Commodity Futures Trading Commission becutives 

PAS, Schedule C and Schedule A Listing 

Last Name First Name Title Department/Office "" Vacate Date 

Behnam Rostin Chairman Office of the Chairman EX-3 

MersIneer Summer Commissioner Office of Commissioner Mersinger EX-4 

Goldsmith Romero Christy Commissioner Office of Commissioner Goldsmith Romero EX-4 

Johnson Kristin Commissioner Office of Commissioner Johnson EX-4 

Pham Caroline Commissioner Office of Commissioner Pham EX-4 

Adamske Steven Di rector, Office of Pub I ic Affairs, CT-17 Office of Public Affairs Schedule C 

Hutchison Clark (Malcolm) Director, D1vis1on of Clearing and Risk, CT-16 Division of Clearing and Risk Schedule C 

Ames Patrick IKea~hanl Senior Advisor, CT-301-15 Office of Commissioner Pham Schedule C 1/13/2023 

Stump Dawn Commissioner Office of Commissioner Stump EX-4 4/13/2022 

Mersinger Summer Chief of Staff to Commissioner Stump, CT-15 Office of Commissioner Stump Schedule C 3/31/2022 

Berkov1n Daniel Commissioner Office of Commissioner Berkovitz EX-4 10/15/2021 

Quintenz Brian Commissioner Office of Commissioner Quintenz EX-4 8/31/2021 

Short Michael Director, Office of Public Affairs, CT-17 Office of Public Affairs Schedule C 5/20/2021 

Blakey Darryl Legislative and Policy Analyst, CT-16 Office of Legislative & Intergovernmental Affairs Schedule C 4/9/2021 

Benison Thomas Senior Advisor Office of the Chairman Schedule C 3/12/2021 

Tarbert Heath Commissioner Office of Commissoner Tarben EX-4 3/5/2021 

Wilken Mollie Public Affairs & Digital Engagement Strategist Office of Public Affairs Schedule C 3/5/2021 

Tarbert Heath Chairman Office of the Chairman EX-3 1/21/2021 

Millard Rachel Deputy Director Office of Public Affairs Schedule C 1/19/2021 
U.S Ol+ICE OF GO\ ERNol.lENT E'Il llCS 

Ccmficonun ufEch,cs ,\g:rccntrnc (:omphonc~ 

(l'cbruJr'< 2021 ,crsion: 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

Senate Confirmed Presidential Appomtee 

(o 0'.lc' c"m:<,·ccd In· ( )(;[_, 

a. Appomtee's Name: Christy Goldsmith Romero 

r,, ill· corn;•lu•.·cl b:, ( >( ,1: 

b. Position Title: Commissioner 

,.,1,,.,-,,:r,1,lnd ·_n (_ICI 

I. c. Agency: Commodity Futures Trading Commission 

Appointee's '' ··w ::Hnpl,·,, ,11,,- ( 1(; I 

Information d. Date Etlucs Agreement Signed: September 14, 2021 

Ir>!,, ,-.,n,·1\" ,I 11' I)( ,I 

e. Date Confirmed: March 28, 2022 

f. Due Date for Certification of Ethics r,, lll· u·r-111,·1,,I ]». {_ll 'I 

Agreement Compliance: July 5, 2022 

I completed all ef the mignatio11s indicated in 

1. mJ' ethics agreement before I asJUmed the duties 

{!)Yes QNo ef "1J mm?11t government position. ON/A Resignations 

a. I have completed all ef the di11estitum 

indicated i11 my ethicJ agreement. I also 

Qves QNo (!) N/A u11dersta11d that I !liq]' 1101 repurchaJe these 

assets dun·11g "!J' appoi11tmmt without 

3. OGE 's prior approval. 

Ot,·estitutes b. I have filed a periodic tra11Jadion report, 

or periodic tra11Jadion reports, (OGE Qves QNo {!)NIA 

Fom,-T) to dis dose the completion ef these 

agreed upon divutitum. Filing Date(s) of OGE Form 278-T Report(s): 

{f I have a managed account or use the servfru 

4. ef al/ investmm/ projeJJional, I have notified the 

Managed manager or prefeJJional ef the !tmitationf Qvcs QNo @NIA 

Accounts i11dimted in nry ethia agreement, !11 addition, 

I am ro11tinui,{e, to monitor punhafef. 

I complied with "'J' interim ream1/ obl(e,atio11f 

5. pending the divestitures required I!]· fllJ' ethics 

Intenm agreement. 

Recusak 

Qves QNo {!)N/A 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 1 
US OFl'ICE 01' CO\TR:,./.\IHST [, rJ ITC~ 

( :ert,f,c11,on or I· th,cs \grcemrnr Comrlnnc, 

, hbruorr W21 1·erst<,n• 

" As nqumd hy 18 U.S.C. § :308, I 1/11// 

6. mlllim,e to na11e from pt1rtm,lnr nltl!lerJ 111 

Recusals 111/iuh I k/llJ111 I /itwe a pena11ttl or 1mp11ted 

jinm11:1ti/ lll(mJ! dmctly a11d Jmd1dahfy ajJerted 

{Note: These 

l!J th~ matter, unless f receive t1 !Mtvu or q11nli_fy 

}1c/11al 11</f,muntr far a 1~g11/atori· e:,-m1ptw11. 

des,,ibe the b. I am nY11Si11g_/rom partimlar matter.r in 

appointu'J amrnt )l)hich tl'!J-'fom1er en1plqyer or dient I semed 111 

.rluhl.r, They <11? the paJ/ )'ear is a parlJ' or represent.r a parlJ', 

11.0I intended ID u11/e.r.r [ have been authorized under S CF R. 

modifj• ethi,'S § 2635.502(d). 

ag,·ument c. I am remsi11g_/rom particular malters 111 ,:ommitmt11!J· or 

in<1te tMW re,wal Jl)hi,h w9jbnner employer or dient I .rerved 

obligotio11J.) 

1n the Wo)'ear.r prior to qy appointment is a 

pari]· or represent, a party, un!m I have 

ruemd a wawer 111id&r Exe,: Order 13989. 

a. I re,emd a wawer p"mmnt to 18 U.S.C 

§ 208. 

7. 1r·1·, • mdrc.ir, ·i,, ,: H, l)t il1C'\\,\l\('I ""ti 

1nclic,1~ th" li1:,LL1Cui rn:u,,1 ""crc·cl l" the 

\'{"ai...-ers and \\.ll\\'[ 

Authorizaoons b. I recewi'd a u',111-cr pun11a11t !IJ f'.xc,'lltil!e 

Order !}989 

(Consult with 

yout lfvc,, mJ1c'1ll ThL J.,,, oFtlH \, ,, ,, II,, I" 

agency's subrce< of the \\ ,LIi< r ,, ·'l'I'• • ,I ' ,, ·I' I 

DAEOif of the ~th,r., 11lulgc, p ,me,. l'· II', I,·,-,,·,,,, 

uncertain ,p,nt,c is-ut .t1eas, .:s appl>c.,·. ' 

under what c. I reuil!ed an authon::;:.atio11 pursuant to authority a 5 C.F.R § 2635.502(d). waiver or 

authorization 

was granted.) It y< , LIHIHat, dn1t "f.,urh<>Hnll<>n ,rocl 

icknnf\ tll\' cm,r(ll p,r,on(• .,, ,,, ,,1,,,"' '''" 

h.1, c been :1•11h,,r11nl ·'.t' g., f, ,, m, r , 1111>1,,,,c, 

f, •1mcr dt<.:ll'. 'J'' ,u,<.:·, t'lll]'IPI < r, 'fHHl•l', 

mt ,c·nt cl,ent, de). 

d. I meil!ed a wail!er pur.r11a11t to 5 C. FR 

§ 2635.503(,). 

I/•,, 11ll", ' ·I" .I .r,d·I· '\,LL,c·· ,nd 

,,l,i,r·t•. :I•, :,-,,c· .. ·1rl• ,,. " • •L :'.L\LC 

@'es 0 No 

@Yes QNo ON/A 

(!)Yes Oo QN!A 

Qves (!)No 

Date: 

Fmancial mterest: 

Oves ®'o 

Date: 

Subject: 

Qves (!)No 

Date: 

CoYereJ person(s): 

Qves {!)No 

Date: 

Former employer or payer: 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
U.S Ol'l'lCE OF GO\'ERNMLt\ l' EJ'J [1( .S 

Cemfica<10n of Eth,cs .\greemem / '.nmplcancc 

February 2021 ,·ers,on, 

8. a. If I committed that I would 

jO,ftit a Jinantial intem/ or 

Payments, P'!yme11f1 1111/ess it was 

Accelerations, rue wed or amlerated prior to 

or Divestitures Mark tlus m_}' assumption ef the duties 

Required to be box if not of the ,go11emment po.rilion: 

Completed applicable: 

Prior to 

Entering [Z] b. Financial interest or 

Government payment at rnsue: 

Service 

1 have completed m;· witral ethin briefing, 

pursuant to 5 CF.R § 2638.305. 

9. 

Requirements 

for Regular 1 have signed the ethu:rpledge pursuant to 

Appointees Axemtive Order 13989. 

tol,c c,,rnpi<-1,·dh:, (1(:I• 

10. I am recusing from particular 

Additional matters involving Accenture and 

Ethics particular matters involving 

Agreement specific parties where 

Requirements Georgetown University is or 

represents a party. 

11. 

Comments of 

Appointee 

0 I received it (or it was ar:celerated) prior to "!)' 

aJJumptio11 qf the dutm ~r the position. 

0 I received it (or if was amlerated a(!er lll)' 

asmmptwn of the duties of the position. 

0 I forfeited it. 

.. 

{!) Yes QNo QN/A 

{!) Yes QNo QN/A 

to he compkted h) .ipp.,mtu 

I am l'ompjying with these requirements as described i11 

the acj_jacent bo.\.·_ 

{!)Yes QNo QN/A 

An}' intenttonally false or misleading statement or re,;ponse provided in this certification is a v10latlon of law 

puni'mable by a fine or imprisonment, or bo~h, under 18 V.S.C. § 1001. 

I rertjfy that the i11JOrmalio11 Appointee's Signature: Date: 

I htwt provilkd is ronplete 't?;r-;/~· ,11 Yi t,z... and ,i.:mrau. u - ' ( 

. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 3 
l!.S <JH-ICI' 01· (;()\'LllNJ\!l·'.\ r L 1·1 llCS 

C,mficatLn~ of li1h1c, li-:rc·<Tr'lc!l! Conipb.tncc 

rf'ebrnar, 21121 1cr,L<m• 

Privacy Act Section 110 of the Etlucs in Government Act of 1978, as amended, reqmres the reporting of this information. The 

!Statement pumary use of the mfom1ation on this report is for review by Government officials to determine an appointee's 

compliance with applicable Federal laws and reeuJations, and the appointee's Ethics Agreement. Failure to provide 

the requested mformauon may result in notification of lack of compliance to the Senate and the head of the 

appointee's agency, or the \'{1hite House, and/or could result in OGE declirung to certtfy the appointee's financial 

disclosure reports. TI1e appointee could also be required to recuse from matters based on uncertainty as to 

whether they have divested or resigned from a matter detemuned to raise potentialconllicts. 

Tlus information \vill be publically posted to the OGE website at ww\v.oge.gov in accordance 

with OGE/GO\'T 1, Execunve Branch Personnel Public Financial Disclosure Reports and Other ::--.;ameRetrieved Ethics Program Records (routine use "k."). Please see OGE/GOVT 1 for more information about 

the maintenance and disclosure of this information. 

Your position as one of our government's most senior leaders bnngs wtth il extraordinary responsibilities. One of 

Filing the those responsibilities 1s ro serve as a role model for all executive branch employees by demonstrating a commitment 

ICel'tification to ethical principles and actively seeking to avoid conflicts of mtcrest. This mcludes compliance with the elhics 

!of Ethics agreement you signed prior to and as a condition of your confirmation. By ~Lgning this Certification of Ethics 

~ement .Agreement Comphancc (Certification) you certify that you have complied with the terms of your ethics agreement. 

.... ompliance The information below is intenJed to help you timely meet your obligat1on to complete and subm1t this form to the 

l'.S. Office of Government Ethics (OGE). 

'You are requued to comply with the provisions of your ethics agreement within three months of the date of your 

confirmation, unless otherwise speelfied. Please: 

• Review your ethics agreement carefully 

• If your ethics agreement requues you to resign from an outside posinon, please note that resignations are 

generally requued "upon confirmation." 

• Identify any provisions of your ethics agreement that may reqwre coordination \\-ith an account manager or 

other third party. 

• Initiate any necessary action early enough to timely comply with your ethics agreement. 

• If you qualify for and wtsh to request a Certificate of Divesnrure, please submit your request as soon as 

possible through your agency's Designated Agency Ethics Official(D_-\EO). 

If your ethics agreement specifics that you have more than three months to comply wtth a particular provision, you 

must still comply with the remaining prov1s1ons within the standard three-month period and submit a Certification 

(through your agenq's D,--\EO) within seven days thereafter. If you have not complied wtth a provision of yam 

ethics agreement, please provide an explanation in Box 11, Comments of Appointee. You will be provided with an 

addmonal Certification to complete and submit to OGE to certify that you have complied wilh all provisions of 

your ethics agreement. 

Extensions: OGE may grant an extension of tllne for complying with a provision of your etlucs agreement 1f, ill 

its sole discretion, 1t detenrunes that an unusual hardship has/\\-ill prevent you from complying timely. Generally, 

waiting for an account manager to sell an interest, not bemg able to locate records, or waiting for OGE to process a 

request for a Certificate of Divestirure are not considered unusual hardships. As noted ill the Pnvacy .-\ct 

Statement above, not submitting your Certification may result in notification of lack of compliance to the Senate, 

the head of your agency, or the \'Chite House. OGE may also decline to certify your financial disclosure reports. 

You may also be required to recuse from matters based on uncertainty as to whether you have completed requued 

divestitures and resignations. OGE may also post a nouce on its website, ill place of your Certification, stating 

that you have not yet submitted the requued certification. 

twhile it is your personal responsibility to take the steps necessary to comply with your ethics agreement, your 

agency's DAEO is available to assist you in completing this Certification and submitting it to OGE. Any 

questions you may have should be directed to your agency's DAEO. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 4 
John Einstman 

Designated Agency Ethics Official 

Legal Division 

September 14, 2021 

U.S. Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, DC 20581 

Dear Mr. Einstman: 

The purpose of this letter is to describe the steps that I will take to avoid any actual or 

apparent conflict of interest in the event that I am confirmed for the position of Commissioner 

for the U.S. Commodity Futures Trading Commission ('"CFTC"). It is my responsibility to 

understand and comply with commitments outlined in this agreement. 

SECTION I - GENERAL COMMITMENTS 

As required by criminal conflicts of interest law 18 U.S.C. § 208(a), I \Vill not participate 

personally and substantially in any particular matter in \Vhich I know that I have a financial 

interest directly and predictably affected by the matter, or in which I know that a person whose 

interests are imputed to me has a financial interest directly and predictably affected by the 

matter, unless I first obtain a \Vritten \Vaiver, pursuant to 18 U.S.C. § 208(b )( 1 ), or qualify for a 

regulatory exemption, pursuant to 18 U.S.C. § 208(b )(2). I understand that the interests of the 

following persons are imputed to me: 

• Any spouse or minor child of mine; 

• Any general partner of a partnership in which I am a limited or general partner; 

• Any organization in which I serve as officer, director, trustee, general partner or 

employee; and 

• Any person or organization \Vith \Vhich I am negotiating or have an arrangement 

concerning prospective employment. 

In the event that an actual or potential conflict of interest arises during my appointment, I 

will consult with an agency ethics official and take the measures necessary to resolve the 

conflict, such as recusal from the particular matter or divestiture of an asset. 

If I have a managed account or otherwise use the services of an investment professional 

during my appointment, then I will ensure that the account manager or investment professional 

obtains my prior approval on a case-by-case basis for the purchase of any assets other than cash, 

cash equivalents, investment funds that qualify for the exemption for diversified mutual funds and 

unit investment trusts at 5 C.F.R. 9 2640.201(a). obligations of the United States, or municipal bonds. 
I will receive a live ethics briefing from a member of the ethics office after my 

confirmation, but not later than 15 days after my appointment, pursuant to the ethics program 

regulation at 5 C.F.R. § 2638.305. Within 90 days ofmy confirmation, I will submit my 

Certification of Ethics Agreement Compliance \Vhich documents my compliance with this ethics 

agreement. 

I understand that as an appointee I will be required to sign the Ethics Pledge (Exec. Order 

No. 13989) and that I will be bound by it. Among other obligations, I will be required to recuse 

myself from particular matters involving specific parties involving my fonner employer or 

fonner clients for a period of two years after I am appointed, with the exception of federal, state, 

and local government. 

I will not modify this ethics agreement without your approval and the approval of the 

U.S. Office of Government Ethics pursuant to the ethics agreement requirements contained 

within the financial disclosure regulation at 5 C.F.R. § 2634.803(a)(4). 

SECTION 2 RESIGNATIONS 

Upon confirmation, I will resign from my positions with the following entities: 

• GeorgetO\vn University 

• University of Virginia 

Pursuant to the impartiality regulation at 5 C.F.R. § 2635.502, for a period of one year after my 

resignation from each of these entities, I will not participate personally and substantially in any 

particular matter involving specific parties in which I know that entity is a party or represents a 

party, unless I am first authorized to participate, pursuant to 5 C.F.R. § 2635.502(d). 

SECTION 3 - SPOUSAL EMPLOYMENT 

My spouse is an employee of Accenture, and she participates in the employee stock 

ownership plan. I will not participate personally and substantially in any particular matter that to 

my knO\vledge has a direct and predictable effect on the financial interests of Accenture, unless I 

first obtain a written waiver, pursuant to 18 U.S.C. § 208(b )( 1 ). 

My spouse is employed by Georgetown University, in a position for which she receives a 

fixed salary. Pursuant to the impartiality regulation at 5 C.F.R. § 2635.502, for as long as my 

spouse continues to \Vork for Georgetown University, I \Vill not participate personally and 

substantially in any particular matter involving specific parties in which I know Georgetown 

University, is a party or represents a party, unless I am first authorized to participate, pursuant to 

5 C.F.R. * 2635.502(d). 

2 
SECTION 4 - PUBLIC POSTING 

I have been advised that this ethics agreement and the Certification of Ethics Agreement 

Compliance \Vill be posted publicly, consistent \Vith the public information la\v a 5 U.S.C. * 552, 

on the \vebsite of the U.S. Office of Government Ethics with ethics agreements of other 

Presidential nominees who file public financial disclosure reports. 

Sincerely, 

Christy Goldsmith Romero 

3 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

Senate Confirmed Presidential Appointee 

'' ,, , •,;111,I, I. <I I,,. ( 1(,1 

a. ,-\ppointee's :['\;ame: Rostin Behnam 

'' " l '·"I'" I d I,. I I(, I 

b. Position Title: Commissioner & Chairman 

'' " , '·"l'k I d I,. I I( ,I 

L c. ,\gency: Commodity Futures Trading Commission 

Appointee's '" ic· '"""l'k,.,I In I H , I 

Information d. Date Ethics Agreement Sit-,'lled: June 28, 2021 

'' ,,· c '"'l'kh,I I, I l(, I 

e. Date Confirmed: December 15, 2021 

f. Dul' Dak for Certification of Ethics '' ,, , •,;111,I, I. <I I,,. ( 1(,1 

Agreement Compliancl': March 22, 2022 

I m111pieted all r:ft/Je res{ltnatio11s imlic,:ted m 

2, mr etlws t\'.f,llY111mt hr/Ure I as,-11111ed the d!ftir,-

Qves QNo ~/my Clf/T/'llt _'<,IJl'f/7/11/U/t positio11. {!)1'/A Resignations 

a. I h11rc cu111pletcd 11!! ~/the dir'eslit11res 

i11ditaffd in n,y et/Jin t{~1w111e1il. 1 a/rf! 

Qves O1\,;o @:\'/1\ Hl/(kr.rfalld that f !llt!)' uo/ np11rrhaH !hf.fr 

,:sse/s d11rl!l,'.f, m_y appomt111t11t IJ'lf!Jout 

3, OCI :· ',- prwr apprut'11!. 

Divestitures b. I ha!'c Jikd a ptrif!dic tmmac!io11 npor!, 

Qves 0° orpniodir (!):s/A lra11.rac!io11 rrpm1s, (OC,'h 

/ ,-rm11-'f; to disclose the rot11pletio11 r?fthese 

t\'.f,!l'Cd 11pu11 d1rcstitures. ['iliog Date(s) of OGE forrn 278- r Report(s): 

4. 

!/! ha!'f a mana,2,td arm11nt or !!st thr .ren'ices 

qf,m 1111·estme11t p,r:fi'ssio11al, I ha/"/' 11Mijled the 

Managed mmhtY,er or J!ivfrmu11al ~/ the limitatium QYes O:\'o @~;, 

Accounts i11ditaffd in fll)' et/Jin t{~1w111e1il. in additiu11, 

I a111 a,11ti1111i1i2, to t1H111itorp111dJases. 

f comphai wi!h N()' i11kri111 lffHJa! ob/{2,aliM.r 

5. pe11di1{'< the dil"l'stitmrs n-quired 0Y 119· ethics 

Interim t{f!,IWl/!e/Jt. Qvcs OJ",.;o {!)1'/A 

Recusals 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 1 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

" /1.r !Wjltfrrd hJ· /8 ( .S.C. J 208, I IJ'l'f! 

6. m11t/111!<' to 1n11re fmm f!m1imlar 111atk1:r /11 

Recusals Jl'hic/1 I k 11on· I lwl'e a pn:ro11al ,,r i111p11ttd 

_fi11,111cfa/ !11tnnt d!red!y ,111d pirdid,i!,IJ' affrdrd 

(Note: These h)' tlw 111atkr, 1111/ts.r I 1rrell·e a 11·a/1·tr or q1wh/J' 

factual statements 

_for t1 rP/!,lllatol]' rxe111f!lf1111. 

describe the b. I am recusingjivtt1 particular matters in 

appointee's curnnt which a,ry former empll!yer or client I served in 

status. Thq are the past year is a par(:y or represents a pa,ty, 

not intended to unless I have been authorized under 5 C.F.R 

modify ethics § 2635.502/d). 

agreement c. I JIJJ remsi1~v,jiv111 partim/ar IJJ,i!ters !!I 

commitments or 

create new recusal 

n·hich J/(Jji,rmer t!llp!o]'tr or climt I se1Ted 

obligations.) 

111 thr two rum· /mor to !IIY ap/10111t11mIt ts a 

par!)' rir represents ii par!)', 1mk,s I hal'e 

nai1·ed ii IJ'ail'er 111Nkr /-:.,-fl: Order 1 3989. 

a. I recet!'ed a I1YIIrer pm,-u,mt tu l8U.S.C. 

§ 20X. 

7. I '-''- llh lc.l'c' ·],c· d.11c·<>1 ·I,, \\ .. 1,,, .n,I 

n,l c .. l, I ,,. 1·11 .. 11, ,,I 1"11c'lc" I ''" c·ic·d I,., I ,,. 

Waivers and \, ,LI'" I 

Authorizations Ii. I nwi1'ffl a 11•al1•erpm:mi1J1I lo 1--'.:xemli!'f 

Order I J9X9. 

(Consult with 

your I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I I h. 

agency's ,ul ,1,·c , ,I I 'c' \, ,ll', c'l '"" ·''l'l" .. , " .ll.L'1.t:'I 

DAEOif "' ·I,, ,·11 ,,, ,,L,I,_,·_ t ,llll,' . ll,l' lc'.I ,l' ll',Lll,1,_ 

uncertain 'I'' c I 1· l I'' '.I, .ll c· .. ,_ ,l' .lt'l 'l,c " r. 

under what I trCfi1'ffl an m!l/w1i:zatio11 pm;rIIa11t lo 

authority a 

C 

5 Cl·Y. § 263'i.502(dJ. waiver or 

authorization 

was granted.) I '', 111''1{ ,-, ',-, ,,j I .ii·,,- / 1·1 ,11 .n,I 

" '1lfl"' l1e c, '-"" d l''r",11 ,. ·' r,' \\ 11 ,.n \,,ll 

l·.1\, "'" I .ii·,,- '" I • .. 1·, ,, 11·, r , -- •I' ',. ,,-, 

f ,1"111' ,l1e,·1 'I"'"' ,,11T,,.,,-, 'I"''"' 

'"" r, --,, il1,,·1 " 

d. I f"l'ffil'erl,: wairerpursm111I to 5 Cl .R. 

§ 2635.503(cj. 

I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I 

IL c'l11 I'' ·I,, ·«1·1,,1 c'""l'l,n . "' ,, ... " 

(!)ves 0 ~() 

@Yes ONo ON/A 

@ves ONo ON/A 

QYcs {!)No 

Date: N/A 

financial interest: 

N/A 

O," <!'10 

Dak: N/A 

Sub1cct: 

N/A 

0 Yes (!)No 

Dak: N/A 

(:(ffCrcd person(~): 

N/A 

Ovcs {!)No 

Dak: N/A 

Former employer or payer: 

N/A 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

8. 

a. if 1 c01111vi!ffd !ha! 111·011/d 

Jhifeil a /i111111cia/ i11!em! or 

Payments, p,!)'fllffll, 1mkrs it was 

Accelerations, f"l'l"l'il"l'd or arcden:ted prior to 

or Divestitures Mark this 111r ass11m/1tw11 ~/the dlttirs 

Required to be box if not of !hf ,~01·en1111e1il po_,ifio11: 

Completed applicable: 

Prior to 

Entering 0 b. Financial interest or 

Government paynwnt at issut': 

Service 

I hcll't m111p!eted II()' initial ethirs lm'iji1i2., 

plf/J"/11111! to 5 C.F.R. § 2638.305. 

9. 

Requirements 

for Regular l /1(1/'f -•(~11ed the dhic_, plu(~e p11rma11/ lo 

Appointees J-:xw11iil'f Order 1 3989. 

' ' •'c l• •1llt•Li,d )' ( 1(,1 

10. 

Additional 

Ethics 

Agreement 

Requirements 

11. 

Comments of 

Appointee 

0 1 rm·ired ii (or ii //'(JS aaeifm!ed) /!rior lo 111)' 

msm11ptio11 of thl' d11fin o/!he posilim1. 

0 I rmi1·ed it (or jfwas ,lffdm:ted '!tier m_y 

ass11111ptiofl of thr duties of the position. 

0 J }rlljh'ted it. 

N/A 

0 Yes 0 '\Jo QN/A 

0 Yes 0 ::,..;: () Q:--:n 

' ' •'c l• •1llt•Li,d ' .. 1 ,;,, JI[' I cc' 

111111 i"o111plri1z~ 11·ith these nq11ire111e1ils tH rkJCribcd i11 

thr arfr'acmt box. 

