Annual Report 2022 for Calendar Year 2021 | U.S. Office of Government Ethics; 5 C.F.R.

part 2634 | Form Approved: OMB No. (3209-0001) (Updated Nov. 2021)

Executive Branch Personnel

Public Financial Disclosure Report (OGE Form 278e)

Filer's Information
Donilon, Michael C

Assistant to President and Senior Adviser, Executive Office of the President, White House - Biden-Harris Administration

Report Year: 2022

Other Federal Government Positions Held During the Preceding 12 Months:

None

Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge.

/s/ Donilon, Michael C [electronically signed on 05/11/2022 by Donilon, Michael C in Integrity.gov]

Agency Ethics Official's Opinion - On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations (subject to
any comments below).
/s/ Kozmycz, Marina M, Certifying Official [electronically signed on 05/11/2022 by Kozmycz, Marina M in Integrity.gov]

Other review conducted by

/s/ Kozmycz, Marina M, Ethics Official [electronically signed on 05/11/2022 by Kozmycz, Marina M in Integrity.gov]

U.S. Office of Government Ethics Certification

Donilon, Michael C - Page 1

1. Filer's Positions Held Outside United States Government
# ORGANIZATION NAME CITY, STATE ORGANIZATION POSITION FROM TO
TYPE HELD

1 PT Fund, Inc. Washington, Corporation Staff 1/2021 1/2021

District of
Columbia

2. Filer's Employment Assets & Income and Retirement Accounts

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

1 TIAA/CREF Van Inst Tg Rtm 30 Inst Yes $50,001 - None (or less
$100,000 than $201)

2 SEP-IRA No

2.1 iShares Core S&P Small-Cap ETF (IJR) Yes $1,001 - $15,000 None (or less
than $201)

2.2 iShares Trust Core MSCI EAFE ETF Yes $1,001 - $15,000 None (or less
than $201)

2.3 iShares INC Core MSCI Emerging MKTS ETF Yes $1,001 - $15,000 None (or less
than $201)

2.4 iShares Trust Currency Hedged MSCI EAFE Yes $1,001 - $15,000 None (or less
ETF than $201)

2.5 Vanguard S&P 500 Growth Index Fund ETF Yes $15,001 - None (or less
Shares (VOOG) $50,000 than $201)

2.6 Vanguard Small-Cap Value Index Fund ETF Yes $1,001 - $15,000 None (or less
Class Shares (VBR) than $201)

2.7 Vanguard Index Fund Vanguard Value Yes $1,001 - $15,000 None (or less
than $201)

Donilon, Michael C - Page 2

 # DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

2.8 Vanguard International Equity Index Yes $1,001 - $15,000 None (or less
than $201)

2.9 Vanguard Real Estate ETF Yes $1,001 - $15,000 None (or less
than $201)

3. Filer's Employment Agreements and Arrangements

# EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE

1 University of Delaware Newark, I will continue to participate in this defined contribution 6/2017
Delaware plan, but I have made no contributions since my
separation (6/2020).

