Rules for Thee: Stephen Miller’s Paperwork Problem
By Zach Everson
In the past seven weeks, Donald Trump’s Justice Department has charged dozens of immigrants, nearly all of them green-card holders, with making false statements on voter-registration forms or citizenship applications. And on Oct. 12, federal agents searched a sitting U.S. representative’s Washington home as part of what the Justice Department called “an ongoing federal criminal investigation”—one that, according to the Wall Street Journal, involves whether the lawmaker’s age was misstated on immigration paperwork 26 years ago.
Yet White House Deputy Chief of Staff Stephen Miller—who wrote in 2023 that the “denaturalization project” begun under Trump, which can strip Americans of citizenship over misstatements on their immigration paperwork, would be “turbocharged” in 2025—ironically appears to have filed inaccurate disclosures of his own.
A Public Citizen analysis compared the certificates of divestiture the U.S. Office of Government Ethics (OGE) issued to Miller’s family with three of his filings, all of which were certified by a White House ethics official:
- his initial financial disclosure, filed in March 2025, which lists the family’s holdings
- his report of the stock sales the family made on Aug. 14, 2025, two days after the certificates were issued
- his annual financial disclosure for all of 2025, which was filed in June 2026
The analysis found several inconsistencies:
Reported sale values don’t match the certified share counts
In at least 10 of the 27 sales on Miller’s Aug. 29, 2025, transaction report, the reported proceeds are too low to match the shares listed on the certificates of divestiture at any price those stocks traded on Aug. 14, the day of the sales (see the appendix for a comparison of all 27 trades). The largest gap is MP Materials: 3,000 shares were worth at least $223,000 that day but were reported as just the $50,000 to $100,000 range. (The Pentagon became the company’s largest shareholder five weeks before the sale.)
None of these stocks appears on Miller’s annual financial disclosure for 2025 that covers through the years end, so the family did not keep any of the shares. No other transaction reports from Miller are available in OGE’s online collection of disclosures, and an OGE staff member told Public Citizen that everything the agency has received for Miller is online. The White House’s own disclosures web page also lists just one transaction report for Miller, identical to the one OGE provided. Officials must report sales of individual stocks by their spouses and dependent children within 45 days.
Figure 1: How Miller’s Numbers Don’t Add Up
| MP Materials, line 9 of Miller’s transaction report | |
|---|---|
| Shares Miller was certified to sell | 3,000 |
| Lowest trading price on the day of the sale (Aug. 14, 2025) | $74.35 |
| Minimum value of the sale (3,000 × $74.35) | $223,050 |
| Value Miller reported | $50,000 to $100,000 |
Note: Reported value ranges are rounded; on the disclosure forms, each range begins $1 higher (e.g., $50,001 to $100,000).
Where did the kids’ money go?
The shares OGE certified for sale from the three children’s custodial accounts were worth roughly $443,000 to $507,000 per child on Aug. 14, 2025—about $1.4 million in all. The children’s accounts also held $165,000 to $400,000 in other investments on Miller’s March 2025 disclosure, including two investment funds and Spotify shares. By the end of 2025, according to Miller’s annual report, each account held just $1,000 to $15,000 in cash, plus, in one account, Spotify shares it already owned. None of the other investments appear, and the report does not explain where the money went.
Figure 2: Where Did the Children’s Money Go?
| Account | Stocks sold Aug. 14, 2025 (278-T lines) | Value of shares sold* | Holdings at end of 2025 (annual report) |
|---|---|---|---|
| Child 1 | GE HealthCare, GE Vernova, GE Aerospace (lines 13–15) | $449,000 to $459,000 | Cash, $1,000 to $15,000 |
| Child 2 | Amazon, Blackstone, Costco, Microsoft (lines 16–19) | $443,000 to $451,000 | Cash, $1,000 to $15,000 |
| Child 3 | AllianceBernstein, Amazon, Arm, Cameco, Microsoft, Palantir, Palo Alto Networks, Charles Schwab (lines 20–27) | $494,000 to $507,000 | Cash, $1,000 to $15,000; Spotify, $15,000 to $50,000 (held before the sales) |
| Total | $1,385,000 to $1,417,000 |
* Shares listed on each child’s certificate of divestiture, valued at the low and high trading prices on Aug. 14, 2025. Children are numbered in the order of their certificates. Year-end holdings are matched to each account using the holdings listed on Miller’s March 2025 new-entrant report, which labels the accounts “Child Brokerage 1” through “Child Brokerage 3” in a different order.
