and help strengthen an essential democratic safeguard.

GAO Financial Disclosure Letter 10132011

Sunlight has long advocated for online disclosure of Personal Financial Disclosure Forms (PFDs) of political appointees subject to Senate confirmation.

Until recently, the White House offered only a static chart of appointees, with their positions, and dates confirmed, while the Office of Government Ethics offered a similar chart. Neither offered online access to the PFD statement, but the OGE page did offer this:

The following individuals have been nominated or appointed by President Obama with the advice and consent of the Senate to the offices indicated. Their Public Financial Disclosure Reports (SF 278) and Ethics Agreements may be obtained by completing OGE Form 201, “Request to Inspect or Receive Copies of SF 278s or Other Covered Records” (2006) (Electronically Fillable PDF Version of OGE Form 201) (PDF) This PDF version of the form has been programmed to be filled in electronically through the use of the Adobe®Reader 6.0 or above and then printed. The Adobe Reader is freely available from the Adobe Web Site.

To access the financial disclosure forms of high level Presidential appointees, one had to find the OGE page, and then submit a form via mail to receive copies.

Not anymore.

The White House has set up a new online request process. This page now moves the request process entirely online, allowing anyone to request a copy of the PFD, and even receive their copy via email.

This is a significant improvement, and lowers the barrier to effective disclosure of essential financial information.

Ultimately, the White House should move beyond a request-based system, and affirmatively post the financial disclosure forms, with any necessary redactions. While this may take a more significant rewriting of the Federal Regulations and Executive Orders that set up the high level financial disclosure system, it would be worthwhile. 21st Century disclosure shouldn't include certifications of use.

In any case, the online submission form is a significant improvement, and should be applauded.

As Kenneth Vogel of Politico notes this morning:

Anyone seeking copies of the financial disclosure reports recently filed by members of his Cabinet and his top aides has to navigate an arcane and intrusive bureaucracy reliant on faxes, dense government forms, snail mail, or proximity to Washington, plus an insider's knowledge of an unpredictable schedule dictated by a host of government officials.

Even cutting the new Administration some slack, which I am willing to do on a number of these early missteps when it comes to using technology to create greater transparency for government, this is just wrong.

There are easy --  even if less than ideal ways -- to make these financial disclosure forms easily accessible: at a minimum a PDF of the documents (PDFs of PFDs) could be posted on line, searchable by name of the person who filed it. (That's not 21st century style disclosure either but it's better than what they are now doing.) That's pretty basic  but at least it would cut out the need to request the documents at all (much less fill out a form to get them), wait for that request to be filled, or to have to be here in Washington to get paper copies. At least anyone could have access to them 24/7.

Of course there are more sophisticated ways those documents could be made accessible - some of them in themselves quite simple. A straightforward downloadable, parsable database could have been created so that we could easily find out more about the nominees. It could also be created in a way to make it interoperable with other data sets that are relevant (like lobbying or campaign finance records).

While we have certainly welcomed and applauded the early Executive Order and Memoranda regarding transparency from the Obama team, the proof is always in the pudding. And the early moves by the Administration are not totally encouraging.