Since their wedding in 2009, Jared Kushner and Ivanka Trump have amassed a formidable collection of contemporary art. The walls of the couple’s $4 million Park Avenue condo are filled with works by both blue-chip and emerging artists, including Alex Israel, Dan Colen, Nate Lowman, Alex Da Corte, and David Ostrowski. Ivanka Trump has regularly showcased the collection on Instagram, posing in front of the artwork in posts tied to her business.

Yet in required financial disclosures, Kushner, a senior advisor and son-in-law to President Trump, failed to report the couple’s art collection. (Trump, who also holds an unpaid title in her father’s administration, is considered covered by Kushner’s disclosures because they are married.)

The omission stands in contrast to disclosures from other senior members of the Trump administration. In recent months, Trump’s top cabinet picks have revealed considerable art holdings as part of required financial disclosures. Commerce Secretary Wilbur Ross disclosed an art collection worth at least $50 million. Treasury Secretary Steven Mnuchin revealed his stake in a $14.7 million Willem de Kooning painting, plus other artworks.

Responding to an inquiry about the collection’s exclusion from Kushner’s financial disclosures, a lawyer advising Kushner told artnet News that the art holdings would be added to a new version of his disclosure form. “Mr. Kushner and Ms. Trump display their art for decorative purposes and have made only a single sale,” said the lawyer in a statement issued by the White House. “To avoid any doubt, however, they will report their art collection.”

A David Ostrowski painting in Ivanka Trump’s apartment is featured in an Instagram post watermarked with Trump’s brand logo. Screenshot via Instagram.

This is not the first time Kushner has failed to disclose assets or business interests. Earlier this month, the Wall Street Journal reported that Kushner did not report his stake in Cadre, a real estate finance startup co-founded with his brother Joshua. The real estate scion-turned-White House advisor also failed to report loans totaling at least $1 billion from more than 20 lenders to properties and companies he co-owns.

Ethics experts say that it’s not uncommon for administration officials to update financial disclosures with more information. The White House did not indicate when the new disclosure would be released.

Inside the Collection

Kushner and Trump’s collection is estimated to be worth millions. Ivanka Trump’s Instagram feed regularly highlights individual works estimated to be worth more than half a million dollars. In one post, two art-market favorites are featured on the same wall, with Trump posing in the foreground: On the left is a black and white Nate Lowman painting that resembles a bullet hole sticker. (A similar work by Lowman, Black Escalade, was auctioned by Sotheby’s in New York for $665,000 in 2013, according to Bloomberg.) On the right is a work by Dan Colen composed of brightly colored wads of chewed bubble gum. (Phillips New York auction house sold a similar work by Colen for $578,500 in 2012.)

Ivanka Trump in her apartment posing in front of works by Nate Lowman (left) and Dan Colen (right). Screenshot via Instagram.

When it comes to art, the disclosure rules for federal employees are complicated, hinging on the distinction between works purchased for investment or for personal enjoyment. Federal employees such as Kushner are required to disclose artwork if it is held for investment purposes and is worth more than $1,000, according to the Office of Government Ethics (OGE).

The ethics office’s website says that artwork displayed for “decorative or artistic purposes” are “not normally” considered an investment. According to the OGE, “periodic sales from a collection of artwork” are the most relevant indicator of whether a collection is held for investment purposes.

Robert Walker, a Washington ethics lawyer, told artnet News that selling one work would not require Kushner and Trump to disclose the holdings. “One can conclude that there is an investment purpose if there is regular activity of selling or buying pieces of artwork,” he says. “A single sale does not necessarily mean that Kushner will need to disclose his art assets.”

Although the couple does not have a public history of selling art, Kushner and Trump are no strangers to the art market. Much of the couple’s collection was reportedly amassed with the help of art advisor Alex Marshall, a prominent presence on the auction circuit. (Marshall did not respond to requests for comment for this story.) Kushner and Trump have also hosted dinners for Sotheby’s at Kushner Properties and attended sales at Christie’s and other houses, according to ARTnews.

The couple’s collection has also played a prominent role in shaping Ivanka Trump’s personal brand. Over the last few years, Trump has cultivated an image as something of a connoisseur, giving interviews to international media about her favorite artists and sharing advice for beginner art collectors on her blog. In October 2015, Trump’s website published “How to Start Collecting Art,” a post by Elena Soboleva of Artsy advising first-time collectors to “invest early in young, on-the-rise artists whose work you love and can afford,” and to “think of art as an investment.”

A Christopher Wool painting in Ivanka Trump’s apartment behind an Ivanka Trump brand Mara Bag. Screenshot via Instagram.

Trump has also burnished this image on social media. On her Instagram feed, photos featuring the collection have been watermarked with Trump’s brand logo. In a post that has since been deleted, a Christopher Wool painting is the prominent backdrop for a shot of an Ivanka Trump brand Mara Bag.

The mix of choreographed “personal” moments with merchandise and art is no accident, according to the former art director for Ivanka Trump’s brand, Katie Evans. On her own website, Evans wrote that product shots in Trump’s apartment were part of a strategy to “weave in our contents and products in an authentic way while still incorporating [Trump] as a person.” Evans removed the text hours after an inquiry from artnet News and did not respond to other requests for comment.

Craig Holman, an ethics expert with the watchdog group Public Citizen, says that using the art collection for that kind of brand marketing suggests a clear business objective. “The art is being used to promote the business interests. It may draw people into it, especially for something like a line of clothing, and cultural business activities that Ivanka Trump stands for,” Holman told artnet News. “It should be fully disclosed.”

A personal spokesperson for Ivanka Trump did not respond to requests for comment.

Additional reporting by Isabel Slone.