The STOCK Act, Insider Trading, and Public
Financial Reporting by Federal Officials
Jack Maskell
Legislative Attorney
April 12, 2013
Congressional Research Service
7-5700
www.crs.gov
R42495
CRS Report for Congress
Pr
epared for Members and Committees of Congress
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
Summary
The STOCK Act (Stop Trading on Congressional Knowledge Act of 2012) was signed into law on
April 4, 2012. It affirms and makes explicit the fact that there is no exemption from the “insider
trading” laws and regulations for Members of Congress, congressional employees, or any federal
officials. The law also expressly affirms that all federal officials have a “duty” of trust and
confidentiality with respect to nonpublic, material information which they may receive in the
course of their official duties, and a duty not to use such information to make a private profit.
The STOCK Act, as part of the law’s regulation of securities transactions by public officials, now
requires expedited, periodic public disclosure of covered “financial transactions” by all officials
in the executive and legislative branches of the federal government who are covered by the public
reporting provisions of the Ethics in Government Act of 1978, as amended. The act thus works to
require not only annual public reporting of such transactions (which reporting has been required
since 1978), but also now requires public reporting within 30 days of receipt of a notice of a
covered financial transaction (but in no event more than 45 days after such transaction). These
periodic reports are filed with reference to any financial transactions of $1,000 or more in
securities, but are not required for transactions in mutual funds or income-producing real
property.
The act as originally adopted had required all public financial disclosure statements filed under
the Ethics in Government Act in the legislative and executive branches to eventually be made in
electronic form, and to be posted on the Internet where they may be publicly searched, sorted,
and, if a log-in protocol is followed, downloaded from official government websites. Because of
safety concerns, privacy threats, and the possibility of malicious use of such data, federal
executives and employees complained about the Internet posting of their detailed financial
information, and filed suit to stop the requirement to post such information on the Internet.
Congress responded by amending the Stock Act to delay the Internet posting requirements of the
public personal financial disclosure reports until a study could be made on the potential impact of
having such personal financial information available on the Internet. Legislation (S. 716, 113th
Congress) passed by the Senate on April 11, 2013, and by the House on April 12, 2013 (and is, as
of this writing, awaiting the President’s signature) would permanently rescind the requirement for
Internet posting for most covered employees in the legislative and executive branches of the
United States Government. However, the requirement for Internet posting of the financial
disclosure reports and all financial information filed by Members of Congress, the President and
Vice President, candidates for Congress, and federal officials appointed by the President and
confirmed by the Senate in positions on the Executive Schedule at Levels I (cabinet level) and II
are in effect and would still be required to be posted on the Internet.
Congressional Research Service
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
Contents
Insider Trading ................................................................................................................................. 1
Commodity Exchange Act ......................................................................................................... 2
Initial Public Offerings (IPOs) .................................................................................................. 3
Public Financial Disclosure Reports ................................................................................................ 3
Elimination of Mortgage Exemption for Personal Residences of Certain Officials .................. 3
Prompt Public Reporting of Financial Transactions ........................................................................ 4
Internet Posting of Disclosure Reports; Electronic Reporting ......................................................... 4
Pensions of Members of Congress ................................................................................................... 6
Other Provisions .............................................................................................................................. 7
Influencing Private Employment Decisions .............................................................................. 7
Negotiations for Post-Government Employment ...................................................................... 7
Bonuses to Fannie Mae and Freddie Mac Executives ............................................................... 7
Study on Political Intelligence ................................................................................................... 7
Contacts
Author Contact Information............................................................................................................. 8
Congressional Research Service
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
n April 4, 2012, the STOCK Act (Stop Trading on Congressional Knowledge Act of
2012) was signed into law.1 The act clarifies and confirms that the “insider trading” rules
Oapply to all government officials, including Members of Congress, and provides for more
transparency and access to the reports on the personal financial information, assets, and
transactions of federal officers and employees.
The STOCK Act has, in summary, four major features:
• First, the law reaffirms the fact that the existing “insider trading” provisions of
securities law and regulations do not contain any exemption or exclusion for
Members of Congress, congressional staff, or other federal officials.
Furthermore, the law makes explicit the duty of confidentiality and trust that all
public employees have concerning material, nonpublic information that comes to
them by virtue of their federal employment.