4. Filer's Sources of Compensation Exceeding $5,000 in a Year

(N/A) - Not required for this type of report

5. Spouse's Employment Assets & Income and Retirement Accounts

None

6. Other Assets and Income

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

1 U.S. Based Bank #1 (Cash) N/A $500,001 - Interest None (or less
$1,000,000 than $201)

Donilon, Michael C - Page 3

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

2 Brokerage acct #1 No

2.1 FIDELITY GOVERNMENT CASH RESERVES Yes $15,001 - None (or less
(FDRXX) $50,000 than $201)

2.2 EDGEWOOD GROWTH FUND INSTL CL Yes $100,001 - None (or less
(EGFIX) $250,000 than $201)

2.3 CHAMPLAIN SMALL COMPANY CLASS Yes $15,001 - None (or less
INSTL (CIPNX) $50,000 than $201)

2.4 GOLDMAN SACHS MID CAP VALUE-INSTL Yes $15,001 - None (or less
SH (GSMCX) $50,000 than $201)

2.5 GOLDMAN SACHS LARGE CAP VALUE Yes $100,001 - None (or less
INSTL (GSLIX) $250,000 than $201)

2.6 PEAR TREE POLARIS FRGN VALUE INSTL Yes $50,001 - None (or less
(QFVIX) $100,000 than $201)

2.7 BOSTON PARTNERS SM CAP VALUE II Yes $15,001 - None (or less
INST (BPSIX) $50,000 than $201)

2.8 SOUND SHORE FUND INSTITUTIONAL Yes $100,001 - None (or less
(SSHVX) $250,000 than $201)

2.9 GOLDMAN SACHS SHORT DURATION Yes $50,001 - None (or less
GOVT INSTL (GSTGX) $100,000 than $201)

2.10 GOLDMAN SACHS HIGH YIELD Yes $50,001 - None (or less
INSTITUTIONAL (GSHIX) $100,000 than $201)

2.11 GOLDMAN SACHS GOVT INCOME- Yes $50,001 - None (or less
INSTITUTIONAL (GSOIX) $100,000 than $201)

2.12 WELLS FARGO CORE BOND FD INSTL Yes $100,001 - None (or less
(MBFIX) $250,000 than $201)

2.13 ALPS ETF TR ALERIAN MLP (AMLP) Yes $1,001 - $15,000 None (or less
than $201)

2.14 ISHARES INC MSCI PAC JP ETF (EPP) Yes $15,001 - None (or less
$50,000 than $201)

Donilon, Michael C - Page 4

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

2.15 ISHARES CORE S&P 500 (IVV) Yes $250,001 - None (or less
$500,000 than $201)

2.16 ISHARES S&P 500 GROWTH ETF (IVW) Yes $50,001 - None (or less
$100,000 than $201)

2.17 ISHARES CORE S&P MID-CAP 400 INDEX Yes $15,001 - None (or less
FUND (IJH) $50,000 than $201)

2.18 ISHARES S&P MID CAP 400 GROWTH ETF Yes $50,001 - None (or less
(IJK) $100,000 than $201)

2.19 ISHARES CORE S&P SMALL-CAP E (IJR) Yes $50,001 - None (or less
$100,000 than $201)

2.20 ISHARES INC CORE MSCI EMERGING Yes $15,001 - None (or less
MKTS ETF (IEMG) $50,000 than $201)

2.21 ISHARES INC MSCI JPN ETF NEW (EWJ) Yes $15,001 - None (or less
$50,000 than $201)

2.22 VANGUARD INTL EQUITY INDEX FDS FTSE Yes $100,001 - None (or less
EUROPE ETF (VGK) $250,000 than $201)

2.23 ISHARES TR ISHS 1-5YR INVS (IGSB) Yes $100,001 - None (or less
$250,000 than $201)

3 Brokerage #2 (284) No

3.1 Fidelity Government Cash Reserves (FDRXX) Yes $15,001 - None (or less
$50,000 than $201)

3.2 SPDR S&P500 ETF TRUST S&P 500 ETF Yes $100,001 - None (or less
USD DIS (SPY) $250,000 than $201)

3.3 VANGUARD INDEX FDS VANGUARD Yes $1,001 - $15,000 None (or less
GROWTH ETF FORMERLY VANGUARD than $201)
INDEX TR VIPERS (VUG)