Qvcs o~() @:--:/A 

Any intentionally false or misleading statement or response provided in this certification is a violation of law 

punishable by a fine or imprisonment, or both, under 18 U.S.C. § 1001. 

I certify that the information 1\ppointet"s Si,1..,>t1aturt': Date: 

I have provided is complete ROSTIN BEHNAM D1g1tJlly s,gned by ROSTIN BEHNAM 

Date. 2022.02 22 12-01 ·29 -05'00' 

and accurate. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 3 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

Privacy Act Secti(>n 1 JIJ (>f rhe l•,thics in Gm·ernmenr ,\er of !978, as amended, reLJuires rhe reporting of thi, informati{Jn. The 

Statement primary use of the information on this report is for rc\'iew h)' Co\'crnmcnt officials to determine an appointee's 

compliance with applicable Federal laws and regulations, and the appomtee's Ethics r\greement. Failure to pro\·idc 

rhe reL1uested inf(>rn1ati(lll may re,ulr in ncJrificaticJn {Jflack cJf ccJmpliance t(J the Senate and rhe head cJfthe 

appointee', agency, or the \\'hitc I lou,c, and/or could rc,ult in (JC!: declining to certify the appointee', financial 

disclosure reports. The appointee could abo be relJUired to recuse from matters ba~ed on uncntainty a~ to 

\\·hethcr the)' ha\'c di\'estcd or resigned from a matter determined to raise potcntialconflicts. 

This information will he puhlicall) posted to the ()GI•: wehsire ar \1 \1 \'.-.<"'"-"''1 in accordance 

\\·ith ( J(, l. ( ,( )\ "] '_ 1, I (;..ccuti\ c Branch Per,onncl Public financial Disclosure Reports and ()tl1cr \:iameRetrien·d Ethics Program Records (routine· use "k."). Pb1se se·e· ( l(; I . (;( )\ I I for more information about 

rhe maintenance and disclosure of this informarion. 

Your posinon as one of our gonTnmcnt's most senior leaders bnngs with it extraordinary· responsibilities. One of 

Filing the those responsibilities is to serve as a rok· model for all necutive branch e·mployee~ by demonstrating ;1 commitme·nt 

Certification to ethical principles and acti\'cly seeking to a\'oid conflict, of intcrc,t. This includes compliance \\ith the ethics 

of Ethics agreement you signed prior to and as a condition of y·our confirmation. By s11-,>t1mg this Certification of Ethics 

/\.greement ,\greement C m1pliance (Certificati{ Jn) ) ou certify that )'( >LI ha\·e n Jmplied \\·ith the tem1, of )·our ethics agreement. 

Compliance The mformation below 1s mtendcd to help you timely· meet your obliganon to complete and subrrnt this form to the 

L:.S. Ofrice ofl~ovnnment Ethic~ (OGE). 

Y(l\l are relJUired to comp Ii· with the provisions of your ethics agreement within three months of the date of your 

confirmation, unlcc;c; otherwise specified. Plca,c: 

• ReYicw your ethics agreement carefully· . 

• lf :our ethin agreement requires :ou t{J resign fnJm an {Jutside p(>,ition, please rn>te thar resignari{HlS are 

generally reLJuired "upon confirmation." 

• ldcntif)' any prm i,ions of your ethic, agreement that may reL1uirc coordination \\·ith an account manager or 

other third party. 

• lninate any necessary· action early· enough to timely comply with your ethicsa1-,,rcement . 

• If you (Jualifr for and wish to request a Certificate of DiYesnturc, please submit your re(JUCst as soon as 

possibk· through your ;1gency's De·signated .,\gency Ethics ( )fficial (D,.\EC )) . 

If your ethics ;1greement specific~ that you ha Ye more than three months to comply with a p;1nicular proyision, i·ou 

must still comply \\ith the remaining prO\isions \\·ithin the standard three-month period and submit a Certification 

(through your agency's DAE()) withm seYcn days thereafter. If y·ou ha Ye not complied with a pro\·1s1on of your 

ethics agreement, please prm·ide an e,pbnarion in Box 1 l, Comments of .,\ppointee. You will he provided wirh an 

additional Certification to complete and submit to OCE to certify that you lune complied with all prO\isions of 

i·our ethic~ agre·ement. 

Extensions: OCE may gram an c;..ternion of time for complying \\ith a prm i,ion of your ethics a1-,>-rccmcnt if, in 

its sok· di~cretion, it dnermine~ that ;m unu~ual hardship ha~/will preYent you from complying time·ly. Generalli·, 

\\·aiting for an accounr manager to ,ell an interest, not being ahle to locate records, or wairing for ()GI•, to process a 

request for a Certificate of DiYcstiture arc not considered unusual hardships. r\s noted in the PriYacy ,-\cc 

Stateme·nt ;1bove, not submitting your Cenitin1tion mai· re·s1dt in notifin1tion of lack of compli;mce· to the· Se·m1k, 

the head of your agency, or the \\'."bite I lou,c. OCE may also decline to ccrtif)' your financial disclosure report,. 

You mai· abo be· relJUired to recuse from m;1tters base·d on uncerrninty as to whether you h;n·e· completed relJUired 

di\'esritures and resignati{HlS. ()GI•: ma) als(> p(>',t a rn>tice on its \\·ehsite, in place of :our Certificati{Jn, staring 

that you ha\T not yet subrrntted the reqmrcd certification. 

While it is your personal responsibility to take the steps necessary to comply v,,ith your ethics agreement, your 

agency's DAEO is available to assist you in completing this Certification and submitting it to OGE. Any 

questions you may have should be directed to your agency's DAEO. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 4 
t • > ( IJ l·I< I·< >I ( ;, ,11 H,\11, I l•:1111<, 

/"nB(,c.Hl<'ll nf Eiluc, .\.~rc·,·m,•,i[ ( 'nmph "" ,· 

1Jnrw 1017 n·r<1nn'1 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

St:n:itt· c:onfirmcd Pn:s1dn1tial .-\ppointt:c 

i ' " ! 

,i. .-\ppomtt:t:\ t\"amc: Rostin Behnam 

' i " 

b. Posiw,n Tuk: Commissioner 

i ' " 

I. c. .-\gcnc:·: Commodity Futures Trading Commission 

.\ppointee's i ' " ' 

Information d. Date Ethics .\gTlTment S1gnnl: July 10, 2017 

. , I. ' ' ' t·. Date Confirmt:d: August 3, 2017 

f. Due Date for Certification of Fth1cs 

i ' ',,.· ':, '' 

:\grcement ('.(1mpli,mce: November 8, 2017 

I m111p1i·t,·d ,ill qi th,· 1,·.•1_~11,1/1011., 111,h,;1/crl 111 

' II!)' dhi,:.- 1i~n·m1,·11t h\'/im· f 11J.,11mc'li tlx d!iln-., 

r:/ll(_)' omrnl_~oI·,·m111m/ p/J.,1(11111. QYcs QNo (!)N/.S 

Resignations 

a. I /,m·,· mmp!dal ,iii 11/th,· di1•,•flil11n·.,· 

i111/imt,•d i11 Ill)' dhicJ" 1{~1<'<'1!1<'111. I aho 

(!)Yes QNn QN/,1 1111d1•1:,·t,111rl 1h111 I mc1J uot 1<'(l1mh,rn· t/,<'s<' 

11.,.rd,· dmi11~ 111y t1pp11i11t11H11! //)itli1111/ 

.1. OC:f ,- 'J prior ,ippnmil. 

Divestitures b. l /J,w,)il,'d d pnmd /iilll.>'ild!l//1 nt11r!, or C!) Yes QNo ON/A f'c>1i11di,· /i;i1u11dirm re;,11rt.-. (( )C"[ i / ·im11 

2"7'8-T) lo r/i.,-d,i.-,• ti,,, mmj,lili1111 (//!l1cN 

t'.i!,l<'<'rl 11p1111 d1rc.,tit1111:J. hling Date(s) of OGE l;orm :?.78-T Report(s): 

October 10, 2017 

f/1 h,m:" 1111111t1r,,·d <1<"(1111111 ,,,. II.I"<' !h,· .,en·:<"<"_,. 

,. 1!f"(ll1 i11N.c!111a1/ pmJ;,s . .-io11,rl. I h1N Jlli.'(/i,·d tlic> 

Managed 1//1111<(!!,tr orpmJ;..r.,i1111,i! o(t/1,• /i111it<1fi1m, C!) Yes QNo ON/I 

. -\ccounts wdfr<tkd 111 11n· <'lhi,-.r ,ir,n','!lh'llf. h- <1,ft//11011 . 

f 1/11/ (l)ll/i111!i1ir, /11 ll/(!/11/1!/'f!llldHo','( 

1 mmpll.-d mt/, Ii() i11tem11 u,11_,,1! ohl'.r,,1tin11., 

o. pmdi11r, the d11·<".,-titm1·., 1<',J11in·d !!) !!!\ ,,1f..1,.,· 

Interim <l!!,li'l'lllr' 11/. o,a, QNo (!)N/.1 

Rccus;,ls 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEW'ING ON OGE'S WEBSITE. 
u .s. OFFICE OF GO\'ER,-.;~ll,.NT ETI ncs Certification of Ethics /\grcemcm Compliance 

Ounc 2017 ,·ersion) 

6. a. I am remsingfrom partimlar matters in 

which I know I have a~ or Ul1/l1ikil 

Roru,,J, financial interest directfy and predictabfy 

. tffected 1!J the matter, unless I have received a 

(Note: These waiver or qualify far a reglflatory exemption. 

jactHal statements b. I am recusingfrom particular matters in describe the 

appointee's cumnt _ which any fomur entpl(!Jer or client I served in 

the pa.rt year i.r a paf!Y or represents a parry, staflll. T~ are unless I hove been authoriZfd under 5 C.F.R 

not intended to § 2635.502/d). 

modify ethics 

agreement c. I am rra11ingfrom partimlar matters in 

commitments or which any former emplqyer or client I seroed 

create new rrcmol in the two year; prior lo nry appointment i.r a 

obligations.) parry or represents a paf!Y, unless I have 

received a waive/under Exec. Onkr 13770. 

a. I received a waiver pursuant Jo 18 U.S.C. 

§ 208. 

7. If )'C~. ind1ntc the dal<' ,,f !lw wai\·cr .md 

indicaw the financial inrcrcsr conrcd by thc 

Waivers and wai\'cr. 

Authorizations b. J received a waiver pursuant to Exet11tive 

Order 13770. 

If}~>. indic-dtL the d.uc of the wainr and the 

mbi<:rt of tlw wai\'cr (i.l', applicable par.1gr.1ph 

of the ctlucs plcdgL", p,trtics, pani,;ubr martn;, 

spc~ifo;: is,-uc arcJs, a, applicable). 

c. I received an ONthoriz.ation pursuanJ Jo 

5 CF.R § 2635.502/d). 

1 f )'C<, irulic.,t~ J~t(· ,,( nuth,,ri~.1rio11 a11d 

1t.lc~1tify the cnn·rcd pcrson(s) a.s to whom you 

hi~c been authnnict.l (q(., fonmr nnph,)-l'r, 

former cliL~ll, spou,c'> cmploi·cr. 

sp<•USl·'s CllffL'fl{ climt, etc), 

d. I received a waiver pursuant to 5 C.F.R 

§ 2635.503(,). 

[fy,·s, indirnrc- the d,Ul' ,,f the· w.nwr .md 

1dc·rml}' till: former cmp!uycr nr payo.:r. 

Rostin Behnam 

@Yes QNo 

QYes QNo @NIA 

QYes QNo @NIA 

. 

QYes @No 

Date: 

Financial interest: 

QYes @No 

~-----

Date: 

Subject 

ov~ @No 

Date: 

Covered.person(s): 

QYes @No 

Date: 

Former employer or payer: 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
[;~ ()1-J-l<J {IJ•(;(>\ll("-\ll"-11·:lfli,, 

( :,•rnf,ur .. ,n ,,f l'.1h1cs .\1:rcc,m·nl { ,nm1>lurH c· 

(l«r>c C1Jl/ 1c·r<""'· 

' !(! ,111;1111illc'd //J,1/ f J/!l!!t!d 

8. jfi!Jeit t1fll,lli<°!ii/ 111/<'i<'i/ /!/' 

Paymcnb, f't!J'lll<'III, !lllft'i.f ii /J'./.1 

.:\ccdcrations, li'<'<'!tnl or a,,,-i,'1iikd p1ir1r lo 

or Di\·estiturcs Mark tlm NI)' 11_.·,·11m;-,1mn 1:r 1/J,, d!lti<'.-

RtlJlllrCd co be box if not o///11·.wm-n1moil ;-w . .-itirlli: 

Completed applicable: 

Prior to 

f•:mcring [Z] "· hnam:1:d 1n1eri:~1 m 

Gon:rnmcnt pa:·111e111 ;ll i-suc: 

Scr\'ice 

I liar·,- ,<,mflet,·d II;')' 111il1,1i' dh1<"i' /mi/I''.~· 

;-,111:1"//dl///1, _:; CFK F }(,JS.JI/_), 

9. 

R.et]Lllrcmcnt~ 

for Rcg-ular J h11·e -•i~1:,·d //,<' dhi,:,"[,i'.•d~c> ;-,111:,:1:11:i !o 

,-\ppoinKcs E.\·,·,11ti1•<' Orrkr I 37-0. 

10. 

:\dditional 

Ethics 

.\grecmcnt 

Rcqu!fement~ 

11. 

Comments of 

.\ppointct 

Rostin Behnam 

0 I n·,m·,'11 r! (or ii w,r, ,1,,-d,·mkd! r,,ior /{} II() 

11.:o'tlllif/1011 t:f th,· 1hlii,·., o/1/i,· f't!.>'!/1011. 

0 I 1,•,ym-J 1! (r!! 1/ J1•,1,· 11.-.-,•fiwkd) !!/J!.!_· ll!J' 

,H.-11m;,1uJ111:f th· d11fi,-..- rftlh· /)(J.U/i11J1. 

0 l_;i1,1<'i-'<'d i.'. 

0 Y,:s 0 ~() 0 t-: /. I 

0 Yl's 0 No 0 t-:/.1 

; 

I am ,MJJ/':)l!l~ wi!/1 ti,,,_,,, l<'!fl!lli'/1/,'I.'/ . .- di dc·.,·.-ri,\·d i,: 

!/,,_, 111!1c1.01t Im_\-

o,,, QNo C!)e>:/1 

.\ny 1ntentirnrnll)- fabe or mi~kading sl:llement or r6pon~e pmYKkd in rh1s cn!ltication is ;\ \'Jobtion of b\\' 

pumahable by a fine or nnpnsonmt·nl. or both. under 18 l'..S.C. )'. I 110 1. 

1 <'Cli'j/i· !hal th,, i11/f/111Jt1tir111 .\ppnintce's S1g11ature: Date: 

I h,ll'r: pm1·idc>d 1J mmpkt,· -0 6A{--- ;,•jzs-/:; <111d th'c'!/l,i/,•, ,/> 

/-.. [.. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 3 
John Einstman 

Deputy General Counsel and 

Designated Agency Ethics Oflicial 

Office of the General Counsel 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

Dear Mr. Einstman: 

June 28, 2021 

The purpose of this letter is to describe the steps that I will take to avoid any actual or 

apparent conflict of interest in the event that I am confirmed for the position of Chairman and 

Commissioner for the Commodity Futures Trading Commission ("CFTC'.). It is my 

responsibility to understand and comply with commitments outlined in this agreement. 

SECTION I - GENERAL COMMITMENTS 

As required by the criminal conflicts of interest law at 18 U.S.C. § 208(a), I will not 

participate personally and substantially in any particular matter in which I know that I have a 

financial interest directly and predictably affecled by the matter, or in which I know that a person 

whose interests are imputed to me has a financial interest directly and predictably affected by the 

particular matter, unless I first obtain a written waiver, pursuanl to 18 U.S.C. § 208(b)(1), or 

qualify for a regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). I understand that the 

interests of the following persons are imputed to me: 

• Any spouse or minor child of mine; 

• Any general partner of a partnership in which I am a limited or general partner; 

• Any organization in which I serve as an officer, director, trustee, general partner, 

or employee; and 

• Any person or organizalion with which I am negotiating or have an arrangement 

concerning prospective employment. 

In the event that an actual or potential conflict of interest arises during my appointment, I 

will consult with an agency ethics official and take the measures necessary to resolve the 

conflict, such as recusal from the particular matter or divestiture of an asset. 

Page I of3 
As required by 7 U.S.C. § 2(a)(8), I understand that, when I am appointed as Chairman 

and Commissioner of the CFTC, I will be prohibited during my term from engaging in 

employment with any entity subject to regulation by the CFTC, and I will also be prohibited 

from participating, directly or indirectly, in any registered entity operations or transactions of a 

character subject to regulation by the CFTC. Further, I understand that, ifl am confirmed as 

Chainnan and Commissioner of the CFTC, I must comply with the requirements of? U.S.C. 

§§ 6, 13(c) and (d), 5 C.F.R. § 5101.102, 17 C.F.R. § 140.735-2, and 17 C.F.R. § 140.735-2a. 

If I have a managed account or otherwise use the services of an investment professional 

during my appointment, I will ensure that the account manager or investment professional 

obtains my prior approval on a case-by-case basis for the purchase of any assets other than cash, 

cash equivalents, investment funds that qualify for the regulatory exemption for diversified 

mutual funds and unit investment trusts at 5 C.F .R. § 2640.201 (a), obligations of the United 

States, or municipal bonds. 

I will receive a live ethics briefing from a member of the ethics office after my 

confirmation but not later than 15 days after my appointment pursuant to the ethics program 

regulation at 5 C.F.R. § 2638.305. Within 90 days ofmy confirmation, I will submit my 

Certification of Ethics Agreement Compliance which documents my compliance with this ethics 

agreement. 

I understand that as an appointee I will be required to sign the Ethics Pledge 

(Exec. Order No. 13989) and that I will be bound by it. Among other obligations, I will be 

required to recuse from particular matters involving specific parties involving my former 

employer or former clients for a period of two years after I am appointed, with the exception of 

federal, state and local government. 

I will not modify this ethics agreement without your approval and the approval of the 

U.S. Office of Government Ethics pursuant to the ethics agreement requirements contained in the 

financial disclosure regulation at 5 C.F.R. § 2634.803(a)(4). 

SECTION 2 - SPOUSE EMPLOYMENT 

My spouse works as a consultant. For as long as my spouse continues to provide these 

services, I will not participate personally and substantially in any particular matter that to my 

knowledge has a direct and predictable effect on my spouse's compensation or contracts, unless I 

first obtain a written waiver, pursuant 18 U.S.C. § 208(b)(l). Pursuant to the impartiality 

regulation at 5 C.F.R. § 2635.502, I also will not participate personally and substantially in any 

particular matter involving specific parties in which I know a client of my spouse is a party or 

represents a party, unless I am first authorized to participate, pursuant to 5 C.F.R. § 2635.502(d). 

My spouse has an equity interest in Pitango Gelato Franchise Co., LLC, an Italian-style 

eatery and cafe. I will not participate personally and substantially in any particular matter that to 

my knowledge has a direct and predictable effect on the financial interests of Pi tango Gelato 

Franchise Co., LLC, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l). 

Page 2 of3 
SECTION> Pl:Bl,J(' l'OSTJN(! 

I have been advised that this ethics ngrccmL·nt and the c_·crlilication ol'l'.Lhics i\grccmcnt 

Compliance \\·ill be posted publicly, i.;unsislcnt \\ith tlll' puhlii.: infnrnrnliun l:m al) l i_S_( • 

~ 552, on the \\·t:hsilc ol'lhc I i.S. Orticc of(im·i.:rnment lJhii.:s \\"ilh cthii.:s agrL'l'llll'lllS of other 

Presidential nominees whu tile public li1rnncial disi.:losurc reports. 

Sini.:crl'ly. 

Rostin lkhmm 
Daniel J. Davis 

General Counsel and 

Designated Agency Ethics Official 

Office of the General Counsel 

Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 21st Street, N.W. 

Washington, D.C. 20581 

Dear Mr. Davis: 

July 10, 2017 

The purpose of this letter is to describe the steps that I will take to avoid any actual or 

apparent conflict of interest in the event that I am confirmed for the position of Commissioner 

for the Commodity Futures Trading Commission ("CFTC"). 

As required by 18 U.S.C. § 208(a), I will not participate personally and substantially in 

any particular matter in which I know that I have a financial interest directly and predictably 

affected by the matter, or in which l know that a person \vhose interests are imputed to me has a 

financial interest directly and predictably affected by the matter, unless I first obtain a written 

waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualif)· for a regulatory exemption, pursuant to 

18 U.S.C. § 208(b)(2). I understand that the interests of the following persons arc imputed to 

me: any spouse or minor child of mine; any general partner of a partnership in which I am a 

limited or general partner; any organization in which I serve as officer, director, trustee, general 

partner or employee; and any person or organization with which 1 am negotiating or have an 

arrangement concerning prospective employment. 

As required by 7 U.S.C. § 2(a)(8), I understand that, when I am appointed a 

Commissioner of the CFTC, I will be prohibited during my term from employment with any 

entity subject to regulation by the CFTC, and I will also be prohibited from participating, directly 

or indirectly, in any registered entity operations or transactions of a character subject to 

regulation by the CFTC. Further, I understand that, ifl am confirmed as Commissioner of the 

CFTC, I must comply with the requirements of 7 U.S.C. § 13(c) and ( d), 5 C.F.R. § 5101.102, 17 

C.F.R. § 140.735-2, and 17 C.F.R. § 140.735-la. 

My spouse is employed by P JPA, LLC, in a position for which she receives a fixed 

annual salary. For as long as my spouse continues to work for PJPA, LLC, I will not participate 

personally and substantially in any particular matter involving specific parties in which I know 

P JPA, LLC, is a party or represents a party, unless I am first authorized to participate, pursuant 

to 5 C.F.R. § 2635.502(d). 

Page 1 of2 
I will divest my interests in Chevron Corporation and ExxonMobil Corporation within 90 

days of my confirmation. With regard to each of these entities, I will not participate personally 

and substantially in any particular matter that to my knowledge has a direct and predictable 

effect on the financial interests of the entity until I have divested it, unless I first obtain a vl'fitten 

waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a regulatory exemption, pursuant to 18 

U.S.C. § 208(b)(2). 

I understand that I may be eligible to request a Certificate of Divestiture for qualifying 

assets and that a Certificate of Divestiture is effective only if obtained prior to divestiture. 

Regardless of whether I receive a Certificate of Divestiture, I will ensure that all divestitures 

discussed in this agreement occur within the agreed upon timeframes and that all proceeds are 

invested in non-conflicting assets. 

If I have a managed account or otherwise use the services of an investment professional 

during my appointment, I will ensure that the account manager or investment professional 

obtains my prior approval on a case-by-case basis for the purchase of any assets other than cash, 

cash equivalents, investment funds that qualify for the exemption at 5 C.F.R. § 2640.201(a), 

obligations of the United States, or municipal bonds. 

I will meet in person with you during the first week of my service in the position of 

Commissioner in order to complete the initial ethics briefing required under 5 C.F.R. § 2638.305. 

Within 90 days of my confirmation, I will document my compliance with this ethics agreement 

by notifying you in writing when I have completed the steps described in this ethics agreement. 

I understand that as an appointee I will be required to sign the Ethics Pledge (Exec. Order 

no. 13 770) and that I will be bound by the requirements and restrictions therein in addition to the 

commitments I have made in this ethics agreement. 

Finally, I have been advised that this ethics agreement will be posted publicly, consistent 

with 5 U.S.C. § 552, on the website of the U.S. Office of Government Ethics ,vith ethics 

agreements of other Presidential nominees who file public financial disclosure reports. 

Sincerely, 

·,,.,,, I ~ •. h,,,{t~ 

Rostin Behnam 

Page 2 of2 
From: 

To: 

Subject: 

Date: 

Attachments: 

Adamske Steven 

Walsh Frank 

RE: Authorization Under 5 C.F.R. § 2635.502(d) to Participate on FIA Matters 

Tuesday, March 29, 2022 5:23:23 PM 

imaoe00l.pnq 

imaqe002.ono 

image003.ong 

1ma9e004.ong 

imaoe005.pnq 

Frank, thank you for your thoughtful response. I appreciate the time and effort you put into this and 

for keeping me on the level. 

From: Walsh, Frank 

Sent: Tuesday, March 29, 2022 5:10 PM 

To: Adamske, Steven <SAdamske@CFTC.gov> 

Subject: Authorization Under 5 C.F.R. § 2635.502(d) to Participate on FIA Matters 

Steve, 

Following up on our conversation and emails on this topic, I write to document the formal waiver 

under 5 C.F.R. § 2635.502(d) to authorize you to participate on certain FIA particular matters 

consistent with the guidance below. 

Factual Background. You formerly worked at the Futures Industry Association ("FIA") prior to 

joining the CFTC. Consequently, you have a "covered relationship" with FIA and cannot participate 

on particular matters that would directly and predictably affect FIA's financial interests for one year. 

With this 1n mind, you inquired about your ability to part1c1pate on several types of matters. First, 

you asked about checking with FIA to ensure that the CFTC has received the list of media attending a 

particular conference so we know who is there and meet with them. Second, you asked about 

approving requests for the Chairman, Commissioners and senior staff members to appear on FIA 

podcasts and events. Finally, you asked about whether you could provide guidance to FIA 1f they 

asked about panel participants at their conferences. You would not be affirmatively engaging with 

FIA to have CFTC people speak, but rather would only be answering their questions. 

With an eye towards mitigating any ethics concerns, you affirmatively stated that you would recuse 

yourself if you received an email or call from FIA asking about a regulation, policy, or seeking intel on 

any substantive matter. 

(b)(5) 
(b)(5) 

In sum, I believe that the Agenc/s interests 1n allowing you to coordinate the CFTC's 
communications plan outweighs the impartiality concerns over your involvement on process or 

ministerial functions. 

Please let me know if you have any questions. 

Sincerely, 

Frank 

From: Adamske, Steven 

Frank M. Walsh 

Associate General Counsel 

Alternate Designated Agency Ethics Official (ADAEO) 

Office of General Counsel 

Commodity Futures Trading Commission 

Cell: (202) 734-2783 

fwalsh@cftc.gov 

i] i] i] i] 

Sent: Tuesday, February 8, 2022 9:14 AM 

To: Walsh, Frank <FWalsh@CFTC.gov> 

Subject: RE, Your Performance Bonus From Your Former Employer 

Frank, 

Thank you for your assistance here. I am just trying to draw within the lines even thought the lines 

are not easily seen. 

(b)(5) 
Again, thanks for the help. 