• Secondly, the law requires the establishment of an electronic filing system for
certain financial disclosure reports that must be filed by legislative and executive
branch officials under the Ethics in Government Act of 1978, and requires that
the public reports of personal financial information filed by Members of and
candidates to Congress, the President, the Vice President, and presidentially
appointed and Senate confirmed officials at levels I (cabinet positions) and level
II of the Executive Schedule are to be available to be publicly accessed on the
Internet in a searchable and sortable format.
• Thirdly, the law requires public reporting within 30 days after receiving a report
concerning, but no later than 45 days after, a covered financial transaction in
income-producing property (such as the purchase or sale of stocks or bonds) by
all legislative and executive branch personnel who are required to file the annual
public financial disclosure reports under the Ethics in Government Act of 1978.
• Finally, the law expands the list of crimes, conviction of which would result in a
Member of Congress losing all of his or her creditable service as a Member for
congressional pension purposes, and broadens the time period when such
conviction would apply to federal pension forfeiture.
Insider Trading
The provisions of the new law expressly affirm that there exists no exemption for Members of
Congress, congressional employees, or for other federal officers or employees from the “insider
trading” prohibitions in federal securities law and regulation.2 It should be emphasized that there
never was any exemption or exception from the “insider trading” provisions of securities law for
Members of Congress, congressional staff, or for other federal employees, and such persons were
subject to the insider trading restrictions in the same manner as members of the general public.3
1 P.L. 112-105, 112th Cong., 126 Stat. 291 (2012); S. 2038, 112th Congress, as amended and passed by the House on
February 9, 2012, and adopted by the Senate, agreeing to the House Amendments, on March 22, 2012. Amendments to
the STOCK Act made by S. 3510, 112th Congress, were signed by the President on August 16, 2012, P.L. 112-173, and
revisions to the effective dates for Internet posting of information were also made in P.L. 112-178 and P.L. 112-207.
2 P.L. 112-105, Sections 4 (Members of Congress and the legislative branch) and 9 (executive and judicial branches).
3 Securities Exchange Act of 1934, 15 U.S.C. §§78a et seq., specifically 15 U.S.C. §78j(b); and the Insider Trading
(continued...)
Congressional Research Service
1
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
However, certain media reports and allegations created the public impression that Members of
Congress and staff were actually exempt or had “excepted themselves” from the insider trading
provisions.4 This legislation addressed that perception.
In addition to affirming that the insider trading restrictions of securities law and regulation apply
to Members of Congress and to other federal officials, the STOCK Act further affirms expressly
that each officer and employee of the legislative branch, each executive branch official, and each
judicial officer and employee owes a duty of trust and confidence to the United States and the
citizens of the United States with respect to material, nonpublic information derived from such
person’s public employment.5
The STOCK Act directs the ethics entities in the House and Senate—the House Ethics Committee
and the Senate Select Committee on Ethics—to issue interpretations of chamber rules “clarifying”
that Members and staff are prohibited from using nonpublic information derived from their
positions “as a means for making a private profit.” Although such explicit regulations already
exist in the executive branch,6 the legislation directs that the Office of Government Ethics issue
such interpretive guidance, and that the Judicial Conference of the United States issue such
guidance to federal judges and to judicial employees.
From the inclusiveness of the language of the legislation, and from previous guidance, it would
appear that the restrictions on the use of nonpublic, material information extends not only to
trading directly by the Member of Congress or by staff on such information, but would extend
also to passing on such material, nonpublic information to another so that such other person may
make a private profit for himself or herself, or for the public official.7
Commodity Exchange Act
The STOCK Act expressly includes Members and employees of Congress within those
employees or agents of the federal government, including all executive branch and judicial branch
officers and employees, who are prohibited from using nonpublic information, imparting such
(...continued)
Sanctions Act of 1984, P.L. 98-376, and 15 U.S.C. §§78t-1(a), (b), and §78ff; S.E.C. regulations at 17 C.F.R.
§§240.10b-5, 240.10b-5-1, 240.10b-5-2. See testimony of Robert Khuzami, Director, Division of Enforcement, U.S.