4 Brokerage Acct #3 No

4.1 FIDELITY GOVERNMENT CASH RESERVES Yes $1,001 - $15,000 None (or less
(FDRXX) than $201)

Donilon, Michael C - Page 5

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

4.2 AMG YACKTMAN FOCUSED I (YAFIX) Yes $1,001 - $15,000 None (or less
than $201)

4.3 AQR MANAGED FUTURES FUND CL I Yes $1,001 - $15,000 None (or less
(AQMIX) than $201)

4.4 JOHCM INTERNATIONAL SELECT FUND CL Yes $1,001 - $15,000 None (or less
I (JOHIX) than $201)

4.5 ARTISAN THEMATIC FD ADVISOR CL Yes $1,001 - $15,000 None (or less
(APDTX) than $201)

4.6 CALAMOS MARKET NEUTRAL INCOME CL I Yes $1,001 - $15,000 None (or less
(CMNIX) than $201)

4.7 AKRE FOCUS FUND INSTL (AKRIX) Yes $1,001 - $15,000 None (or less
than $201)

4.8 RIVER CANYON TOTAL RETURN BOND Yes $1,001 - $15,000 None (or less
INSTL (RCTIX) than $201)

4.9 CHIRON CAPITAL ALLOCATION FUND CL I Yes $1,001 - $15,000 None (or less
(CCAPX) than $201)

4.10 BLACKROCK STRATEGIC INC OPP PORT Yes $1,001 - $15,000 None (or less
CL K (BSIKX) than $201)

4.11 JOHN HANCOCK INCOME FUND CLASS I Yes $1,001 - $15,000 None (or less
(JSTIX) than $201)

4.12 BRANDYWINEGLOBAL GLBL Yes $1,001 - $15,000 None (or less

UNCONSTRAN BD I (LROIX) than $201)