From: Walsh, Frank 

Sent: Monday, February 7, 2022 1:54 PM 

To: Adamske, Steven <SAdamske@CFTC.gov> 

Subject: RE, Your Performance Bonus From Your Former Employer 

Steve, 

(b)(5) 

Sincerely, 

Frank 

From: Adamske, Steven 

Sent: Monday, January 31, 2022 2:28 PM 

To: Walsh, Frank <FWalsh@CFTC.gov> 

Subject: RE· Your Performance Bonus From Your Former Employer 

Frank, 

(b)(5) 

From: Walsh, Frank 

Sent: Monday, January 24, 2022 5:30 PM 

To: Adamske, Steven <SAdamske@CFTC.gov> 

Subject: Your Performance Bonus From Your Former Employer 
Steve, 

(b)(5) 

Please let me know if you have any questions or if you would like to discuss this further. 

Sincerely, 

Frank 

Frank M. Walsh 

Associate General Counsel 

Alternate Designated Agency Ethics Official (ADAEO) 

Office of General Counsel 

Commodity Futures Trading Commission 

Cell: (202) 734-2783 

fwalsh@cftc.gov 

i] i] i] i] 
UNITED STATES OFFICE OF 

GOVERNMENT ETHICS 

LEGAL ADVISORY 

TO: 

FROM: 

Designated Agency Ethics Officials 

Emory A. Rounds, Ill 

Director 

January 22, 2021 

LA-21-03 

SUBJECT: Executive Orders on Ethics Commitments by Executive Branch Personnel 

On January 20, 202 l, President Biden signed an Executive Order titled ''Executive Order 

on Ethics Commitments by Executive Branch Personnel.'" Pursuant to section 4(c)(i) of the 

Executive Ord-:r, the U.S. Oflicc ofGovcrnmcnt Ethics (OGE) is providing agency ethics 

oflicials with th<.: attached copy of the Ethics Pledge and a link to the Executive Order. 

Among other things, this Executive Order requin:s every "appointee" in each execulive 

agency appointed on or a!kr January 20, 2021, to sign thl.! Ethics Pledge established therein. The 

definition of "appointee'' in the Executive Order covers "every full-time, non-career Presidential 

or Vice-Presidential appointee, non-career appointee in the Senior Executive Service ( or other 

SES-type system), and appointee to a position that has hccn excepted from the competitive 

scrvic:c by reason or being of a conlickntial or policymaking character (Schedule C and other 

positions excepted under comparable criteria) in an executive agency." Executive Order, 

sec. 2(b). However, "[i]t does not include any person appointed as a member of the Senior 

Foreign Service or solely as a uniformed service commissioned officer.'" Id. 

With respect to this Executive Order, ethics officials and employees may continue to rely 

on OGE's prior guidance regarding Executive Orders 13490 and 13770 to the extent that such 

guidance addresses hmguagc common to either of these Executive Orders and the new Executive 

Order. OGE ,vill issue additional interpretive guidance as needed to address issues implicating 

new language that appears only in the ne,v Executive Order. 

Additionally, Executive Order 13 770, which applied to appointees appointed on or after 

January 20, 2017, was revoked by an Executive Order signed by President Trump on January 20, 

2021. The latter Executive Order states, in part, that"[ e lmployees and former employees subject 

to the commitments in Executive Order 13770 will not be subject to those commitments after 

noon January 20, 2021." 

As always. agency ethics officials may contact their OGE Desk Officers for advice 

concerning the application of these Executive Orders in individual cases. 

Attachment: Ethics Pledge Form 

1201 NEW YORK AVENW·SUITE S00·WASHINGTON DC•20005 
ETHICS PLEDGE 

I recognize that this pledge is par1 ora broader ethics in government plan designed to restore and maintain public trust in 

govemmenl, and I commit myself to conduct consistent with that plan. I commit to decision-making on the merits and exclusively 

in the public interest, without regard to private gain or personal benefit. I commit to conduct that upholds the independence of law 

enforcement and precludes improper interference with investigative or prosecutorial decisions of the Department of Justice. I 

commit lo ethical choices of post-Government employment that do not raise the appearance that I have used my Government service 

for private gain, including by using confidential information acquired and relationships established for the benefit of future clients. 

Accordingly, as a condition, and in consideration, of my employmenl in lhe United States Govemmenl in a position invested with 

the public trust, I commit myself to the following obligations, which I understand are binding on me and arc enforceable under law: 

I. Lobbyist Gift Ban. I will not accept gifts from registered lobbyists or lobbying organizations for the duration ofmy service as an appointee. 

2. Revolving Door Ban -All Appointees Entering Government. I will not for a period of2 years from the date of my appointment 

participate in any particular matter involving specific parties lhat is directly and substantially related to my former employer or 

former clients, including regulations and contracts. 

3. Revolving Door Ban - UJbbyists and RegUtered Agents Entering Government. If I was registered under the Lobbying 

Disclosure Act, 2 U.S.C. 1601 et seq., or the Foreign Agents Registration Act (FARA), 22 U.S.C. 611 et seq., within the 2 years 

before the date of my appointment, in addilion to abiding by the limitations ofparagniph 2, I will not for a period of 2 years after the 

date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged in registrable activity under FARA, within the 2 years 

before the date of my appointment; 

(b) participate in the specific issue area in which that particular matter falls; or 

(c) seek or accept employment with any executive agency with respect to which I lobbied, or engaged in registrable activity 

under FARA, within the 2 years before the date ofmy appointment. 

4. Revolving Door Ban -Appointees Leaving Goveniment. If, upon my departure from the Government, I am covered by the postemployment restrictions on communicating with employees ofmy former executive agency set forth in section 207(c) of title 18, 

United States Code, and its implementing regulations, I agree that I will abide by those restrictions for a period of2 years following 

the end of my appointment. I will abide by these same restrictions with respect to communicating with the senior White House staff. 

5. Revolving Door Ban -Senior and Very Senior Appointee:; Leaving Government. If, upon my departure from the Govemmcnt, I 

am covered by the post-employment restrictions set forth in sections 207(c) or 207(d) of title 18, United States Code, and those 

sections' implementing regulations, I agree that, in addition, for a period of I year following the end ofmy appointment, I will not 

materially assist others in making communications or appearances that I am prohibited from undertaking myself by (a) holding 

myself out as being available to engage in lobbying activities in support of any such communications or appearances; or 

(b) engaging in any such lobbying activilies. 

6. Revolving Door Ban -Appoi11tees Leaving Goven,ment to Lobby. In addition to abiding by the limitations of paragraph 4, I also 

agree, upon leaving Government service, not to lobby any covered executive branch official or non-career Senior Executive Service 

appointee, or engage in any activity on behalf of any foreign govemment or foreign political party which, were it undertaken on 

January 20, 2021, would require that I register under FARA, for the remainder of the Administration or 2 years following the end of 

my appointment, whichever is later. 

7. Golden Paracli11te Ban. I have not accepted and will not accept, including after entering Government, any salary or other cash 

payment from my former employer the eligibility for and payment of which is limited to individuals accepting a position in the 

United States Government. I also have not accepted and will not accept any non-cash benefit from my former employer that is 

provided in lieu of such a prohibited cash payment. 

8. Employment Qualification Commitment. I agree that any hiring or other employment decisions I make will be based on the 

candidate's qualifications, competence, and experience. 

9. Assent to Enforcement. I acknowledge that the Executive Order entitled "Ethics Commitments by Executive Branch Perso~nel," 

issued by the President on January 20, 2021, which I have read before signing this document, defines certain of the terms applicable 

to the foregoing obligations and sets forth the methods for enforcing I hem. I expressly accept the provisions of that Executive Order 

as a part of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any statutory or other 

legal restrictions applicable to me by virtue ofFederal Government service. 

{14~1)fi--

Signature 

" .., , .Q,: ,_,_ D . P"- Name (Type or Print): -~L-::c,:_ ________________ _ 

fvf "'1 I cl' ~-----::}+-----'' 20 

Date 
ETHICS PLEDGE 

I recognize that this pledge is part of a broader ethics in go,·emment plan designed to restore and maintain public trust in 

go,·cmmcnl and 1 commit lll)·sclf to conduct consistent ,,ilh that plan. I commit to dccision-nmking on the merits and exclusi,·cl)' 

in the public intcrcsl ,,ithout regard to pri,·ate gain or personal benefit. I commit to conduct that upholds the independence of la"· 

enforcement and precludes in1proper interference ,,·ith im·estigativc or prosccutorial decisions of the Dcpartn1ent of Justice. I 

con1mit to ethical choices of post-Go,·emmcnt emplo}·ment that do not raise the appearance tlmt I ha,·e used my Go,·emment scr.·icc 

for pri,·ate gain. including by using confidential infonnation acquired and relationships established for the benefit of future clients. 

According))'. as a condition. and in consideration. of my emplo)·ment in the United SL1tes Go,·cmment in a position invested "'ith 

the public trust. I commit m}·sclf to lhc follo,,ing obligations, ,,·hich I understand arc binding on me ard arc enforceable under law: 

1. Lobb.vist Gift Ban. I ,,ill not accept gifts from registered lobbyists or lobbying organi7.atiom for the duration of m)' service as an 

appointee. 

2. Revoh1ing Door Ban - All .4ppointees Entering Governn,ent. I will not for a period of 2 years from the date of m}· appointment 

participate in a~· particular matter im·ol,·ing specific parties that is directly and substantial))' related to 111)' former cmplO)'Cr or 

former clients. including regulations and contracts. 

3. Re11olving Door Ban - Lobb_vi.i;ts and Registered Agents Enterin!{ Government. lf I "'3S registered under the Lobb)·ing 

Disclosure Act. 2 U.S.C. 16<)1 et seq .. or the Foreign Agents Registration Act (f ARA). 22 U.S.C. 611 et .i;eq .• "·ithin the 2 years 

before the date of 111)' appointment. in addition to abiding by the limitations of paragraph 2, I will not for a period of 2 years after the 

date of Ill). appointment: 

(a) participate in an)' particular matter on \\'hich I lobbied, or engaged in registrable activity under FARA. within the 2 years 

before the date of 111)' appointment; 

(b) participate in the specific issue area in ,,·hich that particular matter falls; or 

(c) seek or accept cmplo)'ment ,,·ith any executive agency "'ith respect to ,vhich I lobbied, or engaged in registrable activity 

under FARA. "·ithin the 2 )'Cars before the date of my appointment. 

4. Re110/ving Door Ban - Appointees Leaving Government. If, upon my departure from the Go,·ernmcnt, I am co,·ercd by the postcmplo)· mcnt restrictions on communicating ,vith employees of my former cxccuti,·e agcnC)· set f onh in section 207( c) of title 18, 

United States Code. and its implementing regulations, I agree that I "ill abide b)· those restrictions for a period of 2 )·cars follo"·ing 

the end of my appoinlment. I \\'ill abide b)' these same restrictions with respect to communicating ,,·ith the senior White House staff. 

5. Revolving Door Ban - Senior and Very Senior Appointees leaving Government. If. upon my departure from the Go,·emment. I 

am co,·ercd by the post-employment restrictions set forth in sections 2<>7(c) or 207(d) of title 18, United States Code, and those 

sections' implementing regulations. I agree that. in addition. for a period of I year follo\\·ing the end of 111}' appointment, I ,,·ill not 

material I)· assist others in making communications or appearances that I am prohibited from undertaking Jll}·sclf by (a) holding 

m)·sclf out as being a,·ailablc to engage in lobb)·ing acti"itics in support of aJl)' such communications or appearances; or 

(b) engaging in any such lobb)·ing activities. 

6. Re110/ving Door Ban - Appointees Leaving Government to Lobb_y. In addition to abiding by the limitations of paragraph 4. I also 

agree, upon leaving Go,•cmmcnt scn1icc, not to lobby any co,·ered exccuti,·e branch official or non-career Senior Exccuti,·e Ser.·ice 

appointee. or engage in an}· acti,·ity on behalf of any foreign go,·emmcnt or foreign political part)' ,,·hich. ,,·ere it undertaken on 

Janual)' 20, 2021, ,,·ould require that I register under FARA. for the rem.under of the Administration or 2 )'ears f ollo,,·ing the end of 

my appointment, "'hiche,·cr is later. 

1. Golden Parachute Ban. I ha,·e not accepted and ,,ill not accept. including after entering Go,·emment, all)· salary or other cash 

pa}·ment from ID}' former employer the eligibilit}' for and pa)·ment of ,,·hich is limited to indi,·iduals accepting a position in the 

United States Go\'ernmcnt. I also ha,·e not accepted and "·ill not accept any non-cash benefit from Ill)' former employer that is 

pro,·idcd in lieu of such a prohibited cash pa)·mcnt. 

8. Emplo_vment Qualification Commitn,ent. I agree that any hiring or other employment decisions I make \\ill be based on the 

candidate's qualifications, competence, and c"-pcricnce. 

9. Asl·ent to Enforcen,ent. I acknowledge that the Exccuti,·c Order entitled ··Ethics Commitments by Exccuti,•e Branch Personnel," 

issued b)' the President on JanUc1')' 2<>, 2<>2 I, ,,·hich I m,·c read before signing this docun1ent. defines certain of the te011S applicable 

to the foregoing obligations and sets forth the methods for enforcing tl1em. I C:\l)ressly accept the pro,·isions of that Exccuti,·e Order 

as a part of th.is agrccn1cnt and as binding on me. I undc~tand that the tcnttS of this pledge arc in addition to an)· statutOI)' or other 

legal rcstrictiom applicable to me by virtue of Federal Government scn:icc. 

Signatu 
ETHICS PLEDGE 

As a condition., and in consideration, ofmy employment in the United States Government in an 

appointee position invested with the public trust, I commit myself to the following obligations, which I 

understand are binding on me and are enforceable under law: 

1. I will not, within 5 years after the termination ofmy employment as an appointee in any executive 

agency in which I am appointed to serve, engage in lobbying activities with respect to that agency. 

2. If, upon my departure from the Government, I am covered by the post-employment restrictions on 

communicating with employees ofmy former executive agency set forth in section 207(c) of title 18, 

United States Code, I agree that I will abide by those restrictions. 

3. In addition to abiding by the limitations of paragraphs I and 2, I also agree, upon leaving 

Government service, not to engage in lobbying activities with respect to any covered executive branch 

official or non-career Senior Executive Service appointee for the remainder of the Administration. 

4. I will not, at any time after the termination of my employment in the United States Government, 

engage in any activity on behalf of any foreign government or foreign political party which, were it 

undertaken on January 20, 20 I 7, would require me to register under the Foreign Agents Registration Act 

of 1938, as amended. 

5. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my 

service as an appointee. 

6. I will not for a period of 2 years from the date ofmy appointment participate in any particular matter 

involving specific parties that is directly and substantially related to my former employer or former 

clients, including regulations and contracts. 

7. Ifl was a registered lobbyist within the 2 years before the date ofmy appointment, in addition to 

abiding by the limitations of paragraph 6, I will not for a period of 2 years after the date of my 

appointment participate in any particular matter on which I lobbied within the 2 years before the date of 

my appointment or participate in the specific issue area in which that particular matter falls. 

8. I agree that any hiring or other employment decisions I make will be based on the candidate's 

qualifications, competence, and experience. 

9. I acknowledge that the Executive Order entitled "Ethics Commitments by Executive Branch 

Appointees," issued by the President on January 28, 2017, which I have read before signing this 

document, defines certain terms applicable to the foregoing obligations and sets forth the methods for 

enforcing them. I expressly accept the provisions of that Executive Order as a part ofthis agreement 

and as binding on me. I understand that the obligations of this pledge are in addition to any statutory or 

other legal restrictions applicable to me by virtue of Government service. 

~C..0-

(Y',eJl_ 
UNITED STATES OFFICE OF 

GOVERNMENT ETHICS 

* 

LEGAL ADVISORY 

TO: 

FROM: 

Designated Agency Ethics Officials 

Emory A. Rounds, III 

Director 

January 22, 2021 

LA-21-03 

SUBJECT: Executive Orders on Ethics Commitments by Executive Branch Personnel 

On January 20, 2021, President Biden signed an Executive Order titled "Executive Order 

on Ethics Commitments by Executive Branch Personnel." Pursuant to section 4(c)(i) of the 

Executive Order, the U.S. Office of Government Ethics (OGE) is providing agency ethics 

officials with the attached copy of the Ethics Pledge and a link to the Executive Order. 

Among other things, this Executive Order requires every "appointee" in each executive 

agency appointed on or after January 20, 202 t. to sign the Ethics Pledge established therein. The 

definition of "appointee" in the Executive Order covers "every full-time, non-career Presidential 

or Vice-Presidential appointee, non-career appointee in the Senior Executive Service (or other 

SES-type system), and appointee to a position that has been excepted from the competitive 

service by reason of being of a confidential or policymaking character (Schedule C and other 

positions excepted under comparable criteria) in an executive agency." Executive Order, 

sec. 2(b). However, "[i]t does not include any person appointed as a member of the Senior 

Foreign Service or solely as a uniformed service commissioned officer." Id. 

With respect to this Executive Order. ethics officials and employees may continue to rely 

on OGE's prior guidance regarding Executive Orders 13490 and 13770 to the extent that such 

guidance addresses language common to either of these Executive Orders and the new Executive 

Order. OGE will issue additional interpretive guidance as needed to address issues implicating 

new language that appears only in the new Executive Order. 

Additionally, Executive Order 13770, which applied to appointees appointed on or after 

January 20. 2017, was revoked by an Executive Order signed by President Trump on January 20, 

2021. The latter Executive Order states, in part, that "[e]mployees and former employees subject 

to the commitments in Executive Order 13770 will not be subject to those commitments after 

noon January 20, 2021." 

As always, agency ethics officials may contact their OGE Desk Officers for advice 

concerning the application of these Executive Orders in individual cases. 

Attachment: Ethics Pledge Form 

1201 NEW YORK AVE I\'W•St:ITE S00·WASHINGTON DC·20005 * * * * 
ETHICS PLEDGE 

I recognize that this pledge i~ part of a hroader ethic~ in government plan de~igned to re~tore and maintain puhlic trust in 

government, and I commit myself to conduct consistent with that plan. I commit lo decision-making on the m.::rib and exclusively 

in the public interest, without regard to private gain or personal benefit. I commit to conduct that upholds the independence of law 

enforcement and precludes improper interference with investigative or prosecutorial decisions of the Department of Justice. I 

commit to ethical choices of post-Government employment that do not rai~e the appearance that I have u~ed my Government service 

for private gain, including by using confidential information acquir.::d and rclatiomhips established for th.: b.::ndit of futur.:: clients. 

Accordingly, as a condition. and in con~ideration, of my employment in the United State~ Government in a po~ition inve~ted with 

the public trust, I commit myself lo the following obligatiom, which I understand arc binding on me and an:: cnfurccabk under law: 

I. Lobb_rist Gi/i Bun. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my service as an 

appointee. 

2. Revofring Door Bun -Alf Appointee.1· Enterinx Government. I will not for a period of 2 year~ from th.: dat.:: or my appointment 

participate in any particular matter involving specific parties that is directly and substantially related to my former employer or 

former client~, including regulation~ and contracts. 

3. Revofring Door Bun - Lohhyists and Registered Agents Entering Gm'ernment. If I wa~ r.::gist.::rcd under th.: Lobbying 

Disclosure Act, 2 U.S.C. 1601 el seq .. or the Foreign Agents Registration Act (FARA), 22 L:.S.C. 611 el seq., within the 2 years 

before the date of my appointment, in addition to abiding by the limitations of paragraph 2, I will not for a period of 2 years after the 

date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged in regi~trahle activity under FARA, within the 2 years 

bdon:: the dale of my appointment; 

(b) participate in th.: sp.::cific issu.:: area in which that particular matter falls: or 

(c) ~eek or accept employment with any executive agency with respect to which l lohhied, or engaged in registrable activity 

under FARA, within the 2 years before the date of my appointment. 

4. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf. If, upon my departure from the Government. I am covered by the po~temployment re~trictions on communicating \Vith employee~ of my former executive agency ~et forth in ~ection 207(c) of title 18, 

United Stales Cod.:, and its implementing regulations, I agrc.:: that I will abide by those r.::slrictions !"or a period or 2 years following 

the end of my appointment. I will abide by the~e ~ame restriction~ with respect to communicating with the ~enior White Hou~e ~taff. 

5. Revofring Door Bun - Senior mu! Ven' Senior Appointees Leari11g Government. Ir, upon my d.::partur.:: from the Government. I 

am covered by the post-employment restrictions set forth in sections 207(c) or 207(d) of title 18, United States Code, and those 

~ections' implementing regulation~, I agree that, in addition, for a period of I year following the end of my appointment, I will not 

materially as~ist others in making communications or appearances that I am prohihited from undertaking myself by (a) holding 

my~df out as b.::ing availabk lo engage in lobbying activities in ~upporl of any such communications or appearanc.::s; or 

(b) engaging in any such lohhying activitie~. 

6. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf to Lohhy. In addition to ahiding hy the limitations of paragraph 4, I also 

agree. upon leaving Government service. not to lobby any covered executive branch official or non-career Senior Executive Service 

appointee. or engage in any activity on behalf of any foreign government or foreign political party which. were it undertaken on 

January 20, 2021. would require that I register under FARA, for the remainder of the Administration or 2 year~ following the end of 

my appointment. whichever is later. 

7. Golden Pamchute Ban. I have not accepted and will not accept, including after entering Government, any salary or other ca~h 

payment from my former employer the eligihility for and payment of which i~ limited to individuab accepting a position in the 

United Stales Gov.::rnmenl. I also have not acc.::ptcd and will not acc.::pl any non-cash benefit from my former employer that i~ 

provided in lieu of ~uch a prohibited ca~h payment. 

8. bnp!oyment Qualification Commit111e11t. I agree that any hiring or other employment deci~ion~ I make \viii he based on the 

candidate's qualifications, competence. and experience. 

9. Assell/ to Eii{orcemenl. I acknowledge that the Executive Order entitled "Ethic~ Commitments by Executive Branch Per~onnel." 

issued hy the President on January 20, 2021, which I have read before ~igning this document, define~ certain of the terms applicable 

lo th.: foregoing obligations and sds forth th.: methods for .::nfurcing th.::m. I cxprc~~ly acc.::pt th.: provisions or that Executive Order 

as a part of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any statutory or other 

legal restriction~ applicable to me by virtue of Federal Government service. 

April12 .2022 ~----------

Date 

Kristin Johnson Name (Type or Print): ________________________ _ 
UNITED STATES OFFICE OF 

GOVERNMENT ETHICS 

* 

LEGAL ADVISORY 

TO: 

FROM: 

Designated Agency Ethics Officials 

Emory A. Rounds, III 

Director 

January 22, 2021 

LA-21-03 

SUBJECT: Executive Orders on Ethics Commitments by Executive Branch Personnel 

On January 20, 2021, President Biden signed an Executive Order titled "Executive Order 

on Ethics Commitments by Executive Branch Personnel." Pursuant to section 4(c)(i) of the 

Executive Order, the U.S. Office of Government Ethics (OGE) is providing agency ethics 

officials with the attached copy of the Ethics Pledge and a link to the Executive Order. 

Among other things, this Executive Order requires every "appointee" in each executive 

agency appointed on or after January 20, 202 t. to sign the Ethics Pledge established therein. The 

definition of "appointee" in the Executive Order covers "every full-time, non-career Presidential 

or Vice-Presidential appointee, non-career appointee in the Senior Executive Service (or other 

SES-type system), and appointee to a position that has been excepted from the competitive 

service by reason of being of a confidential or policymaking character (Schedule C and other 

positions excepted under comparable criteria) in an executive agency." Executive Order, 

sec. 2(b). However, "[i]t does not include any person appointed as a member of the Senior 

Foreign Service or solely as a uniformed service commissioned officer." Id. 

With respect to this Executive Order. ethics officials and employees may continue to rely 

on OGE's prior guidance regarding Executive Orders 13490 and 13770 to the extent that such 

guidance addresses language common to either of these Executive Orders and the new Executive 

Order. OGE will issue additional interpretive guidance as needed to address issues implicating 

new language that appears only in the new Executive Order. 

Additionally, Executive Order 13770, which applied to appointees appointed on or after 

January 20. 2017, was revoked by an Executive Order signed by President Trump on January 20, 

2021. The latter Executive Order states, in part, that "[e]mployees and former employees subject 

to the commitments in Executive Order 13770 will not be subject to those commitments after 

noon January 20, 2021." 

As always, agency ethics officials may contact their OGE Desk Officers for advice 

concerning the application of these Executive Orders in individual cases. 

Attachment: Ethics Pledge Form 

1201 NEW YORK AVE I\'W•St:ITE S00·WASHINGTON DC·20005 * * * * 
ETHICS PLEDGE 

I recognize that this pledge i~ part of a hroader ethic~ in government plan de~igned to re~tore and maintain puhlic trust in 

government, and I commit myself to conduct consistent with that plan. I commit lo decision-making on the m.::rib and exclusively 

in the public interest, without regard to private gain or personal benefit. I commit to conduct that upholds the independence of law 

enforcement and precludes improper interference with investigative or prosecutorial decisions of the Department of Justice. I 

commit to ethical choices of post-Government employment that do not rai~e the appearance that I have u~ed my Government service 

for private gain, including by using confidential information acquir.::d and rclatiomhips established for th.: b.::ndit of futur.:: clients. 

Accordingly, as a condition. and in con~ideration, of my employment in the United State~ Government in a po~ition inve~ted with 

the public trust, I commit myself lo the following obligatiom, which I understand arc binding on me and an:: cnfurccabk under law: 

I. Lobb_rist Gi/i Bun. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my service as an 

appointee. 

2. Revofring Door Bun -Alf Appointee.1· Enterinx Government. I will not for a period of 2 year~ from th.: dat.:: or my appointment 

participate in any particular matter involving specific parties that is directly and substantially related to my former employer or 

former client~, including regulation~ and contracts. 

3. Revofring Door Bun - Lohhyists and Registered Agents Entering Gm'ernment. If I wa~ r.::gist.::rcd under th.: Lobbying 

Disclosure Act, 2 U.S.C. 1601 el seq .. or the Foreign Agents Registration Act (FARA), 22 L:.S.C. 611 el seq., within the 2 years 

before the date of my appointment, in addition to abiding by the limitations of paragraph 2, I will not for a period of 2 years after the 

date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged in regi~trahle activity under FARA, within the 2 years 

bdon:: the dale of my appointment; 

(b) participate in th.: sp.::cific issu.:: area in which that particular matter falls: or 

(c) ~eek or accept employment with any executive agency with respect to which l lohhied, or engaged in registrable activity 

under FARA, within the 2 years before the date of my appointment. 

4. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf. If, upon my departure from the Government. I am covered by the po~temployment re~trictions on communicating \Vith employee~ of my former executive agency ~et forth in ~ection 207(c) of title 18, 

United Stales Cod.:, and its implementing regulations, I agrc.:: that I will abide by those r.::slrictions !"or a period or 2 years following 

the end of my appointment. I will abide by the~e ~ame restriction~ with respect to communicating with the ~enior White Hou~e ~taff. 

5. Revofring Door Bun - Senior mu! Ven' Senior Appointees Leari11g Government. Ir, upon my d.::partur.:: from the Government. I 

am covered by the post-employment restrictions set forth in sections 207(c) or 207(d) of title 18, United States Code, and those 

~ections' implementing regulation~, I agree that, in addition, for a period of I year following the end of my appointment, I will not 

materially as~ist others in making communications or appearances that I am prohihited from undertaking myself by (a) holding 

my~df out as b.::ing availabk lo engage in lobbying activities in ~upporl of any such communications or appearanc.::s; or 

(b) engaging in any such lohhying activitie~. 

6. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf to Lohhy. In addition to ahiding hy the limitations of paragraph 4, I also 

agree. upon leaving Government service. not to lobby any covered executive branch official or non-career Senior Executive Service 

appointee. or engage in any activity on behalf of any foreign government or foreign political party which. were it undertaken on 

January 20, 2021. would require that I register under FARA, for the remainder of the Administration or 2 year~ following the end of 

my appointment. whichever is later. 

7. Golden Pamchute Ban. I have not accepted and will not accept, including after entering Government, any salary or other ca~h 

payment from my former employer the eligihility for and payment of which i~ limited to individuab accepting a position in the 

United Stales Gov.::rnmenl. I also have not acc.::ptcd and will not acc.::pl any non-cash benefit from my former employer that i~ 

provided in lieu of ~uch a prohibited ca~h payment. 

8. bnp!oyment Qualification Commit111e11t. I agree that any hiring or other employment deci~ion~ I make \viii he based on the 

candidate's qualifications, competence. and experience. 

9. Assell/ to Eii{orcemenl. I acknowledge that the Executive Order entitled "Ethic~ Commitments by Executive Branch Per~onnel." 

issued hy the President on January 20, 2021, which I have read before ~igning this document, define~ certain of the terms applicable 

lo th.: foregoing obligations and sds forth th.: methods for .::nfurcing th.::m. I cxprc~~ly acc.::pt th.: provisions or that Executive Order 

as a part of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any statutory or other 

legal restriction~ applicable to me by virtue of Federal Government service. 

~~---------

April 1 _ 20 22 

Signatur.:: Date 

Name (Type or Print): --~Christy_ Goldsmith Romer,o _____ _ 
UNITED STATES OFFICE OF 

GOVERNMENT ETHICS 

* 

LEGAL ADVISORY 

TO: Designated Agency Ethics Officials 

FROM: Emory A. Rounds, 111 

Director 

January 22, 2021 

LA-21-03 

SUBJECT: Executive Orders on Ethics Commitments by Executive Branch Personnel 

On January 20, 2021, President Biden signed an Executive Order titled "Executive Order 

on Ethics Commitments by Executive Branch Personnel." Pursuant to section 4(c)(i) of the 

Executive Order, the U.S. Office of Government Ethics (OGE) is providing agency ethics 

officials with the attached copy of the Ethics Pledge and a link to the Executive Order. 

Among other things, this Executive Order requires every "appointee" in each executive 

agency appointed on or after January 20, 2021, to sign the Ethics Pledge established therein. The 

definition of"appointee" in the Executive Order covers "every full-time, non-career Presidential 

or Vice-Presidential appointee, non-career appointee in the Senior Executive Service (or other 

SES-type system), and appointee to a position that has been excepted from the competitive 

service by reason of being of a confidential or policymaking character (Schedule C and other 

positions excepted under comparable criteria) in an executive agency." Executive Order, 

sec. 2(b). However, "[i]t does not include any person appointed as a member of the Senior 

Foreign Service or solely as a uniformed service commissioned officer." Id. 

With respect to this Executive Order, ethics officials and employees may continue to rely 

on OGE's prior guidance regarding Executive Orders 13490 and 13770 to the extent that such 

guidance addresses language common to either of these Executive Orders and the new Executive 

Order. OGE will issue additional interpretive guidance as needed to address issues implicating 

new language that appears only in the new Executive Order. 

Additionally, Executive Order 13770, which applied to appointees appointed on or after 

January 20, 2017, was revoked by an Executive Order signed by President Trump on January 20, 

2021. The latter Executive Order states, in part, that "[e]mployees and former employees subject 

to the commitments in Executive Order 13770 will not be subject to those commitments after 

noon January 20, 2021." 

As always, agency ethics officials may contact their OGE Desk Officers for advice 

concerning the application of these Executive Orders in individual cases. 

Attachment: Ethics Pledge Form 

1201 NEW YORK AVENW·SUITE SOO·WASHINGTON DC·ZOOOS * 
ETHICS PLEDGE 

I recognize that this pledge is part ofa broader ethics in government plan designed to restore and maintain public trust in 

government, and I commit mysclfto conduct consistent with that plan. I commit to decision-making on the merits and exclusively 

in the public interest, without regard to private gain or personal benefit. I commit to conduct that upholds the independence of law 

enforcement and precludes improper interference with investigative or prosecutorial decisions of the Depertment of Justice. I 

commit to ethical choices of post-Government employment that do not raise the appearance that I have used my Government service 

for private gain, including by using confidential informalion acquired and relationships established for the benefit of future clients. 

Accordingly, as a condition, and in consideration, ofmy employment in the United States Government in a position invested with 

the public trust, I commit myselfto the following obligations. which I understand arc binding on me and are enforceable under law: 

I. lobbyist Gift Ban. I will not accept gifts from registered lobbyists or lobbying organizations for the duration ofmy service as an 

appointee. 

2. Revolving Door Ban -All Appointees Entering Government. I will not for a period of2 year5 from the date ofmy appointment 

participate in any particular matter involving specific panics that is directly and substantially rela!ed to my fonner employer or 

former clients, including regulations and contracts. 

3. Revolving Door Ban - Lobbyists and Registered Agents Entering Governmenl. ]fl was registered under the Lobbying 

Disclosure Act, 2 U.S.C. 1601 et seq., or the Foreign Agents Registration Act (FARA). 22 U.S.C. 611 et seq., within the 2 years 

before the date ofmy appointment, in addition 10 abiding by the limitations of paragraph 2, I will not for a period of2 years after the 

date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged in registrable activity under FARA, within the 2 years 

before the date of my appointment; 

(b) participate in the specific issue area in which that particular matter falls; or 

(c) seek or accept employment with any executive agency with respect to which I lobbied, or engaged in registrable activity 

under FARA, within the 2 years before the date ofmy appointment. 

4. Revolving Door Ban -Appointees Leaving Government. If, upon my departure from the Government, I am covered by the postemployment restrictions on communicating with employees ofmy fonner executive agency set forth in section 207(c) of title 18, 

United States Code, and its implementing regulations, I agree that I will abide by those restrictions for a period of2 years following 

the end ofmy appointment. I will abide by these same restrictions with respect to communicating with the senior White House staff. 

5. Revolving Door Ban - Senior and Very Senior Appointees Leaving Governmenl. If. upon my departure from the Government, I 

am covered by the post-employment restrictions set forth in s\..-ctions 207(c) or 207(d) of title 18, United States Code, and those 

sections' implementing regulations, I agree that, in addition, for a period of I year following the end ofmy 11ppointment, I will not 

materially assist others in making communications or appearances that I am prohibited from undertaking myself by (a) holding 

myself out as being available to engage in lobbying activities in support of any such communications or appearances; or 

(b) engaging in any such lobbying activities. 

6. Revolving Door Ban -Appoinlees l.eaving Governmenl lo l.obhy. In addition to abiding by the limitations of paragraph 4, I also 

agree, upon leaving Government service, not 10 lobby any covered executive branch official or non-carei:r Senior Executive Service 

appointee, or engage in any activity on behalf of any foreign government or foreign political party which, were it undertaken on 

January 20, 2021, would require that I register under FARA, for the remainder of the Administration or 2 years following the end of 

my appointment, whichever is later. 

7. Golden Porachule Bun. I have not accepted and will not accept, including after enti:ring Government, any salary or other cash 

payment from my former employer the eligibility for and payment of which is limited to individuals accepting a position in thi: 

United States Government. I also have not accepted and will not accept any non-cash benefit from my former employer that is 

provided in lieu of such a prohibited cash payment. 

8. Employment Qualification Commilmenl. I agree that any hiring or other i:mployment decisions I make will be b11sed on the 

candidate's qualifications, competence, and experience. 

9. Assen/ lo Enforcemenl. I acknowledge that the Executive Order entitled "Ethics Commitments by Executive Branch Personnel," 

issued by the President on January 20, 2021, which I have read before signing this document, defines certain of the terms applicable 

to the foregoing obligations and sets forth the methods for enforcing them. I expressly accept the provisions orthat Executive Ordi:r 

as a pan of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any st11tutory or other 

legal restrictions applicable to me by virtue of Federal Government service. 
ETHICS PLEDGE 

As a condition, and in consideration, of my employment in the United States Government in an 

appointee position invested with the public trust, I commit myself to the following obligations, which I 

understand are binding on me and are enforceable under law: • 

1. I will not, within 5 years after the termination of my employment as an appointee in any executive 

agency in which I am appointed to seIVe, engage in lobbying activities with respect to that agency. 

2. If, upon my departure from the Government, I am covered by the post-employment restrictions on 

communicating with employees of my former executive agency set forth in section 207(c) of title 18, 

United States Code, I agree that I will abide by those restrictions. 

3. In addition to abiding by the limitations of paragraphs 1 and 2, I also agree, upon leaving 

Government service, not to engage in lobbying activities with respect to any covered executive branch 

official or non.career Senior Executive Service appointee for the remainder of the Administration. 

4. I will not, at any time after the termination of my employment in the United States Government, 

engage in any activity on behalf of any foreign government or foreign political party which. were it 

undertaken on January 20, 2017, would require me to register under the Foreign Agents Registration Act 

of 1938, as amended. 

5. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my 

service as an appointee. 

6. I will μot for a period of 2 years from the date of my appointment participate in any particular matter 

involving specific parties that is directly and substantially related to my former employer or fonner 

clients, including regulations and contracts. 

7. Ifl was a registered lobbyist within the 2 years before the date of my appointment, in addition to 

abiding by the limitations of paragraph 6, I will not for a period of 2 years after the date of my 

appointment participate in any particular matter on which I lobbied within the 2 years before the date of 

my appointment or participate in the specific issue area in which that particular matter falls. 

8. I agree that any hiring or other employment decisions I make will be based on the candidate's 

qualifications, competence, and experience. 

9. I acknowledge that the Executive Order entitled "Ethics Commitments by Executive Branch 

Appointees," issued by the President on January 28, 2017, which I have read before signing this 

document, defines certain tenns applicable to the foregoing obligations and sets forth the methods for 

enforcing them. I expressly accept the provisions of that Executive Order as a part of this agreement 

and as binding on me. I understand that the obligations of this pledge are in addition to any statutory or 

other legal restrictions applicable to me by virtue of Government service. 

Signature Date 

Print or type your full name (last, first, middle) 
Federal Regisler 

Vol. ll6, No. 14 

Monctay, Januarv 25, 2ll21 

Title 3-

The President 

7029 

Presidential Documents 

Executive Order 13989 of January 20, 2021 

Ethics Commitments by Executive Branch Personnel 

Bv the authority vested in me as President bv the Constitution and the 

Ia"ws of the Urlited States of America, includ"ing section 301 of title 3, 

United States Code, and sections 3301 and 7301 of title 5, United States 

Code, it is hereby ordered as follows: 

Section 1. Ethics Pledge. Every appointee in every executive agency appointed 

on or after January 20, 2021, shall sign, and upon signing shall be contractually committed to, the following pledge upon becoming an appointee: 

"I recognize that thic, pledge ic, part of a broader ethics in government 

plan designed to restore and maintain public trust in government, and 

I cnmmil myself In conducl c.nnsistent wilh thal plan. I commit tn dec.isionmaking on the nH:rits and exclusivdy in lhe public inten:st, without regard 

lo private gain or personal benefit. I commit to conducl lhal upholds lhe 

independence of law enforcement and precludes improper interference with 

investigative or prosecutorial decisions of the Department of Justice. I commit 

to ethical choices of post-Government employment that do not raise the 

appearance that I have used my Government service for private gain, including by using confidential information acquired and relationships established 

for the benefit of future clients. 

"Accordingly, as a condition, and in consideration, of my employment in 

the United States Government in a poe>ition invested with the public trust, 

I commit myself to the following obligations, which I undere>tand are binding 

on me and an: enforceable undt:r law: 

"1. Lobbyist Gift Bun. I will nnl accept gifts from registered lobbyists or 

lobbying organizations for the duration of my service as an appointee. 

"2. Revolving Door Han-All Appointees Hntering Government. I will not 

for a period of 2 years from the date of my appointment participate in 

any particular matter involving specific parties that is directly and substantially related to my former employer or former clients, including regulations 

and contracts. 

"3. Revolving Door Ban-Lobbyists and Registered Agents Entering Government. If I was registered under the Lobbying Disclosure Act, 2 U.S.C. 1601 

et seq., or the foreign Agents Registration Act (PARA). 22 U.S.C. 611 et 

seq., within the 2 years before the date of my appointment. in addition 

lo abiding by lhe limitations of paragraph 2, I will nnt for a pt:riod of 

2 years after the date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged 

in registrable activity under .FARA, within the 2 years before the date of 

my appointment: 

(b) participate in the specific issue area in which that particular matter 

falls: or 

(cl seek or accept employment with any executive agency with respect 

to which I lobbied, or engaged in registrable activity under .FARA, within 

the 2 years before the date of my appointment. 

"4. Revolving Door Ban-Appointees Leaving Government. If, upon my departure from the Government, I am covered by the post-employment restrictions 

on communicating with employees of my former executive agency set forth 

in e>ection 207(c) of title 18, United States Code, and its implementing 
7030 Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 

regulations, I agree that I will abide by those restrictions for a period of 

2 years following the end of my appointment. I will abide by these same 

restrictions with respect to communicating with the senior White House 

e>taff. 

"5. Revolving Door Ban-Senior and Ve1y Senior Appointees Leaving Government. If, upon my departure from the Government, I am covered by the 

post-employment ree>trictiom e>et forth in sectiom 207(c) or 207(d) of title 

18. United Statee> Code. and thoc,e e>ections' implementing regulations, I 

agree that. in addition, for a period of 1 year following the end of my 

appoinlmcnl, I will nol materially assist others in making c.ommunicatinns 

or appearances thal I am prohibited from undertaking mysdf by (a) holding 

myself nul as being available In engage in lobbying activities in support 

of any such communications or appearances; or (bl engaging in any such 

lobbying activities. 

"O. Revolving Door Ban-Appointees Leaving Government lo Lohhy. In acl.dilion lo abiding by lhe limitations of paragraph 4, I also agree, upon leaving 

Covernmenl st:rvice, not lo lobby any covered executive branch official 

or non-career Senior Executive Service appointee, or engage in any activity 

on behalf of any foreign government or foreign political party which, were 

it undertaken on January 20, 2021, would require that I register under 

FARA, for the remainder of the Administration or 2 years following the 

end of my appointment, whichever is later. 

"7. Golden Paraclwte Han. I have not accepted and will not accept, including 

after entering Government, any salary or other cash payment from my former 

employer the eligibility for and payment of which is limited to individuals 

accepting a position in the United States Government. I also have not accepted and will not accept any non-cash benefit from my former employer 

that is provided in lieu of such a prohibited cash payment. 

"8. Hmployment QualZfication Commitment. I agree that any hiring or other 

employment decisions I make will be based on the candidate's qualifications, 

competence, and experience. 

"fl. A.,;-;;enl lo Enforcement. I acknowledge lhat lhe Executive Order enlilh:d 

'Ethics Commitments by Executive Branch Personnel,' issued by the President 

on January 20, 2021, which 1 have read before signing this document, defines 

certain of the terms applicable to the foregoing obligations and sets forth 

the methods for enforcing them. I expressly accept the provisions of that 

Executive Order as a part of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any statutory or 

other legal restrictions applicable to me by virtue of Federal Government 

e>erv1ce ,, 

Sec. 2. Definitions. For purposes of this order and the pledge set forth 

in section 1 of this order: 

(a) "Executive agency'' shall include each "executive agency" as defined 

bv section 105 of title 5, United States Code, and shall include the Executive 

Office of the President; provided, however, that "executive agency" shall 

include the United Statee> Poe>tal Service and Poe>tal Regulatory Commission. 

but c,hall exclude the Government Accountability Office. 

(bl "Appointee" shall include every full-time, non-career Presidential or 

Vice-Presidential appointee, non-career appointee in the Senior Executive 

Service (or other SES-type system), and appointee to a position that has 

been excepted from the competitive service by reae>on of being of a confidential or policymaking character (Schedule C and other positions excepted 

under comparable criteria) in an executive agency. It does not include any 

pt:rsnn appointed as a member of lhe Senior Foreign Smvice or solely 

as a uniformed servic.e commissioned officer. 

(cl "Gift": 

(i) shall have the definition set forth in section 2635.203(6) of title 5, 

Code of Federal Regulations; 
Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 7031 

(ii) shall include gifts that are solicited or accepted indirectly, as defined 

in section 2635.203(f) of title 5. Code of Federal Regulations; and 

(iii) shall exclude those items excluded by sections 2635.204(b), (c), (el(l) 

and (3), and (j) through (I) of lillt: 5, Codr. of Fr.dr.ral Regulations. 

(d) "Covered executive branch official" and "lobbyist" shall have the 

definitions set forth in section 1602 of title 2, United Stat"es Code. 

(e) "Registered lobbyist or lobbying organization'' shall mean a lobbyist 

or an organization filing a registration pursuant to section 1603(a) of title 

2, United States Code, and in the case of an organization filing such a 

registration, "registered lobbyist" shall include each of the lobbyists identified therein. 

(17 "Lobby" and "lobbied" shall mr.an to act or havr. acted as a rngistr.rt:d 

lobbyist. 

(g) "Lobbying activities" shall have the definition set forth in section 

1602 of title 2, United States Code. 

(h) "Materially assist" means to provide substantive assistance but does 

not include providing background or general education on a matter of law 

or policy based upon an individual's subject matter expertise, nor any conduct or assistance permitted under section 207(j) of title 18, United States 

Code. 

(i) "Particular matter" shall have the same meaning as set forth in section 

207 of lille 18, United Slates Codr., and section 2035.402(b)(3) of lille 5, 

Codr. of Fr.dr.ral Regulations. 

(j) ''Partir.ular mailer involving specific parlir.s" shall havr. 1hr. samr. meaning as set forth in section 2641.201(hJ of title 5, Code of Federal Regulations, 

except that it shall also include any meeting or other communication relating 

to the performance of one's official duties with a former employer or former 

client, unless the communication applies to a particular matter of general 

applicability and participation in the meeting or other event is open to 

all interested parties. 

(kl "Former employer" is any person for whom the appointee has within 

the 2 years prior to the date of his or her appointment served as an employee, 

offir.t:r, director, truster., or general partner, r.xu:pl lhal "formm employer" 

dor.s nol indudr. any r.xr.r.ulivr. agency or olhr.r entity of lht: Fr.dr.ral Covt:rnmr.nl, Slatr. or local governnH:nl, thr. District of Columbia, Native Amerir.an 

tribe, any United States territory or possession, or any international organization in which the United States is a member state. 

(1) "Former client" is any person for whom the appointee served personally 

as agent, attorney, or consultant within the 2 years prior to the date of 

his or her appointment, but excluding instances where the service provided 

was limited to speeches or similar appearances. It does not include clients 

of the appointee's former employer to whom the appointee did not personally 

provide services. 

(m) "Din:r.tly and substantially rdalt:d lo my former r.mployr.r or former 

dir.nts" shall mr.an mailers in which the appoinlr.e's fnrmt:r r.mployr.r or 

a former dienl is a party or rr.pn:sr.nls a party. 

(n) "Participate" means to participate personally and substantially. 

(o) "Government official" means any employee of the executive branch. 

(pl "Administration" means all terms of office of the incumbent President 

serving at the time of the appointment of an appointee covered by this 

order. 

(q) "Pledge" means the ethics pledge set forth in section 1 of this order. 

(r) "Senior White House staff" means any person appointed by the President to a position under sections 105(a)(2)(A) or (Bl of title 3, United 

States Code, or by the Vice President to a position under sections 106(a)(1)(A) 

or (n) of title 3. 
7032 Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 

(s) All references to provisions of law and regulations shall refer to such 

provisions as are in effect on fanuary 20. 2021. 

Sec. 3. Waiver. (a) The Director of the Office of Management and Budget 

(0MB), in consultation with the Counsel to the President, may grant to 

any current or former appointee a written waiver of any ree>trictiom, contained 

in the pledge signed by such appointee if. and to the extent that, the 

Director of DMD certifiee> in writing: 

(i) that the literal application of the ree>triction is inconsistent with the 

purposes of the restriction; or 

(ii) that it is in the public interest to grant the waiver. Any such written 

waiver should reflect the basis for the waiver and, in the case of a 

waiver of the restrictions set forth in paragraphs 3(b) and (c) of the 

pledge, a discussion of the findings with respect to the factors set forth 

in subsection (bl of this section. 

(b) A waiver shall take effect when the certification is signed by the 

Director of 0MB and shall be made public within 10 days thereafter. 

(c) The public interest shall include, but not be limited to, exigent circumstances relating to national security, the economy, public health, or 

the environment. In determining whether it is in the public interest to 

grant a waiver of the restrictions contained in paragraphs 3(b) and (c) of 

the pledge, the responsible official may consider the following factors: 

(il the government's need for the individual's services, including the existence of special circumstances related to national security, the economy, 

public health, or the environment; 

(ii) lhe uniqueness of the individual's qualifications lo meet lhe government's needs; 

(iii) lhe scope and nature of lhe individual's prior lobbying activities, 

including whether such adivities were de minimis nr rendered on behalf 

of a nonprofit organization: and 

(iv) the exlenl lo which lhe purposes of lhe restriction may be satisfied 

lhrnugh other limitations on lhe individual's serviu:s, such as !hose n:-

quired by paragraph 3(a) of the pledge. 

Sec. 4. Administration. (al The head of every executive agency shall, in 

consultation with the Director of the Office of Government Ethics, establish 

such rules or procedures (conforming as nearly as practicable to the agency's 

general ethics rules and procedures, including those relating to designated 

agency ethics officers) as are necessary or appropriate to ensure: 

(i) that every appointee in the agency signs the pledge upon assuming 

the appointed office or otherwise becoming an appointee: 

(ii) that compliance with paragraph 3 of the pledge is addressed in a 

written ethics agreement with each appointee to whom it applies, which 

agreement shall also be approved by the Counsel to the President prior 

to the appointee commencing work; 

(iii) that spousal employment issues and other conflicts not expressly 

addressed by the pledge are addressed in ethics agreements with appointees 

or, where no such agreements are required, through ethics counseling; 

and 

(iv) that the agency generally complies with this order. 

(b) With respect to the Executive Office of the President, the duties set 

forth in section 4(a) of this order shall be the responsibility of the Counsel 

to the President. 

(c) The Director of the Office of Government Ethics shall: 

(i) ensure that the pledge and a copy of this order are made available 

for use by agencies in fulfilling their duties under section 4(a) of this 

order; 
Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 7033 

(ii) in consultation with the Attorney General or the Counsel to the President, when appropriate, assist designated agency ethics officers in providing advice to current or former appointees regarding the application 

of the pledge; and 

(iii) in consultation with the Attornev General and the Counsel to the 

President, adopt such rules or proced1lres as are necessary or appropriate; 

(A) to carry out the foregoing responsibilities; 

(Bl to authorize limited exceptions to the lobbyist gift ban for circumstances that do not implicate the purposes of the ban; 

(Cl to make clear that no person shall have violated the lobbyist gift 

ban if the person properly disposes of a gift as provided by section 

2635.206 of title 5, Code of federal Regulations; 

(D) to ensure that existing rules and procedures for Government employees engaged in negotiations for future employment with private businesses 

lhal arc alfocled by the employees' official actions do nol affect lhc integrity 

of [be CovernnH:nl 's programs and operations; 

(E) to ensure, in consultation witb lhc Director of lhc Office of Pt:rsonrn:l 

Management, lhal the n:quin:mcnl set forth in paragraph n of the pledge 

is honored by every employee of the executive branc.h; 

(iv) in consullation with the Director of 0MB, rcporl to lhe Prnsidcnl 

on whether full complianc.c is being ad1icvcd with existing laws and 

regulations governing executive branch procurement lobbying disclosure. 

This report shall include recommendations on steps the executive branch 

can take to expand, to the fullest extent practicable, disclosure of both 

executive branch procurement lobbying and of lobbying for Presidential 

pardons. These recommendations shall include both immediate actions 

the executive branch can take and, if necessary, recommendations for 

legislation; and 

(v) provide an annual public report on the administration of the pledge 

and this order. 

(d) The Director of the Office of Government Ethics shall, in consultation 

with the Attorney Cencral, the Counsel lo lhe Prcsirh:nl, and the Director 

of the Office of Pmsonncl Management, report to lhc Pn:sidenl on steps 

lhe executive branch Glll take to expand to lhc fullest exlent practic.ablc 

the revolving door ban set forth in paragraph 5 of the pledge to all executive 

branch employees who are involved in the procurement process such that 

they may not for 2 years after leaving Government service lobby any Government official regarding a Government contract that was under their official 

responsibility in the last 2 years of their Government service. This report 

shall include both immediate actions the executive branch can take and, 

if necessary. recommendations for legislation. 

(e) All pledges signed by appointees, and all waiver certifications with 

respect thereto, shall be filed with the head of the appointee's agency for 

permanent retention in the appointee's official personnel folder or equivalent 

folder. 

Sec. 5. Enforcement. (a) The contractual. fiduciary. and ethical commitments 

in the pledge provided for herein are solely enforceable by the United 

Stales pursuant lo this scclion by any legally available means, induding 

rh:barnH:nl proceedings within any affoctcd executive agcnc.y or judicial 

civil proceedings for declaralory, injunctive, or mo1wlary rdief. 

(b) Any former appointee who is dclt:rmincd, after notice and hearing, 

by the duly designated authority within any agency, to have violated his 

or her pledge may be barred from lobbying any officer or employee of 

that agency for up to 5 years in addition to the time period covered by 

the pledge. The head of every executive agency shall, in consultation with 

the Director of the Office of Government Ethics, establish procedures to 

implement this subsection, which procedures shall include (but not be limited to) providing for fact-finding and investigation of possible violations 
7034 Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 

of this order and for referrals to the Attorney General for consideration 

pursuant to sub:rnction (cl ofthic, order. 