Securities and Exchange Commission, before the House Financial Services Committee, December 6, 2011
(http://www.sec.gov/news/testimony/2011/ts120611rk.htm); note also Donna M. Nagy, Insider Trading, Congressional
Officials, and Duties of Entrustment, 91 BOSTON UNIV. L.R. 1105 (2011). Members of Congress were and are subject to
the restrictions to the extent that any enforcement action by an entity outside of Congress must conform to the “Speech
or Debate” privilege in the United States Constitution, art. I, §6, cl. 1.
4 See, for example, Wall Street Journal, “Congress’s Insider-Trading Non-Scandal,” at A15 (November 16, 2011).
5 P.L. 112-105, Sections 4(b) and 9(b)(2). Existing congressional rules and executive branch regulations and standards
recognize such a “duty of trust” of federal officials (See Standing Orders of the Senate, §87, Senate Manual, S. Doc.
107-1, at 118-119 (2002); House Ethics Manual, 110th Cong., 2nd Sess., at 2 (2008); Code of Ethics for Government
Service, ¶ 8 (H. Con. Res. 175, 72 Stat., pt. 2, B12 (July 11, 1958)), 5 C.F.R. §§2635.702, 2635.703. Federal case law
has expressly recognized the “fiduciary” relationship of trust towards to the public inherent in the position of a Member
of Congress. United States v. Podell, 572 F.2d 31, 32 (2d Cir. 1978).
6 5 C.F.R. §§2635.702, and 2635.703.
7 See House Ethics Committee discussion of “tipping” violations, in Memorandum to All House Members, Officers and
Employees, “Rules Regarding Personal Financial Transactions,” November 29, 2011; see 15 U.S.C. §78j(b), and 17
C.F.R. §240.10b-5.
Congressional Research Service
2
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
nonpublic information, or stealing or converting nonpublic information to purchase or sell
commodities, commodities futures, or options, for personal gain.8
Initial Public Offerings (IPOs)
The STOCK Act amends the Securities Exchange Act of 1934 to provide that all officers or
employees of the federal government who are required to file annual public financial disclosure
reports under the Ethics in Government Act are prohibited from purchasing securities that are the
subject of an “initial public offering ... in any manner other than is available to members of the
public generally.”9
Public Financial Disclosure Reports
Under existing and pre-STOCK Act law, Members of Congress and certain employees of the
legislative branch (including those paid at a rate of pay exceeding 120% of the base salary of a
GS-15), as well as executive branch officials who occupy “a position classified above GS-15,” or,
if not on the General Schedule are in a position compensated at a “rate of basic pay ... equal to or
greater than 120 percent of the minimum rate of basic pay payable for GS-15,” are generally
subject to the public financial disclosure provisions of the Ethics in Government Act of 1978, as
amended.10 Those employees compensated at the rate of pay described above are required to file
detailed public financial disclosure statements by May 15 of the following year if the individual
works for the government for more than 60 days in the calendar year. These disclosure reports
have been available to the public for viewing at the office of the agency ethics officer, or a copy
may be furnished to those requesting a copy.11
Elimination of Mortgage Exemption for Personal Residences of
Certain Officials
Under existing law in the Ethics in Government Act, one of the “liabilities” of over $10,000 that
did not have to be disclosed on an annual personal financial disclosure report was the mortgage
on officers’ or employees’ personal residences.12 By removing the exemption for such disclosure
from reports made by the President, the Vice President, Members of Congress, and nominees and
incumbents in positions which are appointed by the President and confirmed by the Senate (other
than Foreign Service officials below the rank of ambassador, military personnel at or below grade
0-6, or special government employees), the STOCK Act now requires disclosure of information
about the mortgages on such officials’ own personal residences.13
8 P.L. 112-105, Section 5, amending the Commodity Exchange Act, 7 U.S.C. §6c(a).
9 P.L. 112-105, Section 12, amending 15 U.S.C. §78u-1.
10 See now 5 U.S.C. app. §101(f).
11 5 U.S.C. app. §105(b).
12 5 U.S.C. app. §102(a)(4)(A).