4.13 PIMCO INCOME FUND INSTITUTIONAL Yes $1,001 - $15,000 None (or less
FUND (PIMIX) than $201)

4.14 TCW EMERGING MKTS INCOME CL I Yes $1,001 - $15,000 None (or less
(TGEIX) than $201)

4.15 LEGG MASON WESTERN ASSET MACRO Yes $1,001 - $15,000 None (or less
OPP I (LAOIX) than $201)

Donilon, Michael C - Page 6

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

4.16 BNY MELLON GLOBAL REAL RETURN I Yes $1,001 - $15,000 None (or less
(DRRIX) than $201)

5 Acct #5 No

5.1 U.S. Bank #3 (Cash) N/A $500,001 - Interest $15,001 -

$1,000,000 $50,000

6 Brokerage Acct #6 No

6.1 U.S. Based Bank #4 (Cash) N/A $15,001 - Interest $201 - $1,000
$50,000

6.2 ISHARES S&P 100 ETF (OEF) Yes $50,001 - None (or less
$100,000 than $201)

6.3 SPDR S&P 500 ETF TRUST (SPY) Yes $1,000,001 - None (or less
$5,000,000 than $201)

6.4 ISHARES RUSSELL 1000 GROWTH ETF Yes $250,001 - None (or less
(IWF) $500,000 than $201)

6.5 ISHARES CORE DIVIDEND GROWTH ETF Yes $50,001 - None (or less
(DGRO) $100,000 than $201)

6.6 ISHARES RUSSELL 1000 VALUE ETF (IWD) Yes $250,001 - None (or less
$500,000 than $201)

6.7 ISHARES CORE S&P MID-CAP ETF (IJH) Yes $100,001 - None (or less
$250,000 than $201)

6.8 ISHARES CORE S&P SMALL-CAP ETF (IJR) Yes $100,001 - None (or less
$250,000 than $201)

6.9 ISHARES MSCI CANADA ETF (EWC) Yes $15,001 - None (or less
$50,000 than $201)

6.10 VANGUARD FTSE EUROPEAN ETF ETF Yes $15,001 - None (or less
(VGK) $50,000 than $201)

6.11 ISHARES, INC. - ISHARES MSCI UNITED Yes $100,001 - None (or less
KINGDOM ETF (EWU) $250,000 than $201)

Donilon, Michael C - Page 7

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

6.12 ISHARES, INC.MSCI JAPAN ETF MUTUAL Yes $50,001 - None (or less
FUND (EWJ) $100,000 than $201)

6.13 ISHARES MSCI PACIFIC EX JAPAN ETF Yes $100,001 - None (or less
(EPP) $250,000 than $201)

6.14 ISHARES CORE MSCI EMERGING Yes $15,001 - None (or less
MARKETS ETF (IEMG) $50,000 than $201)

6.15 ISHARES MSCI EUROZONE ETF (EZU) Yes $100,001 - None (or less
$250,000 than $201)

6.16 SPDR S&P BANK ETF (KBE) Yes None (or less None (or less
than $1,001) than $201)

6.17 WISDOM TREE JAPAN HEDGED EQUITY Yes None (or less None (or less
FUND (DXJ) than $1,001) than $201)

6.18 WISDOMTREE EUR HDGD EQ FD CMN Yes None (or less $2,501 - $5,000
(HEDJ) than $1,001)

7 Blizzard LLC No

7.1 U.S. Based Bank #5 (Cash) N/A $1,001 - $15,000 Interest $1,001 - $2,500

8 Brokerage Acct #7 No

8.1 U.S. Based Bank #6 (Cash) N/A $15,001 - Interest $1,001 - $2,500
$50,000

8.2 ALASKA ST GO 5% 08/01/26-CA FA GO BDS N/A $50,001 - None (or less

2016 A UT BEO SR LIEN $100,000 than $201)

8.3 ALASKA ST HSG FIN CORP REV 5% N/A $50,001 - None (or less
12/01/24 JD ST CAP PROJ BDS II 2015B $100,000 than $201)
BEO

8.4 ARLINGTON CNTY VA INDL DEV REV 5% N/A $15,001 - None (or less
02/15/28-CA FA AUTH REV REF BDS 2017 $50,000 than $201)
BEO

Donilon, Michael C - Page 8

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

8.5 CELINA TEX DB 5% 09/01/29-CA MS TAX N/A $50,001 - None (or less
WTR WORKS SWR SYS REV CTFS OBLIG $100,000 than $201)
2018 UT BEO

8.6 CITY OF NY GEN OBLIGATION BDS GO N/A $15,001 - None (or less
5.0000% 08/01/25-CA FA FISCAL 2015 $50,000 than $201)
SERIES C AND D BEO

8.7 CLARK CNTY NEV ARPT REV REV 5.0000% N/A $15,001 - None (or less
07/01/22 JJ RFDG-LAS VEGAS-MCCARRAN $50,000 than $201)
INTL ARPT-PASSENGR FAC CHARGE-B
BEO

8.8 CORPUS CHRISTI TEX ISSUES DTD GO N/A $15,001 - None (or less
5.0000% 03/01/26-CA MS PRIOR TO $50,000 than $201)
12/01/1989 IN 220111 GEN IMPT LT BEO

8.9 DANE CNTY WIS GO 3% 06/01/22 JD GO N/A $15,001 - None (or less
CORPORATE PURPOSE BDS 2017 B UT $50,000 than $201)
BEO

8.10 DISTRICT COLUMBIA GO 5% 10/15/28 AO N/A $100,001 - None (or less

GO BDS 2019 A UT BEO $250,000 than $201)

8.11 DORM AUTH OF THE STATE OF NY REV N/A $15,001 - None (or less
5.0000% 10/01/27 AO SCH DISTS REV BD $50,000 than $201)
FING PROG REV BONDS SER 2017A

8.12 EL PASO TEX DB 5% 08/15/29-CA FA COMB N/A $100,001 - None (or less
TAX AND REV CTFS OF OBLIG 2019 UT $250,000 than $201)
BEO

8.13 HAMPTON ROADS SANTN DIST VA REV N/A $50,001 - None (or less
5% 08/01/33 FA WASTEWATER REV REV $100,000 than $201)
BDS 2016 A PRERE 08/01/26 BEO SUB LIEN

8.14 HONOLULU HAWAII CITY & COUNTY GO N/A $50,001 - None (or less
5.0000% 09/01/28 MS - BEO $100,000 than $201)

8.15 HOUSTON TEX UTIL SYS REV 5.0000% N/A $15,001 - None (or less
11/15/23 MN RFDG-COMBINED-FIRST LIEN- $50,000 than $201)
SER B BEO

