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What Trump's financial disclosures do, and don't, tell us

President Donald Trump reported this week to the Office of Government Ethics that he and his businesses took in $434 million in 2018.

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Analysis by Zachary B. Wolf
CNN — President Donald Trump reported this week to the Office of Government Ethics that he and his businesses took in $434 million in 2018.

But who knows, really. The forms -- and he's been filing these as required by law since he was still just a candidate -- are based on his own valuations, they aren't subject to any kind of audit, and they're listed in extremely broad ranges.

We don't know what he told the IRS about his income because he won't release his tax returns or even turn them over when requested to certain members of Congress. On Friday, his Treasury chief, Steven Mnuchin, rejected a subpoena from House Democrats for the documents, though his predecessors -- and some of his would-be 2020 challengers -- have willingly disclosed their own tax filings.

The fact is that Trump lives in two worlds -- a dual reality the President and his businesses have constructed that inflates his worth for the public, or his lenders, and then deflates it for the tax man, as the New York Times recently reported.

"During his fifty-year career, Trump depended on the fact that the public had little access to information about his wealth and income in order to build the myth of his self-made success," wrote Michael D'Antonio, the Trump biographer and critic, on CNN.com.

He's said the public knows everything it needs to because of the disclosures, which list his holdings and income sources all the way down to his Screen Actors Guild pension. But these documents deal in ranges of income, assets and debt. And, more problematically, the documents Trump filed with OGE contain figures that are self-reported -- and that apparently treat Trump's business revenues as his own personal income.

News organizations, including CNN, report on the disclosures because they provide some window into what Trump owns, and they're the best we've got. But both sets of documents together -- the OGE filings and a tax return -- would offer a more complete snapshot of his wealth.

How much did Trump personally make last year?

The OGE gives filers a lot of leeway on what they can report in the "income" column on the financial disclosure documents. That's because the OGE doesn't focus on the income amount when making a determination on whether there's a conflict of interest -- a dollar of income would present the same amount of conflict as $1 million.

The President claimed $434 million in "income" -- again, the word the form uses -- but while some of that came from interest, book royalties and that SAG pension, the majority of what he listed appears to be revenue associated with the Trump Organization's many business ventures.

Trump appears to be treating himself more as a business in the documents than as an individual. It's not clear what his own personal stake is in the money he's claiming as income from his golf courses, hotels and other interests. And we don't really know what the listed values represent -- whether Trump reported as "income" what a given business took in as revenue, or if it's the total that actually flowed to him after expenses. We just don't know.

"This is a president you have to doubt everything he says. And this is a president who has proven the need for stronger laws applying to the president," said Jordan Libowitz, the spokesman for Citizens for Responsibility and Ethics in Washington, a watchdog group.

A peek inside Trump's biggest revenue-generator

One example worth looking at, however, is the Trump National Doral golf course in Miami, which has been Trump's top moneymaker -- way above his other properties, like his Mar-a-Lago resort.

Trump claims on his new disclosures that in 2018, the property generated income of $75,962,848. His forms from last year say the course generated $74,755,375 in 2017. That's about in line with the $75 million total revenue the Trump Organization claimed to Miami-Dade County tax officials in 2017, according to a Washington Post report this week.

But the company told Miami authorities that net operating income -- profit, that is -- fell from $13.8 million to $4.3 million, according to the Post. That's a clear indication that what Trump himself took home from Doral -- his personal income -- was much less than the amount he listed as "income" on his OGE form.

Trump's enormous loans and his obsession with interest rates

Another element of Trump's disclosures is the massive debt he holds -- five loans each exceed $50 million. So that's more than $250 million the president owes three different banks. But it could run into the billions. We don't know.

Libowitz said that debt should be taken into account when Trump goes off on the Fed about interest rates. Trump's variable rate loans are tied to Libor and not the Fed funds rate, but when the Fed lowers rates, Libor tends to go down as well.

"He owes a lot of money," said Libowitz. "We don't know exactly how much, but it's a huge amount. And when you own that much, there are questions about how you can be influenced."

How everyone else treats disclosures

While the President and vice president submit disclosure forms, they aren't subject to ethics requirements governing other federal appointees and employees. And two of the wealthiest members of Trump's Cabinet have had their disclosure forms rejected by OGE this year.

Mnuchin was dinged for not disclosing guidance he got from Treasury that he could sell his stake in a film production company to his now-wife.

Commerce Secretary Wilbur Ross had his forms rejected in February because he did not sell stock as he claimed. These errors could technically be referred to the Justice Department for prosecution, but nobody expects that to actually happen.

Federal law "prohibits Government employees from participating personally and substantially in official matters where they have a financial interest. In addition to their own interests, those of their spouse, minor child, general partner, and certain other persons and organizations are attributed to them," according to the OGE, which certifies them for other executive branch employees, but not for the President.

Libowitz said Congress should fix that and expand the law to apply to the President and vice president as well -- something Democrats pushed as part of an ethics and election reform proposal earlier this year, but which has not gotten a vote in the Senate. Senate Majority Leader Mitch McConnell made clear it won't while he's around.

Neither will Trump willingly give up his tax returns. And maybe, ultimately, voters in 2020 won't mind. We'll know if voters care about these issues long before we have an accurate picture Trump's wealth.

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