(c) The Attorney General is authorized: 

(il upon receiving information regarding the possible breach of any commitment in a signed pledge, to request any appropriate Federal investigative 

authority to conduct such investigations as may be appropriate; and 

(ii) upon determining lhal there is a reasonable basis lo bdicvc lhal 

a breach of a commitment has occurred or will occur or continue, if 

not enjoined, to commence a civil action against the former employee 

in any United States District Court with jurisdiction to consider the matter. 

(d) In any such civil action, the Attorney General is authorized to request 

any and all relief authorized by law, including but not limited to: 

(il such temporary restraining orders and preliminary and permanent injunctions as may be appropriate to restrain future, recurring, or continuing 

conduct by the former employee in breach of the commitments in the 

pledge he or she signed; and 

(ii) establishment of a constructive trust for the benefit of the United 

States, requiring an accounting and payment to the United States Treasury 

of all money and other things of value received by, or payable to, the 

former employee arising out of any breach or attempted breach of the 

pledge signed by the former employee, 

Sec. 6. General Provisions. (a) If any provision of this order or the application 

of such provision is held to be invalid, the remainder of this order and 

other dissimilar applications of such provision shall not be affected, 

(b) Nothing in this order shall be construed to impair or otherwise affect: 

(i) the authority granted by law to an executive department or agency, 

or the head thereof: or 

(ii) the functions of the Director of the Office of Management and Budget 

relating to budgetary, administrative, or legislative proposals. 

(c) This order shall be implemented consistent with applicable law and 

subject to the availability of appropriations. 
Federal Register/ Vol. 86, No. 14 / Momfay, fanuary 25, 2021 / Presidential Documents 7035 

[l'R no,. 2021-ll17G2 

l'ilnrl 1-22-21. 11 1:, .nn] 

nilling ,.orl" .~2fl:l-l'1-P 

(d) This order is not intended to, and does not, create any right or 

benefit, substantive or procedural, enforceable at law or in equity by any 

party against the United States, its departments, agencies, or entities, its 

officers, employees, or agents, or any other person. 

THE WHITE HOUSE, 

fanumy 20, 2021. 
UNITED STATES OFFICE OF 

GOVERNMENT ETHICS 

* 

LEGAL ADVISORY 

TO: 

FROM: 

Designated Agency Ethics Officials 

Emory A. Rounds, III 

Director 

January 22, 2021 

LA-21-03 

SUBJECT: Executive Orders on Ethics Commitments by Executive Branch Personnel 

On January 20, 2021, President Biden signed an Executive Order titled "Executive Order 

on Ethics Commitments by Executive Branch Personnel." Pursuant to section 4(c)(i) of the 

Executive Order, the U.S. Office of Government Ethics (OGE) is providing agency ethics 

officials with the attached copy of the Ethics Pledge and a link to the Executive Order. 

Among other things, this Executive Order requires every "appointee" in each executive 

agency appointed on or after January 20, 202 t. to sign the Ethics Pledge established therein. The 

definition of "appointee" in the Executive Order covers "every full-time, non-career Presidential 

or Vice-Presidential appointee, non-career appointee in the Senior Executive Service (or other 

SES-type system), and appointee to a position that has been excepted from the competitive 

service by reason of being of a confidential or policymaking character (Schedule C and other 

positions excepted under comparable criteria) in an executive agency." Executive Order, 

sec. 2(b). However, "[i]t does not include any person appointed as a member of the Senior 

Foreign Service or solely as a uniformed service commissioned officer." Id. 

With respect to this Executive Order. ethics officials and employees may continue to rely 

on OGE's prior guidance regarding Executive Orders 13490 and 13770 to the extent that such 

guidance addresses language common to either of these Executive Orders and the new Executive 

Order. OGE will issue additional interpretive guidance as needed to address issues implicating 

new language that appears only in the new Executive Order. 

Additionally, Executive Order 13770, which applied to appointees appointed on or after 

January 20. 2017, was revoked by an Executive Order signed by President Trump on January 20, 

2021. The latter Executive Order states, in part, that "[e]mployees and former employees subject 

to the commitments in Executive Order 13770 will not be subject to those commitments after 

noon January 20, 2021." 

As always, agency ethics officials may contact their OGE Desk Officers for advice 

concerning the application of these Executive Orders in individual cases. 

Attachment: Ethics Pledge Form 

1201 NEW YORK AVE I\'W•St:ITE S00·WASHINGTON DC·20005 * * * * 
ETHICS PLEDGE 

I recognize that this pledge i~ part of a hroader ethic~ in government plan de~igned to re~tore and maintain puhlic trust in 

government, and I commit myself to conduct consistent with that plan. I commit lo decision-making on the m.::rib and exclusively 

in the public interest, without regard to private gain or personal benefit. I commit to conduct that upholds the independence of law 

enforcement and precludes improper interference with investigative or prosecutorial decisions of the Department of Justice. I 

commit to ethical choices of post-Government employment that do not rai~e the appearance that I have u~ed my Government service 

for private gain, including by using confidential information acquir.::d and rclatiomhips established for th.: b.::ndit of futur.:: clients. 

Accordingly, as a condition. and in con~ideration, of my employment in the United State~ Government in a po~ition inve~ted with 

the public trust, I commit myself lo the following obligatiom, which I understand arc binding on me and an:: cnfurccabk under law: 

I. Lobb_rist Gi/i Bun. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my service as an 

appointee. 

2. Revofring Door Bun -Alf Appointee.1· Enterinx Government. I will not for a period of 2 year~ from th.: dat.:: or my appointment 

participate in any particular matter involving specific parties that is directly and substantially related to my former employer or 

former client~, including regulation~ and contracts. 

3. Revofring Door Bun - Lohhyists and Registered Agents Entering Gm'ernment. If I wa~ r.::gist.::rcd under th.: Lobbying 

Disclosure Act, 2 U.S.C. 1601 el seq .. or the Foreign Agents Registration Act (FARA), 22 L:.S.C. 611 el seq., within the 2 years 

before the date of my appointment, in addition to abiding by the limitations of paragraph 2, I will not for a period of 2 years after the 

date of my appointment: 

(a) participate in any particular matter on which I lobbied, or engaged in regi~trahle activity under FARA, within the 2 years 

bdon:: the dale of my appointment; 

(b) participate in th.: sp.::cific issu.:: area in which that particular matter falls: or 

(c) ~eek or accept employment with any executive agency with respect to which l lohhied, or engaged in registrable activity 

under FARA, within the 2 years before the date of my appointment. 

4. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf. If, upon my departure from the Government. I am covered by the po~temployment re~trictions on communicating \Vith employee~ of my former executive agency ~et forth in ~ection 207(c) of title 18, 

United Stales Cod.:, and its implementing regulations, I agrc.:: that I will abide by those r.::slrictions !"or a period or 2 years following 

the end of my appointment. I will abide by the~e ~ame restriction~ with respect to communicating with the ~enior White Hou~e ~taff. 

5. Revofring Door Bun - Senior mu! Ven' Senior Appointees Leari11g Government. Ir, upon my d.::partur.:: from the Government. I 

am covered by the post-employment restrictions set forth in sections 207(c) or 207(d) of title 18, United States Code, and those 

~ections' implementing regulation~, I agree that, in addition, for a period of I year following the end of my appointment, I will not 

materially as~ist others in making communications or appearances that I am prohihited from undertaking myself by (a) holding 

my~df out as b.::ing availabk lo engage in lobbying activities in ~upporl of any such communications or appearanc.::s; or 

(b) engaging in any such lohhying activitie~. 

6. Revo!vin?, Door /Jan -Appointees Leal'i11?, Governmellf to Lohhy. In addition to ahiding hy the limitations of paragraph 4, I also 

agree. upon leaving Government service. not to lobby any covered executive branch official or non-career Senior Executive Service 

appointee. or engage in any activity on behalf of any foreign government or foreign political party which. were it undertaken on 

January 20, 2021. would require that I register under FARA, for the remainder of the Administration or 2 year~ following the end of 

my appointment. whichever is later. 

7. Golden Pamchute Ban. I have not accepted and will not accept, including after entering Government, any salary or other ca~h 

payment from my former employer the eligihility for and payment of which i~ limited to individuab accepting a position in the 

United Stales Gov.::rnmenl. I also have not acc.::ptcd and will not acc.::pl any non-cash benefit from my former employer that i~ 

provided in lieu of ~uch a prohibited ca~h payment. 

8. bnp!oyment Qualification Commit111e11t. I agree that any hiring or other employment deci~ion~ I make \viii he based on the 

candidate's qualifications, competence. and experience. 

9. Assell/ to Eii{orcemenl. I acknowledge that the Executive Order entitled "Ethic~ Commitments by Executive Branch Per~onnel." 

issued hy the President on January 20, 2021, which I have read before ~igning this document, define~ certain of the terms applicable 

lo th.: foregoing obligations and sds forth th.: methods for .::nfurcing th.::m. I cxprc~~ly acc.::pt th.: provisions or that Executive Order 

as a part of this agreement and as binding on me. I understand that the terms of this pledge are in addition to any statutory or other 

legal restriction~ applicable to me by virtue of Federal Government service. 

January 13 _ 20 22 ---~-------

Signatur.:: Date 

Name (Type or Print): Steven Adamske 
ETHICS PLEDGE 

As a condition, and in consideration, of my employment in the United States Government in an 

appointee position invested with the public trust, I commit myself to the following obligations, which I 

understand are binding on me and are enforceable under law: 

I. I will not, within 5 years after the termination of my employment as an appointee in any executive 

agency in whic.h I am appointed to serve, engage in lobbying activities with respect to that agency. 

2. If, upon my departure from the Government, I am covered by the post-employment restrictions on 

communicating with employees ofmy former executive agency set forth in section 207(c) of title 18, 

United States Code, I agree that I will abide by those restrictions. 

3. In addition to abiding by the limitations of paragraphs I and 2, I also agree, upon leaving 

Government service, not to engage in lobbying activities with respect to any covered executive branch 

official or non•career Senior Executive Service appointee for the remainder of the Administration. 

4. I will not, al any time after the termination of my employment in the United States Government, 

engage in any activity on behalf of any foreign government or foreign political party which, were it 

undertaken on January 20, 2017, would require me to register under the Foreign Agents Registration Act 

of 1938, as amended. 

5. I will not accept gifts from registered lobbyists or lobbying organizations for the duration of my 

seivice as an appointee. 

6. I will not for a period of2 years from the date ofmy appointment participate in any particular matter 

involving specific parties that is directly and substantially related to my former employer or former 

clients, including regulations and contracts. 

7. If I was a registered lobbyist within the 2 years before the date of my appointment, in addition to 

abiding by the limitations of paragraph 6, I will not for a period of 2 years after the date of my 

appointment participate in any particular matter on which I lobbied within the 2 years before the date of 

my appointment or participate in the specific issue area in which that particular matter falls. 

8. I agree that any hiring or other employment decisions I make will be based on the candidate's 

qualifications, competence, and experience. 

9. I acknowledge that the Executive Order entitled "Ethics Commitments by Executive Branch 

Appointees," issued by the President on January 28, 2017, which I have read before signing this 

document, defines certain terms applicable to the foregoing obligations and sets forth the methods for 

en orcing them. I expressly accept the provisions of that Executive Order as a part of this agreement 

as binding on me. I derstand that the obligations of this pledge are in addition to any statutory or 

o er legal restrictions a pl cable to me by virtue of Government service. 

,;:72/J[/J u}e,r{Cy ACwtK.C 

Print or type your full name (last, "first, middle} 
From: 

To: 

Subject: 

Date: 

Attachments: 

Tente Meghan 

Walsh Frank 

RE: FOR ETHICS SCREENING - FW: Request for Seriatirn Concurrence - Citibank, NA et al. (Off-line Cornrns) 

Thursday, September 15, 2022 10:46:05 AM 

irnaoeOOl.pnq 

irnaoe002.ono 

irnage003.ong 

1ma9e004.ong 

imaoe005.pnq 

imaoe006.ono 

Thank you! I just let the Secretariat know. 

From: Walsh, Frank <FWalsh@CFTC.gov> 

Sent: Thursday, September 15, 2022 10:22 AM 

To: Tente, Meghan <MTente@CFTC.gov> 

Subject: RE, FOR ETHICS SCREENING - FW: Request for Seriatim Concurrence- Citibank, NA et al. 

(Off-line Com ms) 

Meghan, 

Great catch and you are absolutely correct. Commissioner Pham must recuse from Citi particular 

matters for two years, and we are within that timeframe. 

Thanks, 

Frank 

From: Tente, Meghan <IVl I E:ru:(WCI I c.,,uv> 

Sent: Thursday, September 15, 2022 9.30 AM 

To: Walsh, Frank <F\'V2lsh0JCFTC..(Jov> 

Subject: FW: FOR ETHICS SCREENING - FW: Request for Seriatim Concurrence - Citibank, NA et al. 

(Off-line Com ms) 

Hi Frank, 

Am I right that Comm. Pham is recused from this case? l

1

d just appreciate the double-check. 

Meghan 

From: Kirkpatrick, Chris <Cl(i1·kpa:rick1'WCFTC.gov> 

Sent: Wednesday, September 14, 2022 6:34 PM 

To: Rowland, Matthew <lv1Ro1.,vl;;r1d·lilCITC.ecw>; Flood, Nora <Nilood(iilCITC gov>; Mastrogiacomo, 

Elizabeth <IIVl2strogiJCOtTo(SlC.FTC.gov>; Tente, Meghan <MTcntc(WCFTC.':'OV> 

Cc: Charley, Willie <'vVCharleyr'.iJCFTC.gov>; Sidman, Robert <RS1J1~1an I'WCFTC.gov>; Kirkpatrick, Chris 

<CK1rlqJalr1ck(WCI I C.t'UV> 

Subject: FOR ETHICS SCREENING - FW: Request for Serrat1m Concurrence - Citibank, NA et al. (Off-
line Com ms) 

Good evening, 

The attached DOE matter {Citibank, N.A. et al. (Off-line Comms)} has been approved by the 

Chairman's Office for seriat1m circulation. Would you please conduct an ethics screening on behalf 

of your respective Commissioners, and let us know if your Commissioner is cleared to participate in 

this matter? 

Please feel free to contact me with any questions. Thank you. 

Chris 

Christopher Kirkpatrick 

Secretary of the Commission 

Office of the General Counsel 

Commodity Futures Trading Commission 

0: 202-418-59641 C: 202-378-7405 

CKirkpatrick@cftc.gov 

i] i] i] i] 

From: Wedewer, Harry E <H\Vede,ver (WCI I c.,,uv> 

Sent: Tuesday, September 13, 2022 6:53 PM 

To: lnbox- Secretariat <lnboxSccrctJr1;:it01CFTC.. 0 ov> 

Cc: Faulk-White, Donna <DFaulk-'vVhite(@CFTC.gov>; Smalls, Nisha <NSmalls(@CFTC.gov>; OCC 

Circulation <UCCC1rculc l1u1·,/tilCI I C.t'uv>; Cantley, Brent <BC:mlley 'liJCI I Lt'OV> 

Subject: Request for Seriat1m Concurrence - C1t1bank, NA et al. (Off-line Com ms) 

(b)(5) 
Thanb so much. 

Harry 

Harry E. W'edewer 

Assistant Chief Counsel 

Dt,,ision of Enforcement 

Commodity 1-<"uturcs Trading Com1nission 

202-418-5189 (Desk) 

202-641-5822 (Cell) 

h \\ -ed C\\TrftL cftc., '( )\" 

WARNING, This message is intended only for the use of the addressee and may contain information 

that is privileged, proprietary in nature, or otherwise protected by law from disclosure. If you are 

not the addressee, you are notified that reading, copying, or distributing this message is prohibited. 

If you have received this message in error, please telephone or reply to me immediately and delete 

all copies of the message from your computer systems. 
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C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

Senate Confirmed Presidential Appointee 

'' ,, , •,;111,I, I. <I I,,. ( 1(,1 

a. ,-\ppointee's :['\;ame: Caroline Pham 

'' " l '·"I'" I d I,. I I(, I 

b. Position Title: Commissioner 

'' " l '·"I'" I d I,. I I(, I 

L c. ,\gency: Commodity Futures Trading Commission 

Appointee's '" ic· ,,,·,,1,k-1.,I In I H ,I 

Information d. Date Ethics Agreement Sit-,'lled: December 20, 2021 

'' ,,· c '"'l'kh,I I, I l(, I 

e. Date Confirmed: March 28, 2022 

f. Dul' Dak for Certification of Ethics '' ,, ,•,;111,I, I. <I 1,-. ( 1(,1 

Agreement Compliancl': July 5, 2022 

I m111pieted all r:ft/Je res{ltnatio11s imlic,:ted m 

2, mr etlws t\'.f,llY111mt hr/Ure I as,-11111ed the d!ftir,-

{!)Yes QNo ~/my Clf/T/'llt _'<,IJl'f/7/11/U/t positio11. 01'/A Resignations 

a. I h11rc cu111pletcd 11!! ~/the dir'eslit11res 

i11ditaffd in n,y et/Jin t{~1w111e1il. 1 a/rf! 

{!)Yes O1\,;o o:\'/1\ Hl/(kr.rfalld that f !llt!)' uo/ np11rrhaH !hf.fr 

,:sse/s d11rl!l,'.f, m_y appomt111t11t IJ'lf!Jout 

3, OCI :· ',- prwr apprut'11!. 

Divestitures b. I ha!'c Jikd a ptrif!dic tmmac!io11 npor!, 

{!)Yes 0° orpniodir Qs:/A lra11.rac!io11 rrpm1s, (OC,'h 

/ ,-rm11-'f; to disclose the rot11pletio11 r?fthese 

t\'.f,!l'Cd 11pu11 d1rcstitures. ['iliog Date(s) of OGE forrn 278- r Report(s): 

June 14, 2022 

4. 

!/! ha!'f a mana,2,td arm11nt or !!st thr .ren'ices 

qf,m 1111·estme11t p,r:fi'ssio11al, I ha/"/' 11Mijled the 

Managed mmhtY,er or J!ivfrmu11al ~/ the limitatium QYes O:\'o @~;, 

Accounts i11ditaffd in fll)' et/Jin t{~1w111e1il. in additiu11, 

I a111 a,11ti1111i1i2, to t1H111itorp111dJases. 

f comphai wi!h N()' i11kri111 lffHJa! ob/{2,aliM.r 

5. pe11di1{'< the dil"l'stitmrs n-quired 0Y 119· ethics 

Interim t{f!,IWl/!e/Jt. {!)Yes OJ",.;o 01'/A 

Recusals 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 1 
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C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

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" /1.r !Wjltfrrd hJ· /8 ( .S.C. J 208, I IJ'l'f! 

6. m11t/111!<' to 1n11re fmm f!m1imlar 111atk1:r /11 

Recusals Jl'hic/1 I k 11on· I lwl'e a pn:ro11al ,,r i111p11ttd 

_fi11,111cfa/ !11tnnt d!red!y ,111d pirdid,i!,IJ' affrdrd 

(Note: These h)' tlw 111atkr, 1111/ts.r I 1rrell·e a 11·a/1·tr or q1wh/J' 

factual statements 

_for t1 rP/!,lllatol]' rxe111f!lf1111. 

describe the b. I am recusingjivtt1 particular matters in 

appointee's curnnt which a,ry former empll!yer or client I served in 

status. Thq are the past year is a par(:y or represents a pa,ty, 

not intended to unless I have been authorized under 5 C.F.R 

modify ethics § 2635.502/d). 

agreement c. I JIJJ remsi1~v,jiv111 partim/ar IJJ,i!ters !!I 

commitments or 

create new recusal 

n·hich J/(Jji,rmer t!llp!o]'tr or climt I se1Ted 

obligations.) 

111 thr two rum· /mor to !IIY ap/10111t11mIt ts a 

par!)' rir represents ii par!)', 1mk,s I hal'e 

nai1·ed ii IJ'ail'er 111Nkr /-:.,-fl: Order 1 3989. 

a. I recet!'ed a I1YIIrer pm,-u,mt tu l8U.S.C. 

§ 20X. 

7. I '-''- llh lc.l'c' ·],c· d.11c·<>1 ·I,, \\ .. 1,,, .n,I 

n,l c .. l, I ,,. 1·11 .. 11, ,,I 1"11c'lc" I ''" c·ic·d I,., I ,,. 

Waivers and \, ,LI'" I 

Authorizations Ii. I nwi1'ffl a 11•al1•erpm:mi1J1! lo 1--'.:xemli!'f 

Order I J9X9. 

(Consult with 

your I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I I h. 

agency's ,ul ,1,·c , ,I I 'c' \, ,ll', c'l '"" ·''l'l" .. , " .ll.L'1.t:'I 

DAEOif "' ·I,, ,·11 ,,, ,,L,I,_,·_ t ,llll,' . ll,l' lc'.I ,l' ll',Lll,1,_ 

uncertain 'I'' c I 1· l I'' '.I, .ll c· .. ,_ ,l' .lt'l 'l,c " r. 

under what I trCfi1'ffl an m!l/w1i:zatio11 pm;rIIa11t lo 

authority a 

C 

5 Cl·Y. § 263'i.502(dJ. waiver or 

authorization 

was granted.) I '', 111''1{ ,-, ',-, ,,j I .ii·,,- / 1·1 ,11 .n,I 

" '1lfl"' l1e c, '-"" d l''r",11 ,. ·' r,' \\ 11 ,.n \,,ll 

l·.1\, "'" I .ii·,,- '" I • .. 1·, ,, 11·, r , -- •I' ',. ,,-, 

f ,1"111' ,l1e,·1 'I"'"' ,,11T,,.,,-, 'I"''"' 

'"" r, --,, il1,,·1 " 

d. I f"l'ffil'erl,: wairerpursm111! to 5 Cl .R. 

§ 2635.503(cj. 

I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I 

IL c'l11 I'' ·I,, ·«1·1,,1 c'""l'l,n . "' ,, ... " 

(!)ves 0 ~() 

@Yes ONo ON/A 

@ves ONo ON/A 

QYcs {!)No 

Date: 

financial interest: 

O," <!'10 

Dak: 

Sub1ect: 

0 Yes (!)No 

Dak: 

(:(ffCrcd person(~): 

Ovcs {!)No 

Dak: 

Former employer or payer: 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
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8. 

a. if 1 c01111vi!ffd !ha! 111·011/d 

Jhifeil a /i111111cia/ i11!em! or 

Payments, p,!)'fllffll, 1mkrs it was 

Accelerations, f"l'l"l'il"l'd or arcden:ted prior to 

or Divestitures Mark this 111r ass11m/1tw11 ~/the dlttirs 

Required to be box if not of !hf ,~01·en1111e1il po_,ifio11: 

Completed applicable: 

Prior to 

Entering 0 b. Financial interest or 

Government paynwnt at issut': 

Service 

I hcll't m111p!eted II()' initial ethirs lm'iji1i2., 

plf/J"/11111! to 5 C.F.R. § 2638.305. 

9. 

Requirements 

for Regular l /1(1/'f -•(~11ed the dhic_, plu(~e p11rma11/ lo 

Appointees J-:xw11iil'f Order 1 3989. 

' ' •'c l• •1llt•Li,d )' ()(,I 

10. I am recusing from particular 

Additional matters that will have a direct and 

Ethics predictable effect on the financial 

Agreement interests of my family trust. 

Requirements 

11. 

Comments of 

Appointee 

0 1 rm·ired ii (or ii //'(JS aaeifm!ed) /!rior lo 111)' 

msm11ptio11 of thl' d11fin o/!he posilim1. 

0 I rmi1·ed it (or jfwas ,lffdm:ted '!tier m_y 

ass11111ptiofl of thr duties of the position. 

0 J }rlljh'ted it. 

(!) Yes 0 '\Jo QN/A 

{!) Yes 0 ~() Q:--:n 

' ' •'c l"1llt•Li,d )' .. 1 ,;,, JI[' I cc' 

111111 i"o111plri1z~ 11·ith these nq11ire111e1ils tH rkJCribcd i11 

thr arfr'acmt box. 

@Yes o~() Q:--:/A 

Any intentionally false or misleading statement or response provided in this certification is a violation of law 

punishable by a fine or imprisonment, or both, under 18 U.S.C. § 1001. 

I certify that the information 1\ppointet"s Si,1..,>t1aturt': Date: 

I have provided is complete CAROLINE PHAM D1g1tJlly s,gned by CAROLINE PHAM 

Date. 2022.07 01 12·39·38 -04'00' 

and accurate. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 3 
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Privacy Act Secti(>n 1 JIJ (>f rhe l•,thics in Gm·ernmenr ,\er of !978, as amended, reLJuires rhe reporting of thi, informati{Jn. The 

Statement primary use of the information on this report is for rc\'iew h)' Co\'crnmcnt officials to determine an appointee's 

compliance with applicable Federal laws and regulations, and the appomtee's Ethics r\greement. Failure to pro\·idc 

rhe reL1uested inf(>rn1ati(lll may re,ulr in ncJrificaticJn {Jflack cJf ccJmpliance t(J the Senate and rhe head cJfthe 

appointee', agency, or the \\'hitc I lou,c, and/or could rc,ult in (JC!: declining to certify the appointee', financial 

disclosure reports. The appointee could abo be relJUired to recuse from matters ba~ed on uncntainty a~ to 

\\·hethcr the)' ha\'c di\'estcd or resigned from a matter determined to raise potcntialconflicts. 

This information will he puhlicall) posted to the ()GI•: wehsire ar \1 \1 \'.-.<"'"-"''1 in accordance 

\\·ith ( J(, l. ( ,( )\ "] '_ 1, I (;..ccuti\ c Branch Per,onncl Public financial Disclosure Reports and ()tl1cr \:iameRetrien·d Ethics Program Records (routine· use "k."). Pb1se se·e· ( l(; I . (;( )\ I I for more information about 

rhe maintenance and disclosure of this informarion. 

Your posinon as one of our gonTnmcnt's most senior leaders bnngs with it extraordinary· responsibilities. One of 

Filing the those responsibilities is to serve as a rok· model for all necutive branch e·mployee~ by demonstrating ;1 commitme·nt 

Certification to ethical principles and acti\'cly seeking to a\'oid conflict, of intcrc,t. This includes compliance \\ith the ethics 

of Ethics agreement you signed prior to and as a condition of y·our confirmation. By s11-,>t1mg this Certification of Ethics 

/\.greement ,\greement C m1pliance (Certificati{ Jn) ) ou certify that )'( >LI ha\·e n Jmplied \\·ith the tem1, of )·our ethics agreement. 

Compliance The mformation below 1s mtendcd to help you timely· meet your obliganon to complete and subrrnt this form to the 

L:.S. Ofrice ofl~ovnnment Ethic~ (OGE). 