Donilon, Michael C - Page 9

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

8.16 ISLE WIGHT CNTY VA GO 5% 07/01/24 JJ N/A $50,001 - None (or less
GO REF BDS 2017 B UT BEO $100,000 than $201)

8.17 JACKSONVILLE FLA SPL REV REV 5% N/A $15,001 - None (or less
10/01/24 AO REV REF BDS A BEO $50,000 than $201)

8.18 LEANDER TEX INDPT SCH DIST GO 0% N/A $1,001 - $15,000 None (or less
08/15/24 ULTD TAX REF BDS 2013 A than $201)
PRERE 08/15/23 UT BEO OID

8.19 LEANDER TEX INDPT SCH DIST GO 0% N/A $1,001 - $15,000 None (or less
08/15/24-CA ULTD TAX REF BDS 2013 A UT than $201)
BEO OID

8.20 LOUDOUN CNTY VA ECONOMIC DEV REV N/A $50,001 - None (or less
5.0000% 12/01/27-CA JD AUTH PUB FAC $100,000 than $201)
LSE REV BDS LNDN CNTY PUB FACS
PROJ 2016 B BEO

8.21 LOUISIANA ST GO 5% 03/01/27 MS GO BDS N/A $100,001 - None (or less

2019-A UT BEO $250,000 than $201)

8.22 MANSFIELD TEX ECONOMIC DEV REV 4% N/A $15,001 - None (or less
08/01/23 FA CORP SALES TAX REV REV $50,000 than $201)
BDS 2016 BEO SR LIEN

8.23 MASSACHUSETTS ST GO 5% 09/01/29 MS N/A $50,001 - None (or less

REF BDS 2018C UT BEO $100,000 than $201)

8.24 MEMPHIS TENN GO 5% 11/01/23 MN GO N/A $15,001 - None (or less

IMPT REF BDS 2014A UT BEO SR LIEN $50,000 than $201)

8.25 METROPOLITAN TRANSN AUTH N Y REV N/A $50,001 - None (or less
5% 03/01/22 MN DEDICATED TAX FD BANS $100,000 than $201)
2019 A BEO

8.26 MIAMI-DADE CNTY FLA TRAN SYS REV 5% N/A $50,001 - None (or less
07/01/25 JJ SALES SURTAX REV REF BDS $100,000 than $201)
2019 BEO

8.27 MISSISSIPPI ST GO 5% 10/01/26 AO GO N/A $50,001 - None (or less

REF BDS 2017 A UT BEO $100,000 than $201)

Donilon, Michael C - Page 10

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

8.28 PENNSYLVANIA ST GO 5% 07/01/22 JJ GO N/A $15,001 - None (or less

BDS FIRST REF SER UT BEO SR LIEN $50,000 than $201)

8.29 RHODE ISLAND ST & PROVIDENCE GO N/A $15,001 - None (or less
5.0000% 08/01/25-CA FA PLANTATIONS $50,000 than $201)
RFDG-CONS CAP DEV LN-SER D BEO

8.30 STATE OF CONNECTICUT GO 5.0000% N/A $15,001 - None (or less

08/01/26-CA FA BEO $50,000 than $201)

8.31 VA COE BG VA EL FS CY EQP PG REV N/A $15,001 - None (or less

7.7350% 02/01/30 FA TAXABLE REF BDS $50,000 than $201)
2020B TAXBL BEO

8.32 VA ST RES AUTH INFRASTR FOR REV N/A $50,001 - None (or less
5.0000% 11/01/23 MN PREV ISS UNREF $100,000 than $201)
BAL-RFDG NON AMT NON ACE-ST MORAL
OBLIG VA

8.33 VA ST RES AUTH INFRASTRUCTURE REV N/A $1,001 - $15,000 None (or less
5.0000% 11/01/23 MN PREREFUNDED- than $201)
RFDG SR LIEN

8.34 VA ST RES AUTH INFRASTRUCTURE REV N/A $50,001 - None (or less
5.0000% 11/01/27 MN INFRASTRUCTURE- $100,000 than $201)
VA POOLED FING PROG-SER B GUA BEO

