Federal Policy - Disclosure
n“Financial Interest” related to a sponsored project
nWill manufacture or commercialize a product that will predictably result from the project
nResults would be relevant to the development, manufacture, or improvement of a product
nIncome from consulting > $10,000
nResult in subcontract, lease of property or procurement
nReferral of participants or collaborations
n
n
n
Instances relate to the organization with whom the key personnel have a financial interest

Financial Interest + relationship = disclosure

Financial interests that are not related to the sponsored project do not need to be disclosed as part of the proposal/grant process

*** This where differences occur between the federal regulations and USC policy

USC policy applies regardless of funding or “related financial interests” and reporting/disclosure requirements are different.