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Peter Girnus 🦅
@gothburz
The Cyber Populist | Hacks computers by day. Hacks narratives by night. | Your favorite vendor's worst nightmare. | Holding the pen.
加入 December 2017
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I am the Deputy Director of Disclosure Compliance at the Office of Government Ethics. I oversee a team of 11 specialists. We process financial disclosure amendments for senior executive branch personnel. We are very good at our jobs. In Q1 2026, we received 113 pages of periodic transaction reports from a single trust. Form OGE-278-T, filed in duplicate. 3,642 individual stock trades. I want you to understand the scale of our achievement: we processed every single one. On time. In triplicate. Asset type, transaction date, notification date, value range. Every field populated. Every box checked. Every signature dated. 60 trades per trading day. My senior analyst calculated it on her lunch break. She thought the number was remarkable. I told her what was remarkable was our processing speed. For context: the previous 2 administrations filed primarily index funds and Treasury notes. Fewer than 200 transactions per year. My team reorganized the archive. We updated the flowchart. Those were quiet years. The system worked. I will summarize several entries that exemplify our compliance standards. On February 10, the trust purchased $1-5M in Dell Technologies stock. On May 8, at a White House Mother's Day event, the President of the United States said — on camera, into microphones — "Go buy Dell." The stock surged 14.6% to an all-time high of $263.99. Dell's founding family had pledged $6.25B to affiliated financial accounts the previous December. This is compliant. The disclosure was filed within the statutory window. Schedule C, Addendum J — I verified the columns personally. On January 6, the trust purchased $500K-$1M in Nvidia. 1 week later, the Commerce Department approved the sale of Nvidia H200 chips to China. On February 10, the trust purchased an additional $1-5M in Nvidia. The following week, Nvidia announced a major partnership with Meta. The CEO of Nvidia had been cultivating what the press corps describes as a "close personal relationship" with the President. Also compliant. Both transactions filed on time. I color-coded the Nvidia entries green. Green means technology sector. Palantir Technologies required its own subsection. The trust purchased $65-150K in January. Sold $1.1-5.3M in February — the same month the Department of Homeland Security signed a $1B Palantir contract for immigration enforcement. Then purchased another $200-500K in March, after the Pentagon awarded a separate $1B Palantir AI contract. Buy, sell, buy. Each transaction disclosed. Each form complete. My team processed the Palantir cycle in under 4 hours. I nominated them for the Distinguished Processing Award. Some trades carried a designation I should explain: "unsolicited." This means the trade was not broker-recommended. The filer or their representative specifically requested it. The large purchases of Apple, Microsoft, and Amazon — all unsolicited. This is not a flag. This is a checkbox. We check it. The box is checked. Intel deserves mention. The trust increased its Intel position beginning in March — after the federal government acquired a 9.9% equity stake worth $8.9B, now valued above $41B. On April 30, the President posted on Truth Social congratulating Intel. The stock rose 3%. Intel is up 140% year-to-date. I color-coded Intel blue. Blue means strategic national interest. On April 9, 2025, at 9:37 AM, the President posted: "THIS IS A GREAT TIME TO BUY!!! DJT." 3 hours and 47 minutes later, he announced a 90-day tariff pause. The S&P 500 gained $4 trillion in a single session. Trump Media stock rose 22.67%. The President's 53% stake increased $415M before the market closed. The President's annual salary is $400,000. These are separate line items on Form SF-278. This was not on our forms. The President's social media posts are not financial instruments subject to disclosure. They are communications. We file communications in a different cabinet. The trust also executed 9 Coinbase purchases and additional transactions through Robinhood and SoFi — while the administration signed pro-cryptocurrency executive orders, proposed a federal bitcoin reserve, and the Department of Justice dissolved its National Cryptocurrency Enforcement Team. Robinhood served as custodian for several affiliated accounts. Combined crypto-adjacent holdings: $11.6B. Income from crypto in H1 2025: $800M. Fully disclosed. Every form filed. The Commerce Secretary appeared on Fox News and told viewers to buy Tesla stock. This is not within our jurisdiction. We process OGE forms. I have forwarded a memo. The memo has been filed. The late filings require a note. The STOCK Act mandates timely disclosure. When reports are filed late, the maximum penalty is $200. $200. That is the maximum penalty under the STOCK Act for late disclosure of stock trades executed by the President of the United States. The filing fee for a single LLC in Delaware is $250. The President acknowledged the fee. We acknowledged the acknowledgment. People misunderstand what "ethics oversight" means. The word "oversight" contains both "sight" and "over." We see it. Then it is over. My office has 74 employees. We can review, advise, recommend, refer, flag, note, catalog, and file. We cannot block a trade. We cannot delay an executive order. We cannot freeze an account. We have no subpoena power. We have no enforcement mechanism. We have a filing cabinet. It is a very organized filing cabinet. I should mention the blind trust. I drafted the implementation memo in 2017. Memo OGE-2017-041-R. 14 pages. Proper margins. Every president since Lyndon Johnson used a blind trust or equivalent. Jimmy Carter sold his peanut farm. Barack Obama held Treasury notes and index funds. Joe Biden maintained a blind trust. My memo recommended voluntary divestiture or a qualified blind trust within 90 days of inauguration. It was received, acknowledged, and filed. Filed is the final stage. After filed, there is nothing. Filed is where recommendations go to be preserved. The trust is managed by the filer's adult sons, who simultaneously operate the family's private real estate and licensing business. My former director, Walter Shaub, called the arrangement "wholly inadequate" and "not a blind trust." He resigned in 2017. I was promoted to manage his filing backlog. His concerns were documented, stamped, and archived. Third shelf, first cabinet. A new analyst asked me last month why we don't refuse to process the forms. I explained that refusal is not a stage in the compliance lifecycle. The compliance lifecycle has 4 stages. None of them is refusal. A law professor at Oxford described the aggregate pattern as "potentially the most far-reaching securities fraud in history." This is an academic opinion. We do not process academic opinions. We process Form OGE-278-T. The form has been processed. The new STOCK Act reform bill in committee would ban congressional stock trading. It explicitly exempts the President and Vice President. It reduces our projected caseload by zero. The Treasury Secretary has publicly endorsed banning stock trades for members of Congress. Our office processes 60 executive branch trades per day. These are compatible positions. Senator Warren called the volume "unprecedented." She is technically correct. We have never processed this quantity before. I had to requisition a second filing cabinet. Form GSA-3402. Walnut finish. It is beautiful. "Conflict of interest" is a documentation category, not a prohibition. When we identify a conflict, we document it. When we document it, we have addressed it. When we have addressed it, the file is closed. This is the compliance lifecycle. It has 4 stages and a laminated flowchart. The system does not exist to prevent. The system exists to create a record that the system exists. The record is the product. The product is the record. We are in the record business. We are fully staffed. We are well-funded. We are operational. Cumulative transaction value for Q1: $220M-$750M. The next quarterly filing deadline is in 9 days. I expect volume to increase. I have requested a third cabinet.
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