8.35 WASHINGTON D C MET AREA TRAN REV N/A $50,001 - None (or less
5% 07/01/28-CA JJ AUTH GROSS REV REV $100,000 than $201)
TRANSIT REF BDS A-1 BEO

8.36 WASHINGTON ST GO 5% 02/01/30-CA FA N/A $100,001 - None (or less

VARIOUS PURP GO BDS 2019 C UT BEO $250,000 than $201)

8.37 WEST FARGO N D DB 5% 05/01/25 MN REF N/A $15,001 - None (or less
IMPT BDS 2017 A UT INS BEO $50,000 than $201)

8.38 VIRGINIA COLLEGE BLDG AUTH VA REV N/A $100,001 - None (or less
5% 02/01/26 FA EDL FACS REV REV REF $250,000 than $201)
BDS B BEO

8.39 Virginia St Pub Sch Auth S0on Rev 4% N/A $15,001 - None (or less
10/01/20 AO Oblig Prince Willian $50,000 than $201)

Donilon, Michael C - Page 11

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

8.40 Norfolk VA GO 5% 03/01/32 N/A $50,001 - None (or less

$100,000 than $201)

8.41 Roanoke VA GO 5% 04/01/31 N/A $100,001 - None (or less

$250,000 than $201)

9 Brokerage Acct #8 (276) No

9.1 GOLDMAN SACHS FIN SQ GOVT FST Yes $15,001 - None (or less
INSTL (FGTXX) $50,000 than $201)

7. Transactions
# DESCRIPTION TYPE DATE AMOUNT

1 KRE Focus Fund Instl (AKRIX) Purchase 08/13/2021 $1,001 - $15,000

2 BNY Mellon Global Real Estate (DRRIX) Purchase 08/13/2021 $1,001 - $15,000

3 River Canyon Total Return Bond Fund Purchase 08/13/2021 $1,001 - $15,000
Institutional Class Shares (RCTIX)

4 Legg Mason Western Asset (LAIQX) Purchase 08/13/2021 $1,001 - $15,000

5 Brandywine GLOBAL -Global Unconstrained Sale 08/13/2021 $1,001 - $15,000

Bond Fund Class I Shares (LROIX)

6 Calamos Market Neutral Income Fund Class I Sale 08/13/2021 $1,001 - $15,000
Shares (CMNIX)

7 BlackRock Strategic Income Opportunities Sale 08/13/2021 $1,001 - $15,000

Portfolio Class K Shares (BSIKX)

8 artisan Focused Fund (APDTX) Sale 08/13/2021 $1,001 - $15,000

9 AQR Managed Futures Strategy Fund Class I Sale 08/13/2021 $1,001 - $15,000
Shares (AQMIX)

10 Akre Focus Fund Institutional Class Shares Sale 08/02/2021 $1,001 - $15,000
(AKRIX)

Donilon, Michael C - Page 12

# DESCRIPTION TYPE DATE AMOUNT

11 AMG Yacktman Focused Fund Class I Shares Sale 08/02/2021 $1,001 - $15,000
(YAFIX)

12 BlackRock Commodity Strategies Fund Class Sale 02/23/2021 $1,001 - $15,000

K Shares (BCSKX)

