President Trump’s financial disclosure, released on Wednesday, revealed for the first time that he repaid a debt of more than $100,000 to his personal attorney, Michael D. Cohen, in 2017, raising questions about whether his sworn filing from a year ago improperly omitted the transaction.
The disclosure, released by the Office of Government Ethics, did not specify the purpose of the payment. However, Mr. Cohen has paid $130,000 to an adult film actress, Stephanie Clifford, who has said she had an affair with Mr. Trump. Mr. Cohen has said he made the payment shortly before the 2016 election as hush money for Ms. Clifford, who goes by the stage name Stormy Daniels.
Mr. Trump repaid Mr. Cohen between $100,001 and $250,000 in 2017, according to a footnote in the filing, but he did not include that information on last year’s financial disclosure form. The Office of Government Ethics, in a letter to the Justice Department on Wednesday, said that the payment “is required to be reported as a liability.”
Mr. Trump’s formal acknowledgment of the repaid debt to Mr. Cohen draws new attention to whether the president erred in not reporting it on last year’s disclosure form. The document released Wednesday said that Mr. Trump was reporting the repaid debt “in the interest of transparency” but his lawyers declared in the footnote that it was “not required to be disclosed as reportable liabilities.”
The Office of Government Ethics disagreed. A letter accompanying the report sent to Rod J. Rosenstein, the deputy attorney general, from David J. Apol, acting director of the Office of Government Ethics, said the office had determined “the payment made by Mr. Cohen is required to be reported as a liability.”
Mr. Apol also sent a copy of Mr. Trump’s previous financial form to Mr. Rosenstein, noting in his letter that “you may find the disclosure relevant to any inquiry you may be pursuing regarding the President’s prior report that was signed on June 14, 2017.”
Critics of Mr. Trump seized on the repaid debt as proof that the president should have included it in last year’s statement, which was filed voluntarily in June and signed by Mr. Trump under a line saying: “I certify that the statements I have made in this report are true, complete and correct to the best of my knowledge.”
Noah Bookbinder, executive director of Citizens for Responsibility and Ethics in Washington, said in a statement that the inclusion of the payment on this year’s form “raises serious questions as to why it was not disclosed in last year’s filing.” The group, known as CREW, had filed a complaint with the Justice Department and the ethics office asking for an investigation into whether the payment constituted a loan.
Under federal law, an official who “knowingly and willfully falsifies information” on a financial disclosure could face criminal charges.
Marilyn L. Glynn, who served as the general counsel at the Office of Government Ethics from 1997 to 2008, said the letter to the Department of Justice is significant and unusual and that if Mr. Trump intentionally filed an inaccurate disclosure last year, he may have violated the law.
But she added that the matter is now unclear — as the referral from the ethics office does not explicitly state that the agency itself has concluded there was a violation and it is hard to know exactly when Mr. Trump learned about the debt.
“What did he know and when did he know it,” she said. “At time he filed it last year, he may not have known this payment was made or that a payment was made at all.”
Mr. Trump’s disclosure of the repaid debt to Mr. Cohen did little to clear up confusion about the total size of the reimbursements. Rudolph W. Giuliani, Mr. Trump’s attorney, said earlier this month that Mr. Cohen was paid $460,000 or $470,000 from Mr. Trump, which also included money for “incidental expenses” that he had incurred on Mr. Trump’s behalf.
Mr. Giuliani said Mr. Trump started paying Mr. Cohen back through a series of monthly installments of roughly $35,000 and that those payments began last year and may have carried into this year. The filing released on Wednesday capped the amount Mr. Trump paid back to Mr. Cohen in 2017 at $250,000, leaving more than $200,000 of the amount Mr. Giuliani mentioned unaccounted for.
The disclosure did not preclude the possibility that federal investigators could determine the payment to Ms. Clifford violated campaign finance laws. If they conclude it was made with the intention of influencing the presidential campaign — making it an effective political contribution — it would violate election law, which caps individual donations to federal candidates at $5,400 per election cycle.
Candidates are allowed to spend as much as they want on their own campaigns. And, according to the filing, Mr. Trump paid Mr. Cohen back, making Mr. Cohen’s initial payment a loan. But campaign finance law treats personal loans as contributions and the $5,400 limit would have applied. Public campaign filings are also supposed to account for all loans, contributions and payments; Mr. Trump’s made no mention of the Cohen arrangement.
