What to Disclose
Significant Financial Interests Definition:
A Significant Financial Interest (SFI) is a financial interest (anything of monetary value) related to your MSU responsibilities that, when aggregated over the previous calendar year, normally exceeds $5,000 (or less, see below). If its value is not evident (as with equity interest in a non-publicly traded entity, or travel that was paid on behalf of the investigator), then it must be reported as a SFI.
SFIs include not only your personal interests, but also financial interests held with or by your immediate family (spouse, domestic partner, dependent children, or other dependents) and with or by any legal entity that you or your family owns or controls.
Significant Financial Interests Include:
- Income or payments of any kind totaling more than $5,000 over the last calendar year from a single entity;
- Ownership greater than 1% of a single outside entity or ownership interests greater than $5,000 (e.g., stock);
- Serving as a trustee for a trust or estate, or having a beneficial interest in a trust or estate with income from a single entity exceeding $5,000. (If the holdings of the trust are related to your MSU responsibilities, then the trust must be disclosed.);
- Receiving or providing a loan exceeding $5,000;
- Intellectual property rights or licenses with an established fair market value exceeding $5000 or which generate income of any value from other than MSU (including royalties from other domestic universities and teaching materials);
- Unvalued options for stock or ownership of any value in a private company;
- Serving on a governing or advisory board, or in a fiduciary or managerial role, or as a general partner with or without pay;
- Receiving gifts (goods, property, or services, such as travel or other recreational or personal amenities) with value greater than $250;
- PHS investigators only: Sponsored or reimbursed travel or gifts of any value (excluding travel sponsored or reimbursed by domestic federal, state, or local government, a domestic Institution of higher education, or an academic teaching hospital, medical center, or research institute that is affiliated with an institution of higher education).
Exceptions: The following financial interests DO NOT need to be reported:
- SFIs unrelated to your MSU responsibilities;
- MSU salary, remuneration by MSU, or other payments at MSU's behest (including from an MSU-approved practice plan);
- Financial interests arising solely by means of investment in a mutual, pension, or other institutional investment fund over whose management and investments neither you nor any immediate family member has control;
- Indebtedness from a bank, credit union, or other commercial lender;
- SFIs from seminars, lectures, teaching engagements, or service on advisory committees or review panels paid by domestic (U.S.):
- Federal, state, or local government agencies;
- Institutions of higher education;
- Academic teaching hospitals and medical centers; or
- Research institutes affiliated with an institution of higher education.