The children’s accounts also held $165,000 to $400,000 in other investments on the March 2025 report (Child 1: an emerging-markets fund and Spotify shares; Child 3: a bank-stock fund) that do not appear on the annual report. Figures may not sum due to rounding.
Holdings that disappeared with no reported sale
On Miller’s March 2025 disclosure, Katie Miller’s IRA held shares of Arm Holdings, Spotify, Alphabet, Viking Therapeutics, MP Materials, Apple and Amazon, reported at a combined $21,000 to $140,000, as well as $1,000 to $15,000 in cash. On Miller’s annual report for 2025, the IRA is still listed, but it holds just $2,000 to $30,000 in Spotify shares and $1,000 to $15,000 in cash. Miller’s only transaction report for the year lists no sales of Alphabet, Viking Therapeutics or Apple at all, and its sales of Arm, Amazon and MP Materials match the shares on the certificates of divestiture, which do not include the IRA. Public Citizen found no transaction report showing any additional sales.
Figure 3: Katie Miller’s IRA, Before and After
Conclusion
White House Deputy Counsel Scott Gast certified Miller’s 2025 annual report on Sept. 3, 2026, despite its inconsistencies with Miller’s earlier filings.15 Asked about the discrepancies, and whether Miller had filed any transaction reports with the White House that weren’t forwarded to OGE, White House spokeswoman Lauren Bis said in a statement: “The White House regularly works with appointees to provide ethics guidance and help ensure compliance with applicable federal ethics laws and regulations. Stephen Miller complies with all ethics requirements.” Bis did not address any of the specific inconsistencies or say whether any other reports exist.
It is unclear whether the discrepancies in Miller’s paperwork are due to sloppiness, bureaucratic error or another explanation.
What is clear is that the Trump administration has used alleged errors or inconsistencies in official paperwork to justify criminal investigations and prosecutions against perceived political enemies, immigrants, and others.
Under the Ethics in Government Act, the Justice Department can sue anyone who knowingly and willfully falsifies or fails to report required information on a financial disclosure, seeking a civil penalty of up to $75,540. Knowingly and willfully falsifying the form is also a crime. It’s punishable by up to five years in prison under the federal false-statements statute (coincidentally, the same maximum many of the immigrants charged in recent weeks face). OGE’s director and agency heads must refer an official to the attorney general when they have “reasonable cause to believe” the official willfully falsified a report, and the president can discipline officials who fail to report required information.
Nobody is asking for federal agents to search Miller’s home. But Public Citizen’s is asking OGE to review Miller’s filings, require him to explain the discrepancies, and make sure his financial holdings are dutifully reported.
Appendix: Miller’s Reported Sale Values vs. Certified Share Counts
Value of each Aug. 14, 2025, sale at that day’s low and high trading prices, compared with the range Miller reported on his Aug. 29, 2025, periodic transaction report.
| Line in 278-T | Stock | Owner (as matched)* | Shares certified for sale | Price range, Aug. 14, 2025 | Value of shares sold | Range reported on 278-T | Does it match? |
|---|---|---|---|---|---|---|---|
| 1 | AllianceBernstein (AB) | Stephen Miller | 1,000 | $40.965 to $41.60 | $40,965 to $41,600 | $1,000 to $15,000 | No; too low |
| 2 | Amazon (AMZN) | Stephen Miller | 500 | $227.02 to $233.11 | $113,510 to $116,555 | $1,000 to $15,000 | No; too low |
| 3 | Arm Holdings (ARM) | Stephen Miller | 500 | $138.27 to $140.68 | $69,135 to $70,340 | $1,000 to $15,000 | Too low; would match if swapped with line 10 |
| 4 | CrowdStrike (CRWD) | Stephen Miller | 400 | $419.81 to $435.00† | $167,924 to $174,000 | $100,000 to $250,000 | Yes |