Y(l\l are relJUired to comp Ii· with the provisions of your ethics agreement within three months of the date of your 

confirmation, unlcc;c; otherwise specified. Plca,c: 

• ReYicw your ethics agreement carefully· . 

• lf :our ethin agreement requires :ou t{J resign fnJm an {Jutside p(>,ition, please rn>te thar resignari{HlS are 

generally reLJuired "upon confirmation." 

• ldcntif)' any prm i,ions of your ethic, agreement that may reL1uirc coordination \\·ith an account manager or 

other third party. 

• lninate any necessary· action early· enough to timely comply with your ethicsa1-,,rcement . 

• If you (Jualifr for and wish to request a Certificate of DiYesnturc, please submit your re(JUCst as soon as 

possibk· through your ;1gency's De·signated .,\gency Ethics ( )fficial (D,.\EC )) . 

If your ethics ;1greement specific~ that you ha Ye more than three months to comply with a p;1nicular proyision, i·ou 

must still comply \\ith the remaining prO\isions \\·ithin the standard three-month period and submit a Certification 

(through your agency's DAE()) withm seYcn days thereafter. If y·ou ha Ye not complied with a pro\·1s1on of your 

ethics agreement, please prm·ide an e,pbnarion in Box 1 l, Comments of .,\ppointee. You will he provided wirh an 

additional Certification to complete and submit to OCE to certify that you lune complied with all prO\isions of 

i·our ethic~ agre·ement. 

Extensions: OCE may gram an c;..ternion of time for complying \\ith a prm i,ion of your ethics a1-,>-rccmcnt if, in 

its sok· di~cretion, it dnermine~ that ;m unu~ual hardship ha~/will preYent you from complying time·ly. Generalli·, 

\\·aiting for an accounr manager to ,ell an interest, not being ahle to locate records, or wairing for ()GI•, to process a 

request for a Certificate of DiYcstiture arc not considered unusual hardships. r\s noted in the PriYacy ,-\cc 

Stateme·nt ;1bove, not submitting your Cenitin1tion mai· re·s1dt in notifin1tion of lack of compli;mce· to the· Se·m1k, 

the head of your agency, or the \\'."bite I lou,c. OCE may also decline to ccrtif)' your financial disclosure report,. 

You mai· abo be· relJUired to recuse from m;1tters base·d on uncerrninty as to whether you h;n·e· completed relJUired 

di\'esritures and resignati{HlS. ()GI•: ma) als(> p(>',t a rn>tice on its \\·ehsite, in place of :our Certificati{Jn, staring 

that you ha\T not yet subrrntted the reqmrcd certification. 

While it is your personal responsibility to take the steps necessary to comply v,,ith your ethics agreement, your 

agency's DAEO is available to assist you in completing this Certification and submitting it to OGE. Any 

questions you may have should be directed to your agency's DAEO. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 4 
.John Einstman 

Designated :\gem.:: Ftlm:s Offici~d 

Legal DI\ 1sinn 

D, .. TL·mher 2/J. 202 l 

i ·.s. Comnrndit) Fu1urcs Trading Commission 

Three Lal'a: L'tte Centre 

1155 21st Str...:...:t. '.\. \\". 

\\·ashington. DC 20581 

Dear r-.lr. Einstman: 

The purpose of this 1.-:tter is to descrihe the step.'-. that I \\ill take to ,noid an) actual or 

apparent conflict of interest in the ewnt that I am contirm...:d for the position of Commissioner 

for the l}.S. Commodity Futures Trading Commission ("CFTC'J. /1 i-; rn: n:sponsibilit: to 

understand and com pl: \\ ith commitments outlined in this agreement. 

SECTION 1 - GENERAL COMMITMENTS 

As required by criminal conflicts of interest law 18 lJ.S.C. § 208(al. I \\J]l not participate 

personally and substantially in any particular matter in \\-hich I knO\\. that I ha\·e a financial 

interest directly and predictably affected by the matter. or in which I know that a pnson \\hose 

interests are imputed to me has a financial interest directly and predictahly affected by the 

matter. unless I first obtain a written waiver. pursuant to 18 U.S.C. § 208(6)(1 ). or qualit~ for a 

regulatory exemption. pursuant to 18 lJ.S.C. § 208(h)(2). I understand that the interests of the 

following persons are imputed to me: 

• Any spouse or minor child of mine: 

• Any general partner ofa partnership in which I am a limited or general partner: 

• Any organization in which I serve as an officer. director. trustee. general partner 

or employee: and 

• Any person or organization with which I am negotiating or have an arrangement 

concerning prospective employment. 

In the event that an actual or potential conflict of interest arises during my appointment I 

will consult with an agency ethics official and take the measures ncccssaD to rcsoln:: the 

conflict. such as rccusal from the particular matter or di\'cstiture of an asset. 

If I have a managed account or otherwise use the scrYices of an investment professional 

during my appointment. then I will ensure that the account manager or im·estment professional 

obtains my prior approval on a case-by-case hasis for the purchase of any assets other than cash. 

cash equivalents. investment funds that qualify for the exemption for diversified mutual funds and 

unit investment trusts at 5 C.F.R. S 2640.201(a). obligations oflhc United St.-iks. ,)r municip.-il blllHk 
l \\ 111 rccci\'c a li, c c1hic-; hriding from a lllL'lllhl'r or lhL' ethic, onicc afk-r rn) 

c1llllir111c1tion. hu1 nut lakr than 15 day:-, alter my appointment. pursuant 10 the ethic-; program 

rcgubt1011 at 5 C 1: R. ~ 26.lX.305. Within 90 days ofmy conJirnrntion. I \\ill :-,uhmil my 

Ccrtificalion (l!Tthics Agreement Compli,mcL· \\hich documents !ll) complianu:: \\ith th1:-, ethic:-, 

agreement. 

I understand that as an appointee I \\ill be required to sign the l:thics Pledge (Lxec Order 

'.\o. 1.1989) and that I \\j]] be hound by ii. /\n10ng other obligations. I will he required to recuse 

111) self from particular matter:-, inn1\ving specilic parties im·olving my former emplo) er or 

former clients for a period ot"l\\o years after I am appointed. \\ith the exccrtion or t\::deral. state. 

and local gtivcrnment 

I \\"ill not modify this ethics agreement without:, our approval and the apprO\·al of the 

U.S. Office of Go\·ernment Ethics pursuant to the ethics agret::ment requirements contained 

\\ithin the financial disclosure regulation at 5 C.F.R. ~ 2634.803(a)(4). 

SECTIO:sl 2 - CIT! 

Upon confirmation. I will resign from my position \\ith Citigroup (J!obal l'vfa.rkcts Inc. 

( .. Citi .. ). I hold un\'estcd deferred stock. Citi has informed me that. consistent\\ ith internal 

policy. they \\·ill (1) cancel 25% ofrny unvested deferred stock, and (2) distribute the remaining 

unvested deferred stock as soon as administratively practicable thereafter. I will di Yest or forfoit 

all ofmy interests in Citi as soon as practicable but not later than 90 days after m~ confirmation. 

I will not participate personally and substantially in any particular matter that to my knO\\ ledge 

has a direct and predictable effect on the financial interests ofCiti until I ha\'e di\'ested it. unkss 

I first obtain a written waiwr. pursuant to 18 lJ.S.C. ~ 208(6)( I). or qualify for a regulatory 

exemption. pursuant to 18 U.S.C. S 208(6){2). I have verified that I \\'ill be ablc to carr: out thi: 

diYestiturcs within the timeframe described aho\'e. In addition. ifCiti decides to pay me a bonus 

for work I performed during 202L I \Viii not accept the bonus and will forfeit it. unless I rcceiYe 

the bonus before I assume the- duties of the position of Commissioner. Pur.su~mt to the 

impartiality regulation at 5 C.F.R. ~ 2635.503, if I receive the bonus. I will not participate 

personally and substantially in any particular matter invoh·ing specific parties in\\ hich Citi is a 

party or represents a party for a period oft\\O years from the date on \\hii:h I receive the bonus. 

unless I first receive a written waiver pursuant to 5 C.F.R. ~ 2635.50](c). Pursuant to the 

impartiality regulation at 5 C.F.R. ~ 2635.502, if! do not receive the bonus. I \\ill not participate 

personally and substantially in any particular matter in\'olving spccifa:: parties in \\hich l knm\ 

Citi is a party or represents a party for a period of one year from the datl' of my resignation. 

unless I am first authorized to participate. pursuant lo 5 C.F.R. * 26J5.502(d). 

SITTIO:si 3 - IJIVESTrn:RFS 

As soon as practicable. but not later than 90 days alter my cnntirmation. I will diH·st my 

interests in the fo!!(ming: 

• Ethercum (Coinhase account) 

1 
With rq,!:ird to thi-, \irtual currency. I \\ill not part1upak pn'>nnally and-,uh'>tant1all_\ in an;-

p:irticul:ir rnattcr that. tom;- knm\ !edge. has a Ji red and pn.:Jictahle cffci.:t on the financial 

inll"rc'>IS of the \·irtu:il curn.::nc;, until I ha\'c Ji\cstcd it. unlcs-" I lir'>t obtain a \\nttcn \\ai\cr. 

pursuant to l XI :.s.c·. ~ 20X(b)( 1 J I ha\c \'crilied that I \\ill be c1hk hi carr;, out the di\-cs;11turc:--

\\ithin the t1mcframc dcscrib,xl ahmc. 

I understand that I may be c!ig1hlc to request a Certificate or Divestiture for qualit\ing 

usscts and th.it a Ccrtificutc ofDi\cstiturc is dlccti\e on!;, ifohtaincd prior tu di\cstiturl.! 

Regardless of,\hcthcr I recciH· a (\::rtificatc ofD1\'cstitun.:. I ,,ill ensure that all di\cstiturc:--

disi.:usscd in this agreement occur within the agrecd upon timcframes and that all proceeds arc 

m, cstcd in non-conflii.:ting ussets. I understand that I must submit in a time I) fo-.hion my request 

for a Cc11ificatc ot" Di\·cslilun.: 10 allow for adequate time for O(jl; to process the ('i.::rtificzite of 

Di\'cstitun::. and in order to di Yest assets\\ ithin the agreed upon time frame 

I (including my spouse and dependent children ifc1ppllcahle) \\ill not repurchc1sc any 

asset I was rc4uircd to divest \\ithnut consulting with an ugeni.:y ethics ollicial and the l ·.s. 

Onice of (Jo\'ernmcnt Ethics. 

SECTION 4 OUTSIDE POSITIONS 

I \\ill retain my position as a trustee of the Family Revocable Trust#]. I \\ill not rccei,c 

any fees for the services that I provide as a trustee during my appointment to the position of 

Commissioner. I will not partieipc1te personally and substantially in any particular matt("r thc1t 10 

my knowledge has <1 direct and predictable effect on the financial interests of the Family 

Revocable Trust #L unless I first obtain a written waiver. pursuant to 18 Li.S.C. ~ 208(6)( 1 ). or 

qualify for a regulatory exemption. pursuant to 18 U.S.C. ~ 208(6)(2). 

SECTION 5 - PUBLIC POSTING 

I h::J.Ye been advised that this ethics agreement and the Certification of Ethics Agreement 

Compliance will be posted publicly. consistent with the public information law a 5 L.S.C. ~ 552. 

on the website of the U.S. Office of Government Ethics with ethics agreements of other 

Presidential nominees who file public financial disclosure reports. 

Sincerely. 

Caroline Phmn 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

Senate Confirmed Presidential Appointee 

'' ,, , •,;111,I, I. <I I,,. ( I( ,I 

a. ,-\ppointee's :['\;ame: Summer Mersinger 

'' " l '·"I'" I d I,. I I(, I 

b. Position Title: Commissioner 

'' " l '·"I'" I d I,. I I(, I 

L c. ,\gency: Commodity Futures Trading Commission 

Appointee's '" ic· '"""l'k,.,I In I H ,I 

Information d. Date Ethics Agreement Sit-,'lled: January 13, 2022 

'' ,,· c '"'l"kh,I I, I l(, I 

e. Date Confirmed: March 28, 2022 

f. Dul' Dak for Certification of Ethics '' ,, ,•,;111,I, I. <I 1,-. ( 1(,1 

Agreement Compliancl': July 5, 2022 

I m111pieted all r:ft/Je res{ltnatio11s imlic,:ted m 

2, mr etlws t\'.f,llY111mt hr/Ure I as,-11111ed the d!ftir,-

Qves QNo ~/my Clf/T/'llt _'<,IJl'f/7/11/U/t positio11. {!)1'/A Resignations 

a. I h11rc cu111pletcd 11!! ~/the dir•esl!t11res 

i11ditaffd in n,y et/Jin t{~1w111e1il. 1 a/rf! 

Qves O1\,;o @:\'/1\ Hl/(kr.rfalld that f !llt!)' uo/ np11rrhaH !hf.fr 

,:sse/s d11rl!l,'.f, m_y appomt111t11t IJ'lf!Jout 

3, OCI :· ',- prwr apprut'11!. 

Divestitures b. I ha!'c Jikd a ptrif!dic tmmac!io11 npor!, 

Qves 0° orpniodir (!):s/A lra11.rac!io11 rrpm1s, (OC,'h 

/ ,-rm11-'f; to disclose the rot11pletio11 r?fthese 

t\'.f,!l'Cd 11pu11 d1rcstitures. ['iliog Date(s) of OGE forrn 278- r Report(s): 

4. 

!/! ha!'f a mana,2,td arm11nt or !!st thr .ren•ices 

qf,m 1111·estme11t p,r:fi'ssio11al, I ha/"/' 11Mijled the 

Managed mmhtY,er or J!ivfrmu11al ~/ the limitatium QYes O:\'o @~;, 

Accounts i11ditaffd in fll)' et/Jin t{~1w111e1il. in additiu11, 

I a111 a,11ti1111i1i2, to t1H111itorp111dJases. 

f comphai wi!h N()' i11kri111 lffHJa! ob/{2,aliM.r 

5. pe11di1{'< the dil"l'stitmrs n-quired 0Y 119· ethics 

Interim t{f!,IWl/!e/Jt. Qvcs OJ",.;o {!)1'/A 

Recusals 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 1 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

" /1.r !Wjltfrrd hJ· /8 ( .S.C. J 208, I IJ'l'f! 

6. m11t/111!<' to 1n11re fmm f!m1imlar 111atk1:r /11 

Recusals Jl'hic/1 I k 11on· I lwl'e a pn:ro11al ,,r i111p11ttd 

_fi11,111cfa/ !11tnnt d!red!y ,111d pirdid,i!,IJ' affrdrd 

(Note: These h)' tlw 111atkr, 1111/ts.r I 1rrell·e a 11·a/1·tr or q1wh/J' 

factual statements 

_for t1 rP/!,lllatol]' rxe111f!lf1111. 

describe the b. I am recusingjivtt1 particular matters in 

appointee's curnnt which a,ry former empll!yer or client I served in 

status. Thq are the past year is a par(:y or represents a pa,ty, 

not intended to unless I have been authorized under 5 C.F.R 

modify ethics § 2635.502/d). 

agreement c. I JIJJ remsi1~v,jiv111 partim/ar IJJ,i!ters !!I 

commitments or 

create new recusal 

n·hich J/(Jji,rmer t!llp!o]'tr or climt I se1Ted 

obligations.) 

111 thr two rum· /mor to !IIY ap/10111t11mIt ts a 

par!)' rir represents ii par!)', 1mk,s I hal'e 

nai1·ed ii IJ'ail'er 111Nkr /-:.,-fl: Order 1 3989. 

a. I recet!'ed a I1YIIrer pm,-u,mt tu l8U.S.C. 

§ 20X. 

7. I '-''- llh lc.l'c' ·],c· d.11c·<>1 ·I,, \\ .. 1,,, .n,I 

n,l c .. l, I ,,. 1·11 .. 11, ,,I 1"11c'lc" I ''" c·ic·d I,., I ,,. 

Waivers and \, ,LI'" I 

Authorizations Ii. I nwi1'ffl a 11•al1•erpm:mi1J1! lo 1--'.:xemli!'f 

Order I J9X9. 

(Consult with 

your I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I I h. 

agency's ,ul ,1,·c , ,I I 'c' \, ,ll', c'l '"" ·''l'l" .. , " .ll.L'1.t:'I 

DAEOif "' ·I,, ,·11 ,,, ,,L,I,_,·_ t ,llll,' . ll,l' lc'.I ,l' ll',Lll,1,_ 

uncertain 'I'' c I 1· l I'' '.I, .ll c· .. ,_ ,l' .lt'l 'l,c " r. 

under what I trCfi1'ffl an m!l/w1i:zatio11 pm;rIIa11t lo 

authority a 

C 

5 Cl·Y. § 263'i.502(dJ. waiver or 

authorization 

was granted.) I '', 111''1{ ,-, ',-, ,,j I .ii·,,- / 1·1 ,11 .n,I 

" '1lfl"' l1e c, '-"" d l''r",11 ,. ·' r,' \\ 11 ,.n \,,ll 

l·.1\, "'" I .ii·,,- '" I • .. 1·, ,, 11·, r , -- •I' ',. ,,-, 

f ,1"111' ,l1e,·1 'I"'"' ,,11T,,.,,-, 'I"''"' 

'"" r, --,, il1,,·1 " 

d. I f"l'ffil'erl,: wairerpursm111! to 5 Cl .R. 

§ 2635.503(cj. 

I 111, ''" ,-, h, ,Ill, •,r h ,. ' ,--,<I 

IL c'l11 I'' ·I,, ·«1·1,,1 c'""l'l,n . "' ,, ... " 

(!)ves 0 ~() 

@Yes ONo ON/A 

@ves ONo ON/A 

QYcs {!)No 

Date: 

financial interest: 

O," <!'10 

Dak: 

Sub1ect: 

0 Yes (!)No 

Dak: 

(:(ffCrcd person(~): 

Ovcs {!)No 

Dak: 

Former employer or payer: 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

8. 

a. if 1 c01111vi!ffd !ha! 111·011/d 

Jhifeil a /i111111cia/ i11!em! or 

Payments, p,!)'fllffll, 1mkrs it was 

Accelerations, f"l'l"l'il"l'd or arcden:ted prior to 

or Divestitures Mark this 111r ass11m/1tw11 ~/the dlttirs 

Required to be box if not of !hf ,~01·en1111e1il po_,ifio11: 

Completed applicable: 

Prior to 

Entering 0 b. Financial interest or 

Government paynwnt at issut': 

Service 

I hcll't m111p!eted II()' initial ethirs lm'iji1i2., 

plf/J"/11111! to 5 C.F.R. § 2638.305. 

9. 

Requirements 

for Regular l /1(1/'f -•(~11ed the dhic_, plu(~e p11rma11/ lo 

Appointees J-:xw11iil'f Order 1 3989. 

' ' •'c l• •1llt•Li,d )' ( 1(,1 

10. I am recusing from particular 

Additional matters involving specific parties 

Ethics in which I know a client of my 

Agreement spouse is a party or represents a 

Requirements party. 

11. 

Comments of 

Appointee 

0 1 rm·ired ii (or ii //'(JS aaeifm!ed) /!rior lo 111)' 

msm11ptio11 of thl' d11fin o/!he posilim1. 

0 I rmi1·ed it (or jfwas ,lffdm:ted '!tier m_y 

ass11111ptiofl of thr duties of the position. 

0 J }rlljh'ted it. 

0 Yes 0 '\Jo QN/A 

0 Yes 0 ::,..;: () Q:--:n 

' ' •'c l• •1llt•Li,d ' .. 1 ,;,, JI[' I cc' 

111111 i"o111plri1z~ 11·ith these nq11ire111e1ils tH rkJCribcd i11 

thr arfr'acmt box. 

@Yes o~() Q:--:/A 

Any intentionally false or misleading statement or response provided in this certification is a violation of law 

punishable by a fine or imprisonment, or both, under 18 U.S.C. § 1001. 

I certify that the information 1\ppointet"s Si,1..,>t1aturt': Date: 

D1~1lally signed by SUMMER 

I have provided is complete SUMMER MERSINGER MERSINGER 

and accurate. Dato 2022 061516 50 07 -04'00' 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 3 
l .S. ( ll J'IU· ( ll' Ci J\'l'.R:\\11·:\T l·TJ ITCS 

C<Tt1fo·cit1o!l ut" I· thl<, .\gT<·rn1<·nt ( "rnpl1cinn· 

-'_l'd,ru,m 211.!.l ,cr,i,,n) 

Privacy Act Secti(>n 1 JIJ (>f rhe l•,thics in Gm·ernmenr ,\er of !978, as amended, reLJuires rhe reporting of thi, informati{Jn. The 

Statement primary use of the information on this report is for rc\'iew h)' Co\'crnmcnt officials to determine an appointee's 

compliance with applicable Federal laws and regulations, and the appomtee's Ethics r\greement. Failure to pro\·idc 

rhe reL1uested inf(>rn1ati(lll may re,ulr in ncJrificaticJn {Jflack cJf ccJmpliance t(J the Senate and rhe head cJfthe 

appointee', agency, or the \\'hitc I lou,c, and/or could rc,ult in (JC!: declining to certify the appointee', financial 

disclosure reports. The appointee could abo be relJUired to recuse from matters ba~ed on uncntainty a~ to 

\\·hethcr the)' ha\'c di\'estcd or resigned from a matter determined to raise potcntialconflicts. 

This information will he puhlicall) posted to the ()GI•: wehsire ar \1 \1 \'.-.<"'"-"''1 in accordance 

\\·ith ( J(, l. ( ,( )\ "] '_ 1, I (;..ccuti\ c Branch Per,onncl Public financial Disclosure Reports and ()tl1cr \:iameRetrien·d Ethics Program Records (routine· use "k."). Pb1se se·e· ( l(; I . (;( )\ I I for more information about 

rhe maintenance and disclosure of this informarion. 

Your posinon as one of our gonTnmcnt's most senior leaders bnngs with it extraordinary· responsibilities. One of 

Filing the those responsibilities is to serve as a rok· model for all necutive branch e·mployee~ by demonstrating ;1 commitme·nt 

Certification to ethical principles and acti\'cly seeking to a\'oid conflict, of intcrc,t. This includes compliance \\ith the ethics 

of Ethics agreement you signed prior to and as a condition of y·our confirmation. By s11-,>t1mg this Certification of Ethics 

/\.greement ,\greement C m1pliance (Certificati{ Jn) ) ou certify that )'( >LI ha\·e n Jmplied \\·ith the tem1, of )·our ethics agreement. 

Compliance The mformation below 1s mtendcd to help you timely· meet your obliganon to complete and subrrnt this form to the 

L:.S. Ofrice ofl~ovnnment Ethic~ (OGE). 

Y(l\l are relJUired to comp Ii· with the provisions of your ethics agreement within three months of the date of your 

confirmation, unlcc;c; otherwise specified. Plca,c: 

• ReYicw your ethics agreement carefully· . 

• lf :our ethin agreement requires :ou t{J resign fnJm an {Jutside p(>,ition, please rn>te thar resignari{HlS are 

generally reLJuired "upon confirmation." 

• ldcntif)' any prm i,ions of your ethic, agreement that may reL1uirc coordination \\·ith an account manager or 

other third party. 

• lninate any necessary· action early· enough to timely comply with your ethicsa1-,,rcement . 

• If you (Jualifr for and wish to request a Certificate of DiYesnturc, please submit your re(JUCst as soon as 

possibk· through your ;1gency's De·signated .,\gency Ethics ( )fficial (D,.\EC )) . 

If your ethics ;1greement specific~ that you ha Ye more than three months to comply with a p;1nicular proyision, i·ou 

must still comply \\ith the remaining prO\isions \\·ithin the standard three-month period and submit a Certification 

(through your agency's DAE()) withm seYcn days thereafter. If y·ou ha Ye not complied with a pro\·1s1on of your 

ethics agreement, please prm·ide an e,pbnarion in Box 1 l, Comments of .,\ppointee. You will he provided wirh an 

additional Certification to complete and submit to OCE to certify that you lune complied with all prO\isions of 

i·our ethic~ agre·ement. 

Extensions: OCE may gram an c;..ternion of time for complying \\ith a prm i,ion of your ethics a1-,>-rccmcnt if, in 

its sok· di~cretion, it dnermine~ that ;m unu~ual hardship ha~/will preYent you from complying time·ly. Generalli·, 

\\·aiting for an accounr manager to ,ell an interest, not being ahle to locate records, or wairing for ()GI•, to process a 

request for a Certificate of DiYcstiture arc not considered unusual hardships. r\s noted in the PriYacy ,-\cc 

Stateme·nt ;1bove, not submitting your Cenitin1tion mai· re·s1dt in notifin1tion of lack of compli;mce· to the· Se·m1k, 

the head of your agency, or the \\'."bite I lou,c. OCE may also decline to ccrtif)' your financial disclosure report,. 

You mai· abo be· relJUired to recuse from m;1tters base·d on uncerrninty as to whether you h;n·e· completed relJUired 

di\'esritures and resignati{HlS. ()GI•: ma) als(> p(>',t a rn>tice on its \\·ehsite, in place of :our Certificati{Jn, staring 

that you ha\T not yet subrrntted the reqmrcd certification. 

While it is your personal responsibility to take the steps necessary to comply v,,ith your ethics agreement, your 

agency's DAEO is available to assist you in completing this Certification and submitting it to OGE. Any 

questions you may have should be directed to your agency's DAEO. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 4 
J,lllll,lfV 1 J, 2()22 -

.I l l ll 11 l: i 11 St 11 l, 111 

l)csig11c.1tcc.l Agl'tll'Y l~tl1ics ()f'fici,1I 

Lel!,t I l) i ,, is i( ln .. lJ .S. ( .l)llllllllOil V r:lltllfCS ·1·r,1di11g ('()llllllissi(}ll . ~ 

·1·11rcc 14,tf,,yctte ( ·c11tre 

1155 21st Street. N.\V. 

\\',1sl1ingtllll. l)(' 2()581 

Dear ~1r. Ei11sl111a11: 

1·11c pllrpllSC llt· tl1is letter is ltl describe tl1c steps tl1,1l I will take l<.) avoid a11y ,1cll1al <.lr 

,11111arcnt C<lntlict <lt· interest in tl1c c\i·cnt th,1t I a1n C<lnfirrncd f<lr the p<lsiti<>n <lf ( '<lrnrnissi<lner 

lt)r tl1c U.S. C'tlt11111tldity ~-t1lt1rcs ·1·r,1di11g l'o111111issi<.ltl ('"(-.FT('''). It is n1y rcspl>Jlsil->i)ity l<.> 

untlcrsta 11d ,1nJ C<lll1Jl ly ,vi th C<>111111 i t111cnts lllll Ii nc<.I in th is agrcc111cnt. 

