Additional reporting by Tierney Sneed.

Why is Jared Kushner having so much trouble with his disclosure forms? Read a reporter’s notebook post (Prime access) »

Jared Kushner quietly filed an addendum to his personal financial disclosure adding even more previously undisclosed business interests in recent weeks — and may have even more to disclose, according to real estate documents shared with TPM.

Kushner, President Trump’s son-in-law and a top adviser, wrote a letter to White House Deputy Counsel Stefan Passantino dated Jan. 3, 2018 adding a number of additional business interests that had not previously been on his personal financial disclosure form.

That letter, which has not been previously reported, corrects and adds new corporate positions and details of his companies’ structures that he legally was required to disclose, in a seeming attempt to square his filing with spouse Ivanka Trump’s as well as clean up some previously overlooked items.

“Following the certification of my spouse’s financial disclosure report by the Office of Government Ethics on December 26, 2017, I am writing to provide conforming information and other updates to the financial disclosure report that I signed on March 9, 2017,” Kushner wrote in the letter:

The White House passed along the letter to the Office of Government Ethics, which signed off on it on Jan. 8 with a note that Kushner remains “in compliance with applicable laws and regulations.”

This is Kushner’s latest attempt to fully lay out all of his sprawling real estate and other holdings in the legally required filings to the Office of Government Ethics, after previous efforts fell far short. Kushner added 77 additional assets and more than $10 million in previously undisclosed holdings last July, months after his initial filing, saying they were “inadvertently omitted.”

Top ethics experts say that while corrections and amendments happen from time to time, the number and scope of amendments Kushner has filed are highly unusual.

“This is really out of the ordinary,” said Don Fox, a former acting director and general counsel of the Office of Government Ethics who served during the administrations of both President Obama and President George W. Bush. “It’s really uncommon you’d still be trying to get the form correct at this stage in the game and there’d have been as many amendments over such a protracted period of time that we have.”

The latest amendments to Kushner’s personal financial disclosure filings come amidst increasing scrutiny of his assets, which have drawn interest for months given the potential conflicts of interest posed by the extensive business interests of Kushner and his family, including some troubled projects that reportedly have squeezed them financially and forced them to borrow heavily.

The Internal Revenue Service and Justice Department have issued subpoenas to lenders and investors in real estate projects managed by Kushner’s family, Bloomberg reported Thursday, seeking information from people who lent money for Kushner Cos. projects in New York and New Jersey. According to Bloomberg, that likely stems from a separate investigation than the ongoing FBI probe into possible ties between Russia and Trump’s team.

According to a separate recent update from Ivanka Trump, Kushner appears to have taken out millions more in loans in recent months, a sign that his business may be on the rocks. The couple are currently battling a lawsuit filed in December that accuses them of illegally omitting information for 32 other companies, raising the possibility of hidden conflicts of interest.

Kushner’s letter added that he made between $5,000 and $15,000 from Calamos Convertible Opportunities and Income Fund and that he was a director for RealCadre Company, Inc., which during the covered disclosure period became another entity he’d already disclosed, as well as his position on the board of his family’s charitable trust. He also adds more than a half-dozen previously undisclosed LLCs that were part of the corporate structure of assets he’d previously reported, changed the description of a few assets Ivanka owns, and added more LLCs related to her ownership stake in Trump Old Post Office, LLC.

Even with Kushner’s latest updates, however, it appears as though his financial disclosure forms still may not fully be up to snuff under ethics law.

The liberal group American Bridge combed through public records to identify Kushner holdings that he failed to report on his form, unearthing a handful more corporations that from publicly available information appear as though they should be disclosed. The documents were pulled as part of a new effort from American Bridge to lay out all public records related to Kushner’s complex financial holdings.

TPM provided Kushner’s legal team with an array of publicly available corporate documents obtained by American Bridge showing Kushner’s undisclosed business interests and corporate positions. Kushner’s lawyers declined to comment on the record on the specific examples provided. A spokesperson for Kushner told TPM that he “has provided complete information on his disclosure forms” but left open the possibility of further updates being filed.

Some of the examples American Bridge found appear to be clear-cut violations, while with others it’s impossible to know from publicly available information whether or not Kushner had a financial stake that he would have had to report them.

For example, Kushner has not disclosed his involvement with Park Valley Owner, LLC. Kushner signed a limited warranty deed in December 2015 as manager for Park Valley Owner, LLC. Ethics law requires all executive branch employees to include in their personal financial disclosure forms all “positions outside the U.S. government” they held for the two calendar years prior to their federal employment. The omission appears to violate that rule. Kushner may not be required to disclose this specific property if he signed the deed as a representative of previously disclosed company that controlled Park Valley Owner LLC. But even in that case, Fox says, Kushner would likely have to disclose Park Valley Owner LLC because of underlying assets.

“The property is an apartment complex just outside Cincinnati. I assume it has considerable value. Jared is listed as manager in December 2015. The reporting period for positions outside the government is two previous years,” Fox said. “I think it’s certainly reportable.”

Another potential violation: Landings Building, LLC, which was controlled by The Landings, Inc., where Kushner served as vice president, was not disclosed. Leaving off this sub-LLC would only be allowable if Kushner had no stake in the underlying assets. But Kushner’s latest addendum adds four other similarly named Landings LLCs under The Landings, Inc. that hadn’t been previously disclosed under the same umbrella organization, and it’s unclear why Landings Building 136A LLC wouldn’t meet the same requirements.

Other Kushner-connected LLCs that aren’t on his personal financial disclosure include Bauer Realty Corporation and Bauer Drive Associates. Bauer Realty Corporation is the managing member of Bauer Drive Associates, according to public filings. Bauer Drive Associates owns a $3 million property at 128 Bauer Drive in northern New Jersey, according to public records covering the past three years. Kushner disclosed his stake in the property and his position with 128 Bauer Drive Associates but not in these controlling LLCs.

Kushner was also an authorized signatory for Landings NYT MT LLC, Walkill NYT LLC, Oakwood NYT LLC and Elmwood NYT LLC, four LLCs that were involved in his purchase of the 229 West 43rd Street building in New York City in November 2015. The four weren’t dissolved until November 2016, according to public records — well within the required disclosure period.

A Kushner spokesperson argued that the updates in the letter were part of the normal personal financial disclosure process. Kushner’s representatives refused to discuss on the record whether he should have disclosed the business interests and corporate positions that American Bridge found through its public filings search or explain what spurred his latest update.

“Under the direction of financial advisors and experienced ethics attorneys, Mr. Kushner has provided complete information on his disclosure forms, often more than others in prior administrations ever did, and in compliance with the rules and requirements,” a Kushner spokesman told TPM. “As with anyone in government who has numerous financial holdings, he will update and supplement his disclosures whenever appropriate and will continue his transparent and thorough process.”

But that doesn’t line up with what ethics experts who’ve reviewed personal financial disclosures for earlier administrations say.

“It’s just sloppy, and he doesn’t take a great deal of interest at all in getting this public financial disclosure form correct,” said Fox. “If he did he would have accomplished it by now.”