Late filings

A 278-T is due 30 days after the official is notified of a trade — a broker confirmation, a statement — and never later than 45 days after the trade itself (5 U.S.C. Section 13105(l)). Whichever deadline comes first governs. Past it, the filing is late.

Each 278-T form has a column asking whether notification of the trade was received more than 30 days ago. A "Yes" means the official certified they learned of the trade more than 30 days before reporting it — the form's own late-disclosure marker. Open Cabinet repeats that certification; it computes nothing.

Under 5 U.S.C. Section 13106(d), a report filed more than 30 days past its deadline carries a $200 fee — once per report, not per transaction, and flat no matter how late. A report a year overdue costs the same as one 31 days overdue. The filer's agency collects the fee and can waive it for "extraordinary circumstances." Larger penalties exist only for knowing and willful violations, and require the Justice Department.

A late filing is not proof of wrongdoing. A slow broker can blow the 45-day cap through no fault of the filer. Amended reports re-list old trades. Agencies can extend deadlines by up to 90 days, and extensions are not visible in this data. Patterns across many trades tell the story — not any single flag.