SE('TIC)N I ·· <,ENEllAL l'OMMITMENTS 

As required b),. the cri111in,1l Cl>nflicts <>f interest l,t\\' ,it 18 U.S.('. * 2()8(a), I will n<>t 

particip,1tc pcrsllt1,111)' a11d subst,111tially i11 any partict1lar 111altcr in whicl1 I k11ow that I have a 

financi,11 interest directly and predictably ,,t·fcctcd by the matter. <>r in whicl1 I kn<>W tl1at ,, pcrsl>n 

,vl1osc interests arc in1pt1tcd t<.l 111c l1as a fi11a11cial i11tcrcst directly a11d predictably af'Jcctcd by tl1c 

p,1rtict1l,1r 1n,1ttcr. unless I first <>ht,tin a ,vritten Wttiver, 11t1rst1ant t<> 18 lJ.S.('. * 2()8(h)( I), l>r 

qt1alify tor a rcgt1lat<.)ry cxcn1pti<.l11. purst1a11l to 18 U.S.C. * 208(b)(2). I t1ndcrstand tl1at the 

interests of the tullo,,·ing persons ,ire i111pt1ted to n1e: 

• A11y sp<.)usc or n1inor cl1ild ot· n1i11c: 

• Any gcner,11 partner of a pa11ncrsl1ip in which I ,tm a li1nite<.l or gener,tl partner: 

• Any <lrga11izati(>n in \\'hicl1 I sen.re as a11 <>flicer, direct<>r, trustee. general partner, 

or cn1ploycc: and 

• Any pers<>n <>r <>rganiz,1ti(>n with ,vhich I arn ncg<.>ti,,ting <.lr h,t\'e ,,n arr,,ngernent 

co11ccn1i11g prospective cn1pl<.>ymc11l. 

In the C\'Ct1t tl1at an actual or potc11lial C<.)11Jlict of' i11tcrcst arises during n1y ,1ppoi11t111c11t. I 

,viii consult ,,,ith an agency ethics of'fici,tl ,,nd l,1ke tl1e n1e,1sures necess,try to resolve tl1e 

co11flict, such as rccl1sa1 J'ro111 tl1c particular n1attcr or divcslilt1rc ot· ,111 ~isscl. 

If I have a ma11,1gcd ,1ccol1nt or <)lher\visc lJSe tl1e services of ;111 i11vcst111c11t profcssiL111a1 

during n1y apptlir1tn1cnt. tl1en I will enst1re that the accot111t 111,111agcr or invcstn1ent professi()n,11 

obtai11s my prior apprc>,·al 011 a case-by-case basis ftlr tl1c pL1rcl1ase ot· ~111y ,lsscts otl1cr tl1,111 c,1st1. 

cash equivale11ts, in\1est111ent funds th,tt quality for tl1c rcgul,tt<.>ry cxc111ption for c.iiversific<.i 

I 
mutual funds and unit investment trusts at 5 C.F.R. § 2640.201(a), obligaticlns of the United 

States. or municipal bonds. 

I will receive a live ethics briefing from a member of the ethics office after my 

confi1111ation, but n<lt later than 15 days after 1ny app<lint1nent, pursuant tel the ethics pr<lgram 

regulation at 5 C.F.R. § 2638.305. Within 90 days of my confirrnation, I will st1bmit my 

Certification <.lf Ethics Agreement Cornpliance which d,Jcuments my cclmpliance with this ethics 

agreement. 

I understand that as an appointee I must continue to abide by the Ethics Pledge (Exec. 

Order No. 13989) that I previously signed and that I will continue to be bound by it. Among 

other obligations, I will be required to recuse myself from particular matters involving specific 

parties involving my for 111cr employer or for 111er clients for a period of two years after I am 

appointed, ,vith the excepti<.ln <lf federal, state, and local government. 

I will ntJt modify this ethics agreement without your approval and the appr<lval of the 

U.S. Office of Government Ethics pursuant to the ethics agreement requirements contained in the 

financial disclosure regulation at 5 C.l-'.R. § 2634.803(a)(4). 

SECTION 2 - SPOUSE EMPLOYMENT 

My spouse is the sole proprietor of his consulting fi11n, which does business as The Redto-Black Group. I will not participate personally and substantially in any particular matter that to 

my knowledge has a direct and predictable effect on the financial interests of The Red-to-Black 

Group, unless I first obtain a written waiver. pursuant to 18 U.S.C. § 208(b)(I). Pursuant to the 

impartiality regulation at 5 C.F.R. § 2635.502, I also will not participate personally and 

substantially in any particular matter involving specific parties in which I know a client of my 

spouse is a party or represents a party, unless I am first authorized to participate, pursuant t<l 

5 C.F.R. § 2635.502(d). 

SECTION 3 - PUBLIC POSTING 

I have been advised that this ethics agreement and the Certification of Ethics Agreement 

Compliance will be posted publicly. consistent with the public info1111ation law at 5 U.S.C. § 

552. on the ,vcbsite of the U.S. Office of Government Ethics with ethics agreements of other 

Presidential nominees who file public financial disclosure reports. 

Sincerely, 

ummcr Mersinger 

2 
l 1 S. 1 ll+ICE OF Gll\'ER!'<:..!ENT 1-.Tl l\l.S 

( :emlical.!on of 1-:!lucs :\grcrn,rn, C:ornpl1,u1c~ 

[hbrn,1ry 20~1 , er,ion) 

CERTIFICATION OF ETHICS AGREEMENT COMPLIANCE 

Senate Confirmed Presidential Appointee 

ro lw u,n1pktc-d hy ( l(;E 

a. Appointee's Name: Kristin Johnson 

'" ht 0>1nplctcd b: ()(;],: 

b. Position Title: Commissioner 

re, lw n,mpln,·d h)· ( )( ;1,. 

1. c. Agency: Commodity Futures Trading Commission 

Appointee's w lil' u ,mpkt,·,l \,)' l l(; I' 

Information d. Date Ethics Agreement Signed. September 23, 2021 

tn l,,· ccnnpl,·tnl b,- l lei I·. 

C. Date Confirmed: March 28, 2022 

f. Due Date for Certification of Ethic, to l,c c<1mplt-1ct.l l,1 ( l(,I,' 

Agreement Compliance: July 5, 2022 

I completed all of the resit,11alio11J i11di,<Jlcd in 

2. "!)' ethm a,greemml b~/Ore I asmmed th,, dutiu 

{!)Yes 1!f "!J mmnt p,ovemment p0Jitio11. ONo ON/A Resignations 

a. I havi' romp!ded a!! q/the dtN:,·1t!J111'.-

111dimted i11 !JI)' ethi,T ,wl'ement. I also 

{!)Yes QNo ON/A 1mderstand !hut I muy 110! rcpurd1u.,-e Ihm· 

mset.r drm11g ll'.J' appomtmwt 11.ithout 

3. OGF '.r pmr 11pprmia/. 

Divestitw:es b. / hawfi/ed a penodic trumadion report. 

{!)Y6 0° orperiod1t tr,mJadir//1 rtpori.1, (OGE ON/,\ 

/iorm-7) !11 d!fJ1m the mmp!etto11 q/thr:..-e 

"._grred 11pon di1.,cstit11rcs. hling Date(s) of OGE Fonn 278-T Rcport(s): 

HI h,11-,,· a m,ma._~ed acmrmt or me the un·it"es 

4. of,m i11w.,-/mml profusiona!, f ht1N 110l!JleJ the 

Managed m111111p,er orpmj'eSJio11u! ~/the limitulions QYcs QNo (!) N/,\ 

Accounts ind1u1ted 111 "!J' ethics O/!rcemmt. In additio11. 

I flm co11!i11ui11g to monitor pHrd,a . .-e.r. 

I mmplied with "!J' i11tm',1J n:msul ob1{5t1tio11J 

5. pmdl!tJ', the dinJ!if11ra nq11iml by ll!J' tt!ii,s 

Interim tiJ!,ri'ff!lf!I!. 

Rccu,,1, 

{!)Ye.s ONo ON/A 

THIS CERTIFICATION WIIL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 1 
LI S. 01· FICE ( ll• Cl)\ EllN~!l·N"l' l:TI I !CS 

r:~rt,!icoti,}n of Ethic, .\greemrnr C,mpli.rnn· 

(J•ebruary 211:1 Yersu.>n) 

" A, required h}' f8 USC§ :.l08, I wt!/ 

6. ,011ti1111e to r1'11/Je_f1vm pm1,;1i/ar nhlf!ers 111 

Recusals /11/mh I k11ow I /Ja/!t a pe1rn11tt! or 1mp11ted 

/immu,,/ 111/neJ/ 1/ired_!y am/ p1u/Jctabfy aj_lfcted 

(Note: These 

bi• the 111atffr, 1111/ns I reawe a JNJit•tr or q11ahfr 

fa.Illa/ statwmrt.r 

_for a 1~g11/,rfory e.,·emptwN. 

deHribt thr I,_ I am rwui,;gjiYJm pmtiCJ1!t1r llllllfen in 

a:ppointre'.r cumnt which lJl!J'.fimner empl[!rer or dim! I .reind 111 

Jlaf:1'J'. Thry are the paJl_year is a par!)' or reprmnls a pur(y, 

noJ inJmded to 11n!eJJ I have been a11tlrorr;_ed :mdn j C l·.R 

modify ethia § 2635.502(d). 

agrtemo:I l c1m mmi1;g_from partim!ar nMflrn in 

(l)mmi/ments or C 

,naJe new rt,usal whi,h <ll!J)immremployerordient I umed 

obligation.r.) 

i11 the !ivo_ye11n pnOr to "~J' appomlment ts t1 

parfJ• or reprr.ren!s a part)-', 1111/eff l ht1N 

receind a wamer under Ex,•,: Order/ 3')89. 

a. I recewed a 1v<1iver p11rmm1I lo /8 u.s.c 

§ 208. 

7. It ,c, ,nchc.ne rlic· cl.II" .,1 ,1,_, "'""'' :on,I 

,nJtcJll' the· fou[]u.d ][l[cr<,1 conrnl b) th,· 

\'Vai1;ers and \\Jl\'l'f. 

Authorizations b. I re,1:i1wf a wc1inr pmr11c111t to I lxe,utin 

Order/ 3')89. 

(Consult with 

your If ,c·,. mJtcatc lhc J.rfc <>f illl w,LL1Tr ,Hi<l ilw 

agency•s ;t1hJ<'CI ufTh(· '-,,;,-,., ,:u· ·'l'Phc,bl" pJr.1;:r.11,h 

DAEOif ,,( rl,, l'lhic, plnlc'.c, )',\!l<l'.'. )l,H'li(lli.ll' 111.11r,·r,_ 

uncertain >[>cuC«· i"uc ,lll'.l'. ,,s •'i'l'l,l".ll,lr-> 

under what I re,m,ed 1.111 1.111thrm"{plto11 pHrJNant to authority a 

C. 

5 CFR. § 2635.502(d). waiver or 

authorization 

was granted.) l t ,,.,, 111<\rutc· J,uc , ,( .u11h,m1.m, '" .rnd 

idcnt, f\ rh" n ,n·n ti l'"r,un, ,,1 "" I•, "It, ,m ) nu 

l,,ll ,· lin·<i .,nd,.,rr,nl (, g, r<.,m,·, ,·rn1,l,,,c·1, 

I< ,,m,, dtc·nt. ']'""'':'' ,·n,1,101 u, '1'' '"'"·, 

n111c·nr d1t"11t. c1, ). 

J. / l"t'c"ciwd" 1vaiwr p11rmm1I lo 5 C.FR 

§ 2635.503(,). 

If), ,, ,.,,1,r,,r,· tlw d.11,· of rlw \S.Hv.-r .rnd 

1,lcnt1fi tl1t· i",,nmr c·,n11l,/\u ,,r f'.!H< 

@'es 0 No 

@Yes Oo QNIA 

(!)ve, 0° QN!A 

QYes (!) No 

Date: 

Finanual tnterest: 

OYes ~o 

Dale: 

Subject: 

0 Yes @No 

Date: 

Covered person(s): 

QYes {!)No 

Date: 

hirmer employer or payer: 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 2 
lJ S. ( lFFICE ( )]• l;O\'ERN~IE'.':'J' l:.'ll Jl(_S 

Ccrnficau"" of Etlucs ;\grc~mtr1l (_,,mplcrncc 

(Fcl,ru,ir}' 21121 ,·crnn11) 

8. a. !/ I tommitll':d that I 1vmild 

)O!fi'il a jinandal i11tms! or 

Payments, P"l·mmt, un!us it U'IIJ 

Accelerations, reaived or 11,ce!eruted prior to 

or Divestitures Mark this !l~}' m,11mptio11 of t/Je d11tm 

Required to be box if nnt 1f the gonmmmf p11.rition: 

Completed applicable: 

Prior to 

Entering [Z] b. F1nancial interest or 

Government parment at issue: 

Service 

I han wmpleted 'llJ' initial ethfrr bn'ifi,ir,,, 

p,muant to 5 CFR. § 2638.305. 

9. ' ' . ' 

Requirements ' 

for Regular 1 h111e s{r,,net! the ethio ple1~e pumM11t lo 

Appointees E.,:emtiw Order I 39!/9. 

' ' . 

to LL com11h-r~d I,, { l(; I 

10. I am recusing from engaging in 

Additional any work related to the contracts 

Ethics I have signed with respect to 

Agreement future writing. 

Requirements 

---------------------

11. 

Comments of 

Appointee 

0 I m·eil'td it (or ii wi;J a<"Celeratcd) p,ior lo "!J' 

llJJfll1Jptio11 of !ht' duties q( the pofl//011. 

0 I re.-eind it {or ffll'lu ,mdemted afier my 

a.rsumptio11 q( the duticJ ~l the pos11!011. 

0 lforfaited it. 

{!) Yes ONo ON/A 

(!) Ye~ QNo ON/A 

r,, b,· ,,,,npkt,·d In ~1•1,uint,·c 

I am mmpfyin_!!, with thcH n·quirmHntJ m desoibcd in 

th,· adji;ant ho.--..:. 

{!)Yes ONo ON/A 

Any intentionally false or misleading statement or response provided in this certification is a violation of law 

punishable by a fine or imprisonment, or both, l1'1der 18 U.S.C. § 1001. 

I ctrftfy that the infomtation ·'I~"'"'" 

I '1avt prowkd iJ (Ontpkte 1)2/z_q /7-()2°2 

a,:d a.(11.rate. 

1/ / ----

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S \VEBSITE. 3 
ITS ()l<FIU, UF (;t l\'hlm~ll,N'i' ~Tl IH.S 

{:crnlicit"m of Ethics ,\gre~mcm C,,mpL,me<' 

(l'd,ruary 21121 ,crsil'<I) 

i>rivacy Act Scct10n 110 of the Ethics in (;.on:rnment _\ct of l 'J78, as amemle<l, requires the reporting of tlus mfonnation. The 

Statement pnmary use of the information on this report is for re\·iew b1· Government officials lo determmc an appomtee's 

compliance \vith applicable l'edernl laws and regubtiom, and the appomtec's Ethics .-\greement Failure to provide 

the requested mfonnation m'.ly result in notific1tion of lack of compliance to the '.:ienale and the head of the 

appomtee's agency, or the \\l11te House, an<l/or coul<l result in OGE declining to certify the appointee's financial 

disclosure reporb. The appointee could also be required to rc-cuse from nutters based on uncertainty as to 

whether they h,we d!Yested or resigned from a matter detennined to raise potentialconilicts. 

This information will be publically posted to the OGE website at \\'\\'\v.ogc.gov in accordance 

with OG_E/GO\''J'- I, Exeeuti\T Branch Personnel Public Financial Disclosure Report~ and ()ther .t\ameRetrieved Ethics Prngr'.lm Records (wutine use "k."). Please see OCE/CO\T 1 for more mformation about 

the maintc-nance and disclosure of this information. 

Your position as one of our govemment\ most senior leaders brings \\1.th it exlrnordinary responsibilities. One of 

Oiling the those responsibilities 1s to serve as a mle moJd for all executi\·e branch emplorees by demonstrating a comnutment 

Certification to ethical principles and activcl)-' seeking to avoid conflicts of intrrest. This includes compliance \\1.th the ethics 

of Ethics agreement you signed pnor to and as a condition of your confirmation. By signing this Certification of Ethics 

~teemen.t .--\.greemcnt Compliance (Certification) you certify that you haYe complied with the teans of your etlucs agreement. 

Compliance The information below is mtended to help you timely meet your obligation to complete and submit thi~ form to the 

U.S. Office of Government Ethics (OGF). 

You are requued to comply with tl1e prn\·1s1ons of your ethics agreemenr within three months of the date of your 

confirmation, unless otherwise specified. Plea~e: 

• Review your ethic~ agreement carefully 

• If your ethics agreement requires you to resign from an outside position, please note that resignations arc 

generally reqwred "upon confirmation." 

• Identify any pnl\'isions of your ethics agreement that may requrre coordmat1on \\1.th an account manager or 

other third p'.lrty 

• Initiate any necessary actlon early enough to tuncly comply with your ethics agreement . 

• If you quahfy for and \l.1sh to rcciuest a Cemficate ofDi\TStitnre, please submit your reque~t as soon as 

poss1ble through your agency's Desi,smatcd .\gcncy Ethics Official(D.\EO). 

If your etlucs agreement specifies that you have more than three months to comply \"1th a partlcular prov1s1011, you 

must std! comply \vith the remauwig proY!SLons Witlw1 the standard three-month period and submit a Certification 

(through your agency's D.-\EO) \\ithin sen·n days thcrcaftl'r. If you have not complied \\1.th a prnv1sion of rour 

etlucs agreement, please provide an explanation in Box l 1, C:ommenls of ~\ppomlec. You \Vill be provided \\ith an 

additional Certification to complete and submit to OGE tu cer11fy that you ha\T complied wnh all provisions of 

your etlucs agreement. 

Extensions: (_)(;J";: may grant an extemton of tllne for complymg with a provision of yom ethics agreement 1f, m 

its sole <l.tscretlon, it dctennincs that an lmusu.:11 hardship has/will prevent you from compl)11Ig 11rncly. Generally, 

waiting for an account m'.lnagcr to sell an interest, not being able to locate records, or waiting for OGE to process a 

request fot a Certificate of Divestiture are nut considered unusual hardships .. -\snored in the Privacy :\ct 

Statement above, not submitting your Cnhficarion may result in notification of lack of compL.ance to the Senat<:, 

the head of your agency, or the \\,,hite House. OGE may also decline to cerllfy your financial disclosure reports. 

You may also be rn1uire<l to recu~t· from matters based on uncertamty as to whc-thcr you haYe completed reqwred 

divestitures and res1gn,1tions. OGF may also post a notice on its web~ite, in place of your Certification, stating 

tl1at you ha\T not yet submitted the required certification. 

\Vhil~ it is your personal responsibility to take the steps necessary to comply with your ethics agreement, your 

agency's DAEO is available to assist you in completing this Certification and submitting it to OGE. Any 

questions you may have should be directed to your agency's DAEO. 

THIS CERTIFICATION WILL BE POSTED FOR PUBLIC VIEWING ON OGE'S WEBSITE. 4 
CONTROLLED 

John Einstman 

Designated Agency Ethics Official 

Legal Division 

August 18, 2021 

U.S. Commodity Futures Trading Commission 

Three Lafayette Centre 

1155 2 l st Street, N.W. 

Washington, J)C 20581 

Dear Mr. Einstman: 

The purpose of this letter is to describe the steps that I will take to avoid any actual or 

apparent conflict of interest in the event that I am confirmed for the positlon of Commissioner 

for the U.S. Commodity Futures Trading Commission ("CFTC"). It is my responsibility to 

understand and comply with commitments outlined in this agreement 

SECTION I - GENERAL COMMITMENTS 

As required by criminal conflicts of interest law 18 U.S.C, § 208(a), I will not participate 

personally and substantially in any particular matter in which I know that I have a financial 

interest directly and predictably affected by the mattel', or in which T know that a person whose 

interests are imputed to me has a financial interest directly and predictably affected by the 

matter, unless I first obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a 

regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). I understand that the interests oflhe 

following persons are imputed to me: 

• Any spouse or minor child of mine; 

• Any general partner ofa patinership in which Tam a limited or general partner; 

• Any organization in which I serve as officer, director, trustee, general partner or 

employee; and 

• Any person or organization with which I am negotiating or have an arrangement 

concerning prospective employment. 

In the event that an actual or potential conflict of interest arises during my appointment, 1 

will consult with an agency ethics official and take the measmes necessary to resolve the 

conflict, such as recusal from the particular matter or divestiture of an asset. 

If I have a managed account or otherwise use the services of an investment professional 

during my appointment, then I will ensure that the account manager or investment professional 

obtains my prim· approval on a case-by-case basis for the pmchase of any assets other than cash, 

cash equivalents, investment funds lhat qualify for the exemption for diversified mutual funds and 

unit investment trnsts at 5 C.F.R. § 2640.201 (a), obligations of the United States, or municipal bonds. 
I will receive a live ethics briefing from a member of the ethics office after my 

confirmation, but not later than 15 days after my appointment, pursuant to the ethics program 

regulation at 5 C,F.R, § 2638.305, Within 90 days ofmy confirmation, l will submit my 

Certification of Ethics Agreement Compliance which documents my compliance with this ethics 

agreement. 

l understand that as an appointee I will be required to sign the Ethics Pledge (Exec. Order 

No. 13989) and that I ,vii! be bound by it. Among other obligations, l will be required to recuse 

myself from particulal' rnalters involving specific parties involving my former employer or 

former clients for a period of two years after I am appointed, with the exception of federal, state, 

and local government. 

l will not modify this ethics agreement without yom approval and the approval of the 

lJ ,S. Office of Government Ethics pursuant to the ethics agreement 1·equirements contained 

within the financial disclosme regulation at 5 C.F.R. § 2634.803(a)(4). 

SECTION 2- EMORY l!NTVERSTTY SCHOOL OF LAW 

Upon confirmation, I will resign from my position as Senior Associate Dean of Faculty 

and Academics, however I will take an unpaid leave of absence from my position as Pt'ofcssor of 

Law at Emory University School of Law. I will not participate personally and Sl1bstantiaUy in 

any particular matter that, to my knowledge, has a direct and predictable effect upon the financial 

interests of Emory University, unless l first obtain a written waivet', pursuant to 18 0.S.C. § 

208(6)( I), or qualify for either the exemption for employees on leave from institutions of higher 

learning allowing participation in certain particular matters of general applicability at 5 C.F.R. § 

2640.203(b), or another regulatory exemption, pursuant to 18 U.S.C. § 208(b)(2). 

SECTION 3- OTIIER RESIGNATIONS 

Upon confirmation, I will resign from my position with the: 

• Association for the Promotion of Political Economy. 

Additionally, in December 2020, I resigned from my position with Tulane University. Pursuant 

to the impartiality regulation at 5 C.F.R. § 2635.502, for a period of one year after my 

resignation from each of these entities, I will not participate personally and substantially in any 

particliiar matter involving specific parties in which I know that entity is a party or represents a 

party, unless I am first authorized to parlicipate pursuant to 5 C,F.R. § 2635.502(d). 

SECTION 4-lllV1°:STITIJRES 

As soon as practicable, but not later than 90 days aftct' my confamation, Twill divest my 

interests in the following: 

• Bitcoin (Coinbase account) 

2 
• The Goldman Sachs Group, Inc. 

• JPMorgan Chase & Co. 

Wilh regard to each of these entities and virlual currency, Twill not participate personally and 

substantially in any particular matter that, to my knowledge, has a direct and predictable effect 

on the financial interests of the entities or virtual currency until I have divested it, unless I first 

obtain a written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for a regulatory ex.emption, 

pmsuanl to 18 U .S.C. § 208(b)(2). J have verified that Twill be able to carry out the divestitures 

within the timeframc described above. 

r understand that [maybe eligible to request a Certificate of Divestiture for qualifying 

assets and that a Certificate of Divestiture is effective only if obtained prior to divestiture. 

Regardless of whether l receive a Certificate of Divestiture, I will ensure that all divestitures 

discussed in this agreement occur within the agreed upon timeframcs and that all proceeds arc 

invested in non-conflicting assets. I understand that I must submit in a timely fashion my request 

for a Certificate of Divestiture to allow for adequate time for OGE to process the Certificate of 

Divestiture, and in order to divest assets within the agreed upon tirneframe. 

T (including my spouse and dependent children if applicable) will not repurchase any 

asset I was required to divest without consulting with an agency ethics official and the U.S. 

Office of Government Ethics. 

SECTION 5 INTELLECTUAL PROPERTY 

Bet-Ore lcaming of my consideration for a possible nomination to a position at the CFTC, 

I completed work on a handbook on the subject of artificial intelligence and the law for 

Cambridge University Press. I may receive future royalties from Cambridge University Press for 

sales for the print or audio edition of the handbook. I understand that I may not work on this 

book or perform any other services for compensation during my appointment to the position of 

Commissioner. Purs11ant to the impartiality regulation at 5 C.F.R. § 2635.502, I will not 

participate personally and substantially in any particular matter involving specific parties in 

whicb l know Cambridge University Press is a party or represents a party, unless I am first 

authorized to participate, pursuant to 5 C.F.R. § 2635.502(d). 

3 
SECTION 6- PUDLIC POSTING 

I have been advised that this ethics agreement and the Certificalion ofElhics Agreement 

Compliance will be posted publicly, consistent with the public information law a 5 lJ.S.C. § 552, 

on the website of the U.S. Office of Government Ethics with ethics agreements of other 

Presidential nominees who file public financial disclosure reports, 

4 
St11dt..rd form SO 

l(o,. 7191 

U.S, Of'lkc or P<'r,c;,ond Mana1i:cmcu1 

fPM Supp. 2,6-3) Subcb 4 

1. Namr (Last. l'irst. Middle) 

MERSINGER. SIJl\1M£R K 

FIRST ACTION 

!Ii-A. Code 5--B. Nature of Aetlon 

NOTIFlCATION OF PERSON EL ACTION 

2. Social Seouril)· Number I -'- D•I• of Birth 4. [ffoctl\'e Dote (b) (6) 

0.S/09/2023 

SECOND ACTION 

6- A. Cod• 6-8. Nature of Action 

571 CONY TO EXC APPT NTE 06/12/23 

5-C. Code 5--0. Legal Au1bori1y 6-C. Code 6--0. Lfgal Aulbority 

ZNM PL 93 463 

5-t;.CO<le 5-f. Legal Authority 6-E. CO<lt 6--f'. Legal Aulhority 

7. FRO~I: Po,l1lon TIiie nn~ Number 15. ·10: l'O!lilion Tille and 'lumber 

COl\1MISSTON£.R 

0 I 009006 0 I 0090 

K. Pl)' Plan I'· O«. Cod• r· Gradt or L,v,11' I. Slfp .,. Rut l. Total s,,,ry I IJ. Pay Ba,ls 111. Par Plan I "· Oe<. Cnd• 

EX 0301 

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04 00 I 58,500.00 PA 

JlA. Buie Pa)' 128. Loolity Adj. I l?C .. \dj. 81,lc P2) I 120. 0rhor P•y ZOA. Basic ray 218. Lou.liry Adj. 

