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The annually filed documents, which reveal the financial interests of federal workers, provide a rare window into the finances of Trump, who otherwise has notoriously eschewed traditions of transparency established by his recent predecessors in the White House.
This year's financial disclosure filing by Trump — which is not yet publicly available — could be especially significant.
That reimbursement was for a hush-money payment that Cohen made to porn star Stormy Daniels in late 2016 in exchange for her silence about an alleged affair with Trump. The White House has denied any such affair.
"Funneled through a law firm, and the president repaid it," said Giuliani, the former New York mayor, during a Fox News interview on May 2.
And in his first financial disclosure form as president — which was filed last June — Trump did not appear to include any mention of his reimbursement payments to Cohen in 98 pages.
Giuliani told The New York Times that the payments to Cohen were meted out in $35,000 increments over several months, totaling up to $470,000.
The excess above $130,000 was for things that included "incidental expenses," as well as "a little profit and a little margin for paying taxes," Giuliani said.
On May 4, Democratic Rep. Elijah Cummings said Trump may have broken the law by not disclosing his debt to Cohen in his financial disclosure report last year.
Cummings noted that under federal law "it is a crime to knowingly and willfully make a false and fraudulent representation to a federal office or entity."
Walter Shaub, former director of the U.S. Office of Government Ethics, has strongly argued that Trump must disclose any payments over $10,000 on the government form.
"There are no loopholes," Shaub said in a tweet Tuesday.
In an op-ed published Monday in USA Today, Shaub said Trump has an obligation to disclose any liabilities that top $10,000 at any time during calendar year 2017 "even if he repaid them later that year."
"That includes his debt to Michael Cohen," Shaub wrote.
"The question is whether Trump will disclose that debt, as well as any others he might have omitted," Shaub wrote. "The answer should be easy, but the president is in a difficult position. He left out the Daniels-related debt in the financial disclosure report he filed on June 14, 2017. "
"Disclosing it now means acknowledging that he should have disclosed it last year. Disclosure may also lead to damaging revelations if he omitted other liabilities from any past financial disclosure reports or incurred new ones since June. As a result, the president's team could be looking for a way to justify the omission."
The White House did not respond when CNBC asked if Trump planned to file his disclosure form on Tuesday. Trump could obtain a 30-day extension if he is not ready to file Tuesday.
With the exception of President Gerald Ford in 1976, Trump is the only major party nominee for president in at least four decades not to release his tax returns during a campaign, according to Tax Analysts' Tax History Project. As president, Trump likewise has not released his returns.
Despite that, the financial disclosure report that Trump is obligated to file each year does shed light on his assets and liabilities.
In last year's filing, Trump reported income of at least $594.57 million, which includes income from asset sales.
But he also reported another $315 million, at least, in liabilities. Trump owed Deutsche Bank a whopping $130 million of that.
Among the report's highlights were $7 million in book royalties, more than $37 million in income from Trump's private Mar-a-Lago club in Florida, where he frequently spends weekends, and more than $160 million in income from several golf courses he owns.