Roger is a SES Officer for the Department of the Army. On 4 January, his financial adviser sold $1,001 worth of his BigCo stock and purchased $1,001 worth of SmallCo stock based on some insight he had on the market. Roger does not work on any official matters involving BigCo or SmallCo. In fact, these companies do not work with the Army. He did not instruct the financial adviser to make these stock trades, but once he found out about them, he is not sure if he needs to report them