13 P.L. 112-105, Section 13.
Congressional Research Service
3
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
Prompt Public Reporting of Financial Transactions
The Ethics in Government Act of 1978 has, since its enactment, required the annual public
reporting of all “transactions” in income-producing property of over $1,000 in value for covered
executive and legislative branch officers and employees.14 This requirement applies generally to
the purchase or sale of such assets as stocks, bonds, commodity futures, or other securities, as
well as the purchase or sale of real property which is income producing (such as rental property).
The STOCK Act requires, as of July 3, 2012, the public reporting of covered transactions
exceeding $1,000 in many of these income-producing assets to be made within 30 days of
receiving notice of the transaction, but not later than 45 days after the transaction, from all federal
officers and employees in the legislative and executive branches who are required to file public
financial disclosure reports under the Ethics in Government Act of 1978, as amended.15 This
requirement for more prompt public reporting of financial transactions will not apply to a widely
held investment fund, such as mutual funds, if the fund is publicly traded, the assets are widely
diversified, and the reporting individual neither exercises nor is allowed to exercise control over
the financial interests of the fund.16 Furthermore, the periodic transaction reports generally apply
only to transactions in securities, and do not apply to transactions in things such as real property.
Such transactions in income producing real property, or in such holdings as mutual funds, must
still, however, be reported on the annual financial disclosure reports of the official. In
clarifications adopted as an amendment to the STOCK Act in August of 2012, it is now clear that
reporting individuals who are required to file periodic transaction reports must file such reports
with respect to covered transactions by the official’s spouse or dependent children, except in very
limited and unusual circumstances.17
Although the requirement for Internet posting of the periodic financial transaction forms filed by
most federal officials will be rescinded in legislation recently passed by Congress, the underlying
requirement to report such transactions to the proper, relevant ethics office within 30 days of
receiving notice of the transaction, but not later than 45 days after the transaction, remains in
force and continues to be required by all covered officials ̶ that is, for all public filers ̶ in the
legislative and executive branches of government.
Internet Posting of Disclosure Reports;
Electronic Reporting
The STOCK Act as originally adopted had required the posting on the respective official websites
of the House and Senate the annual financial disclosure reports, as well as the new prompt
reporting disclosures of financial transactions, made in 2012 by Members, officers of the House
14 5 U.S.C. app. §102(a)(5). Such reporting is also required of judicial branch employees and federal judges and
justices. 5 U.S.C. app. §102(f)(11) and (12).
15 P.L. 112-105, Section 6.
16 P.L. 112-105, Section 14.
17 P.L. 112-173, Section 2, 126 Stat. 1310 (August 16, 2012). With respect to filers in the House of Representatives, the
periodic reporting of spousal and dependent children transactions is effective January 1, 2013. P.L. 112-1178, Section
3(a), 126 Stat. 1409 (September 28, 2012).
Congressional Research Service
4
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
or Senate, candidates to Congress, and employees of the entire legislative branch who are
required to file public financial disclosure reports under the Ethics in Government Act.18
Similarly, the public disclosure reports made in 2012 by officers and employees of the entire
executive branch under the Ethics in Government Act (including the periodic transactions reports)
had been required under the original provisions of the STOCK Act to be posted on the official
websites of the respective executive branch agencies.19 In subsequent reporting years, these
reports were to be posted on the publicly accessible websites no later than 30 days after filing.20
With regard to such Internet postings of the detailed financial information of nearly 30,000
federal employees in the executive and legislative branches of government, concerns were
expressed by federal employees, officials, and employee associations over increasing the
opportunities and potential for identity theft, the increased prevalence of “data mining” on the
Internet for malicious purposes, and concerns over the safety of federal workers and their
families, particularly those who serve abroad. Additionally, a group of federal executive
employees filed suit against the provision in the United States District Court for the Southern
District of Maryland.21 In that case, on March 27, 2013, the court denied in part the government’s
motion to dismiss the suit, and strongly indicated its view that forced publication of employees’
financial reports on the Internet, in light of new technologies and communications, might violate
a constitutional “right to informational privacy” of federal employees.22 Although the Supreme
Court and courts in other federal circuits have not necessarily recognized an expanded personal
“privacy” right under the Constitution to this extent,23 the District Court in Maryland indicated
that such interests were protected under precedents in the Fourth Circuit.