Mr. Giuliani has argued that Mr. Cohen made the payment to Ms. Clifford on Mr. Trump’s behalf for personal reasons not related to the campaign and should not, therefore, be counted as campaign expense subject to election law restrictions. This new disclosure could help bolster that argument by Mr. Trump.
Beyond the repaid debt to Mr. Cohen, the 92-page form provides the most detailed window into how Mr. Trump’s finances have fared during his presidency.
The document, which covers calendar year 2017, showed total income from Mr. Trump’s business operations and investments of at least $453 million and assets valued at a minimum of $1.4 billion. The prior year’s disclosure showed total income of at least $597 million and a similar level of assets, but that report spanned nearly a 16-month period so is not directly comparable.
It provides the first extended look at the performance of Mr. Trump’s Washington hotel, which opened in September 2016 and has become a magnet for lobbyists and Republican aides. The hotel is one of his best performing properties, and the disclosure listed revenues of $40.4 million.
Mr. Trump’s Mar-a-Lago resort in Florida, which the president frequents in the winter months, saw revenues of $25.1 million. Last year’s filing listed revenues over a 16 month period at Mar-a-Lago of $37.3 million.
Other properties have not fared as well, including Trump National Doral, a golf resort near Miami, which is Mr. Trump’s biggest cash flow generator. It reported revenue of $74.8 million. Revenue there had tumbled in the filing a year ago, even after a major renovation.
Mr. Trump earned at least $1.1 million from his operations in India, the most active location overseas for the Trump Organization, with at least four active real estate projects, in Mumbai, Pune, Kolkata and Gurgaon, which is outside of New Delhi.
At least an additional $1.1 million came from operations in the Philippines and Istanbul and at least $558,000 from Panama, where the Trump family had a branded condo and hotel complex, which was renamed earlier this year after a dispute with condo owners.
The form also shows that Melania Trump earned between $100,001 and $1,000,000 from Getty Images, the photo licensing company.
Individual performance aside, there are broader signs that the business is retreating somewhat during the first part of Mr. Trump’s presidency.
Since he took office, Mr. Trump’s name has been erased from three of his family company’s prized properties. His company has watched its pipeline of deals ebb and flow. And one new line of business it has pursued is limited to quietly managing other companies’ hotels that are unattached to its once-flashy brand.
The owners of struggling hotels in Toronto and New York have paid the Trumps millions of dollars to remove their name from the properties after the election. In Panama, a nasty feud engulfed the Trump hotel there when the majority owner wanted the Trumps out — leading to the Trump name being pried off with a crowbar.
The president’s company has also been stymied by some of the new ethics restrictions it voluntarily adopted after the election.
As part of a voluntary ethics plan, the Trump Organization has not pursued new deals in foreign countries, cutting off an important stream of business that was projected to provide much of its future revenue. The Trump Organization is also subjecting all new domestic projects to vetting from an outside ethics adviser, which appears to have had a chilling effect on certain potential deals: the company has yet to open a new hotel in the United States since Mr. Trump took office.
The Trumps also had a wave of cancellations at the Mar-a-Lago club amid a backlash over the president’s comments about the violence in Charlottesville, Va. last summer.
Faced with these challenges, the company has decided to focus primarily on its existing properties, which consist of 16 golf courses, a winery, seven stand-alone hotels, Mar-a-Lago and a portfolio of commercial and residential real estate properties. While the Trump Organization owns many of those properties, it shifted in recent years to branding and managing properties, rather than owning them outright.
In at least one case, the Trumps began quietly managing a hotel propertyin Livingston, New Jersey, which is owned by the family of Jared Kushner, Mr. Trump’s son-in-law and adviser. Mr. Trump reported $20,000 in fees on that deal.
And despite rolling out two new and more affordable hotel lines —- Scion, a four-star-chain, and American Idea, a budget-friendly brand — the Trump Organization has only announced one such endeavor, a deal in the Mississippi Delta
The filing showed that Mr. Trump has received $26,667 in management fees related to the project.
The head of the company’s hotel division, Eric Danziger, said in March that the pipeline of current deals is “still very active,” and that he is continuing to line up new Scion and American Idea hotels.