13 Chiron Capital Allocation Fund Class I Shares Sale 01/26/2021 $1,001 - $15,000
(CCAPX)

14 Roanoke VA GO 5% 04/01/31 Purchase 10/01/2021 $100,001 -

$250,000

15 Virginia St Pub Sch Auth Spl Rev 4% 10/01/30 Purchase 10/22/2021 $15,001 -
Prince William Co $50,000

16 Norfolk VA GO 5% 03/01/32 Purchase 08/18/2021 $50,001 -

$100,000

17 GOLDMAN SACHS FIN SQ GOVT FST Sale 06/14/2021 $15,001 -

INSTL (FGTXX) $50,000

18 Fidelity Government Cash Reserves (FDRXX) Purchase 06/14/2021 $15,001 -

$50,000

19 iShares Core S&P Small-Cap ETF (IJR) Purchase 05/11/2021 $1,001 - $15,000

20 iShares Core S&P Small-Cap ETF (IJR) Purchase 05/13/2021 $1,001 - $15,000

21 iShares Inc Core MSCI Emerging MKTS Purchase 05/11/2021 $1,001 - $15,000

22 iShares Inc Core MSCI Emerging MKTS Purchase 05/13/2021 $1,001 - $15,000

23 iShares Trust CORE MSCI EAFE ETF Purchase 05/11/2021 $1,001 - $15,000

24 iShares Trust CORE MSCI EAFE ETF Purchase 05/13/2021 $1,001 - $15,000

25 Vanguard Index Funds Vanguard Value Purchase 05/13/2021 $1,001 - $15,000

26 Vanguard S&P 500 Value Index FundETF Purchase 05/11/2021 $15,001 -

Shares (VOOV) $50,000

27 Vanguard S&P 500 Value Index FundETF Purchase 05/13/2021 $15,001 -

Shares (VOOV) $50,000

Donilon, Michael C - Page 13

# DESCRIPTION TYPE DATE AMOUNT

28 Vanguard Small-Cap Value Index Fund ETF Purchase 05/11/2021 $1,001 - $15,000
Class Shares (VBR)

29 Vanguard Small-Cap Value Index Fund ETF Purchase 05/13/2021 $1,001 - $15,000
Class Shares (VBR)

30 iShares Trust Currency Hedged Purchase 05/13/2021 $1,001 - $15,000

31 Vanguard International Equity Purchase 05/13/2021 $1,001 - $15,000

32 Vanguard Real Estate ETF Purchase 05/13/2021 $1,001 - $15,000

8. Liabilities

None

9. Gifts and Travel Reimbursements

None

Endnotes

Donilon, Michael C - Page 14

Summary of Contents

1. Filer's Positions Held Outside United States Government

Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the
filer did not receive compensation.

This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an honorary nature; (3) positions held as
part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests as a limited partner or non-
managing member of a limited liability company.

2. Filer's Employment Assets & Income and Retirement Accounts

Part 2 discloses the following:

● Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria,
scholarships, and prizes)
● Assets related to the filer's business, employment, or other income-generating activities (1) that ended the reporting period with a value greater than $1,000 or (2) from
which more than $200 in income was received during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their
underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or
other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the
asset qualifies as an excepted investment fund (EIF).

3. Filer's Employment Agreements and Arrangements

Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as
the following:

● Future employment
● Leave of absence
● Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer)
● Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan
● Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a
company's profits, etc.)

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4. Filer's Sources of Compensation Exceeding $5,000 in a Year

Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period.

The filer discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its
payment to the filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client
is paying.

5. Spouse's Employment Assets & Income and Retirement Accounts

Part 5 discloses the following:

● Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership
share)
● Sources of honoraria for the filer's spouse greater than $200 during the reporting period
● Assets related to the filer's spouse's employment, business activities, other income-generating activities (1) that ended the reporting period with a value greater than $1,000
or (2) from which more than $200 in income was received during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and
their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business,
employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0
- $200 or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria).

6. Other Assets and Income

Part 6 discloses each asset, not already reported, (1) that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in investment income
was received during the reporting period. For purposes of the value and income thresholds, the filer aggregates the filer's interests with those of the filer's spouse and dependent
children.

This section does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits
associated with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial
institution with a value of $5,000 or less (unless more than $200 in income was received). Additional exceptions apply. Note: The type of income is not required if the amount of
income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF).

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7. Transactions

Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during the
reporting period.

This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money
market accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions
apply.

8. Liabilities

Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period.

This section does not include the following types of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a
personal motor vehicle, household furniture, or appliances, unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances,
if the outstanding liability did not exceed $10,000 at the end of the reporting period. Additional exceptions apply.

9. Gifts and Travel Reimbursements

This section discloses:

● Gifts totaling more than $415 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.
● Travel reimbursements totaling more than $415 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.