In response to such concerns and judicial actions, Congress had delayed the implementation of
the requirement for Internet posting of personal financial data for most federal officials until the
potential impact of these new Internet disclosures may be studied by the National Academy of
Public Administration [NAPA].24 Issuing their study on March 28, 2013, the NAPA, in a detailed
report, concluded that “the online posting requirement does little to help detect conflicts of
interest and insider trading, but that it can harm federal missions and individual employees.”25
The panel thus recommended that “the online posting requirement be indefinitely suspended
while continuing the implementation of all the other provisions of the STOCK Act.”
Under the latest amendments to the STOCK Act passed by Congress, the disclosure reports and
periodic transactions reports for high level officials ̶ the President, Vice President, Members of
Congress, candidates to Congress, and Presidential appointed and Senate confirmed officials on
18 P.L. 112-105, Section 8(a)(1) .
19 P.L. 112-105, Section 11(a)(1).
20 P.L. 112-105, Sections 8(a)(1), 11(a)(1).
21 Senior Executives Association v. United States, Civil Action No. 8:12-cv-02297 (S.D. Md. March 27, 2013).
22 The court had earlier, on September 13, 2012, granted a motion for a temporary preliminary injunction upon the
implementation of the requirement for Internet posting of such information for executive branch employees.
23 See, e.g., discussion of “informational privacy” in Congressional Research Service, Library of Congress, THE
CONSTITUTION OF THE UNITED STATES OF AMERICA, ANALYSIS AND INTERPRETATION [CONSTITUTION ANNOTATED], S.
Doc. 108-17, at 1778-1787 (2004); see also Duplantier v. United States, 606 F.2d 654 (5th Cir. 1979), upholding public
financial disclosure requirement of the Ethics in Government Act for federal judges against privacy challenge.
24 P.L. 112-178, Section 2, 126 Stat. 1408-1409 (September 28, 2012).
25 National Academy of Public Administration, THE STOCK ACT: AN INDEPENDENT REVIEW OF THE IMPACT OF
PROVIDING PERSONALLY IDENTIFIABLE FINANCIAL INFORMATION ONLINE, at i ,53-61(March 2013).
Congressional Research Service
5
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
the Executive Schedule I (cabinet level) and Executive Schedule II ̶ continue to be required to be
posted on the Internet.26 However, for all other officers and employees in the legislative and
executive branches of government who must file public reports with their agencies, these reports
will no longer be required to be posted on the Internet.27
By January 1, 2014, the Clerk of the House and Secretary of the Senate, as well as the appropriate
entities in the executive branch of government, are instructed to develop and implement an
electronic filing system for the financial disclosure reports required to be filed under the Ethics in
Government Act for Members of and candidates for Congress, the President, the Vice President,
and presidentially appointed and Senate confirmed officials on Levels I and II of the Executive
Schedule.28 The system is to allow the public to search these reports on the Internet and, with a
login, to be able to download the reports. The system for the executive branch is to be maintained
on the official website of the Office of Government Ethics.
In the legislative branch, the reports filed by Members of Congress are to be kept for a period of
six years after the date the person is no longer a Member; and other reports filed by legislative
officers and employees are to be retained for a period of six years after receipt.29
Pensions of Members of Congress
Under current law, if convicted of certain offenses relating to corruption in public office while
serving as a Member, a Member of Congress forfeits all of his or her creditable service as a
Member for federal pension purposes.30 This bill expands that provision so that a Member of
Congress would lose the credit for service as a Member for pension purposes if convicted of one
of the numerous corruption offenses not only during time served as a Member of Congress, but
also if convicted of any of such offenses while the President, the Vice President, or as an elected
official of a state or local government.31
The STOCK Act also adds numerous other federal criminal laws for which a final felony
conviction would result in losing creditable service as a Member of Congress for federal pension
purposes. Such other criminal offenses include conflicts of interest (18 U.S.C. §203); conspiracy
to make false claims (18 U.S.C. §286); making false claims to the government (18 U.S.C. §287);
vote buying (18 U.S.C. §597); illegal solicitation of political contributions from federal
employees (18 U.S.C. §602); soliciting political contributions in a federal building or office (18
U.S.C. §607); theft, conversion, or embezzlement of government funds or property (18 U.S.C.
