Conflict-of-Interest · 4-Vector Breakdown
Four ways political pressure can flow at the executive-branch level, scored independently from primary public records.
📈 Vector 1 · Personal Holdings disclosed assets
Howard Lutnick has disclosed 117 assets across 3 OGE filings.
Total declared value range: $457.3M – $452.0M.
Filings3
Assets117
Positions held835
Latest filing2025-11-05
💼 Vector 2 · Outside Positions & Income board seats, consulting
Disclosed 20 outside positions on OGE filings — board seats, advisory roles, and consulting agreements.
First 5 positions
Page Nineteen, Inc.
CF ACQUISITION HOLDINGS X, LLC
1100 HIDDEN RIDGE, LLC
KBCR PROPERTIES LLC
CF SAWYER DEPOSITOR, LLC
🏛 Vector 3 · Government Action Conflict department-aligned deals
4 federal equity / loan / grant deals tracked under Department of Commerce.
These are public deals where the government took an equity stake, made a loan, or awarded a grant to a public company.
Cross-referenced with this official's disclosed holdings would surface conflicts.
USAR · USA Rare Earth Inc
Commerce Dept took 8-16% equity stake plus $1.3B loan + $277M grant. Rare-earth domestic supply chain.
MU · Micron Technology +17.0% in 30d
$6.1B grant for NY + Idaho fabs.
TSM · TSMC ADR (US) +8.5% in 30d
$6.6B grant + up to $5B loan for Arizona fabs.
INTC · Intel Corporation -29.4% in 30d
$8.5B in direct grants + $11B in loans for US semiconductor fabs.
⚡ Vector 4 · Reported Transactions 278-T disclosures
30 reported transactions on file across all OGE 278/278-T filings.
| Date | Asset | Type | Range |
|---|---|---|---|
| 2025-10-06 | CF Group Management, Inc. | sale | Over $50,000,000 |
| 2025-10-06 | BGC BGC Group, Inc. Class B | sale | Over $50,000,000 |
| 2025-10-06 | Tangible Benefits, LLC | sale | $250,001 - $500,000 |
| 2025-10-06 | KBCR Management Partners, LLC | sale | $5,000,001 - $25,000,000 |
| 2025-10-06 | LFA, LLC | sale | Over $1,000,000 |
| 2025-10-06 | Cantor Fitzgerald, L.P | sale | Over $50,000,000 |
| 2025-10-06 | BGC Shares in Retirement Accounts | sale | $1,000,001 - $5,000,000 |
| 2025-10-06 | NMRK Shares in Retirement Accounts | sale | $1,000,001 - $5,000,000 |
| 2025-10-06 | BGC Shares in Retirement Accounts | sale | $50,001 - $100,000 |
| 2025-10-06 | NMRK Shares in Retirement Accounts | sale | $50,001 - $100,000 |
Showing top 10 of 30. Full timeline + filing-by-filing breakdown in Pro.
Top Disclosed Holdings · 3 duplicate rows collapsed across filings
Top 12 unique assets across 3 OGE filings. When the same asset appears in multiple years, we show the highest reported value bracket and tag the row with a × filing count. Holdings reported in valuation brackets per OGE convention.
| Asset | Type | Value bracket | Income | Flags |
|---|---|---|---|---|
| BGC · BGC Group Inc. Class B × 3 filings | common stock | $25,000,001 - $50,000,000 | dividends | — |
| BGC GROUP, INC. | restricted stock units | $5,000,001 - $25,000,000 | — | — |
| Newmark Holdings, L.P. | partnership units | $5,000,001 - $25,000,000 | Partnership / Distributions | — |
| NMRK · Newmark Group, Inc. DRS × 2 filings | common stock | $5,000,001 - $25,000,000 | Dividends | — |
| Promissory Note - Lutnick 1999 Descendants' Trust | promissory note | $5,000,001 - $25,000,000 | interest | — |
| Structured Services Investor, LLC | LLC interest | $5,000,001 - $25,000,000 | dividends | — |
| Cantor Fitzgerald, L.P. | partnership | $5,000,001 - $25,000,000 | Partnership / Distributions | — |
| CF Realty Fund III, L.P. | limited partnership | $5,000,001 - $25,000,000 | dividends | — |
| Promissory Note - 122 Sandune Court, LLC | promissory note | $5,000,001 - $25,000,000 | interest | — |
| 770 Ocean Road Properties LP | real estate | $5,000,001 - $25,000,000 | Rent or Royalties | — |
| RUM · Rumble Inc. | common stock | $1,000,001 - $5,000,000 | — | — |
| Newmark Group, Inc. | cash receivable | $1,000,001 - $5,000,000 | — | — |
Top Reported Liabilities
| Description | Value bracket |
|---|---|
| Cut 7 Carry, L.P. Capital Commitment $5,000,001 - $25,000,000 2024 N/A On Demand | $5,000,001 - $25,000,000 |
| Bank of America, N.A Secured Facility Over $50,000,000 2019 SOFR + 1.65% June 20 | Over $50,000,000 |
Forensic Timeline
View Howard Lutnick's year-by-year financial timeline →
3 filings · all line items grouped by year, with sector flags and federal-action overlays.
Donor Plane · Personal political contributions
Search the FEC individual-contributions index for political donations made by Howard Lutnick (or their employer firm). 218M-row dataset, 1.14M aggregated donor profiles.
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Sources: U.S. Office of Government Ethics (OGE) Form 278 / 278-T disclosures · government_equity_stakes derived from press releases and SEC 8-K filings. Every figure above traces to a primary federal record.
· Latest filing: https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/66A69EB879848CF885258CC9002C8582/$FILE/Howard-Lutnick-06.17.2025-278T.pdf
Composite conflict score · scandal-vector flags · government-action timeline · per-asset matched conflicts · all coming online for Pro members.