For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $166 or less. Regardless of the value, this section does not include the
following items: (1) anything received from relatives; (2) anything received from the United States Government or from the District of Columbia, state, or local governments; (3)
bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food,
lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their
relationship to the filer. Additional exceptions apply.

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Privacy Act Statement

Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. app. § 101 et seq., as amended by the Stop Trading on Congressional Knowledge Act of 2012
(Pub. L. 112-105) (STOCK Act), and 5 C.F.R. Part 2634 of the U. S. Office of Government Ethics regulations require the reporting of this information. Failure to provide the
requested information may result in separation, disciplinary action, or civil action. The primary use of the information on this report is for review by Government officials to
determine compliance with applicable Federal laws and regulations. This report may also be disclosed upon request to any requesting person in accordance with sections 105
and 402(b)(1) of the Act or as otherwise authorized by law. You may inspect applications for public access of your own form upon request. Additional disclosures of the
information on this report may be made: (1) to any requesting person, subject to the limitation contained in section 208(d)(1) of title 18, any determination granting an exemption
pursuant to sections 208(b)(1) and 208(b)(3) of title 18; (2) to a Federal, State, or local law enforcement agency if the disclosing agency becomes aware of violations or potential
violations of law or regulation; (3) to a source when necessary to obtain information relevant to a conflict of interest investigation or determination; (4) to the National Archives
and Records Administration or the General Services Administration in records management inspections; (5) to the Office of Management and Budget during legislative
coordination on private relief legislation; (6) when the disclosing agency determines that the records are arguably relevant to a proceeding before a court, grand jury, or
administrative or adjudicative body, or in a proceeding before an administrative or adjudicative body when the adjudicator determines the records to be relevant to the
proceeding; (7) to reviewing officials in a new office, department or agency when an employee transfers or is detailed from one covered position to another, a public financial
disclosure report and any accompanying documents, including statements notifying an employee's supervising ethics office of the commencement of negotiations for future
employment or compensation or of an agreement for future employment or compensation; (8) to a Member of Congress or a congressional office in response to an inquiry made
on behalf of and at the request of an individual who is the subject of the record; (9) to contractors and other non-Government employees working on a contract, service or
assignment for the Federal Government when necessary to accomplish a function related to this system of records; (10) on the OGE Website and to any person, department or
agency, any written ethics agreement, including certifications of ethics agreement compliance, filed with OGE by an individual nominated by the President to a position requiring
Senate confirmation; (11) on the OGE Website and to any person, department or agency, any certificate of divestiture issued by OGE; (12) on the OGE Website and to any
person, department or agency, any waiver of the restrictions contained in Executive Order 13770 or any superseding executive order; (13) to appropriate agencies, entities and
persons when there has been a suspected or confirmed breach of the system of records, the agency maintaining the records has determined that there is a risk of harm to
individuals, the agency, the Federal Government, or national security, and the disclosure is reasonably necessary to assist in connection with the agency's efforts to respond to
the suspected or confirmed breach or to prevent, minimize, or remedy such harm; and (14) to another Federal agency or Federal entity, when the agency maintaining the record
determines that information from this system of records is reasonably necessary to assist the recipient agency or entity in responding to a suspected or confirmed breach or in
preventing, minimizing, or remedying the risk of harm to individuals, the recipient agency or entity, the Federal Government, or national security. See also the OGE/GOVT-1
executive branch-wide Privacy Act system of records.

Public Burden Information

This collection of information is estimated to take an average of ten hours per response, including time for reviewing the instructions, gathering the data needed, and completing
the form. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Program
Counsel, U.S. Office of Government Ethics (OGE), Suite 500, 1201 New York Avenue, N.W., Washington, DC 20005-3917.

Pursuant to the Paperwork Reduction Act, as amended, an agency may not conduct or sponsor, and no person is required to respond to, a collection of information unless it
displays a currently valid OMB control number (that number, 3209-0001, is displayed here and at the top of the first page of this OGE Form 278e).

Donilon, Michael C - Page 18