§641); false statements to the government (18 U.S.C. §1001); obstruction of proceedings before
26 S. 716, 113th Congress, passed by the Senate on April 11, 2013, and by the House on April12, 2013, and awaiting the
President’s signature.
27 S. 716, 113th Congress, Section 1; see also P.L. 112-173, Section 1, 126 Stat. 1310 (Aug. 16, 2012); P.L. 112-178,
Section 1(a) and (b), 126 Stat. 1408 (September 28, 2012), and P.L. 112-207, Section 1 (December 7, 2012).
28 S. 716, 113th Congress, Section 1(b).
29 P.L. 112-105, Section 8(c).
30 5 U.S.C. §8332(o) (CSRS), and 5 U.S.C. §8411(l) (FERS), added by the “Honest Leadership and Open Government
Act of 2007,” P.L. 110-81, title IV. See also “Hiss Act” provisions, at 5 U.S.C. §8311 et seq., relating to national
security offenses. See generally, CRS Report 96-530, Loss of Federal Pensions for Members of Congress Convicted of
Certain Offenses, by Jack Maskell.
31 P.L. 112-105, Section 15(a).
Congressional Research Service
6
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
government agencies (18 U.S.C. §1505); attempt to evade or defeat paying taxes (26 U.S.C.
§7201), among other offenses.32
Other Provisions
Influencing Private Employment Decisions
Section 18 of the Stock Act amends 18 U.S.C. Section 227 to include officers and employees of
the executive branch of government in the prohibition on wrongfully attempting to influence
private employment decisions based on partisan political affiliations.
Negotiations for Post-Government Employment
The STOCK Act now requires any individual who must file a public financial disclosure report
under the Ethics in Government Act to report all negotiations or agreements for future private
employment within three days after commencement of such negotiations or agreement to the
employee’s supervising ethics office, and then to recuse himself or herself when there is a conflict
of interest or an appearance of a conflict of interest “with respect to the subject matter of the
statement.”33 These provisions do not appear to supersede, but appear to add to, the existing
criminal conflict of interest provision in 18 U.S.C. Section 208. With respect to all executive
branch employees, 18 U.S.C. Section 208 requires recusal of such executive branch officer and
employee from any particular governmental matter when that matter may affect the financial
interests of “any person or organization with whom he [the employee] is negotiating or has any
arrangement concerning prospective employment.” Additionally, there are detailed executive
branch regulations on negotiating and seeking private employment, at 5 C.F.R. Section 2635,
Subpart F, Sections 2635.601 - 2635.606.
Bonuses to Fannie Mae and Freddie Mac Executives
The STOCK Act prohibits the receipt of bonuses by “senior executives” at the Federal National
Mortgage Association and the Federal Home Loan Mortgage Corporation during any period of
conservatorship for those entities after the passage of this act.34
Study on Political Intelligence
The STOCK Act had required a report to be made by the Comptroller General of the Government
Accountability Office, in consultation with the Congressional Research Service, within one year
concerning the role of “political intelligence” in the financial markets, including the extent that
such information sold is considered nonpublic; the legal and ethical issues in the sale of political
intelligence; benefits from imposing reporting and registration requirements on those who engage
in political intelligence; and legal and practical issues in imposing such reporting and registration
32 P.L. 112-105, Section 15(b).
33 P.L. 112-105, Section 17.
34 P.L. 112-105, Section 16.
Congressional Research Service
7
The STOCK Act, Insider Trading, and Public Financial Reporting by Federal Officials
requirements.35 The Government Accountability Office has released this report discussing
potential issues in the implementation of such registration requirements, the difficulties of
measuring the impact of a particular piece of “political intelligence” on financial markets, the
practical issues in attempting to determine the public or non-public nature of particular
disclosures, and discussing the costs versus the benefits of a registration scheme for political
intelligence firms similar to the registration of lobbyists and lobbying firms.36
Author Contact Information
Jack Maskell
Legislative Attorney
jmaskell@crs.loc.gov, 7-6972
35 P.L. 112-105, Section 7.
36 United States Government Accountability Office, “POLITICAL INTELLIGENCE, Financial Market Value of Government
Information Hinges on Materiality and Timing,” GAO-13-389 (April 2013).
Congressional Research Service
8