| 5 | Intel (INTC) | Stephen Miller | 5,000 | $21.90 to $24.20 | $109,500 to $121,000 | $100,000 to $250,000 | Yes |
| 6 | IonQ (IONQ) | Stephen Miller | 2,000 | $39.28 to $41.12 | $78,560 to $82,240 | $15,000 to $50,000 | No; too low |
| 7 | Micron (MU) | Stephen Miller | 1,000 | $121.40 to $125.74 | $121,400 to $125,740 | $50,000 to $100,000 | No; too low |
| 8 | Super Micro (SMCI) | Stephen Miller | 2,000 | $44.67 to $45.6682 | $89,340 to $91,336 | $50,000 to $100,000 | Yes |
| 9 | MP Materials (MP) | Stephen Miller | 3,000 | $74.35 to $78.159 | $223,050 to $234,477 | $50,000 to $100,000 | No; too low |
| 10 | Arm Holdings (ARM) | Katie Miller | 55 | $138.27 to $140.68 | $7,605 to $7,737 | $50,000 to $100,000 | Too high; would match if swapped with line 3 |
| 11 | Intel (INTC) | Katie Miller | 1,000 | $21.90 to $24.20 | $21,900 to $24,200 | $15,000 to $50,000 | Yes |
| 12 | National Beverage (FIZZ) | Katie Miller | 100 | $44.98 to $46.37 | $4,498 to $4,637 | $1,000 to $15,000 | Yes |
| 13 | GE HealthCare (GEHC) | Child 1 | 333 | $73.25 to $75.12 | $24,392 to $25,015 | $15,000 to $50,000 | Yes |
| 14 | GE Vernova (GEV) | Child 1 | 250 | $620.28 to $640.2799 | $155,070 to $160,070 | $50,000 to $100,000 | No; too low |
| 15 | GE Aerospace (GE) | Child 1 | 1,000 | $269.48 to $274.16 | $269,480 to $274,160 | $100,000 to $250,000 | No; too low |
| 16 | Amazon (AMZN) | Child 2 | 500 | $227.02 to $233.11 | $113,510 to $116,555 | $100,000 to $250,000 | Yes |
| 17 | Blackstone (BX) | Child 2 | 550.164 | $172.49 to $176.045 | $94,898 to $96,854 | $50,000 to $100,000 | Yes |
| 18 | Costco (COST) | Child 2 | 104.024 | $975.18 to $988.2925 | $101,442 to $102,806 | $50,000 to $100,000 | No; too low |
| 19 | Microsoft (MSFT) | Child 2 | 255.602 | $520.14 to $525.9499 | $132,949 to $134,434 | $15,000 to $50,000 | No; too low |
| 20 | AllianceBernstein (AB) | Child 3 | 835 | $40.965 to $41.60 | $34,206 to $34,736 | $15,000 to $50,000 | Yes |
| 21 | Amazon (AMZN) | Child 3 | 165 | $227.02 to $233.11 | $37,458 to $38,463 | $100,000 to $250,000 | Too high; would match if swapped with line 2‡ |
| 22 | Arm Holdings (ARM) | Child 3 | 225 | $138.27 to $140.68 | $31,111 to $31,653 | $15,000 to $50,000 | Yes |
| 23 | Cameco (CCJ) | Child 3 | 710 | $75.18 to $77.145 | $53,378 to $54,773 | $15,000 to $50,000 | No; too low |
| 24 | Microsoft (MSFT) | Child 3 | 70 | $520.14 to $525.9499 | $36,410 to $36,816 | $15,000 to $50,000 | Yes |
| 25 | Palantir (PLTR) | Child 3 | 1,200 | $179.20 to $185.33 | $215,040 to $222,396 | $100,000 to $250,000 | Yes |
| 26 | Palo Alto Networks (PANW) | Child 3 | 220 | $173.455 to $177.85 | $38,160 to $39,127 | $15,000 to $50,000 | Yes |
| 27 | Charles Schwab (SCHW) | Child 3 | 500 | $95.60 to $98.21 | $47,800 to $49,105 | $15,000 to $50,000 | Yes |
* The 278-T does not identify which family member’s account each sale came from. Public Citizen matched sales to owners using the certificates of divestiture, which list the shares each family member had to sell. The 278-T appears to list the sales in the same order as the certificates, and children are numbered in the order of their certificates. Five stocks were sold by more than one family member. Under any assignment of those sales among family members, at least 10 of the 27 reported values cannot match the certified share counts. If both documents followed the same order, 13 of the 27 reported values do not match.
† CrowdStrike split its stock 4-for-1 in July 2026. Historical prices published after the split are adjusted for it, so the published Aug. 14, 2025, low and high ($104.9525 and $108.75) have been multiplied by four to reflect the prices at which the shares actually traded that day.
‡ Swapping lines 2 and 21 would resolve line 21, but line 2’s reported range ($1,000 to $15,000) would still be too low for the shares in either sale.