I 

2.0C. Adj. Bask P•i 

1

200. Olhtr Pty 

.00 .oo J S8,S00.00 .00 158,500.00 .oo 

14. Narnc and Location or Posilion·s Organi,ation 22. Name and Location of Position's Organltllllon 

COMMODITY FUTURES T RADING COM~USSION 

OF'F'ICE OF' THE COMMlSSIONER 

CT CfOJOOOOOOOOOOOOOO pp 08 2023 

EMPLOYEE DAT A 

23. Yelerus Pttferenct 24, Ttnur< IZS. Agency Use r.7 1-,,._,,.r J - 10-1"•1-fft/Olubil.iv !-l~Pel.11/0tkrr 

I 

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rso7

27.FEGLI 28. Annuh•nt lndlc21or 

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POSITION DATA 

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ri-71 - r 61flpc:1ldn~n•I~ :l-~F..li\(,Utff'1ll 

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38. Duty Station Cod• 39. Out)· Station (Cit)• - County- Stale or Oversea, Location) 

11-001~001 WASRTNGTON DIST OF COLUMBTA DC 

1 40. Agency Dalli 1 41. 1 ,2. I ~3. 144. 

45. Remarks 

REASON FOR TEMPORARY APPOINTMENT: TEMPORARY NEED . 

46. Employing Deparltnenl or Agen<y 50. Slgn•iu••t/Au1hen1le>11ion ud Title ur Appro, Ing Offlclal 

COM.l\lODITY FUTURES TRADING COMMJSSION ELECTRONICALLY S IGNED BY: 

47. Agency Co4e 

1

48. P,rsonn,1 Offkc ID 

1

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CTOO 4 173 04/09/202J C1-TTEF, T AL£,'T M ANAG£Mll'.NT 

2 - OPF Copy- Loni;:-Term Record- 1)0 NOT l)ESTROY 

26. Vctcr•ns Preference for Rlf' 

n vES N No 

29. Pa,• lute D,tunllnsnl 

T I BELOWTRE MTNTMUM I 

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I 

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Pay Period 

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8888 

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Ke,. 7191 

U .S. Orr111,;c or P~nonnt'I M•n~nnco1 

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1. Name (Last. First. Middle) 

J OHNSON. KRISTIN N 

FIRST ACTION 

5-A.Code S--B. Nature of Action 

171 EXC APPT NTE 04/13/25 

s-C.Code S--D. Lego! Authority 

z:-a.1 PL9J463 

5-E. Code ~ "- Ugal AurhOnry 

7. l'RO~I: Po,ltion Tltk and Numbce 

NOTIFlCATION OF PERSONNEL ACTION 

2. Sod•l .',e,urit) N1mb,r 

(b) (6) 

13. Dot, of Birtb 

I 

~- f.ffecth-• 0•t• 

03/30/2022 

SECOND ACTION 

6-A. Code 6-B. Naturr of Action 

6-C. Cod• 6-0 . Legal Authority 

6-1£. Cod< 6-F. Legal AulhOrlt)' 

15. TO: Pos-ition Thie and Number 

COMJ\fTSSfONER 

01009002 010090 

K, Pa)' Pl"" 1 •·Ott. Cod• I'°' Gndc nr u»••r I. Socp or Katt I. To(al ~1l1ry I IJ. Pay Bnd, 16. Pay Pin I t7. 0cc. Code 

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04 00 158,500.00 PA 

IL-\. Bul<P1)' 118. Locality Adj. llC. ,\dj. Ba,ic Pay 

1

12.0. Ocher Pa3 20A. Basic Pay 288. Localil) Adj. 

1

20C. Adj. Bilk Pl) 

I 

200. Orhtr P,y 

.00 I .oo 158,500.00 .oo 158,500.00 .00 

- 14. Name and Location of Positlon'1 Organlrution 22. Name •nd Lor•tion of Position's Ori::auizution 

COMMODITY FUTURES TRADING COMMISSION 

OFC OF THE COMMlSSIONER 

CT CF0200000000000000 pp 072022 

EMPLOYEE DATA 

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rco27. Fl EGLI 28. Annuitant Indicator 29. Pay R•te Determinanc 

BASIC 9 I NOT APPLICABLE T I BELOW THE 1'fTNIMUM l 

30. Retirement Pl•• 31. Senice Comp. Dal, !ua\'e) 32. Work Sd1cdulc 33. Part-Time Boun Per 

r-;;-iFE:RS (FRAE) 03/30/2022 F I FULL TIME I Biweekly 

Pay Period 

POSITION DATA 

34. Porltlon Occupied 35. FLSA Cat,gory 36. Appropriation Code 37. Bargaining I/oil Stai-as 

ri-7 I - Cl'lfflptUlh:t SCf"\'ft J-:-.~c;cnfcnt l E- Cumpl 

1-t:utpkd Sa,1ict: .. - ~ Carttf' llHt~td E "¥ - 1",e .eu,-pe 8888 

38. Duty Station Code 39. Duty Station (Clly- County- State or Oveeseas Location) 

11-0010-001 WASHINGTON DIST Of COLtiMBTA DC 

40. Afl<ncy Data I 41. 1 42. I 43. 144. 

4

hff'Cf~BLE FOR LEAVE. 

APPOINTMENT AFFI DAVIT EXECUTED 03/30/2022 . REASON FOR TEMPORARY AP POINT:'1ENT : AP POINTP.ENT AS CO::-!MCSSIONER FOR 

A TERM EXPIRING 04/30/2025 . APPOINTMENT IS '.:1ADE ACCORDlNG TO PROVISIONS 

OF P 1 93- 463 . 

FROZEN SERVICE : 00 YRS . 00 MOS. 

CREDITABLE MILITARY SERVICE ; 00 YRS . 00 MOS . 

PREVIOUS RETIREMENT COVERAGE : PREVIOUSLY COVERED. 

EMPLOYEE IS AUTOMATICALLY COVERED UNDER FERS, FERS- RAE OR FERS - FR~E. 

46. Employing Department or Agency SO. Sig tuUort/Authentication .and Tifle of Approving 0fOc:ial 

COMMODITY FUTURES TRADING COl\l~USSION E:LECTRONTCAtLYSTGNEO BY: 

47. A2,ncy Code 

1

43. Ptrsorinel Office I 0 49. Approvad Date TONIA PA T'l'ERSON 

CTOO 4173 03/31/2022 CHlEF, TALENT M ,o\NAGEMENT 

S--P•l"I ~3 Ht 2 - OPF Copy- Long, Term Record - UO NOT llESTROY l'!dltWn • Prlur tu 71'1 A-,: NU4 Ua-•bk .M t\.T 6130.,,J 

NSN 7~0-Ul-3Jr623~ 
Slaodard Form 51 

Kt1. 7/91 

U.S. Office of P('rtonnd Mana;ffl1~nl 

Fl'M S11pp Z9fr3J .. Sub<b 4 

I. 1'•me (Last, First, Middle) 

PHAl\1, CAROLINE D 

FffiST ACTION 

5-A,Codc !'i- B. NNture o( AcrJon 

171 EXC APPT NTE 04/ 13/27 

5-C.Code 5-0. Legal Aucborhy 

ZNM P l 93 463 

5-£.Cod• S-F. l eg•I A UI h oriry 

7. FROM: Po~lllon Tille and Number 

NOTIFICATION OF PERSONNEL ACTION 

Z. Social Se<urity Ntmb~r I 3. Datt of Blrtb 

I 

4. Effective Dalt (b)(6) 

0 -'/1 4/2022 

SECOND ACTION 

Ch \. Codt 6-8. Nature or Action 

6-C. Cod, 6-0. Legal Autborlly 

6-E. Cod• 6- f'. Legal Authority 

lS. TO: Posirion Titl~ and Numbt'r 

COMJ\11SSIONER 

01009003 010090 

R. P,y Plan 1•· O«. C..t, t O. Gnde nr L.•••lr l. ~,.p•r R,0•111. T .. ,I S,1,,y 1 1), P•1· s .. ,. 1,. Pa~ Plu 1 17. O«. CtHle 

FX OlOI 

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0~ 00 I58,SOO.OO PA 

12A. 8.ad~ Pti} 

1

11.D. Lo6Hty A4J. I nc .. ldJ. o .. 1c P,1 

I 

UaD. (>cbc.r P aJ l(IA. Bask Pay lt8. Localit)' Adj. 

1

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1

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14. Name and Location of Position•, Organi·,..at_ion 22. Name and Location or Pusltlun•s OrgMob:.a1Uun 

COMMODITY FUTURES TRADING COMMISSION 

OFFICE OF THE COJ\1M1SSIONER 

CT CFOSOOOOOOOOOOOOOO pp 08202'2 

EMPLOYEE DATA 

117

23. Yetera s Preferenc, 24. Tenure 25. Agcnc) Use 26. Vcterani Prd"crfflcc for Rlf I - Nonr .l-10-Pvint/Ub:abiUJ S - lf-Poiat!Orl t r I

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1

27.fEr,J 28. Annuhant Indicator 29. Pay Rate Determinant 

BASIC 9 I NOT APPLICABLE T I BELOWTifE MTNlMUM I 

30. Rellrement Plan l 31. Servict Comp. Oat, (L<ne) 32. Work S(htdulc 33. Parl- Timc Iloun Per 

~ FERS(RAE) 10/12/2020 F I FULL TII\JE 1

91,..oekly 

Pay Period 

POSITION DATA 

34. Position O«upied 35. FLSA Cat,gory 36. Approprlalion Code 37. Bargaining Unit Status 

f---;-71-C'otnfk-'thh~Scnltt .,-~Di,:,,~,... !El C- l\rn1pt 

2 - •:1ttftfd Suviff , - ~ c,rttr Mn~,vf'd N-N•ltf•t11tpl 8888 

38, Duty S1J1rlon Code 39. Duty Station (City - County - ~tah: or Ovcncas lA1:atiun) 

11-0010.001 WASITTNCTON DIST OT COLUMBIA DC 

40. Agency Dara I"'- 1 •z. 1 43. I""

· 

4

h~~f~BLE FOR LEAVE. 

APPOINTMENT AFFI DAVIT EXECUTED 04/14/2022 . 

REAS0:-.1 FOR TEMPORARY APPOINTMENT : APPOINTMENT AS COMMISSIONER :OR A 

TERM EXPIRING 04/13/2027 . APPOINTMENT IS MADE ACCORDING 'IO PROVISIONS 0 

p L 93 4 63 . 

FROZEN SERVICE: 00 YRS . 00 MOS . 

CREDI TABLE MI LITARY SERVICE: 00 ~RS . 00 MOS . PREVIOUS RETIR!:MENT COVERAGE: PREVIOUSLY COVERED. 

EMPLOYEE I S AUTOMATICAL:Y COVERED UNDER FERS, FERS - RAE OR FERS - FRAE . 

46. Employing !Hpar11nen1 or Agency SO. Signa1Ure/Au1hu1ic1tion and Tille or Appro~lng Official 

CO~ll\lODITY FUTURES TRADING COl\lMISSION ELECTRONIC ALL V SIGNED BY: 

41. Agen<y Code 

1

4ll. Pcrsonn<I Offi« ID 

1

49. Approvol Dote TONI A PATTERSON 

CTOO 4 1?.3 04/14/2022 CHTEF, TALENT M ANAC£Ml1N'T 

S-PHt 54rll 6 l • 0 1'F Copy- Loni;-Term Record· VO NOT IJESTROY £dlflu1u Prfor lo 1/91 Arc NOi Urablc 4Rcr6/JOi9) 

!'IS."i 7!<4IHIJ-JJ3-6lJN 
Sluclard form 50 

Ke,. 7191 

U.S. Otr"-"c orPt'nonnd J\IH•~cmm1 

fPM Supp. 2'6-33, Subcb. ◄ 

NOTIFICATION OF PERSONNEL ACTION 

l. Namt (Lui, f'lrst, J\liddleJ !. Soci•I S.,curity Numher I l. Ode of81rtb 

I 

.1. £froctive Date (b) (6) 

ADAJ\ISKE. STEVEN W 0 1/02/2022 

FlRST ACTION SECOND ACTION 

S--A. Code S--8. Nature. or Act1on 6-A.Code 6-B. Naturt or Action 

170 EXCAPPT 

S-C. Code S--D. Legal Authority 6- C. Code 6-D. L<1al A1llbority 

Y7M SCH C 213 3379 

5-E.Code S--fl. 14:•I Authority 6-E. Collc 6-F. Ltga l Authority 

7. l'ROJ\I: Po,ltton Title and Nun1bcr lS. TO: Poslllon TIiie und Number 

DIR. OFC OF PUBLIC AFF ArRS 

01026701 010267 

H. " 'Y PIH I'· O<t. Codt r o. Grad, or L<nllll, S<q, or R:,tt l. Tocll Sal,ry I IJ. Pay B••k 16. P•)' Plan 117. O«. Code 

CT 0301 

Ill Grad, or Level I 19$1tp or R11, 20. Tnul Sabry/Award Ill. Pay Bui• 

17 I 00 230,000.00 PA 

12A. Buie Par 1!11. Lo<>lll)' Adj, I nc. Adj. Bade Pa, 

1

12D. Otlx.r hf 10/\. Bask: Pay 208. Lonlll)' Adj. l

?OC /\dj, Bui< Pai I ?OD. Olh.r Pa)' 

.00 .00 230,000.00 .oo 230,000.00 .00 

14. Name ind Location ol' Position'sOri:anbatlon 22. Name and U>CJlllon or Potilion's Org1rnlZ111ion 

COMMODITY FUTURES TRADING COMMISSION 

OFFICE OF THE CllArRMAN 

OFFICE OF PUBLIC AfFAfRS 

er CFOl20000000000000 pp 01 2022 

EMPLOYEE DATA 

23. Veterans Prererence 24. Tenure f~"1)U~ 26. Veterans Pttfcrcnet for Rtr 177. 1-NMI.~ l - lO-t'UlfttlU.1ablli,y ~- 11-f"fliial'UlblT 1-- -;--i o• N.., 1-c.111cUd Clft•I 

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27. FEGLJ 28. Annulta t Indicator 29. Pav Rate Dflerminao1 

rio7 WATVED A I T I BELOW THE MTNIMUl\1 I 

30. Retlrement Plan JJ. Sen·ke Comp. Date (Leare) 32. Worl< Sd,cdulc 33. Part-Time Bours P,r 

r.iFERSANDFICA 09/19/1997 F I FULL TIM£ I 

Bi,-tckly 

Pay Period 

POSITION DATA 

34. Podtloo O.:cupi«I JS. f'LSA Category 36. Appropriation Code 37. Bargaining Unit Sta1us 

rzi •-r..• .. p:,thJn,..n1« , - :O.C."¢ (:dC'r-.1 r77 c- E\flllp!: 

l - l:,1..ttpc,,cl Stn-ict: , -S.tStar«r.Hf'Wt'\td N- NotntflllPII: 8888 

38. Duty Station Code 39. Duty Station (Cily- County- Sute or o,·erseu l.Kation) 

11-001~001 WASmNCT'ON DIST OF COLUl\lBlA DC 

40. Aeeney Data 1 41. I . 143. 144. 

4

K?•:A:•rk~EEMPLOYED ANNUITANT, YOU S ERVE AT THE WI~L OF T HE APPOINTING 

OFFICER. 

APPOINTMENT AFFIDAVIT E XECUTE D 01 / 03 /20 22 . 

FROZEN SERVICE: 00 YRS . 0 0 MOS . 

CREDITABLE MI LITARY SERVICE: 00 YRS . 00 MOS . 

PREVIOUS RETIREMENT COVERAGE : PREVI OUSLY COVERED . 

EMPLOYEE IS AUTOMATICALLY COVERE D UNDER FERS , FERS - AAE OR FERS - FRAE . 

46, Eniploylng Departmenl or Agency SO. S1tnature/Au1hen1kallon ud Title of ApproslnR Official 

COl\LlllODITY FUTURES TRADLNG COl\t~USSlON ELECTRONICALLY SIGNED BY: 

47. A2enC)' Code l 48. Personnel Office IO 

1

49. Apprn,•al Date TONIA PATTERSON 

CTOO 4173 01/02/2022 CHTEF, TALENT MANAGEMENT 

2 • Ol'F Copy· Long-Tenn Record· UO NOT IJESTROY Edttlo•• l'rtur lu 71'! I • re No( Uubk An,.,. 6/JW,J 

!'<SN TMtHII-JJJ,-6238 
(b)(6) STEVEN W. ADAMSKR 

Senior Communications and Public Policy Professional 

• Public Affairs Strategist with over 25 years of communications, media, policy, and 

campaign experience with a proven track record of delivering high-level communications 

strategies and media exposure at all levels of government and industry. 

• Crisis Manager with a tested ability to calmly respond to crises by developing clear and 

targeted commWl.ications strategies for rapid deployment. 

• Influential Policy Advisor ·with significant influence in developing and implementing 

banking, housing, and derivatives policies. 

• Experienced Media Spokesperson with experience under pressure working '"'ith the press 

on a series of complex economic, financial, and reputational issues. 

• Team Leader with proven experience in motivating, guiding, and managing employees. 

Selected Accomplishments 

• Designed and implemented successful messaging and press strategies in both 

industry and government to carry out the organization's strategic goals. 

• Fostered trusting bipartisan working relationships with principals and staff on both 

sides of the political aisle, the financial industry, banking and securities regulators, and Capitol Hill. 

• Orchestrated rapid response and crisis communications strategies to limit exposure 

to outside controversies such as the MF Global collapse, the fall of Fannie Mae and Freddie 

Mac, and the fallout from the broader 2008 financial and economic crisis. 

• Built an extensive network of media contacts with influential financial reporters 

representing broadcast, print, '"ire, and opinion in Washington, DC, New York, London, Brussels, and Asia. 
COMMUNICATIONS EXPERIENCE 

FIA 

Vice President, Head of Communications and Public Affairs 

February 2018 - Present 

• Head of con:i~unications for the global organization whose mission is to advocate for open, transparent, 

and competitive markets for the futures, options, and centrally cleared derivatives industry. 

• Responsible for all strategy, messaging, and execution of communications plans designed to promote FIA's 

advocacy and other strategic goals. 

• Obtained positive media coverage for major initiatives by developing and maintaining extensive media 

relationships. Secured numerous interviews for the CEO and other senior staff. 

• Created and worked as executive producer of FL\'s podcast, FIA Speaks. 

• Developed the strategy and directed FLl\'s social media presence. 

• Worked as a member of the team that redesigned FIA's website and online presence. 

• Responsible for ·writing tl1e CEO's speeches, statements, and other public remarks. 

Commodity Futures Trading Commission June 2011 - October 2017 

Senior Policy Advisor and Director of Public Affairs 

• Held two senior roles: Director of Public Affairs and Senior Policy Advisor to Commissioner Sharon Y. 

Bowen. 

• Served for six years as the agency's Director of Public Affairs and senior advisor to four Chairmen \\ith 

specific responsibility for strategically planning the Chairman's message to implement the derivatives 

reforms included in the Dodd-Frank Wall Street Reform and Consumer Protection Act and other 

initiatives. 

• Successfully implemented press strategy on Chairman Giancarlo's initial proposals to create a new FinTech 

initiative, Market Intelligence Branch, and Project KISS designed to simplify and streamline the 

Commission's rules. 

• Responsible for the rollout of major enforcement actions such as benchmark manipulation actions that 

garnered worldwide attention. 

• Directed crisis communications responses to the collapse of MF Global and Peregrine Financial, the 

criticism of the agency and the agency's rules from the financial industry and Congress, and reputational 

issues related to the Chairman. 

• Directed the agency's social media presence on Facebook and Twitter. Interacted daily \',ith reporters and 

other interested parties on Twitter and other social media platforms. 

Department of Treasury July 2010 - June 2011 

Deputy Assistant Secretary for Public Affairs 

• Served as strategic public affairs advisor to Secretary Geithner and other senior Treasury officials to assist 

Secretary Geithner, Treasury, and the Administration to communicate its efforts to reform the financial 

system. 

• Worked as Treasury's chief spokesman with on the record resp()nsibility for Secretary Geithner, Office of 

Domestic Finance, and the Office of Financial Stability, which implemented the Troubled Asset Relief 

Program. 

• Led efforts to strategically roll out the communications efforts for the Treasury's role in implementing the 

Dodd-Frank Act, the Administration's housing finance reforms, efforts to raise the debt limit, foreign 

exchange derivatives exemption, and the G20 Finance Minister's meeting in Gyeongju, South Korea. • Handled complex media inquiries such as criticism of TARP and the housing foreclosure avoidance 

programs, reports by oversight bodies, Geithner's role as President of the New York Federal Reserve Bank, 

and criticism from Congress. 

Filtered the numerous television , radio, and print interview requests for Secretary Geithner and other 

senior Treasury officials. • Managed a staff of five direct reports and helped oversee the 20-pcrson Public Affairs staff. 

House Financial Services Committee 

Communications Director 

June 2005-August 2010 
• Responsible for the entire communications and press operation for Chairman Barney Frank a11d on the 

record spokesperson for the House Committee on Financial Services. 

• Served as a member of the Committee's senior staff involved in crafting policy, messaging, and political 

strategy surrounding the Wall Street Reform and Consumer Protection Act, the 2008 financial and 

subprime crisis, the development and implementation of TARP, the coordination of federal housing policy 

and affordable housing, and the automotive industry rescue legislation. 

• Successfully crafted and implemented a messaging strategy to push the Chairmen and the Democratic 

agenda. 

• Managed the committee's rapid response and crisis communications that included responding to criticism 

that federal housing policy caused the financial crisis. 

• Managed press staff and digital media personnel. 

• Developed and maintain working relationships with major daily news reporters, columnLc;ts, producers, 

and editorial 1⁄2Titers. 

• Garnered significant media coverage for the Committee and Chairman Frank including front-page stories 

in U.S. and international dailies, editorials, op-eds, profile pieces, national and regional radio, and 

television including Sunday news shows. 

Corzine for Governor and Office of U.S. Senator Jon S. Corzine June 2004-March 2005 

Press Secretary 

• Served as on-the-record spokesperson for Corzine for Governor and responsible for the day-to-day press 

operation of the DC Senate office. Aggressively pitched TV appearances; print and magazine interviews and 

editorial board meetings; successfully obtained coverage in the New York Times, Washington Post, and 

L.A. Times and on CNN, Fox, and MSNBC. 

Congresswoman Zoe Lofgren June 2002-May 2003 

Communications Director 

• Responsible for all aspects of the Congresswoman's press and media operation. Developed event ideas, 

turned legislative ideas into press stories, extensively pitched national and local TV, print, and radio 

outlets, wrote and pitched op-eds, and created newsletters. Completely rebuilt the Congresswoman's press 

operation and website that was left in neglect by a predecessor. 

Congresswoman Louise Slaughter June 2001-June 2002 

Press Secretary 

• Responsible for all media and press strategy including message development, the timing of releases, event 

idea and execution, and turning legislative ideas into media events. Wrote press releases, advisories, opeds, newsletters, briefings, and talking points. Pitched stories to both local and national press, handled 

media requests and interviews, and redesigned the website. 

Federal Communications Commission February 2000-July 2000 

Assistant Director of Media Relations 

• Managed press coverage and message implementation for the Chairman of the FCC; successfully obtained 

positive coverage in major national dailies, wire services, TV, and regional outlets. 

• Implemented communications plans and press strategy for various FCC initiatives; developed relationships 

and worked daily \\'ith reporters and producers who cover the FCC beat. 

• Pitched feature stories, editorials, and interviews with the chairman, commissioners, and other senior FCC 

officials. 

Department of Interior August 1999-February 2000 

Bureau of Reclamation 

Director of Communications 

• Served as primary spokesperson for Secretary Babbitt on western water and related issues. 

• Developed and implemented press and communications plans for the Secretary's initiatives such as Bay- Delta, Platte River, and the Florida Everglades restoration programs. 

• Supervised and managed the Bureau of Reclamation's public affairs staff and regional public affairs offices. 
Special Assistant for Outreach and Communications June 1993 - August 1999 

• Developed and implemented outreach plans for the Everglades and Bay-Delta restoration programs. 

Outreach efforts focused on local media, Congress, stakeholders, and state, county1 and local officials. 

• Identified and resolved problematic and politically contentious issues for Deputy Secretary John 

Gararnendi. 

• Concentrated on policy development, issue management, political oversight, congressional and 

constituency outreach, and communications strategy. 

Deparbnent of State - NATO 50th Anniversary Summit January 1999 - May 1999 

~puty Director for Communications 

• Directed and managed the media relations and the media operations teams. 

• Implemented a communications plan that included a ramp-up of activities to raise awareness of NATO's 

importance to America; local interest and behind-the-scenes stories; and extensive use of radio and 

satellite time to communicate a message and special announcements. 

• Oversaw the development and design of the $3 million International Media Center. 

CAMPAIGN AND POLmCAL EXPERIENCE 

Joe Lieberman for President May 2003-February 2004 

Director of Advance and Trip Director 

• Responsible for visually communicating the Senator's message by developing and implementing event 

ideas, finding event participants and locations, and designing and utilizing backdrops, venues and music. 

• Built an advance operation from the ground up. Hired, trained, and managed advance and press advance 

staff, managed budgets, and handled travel logistics for the candidate, staff, and traveling press. 

• Worked as a member of the campaign's senior staff and communications team, and traveled extensively 

with Senator Lieberman and traveling press corps. 

Gore/Lieberman 2000 and Gore 2000 July 2000-

November 2000 

Scheduler 

• Managed and scheduled campaign trips for Vice President Al Gore and Senator Joe Lieberman; Supervised 

and managed the travel planning process which comprised of successfully executing consistent and specific 

message goals, policy direction, and political needs; directed and supervised advance teams and managed 

budgets. 

Office of Vice President Al Gore June 1997 - June 1998 

Scheduler 

• Served as one of three schedulers who managed and produced the Vice President's daily schedule. Specific 

duties included message implementation, event management, advance, and political oversight. 

Agency Re,t>resentative: White House Council of Environmental Quality 

• Developed and coordinated the President's and Vice President's Earth Day event; organized cabinet and 

sub-cabinet Earth Day plans, which included developing overall message and theme. 

Clinton/Gore '92 and '96 

Lead Advance 

1996 

April 1992-November 1992 

August 1996 - November 

• Produced and managed campaign appearances for Vice President Gore. Responsible for overall visit 

coordination and event production including and design, budget management, and supervising advance 

staff. 

The White House - Health Care Task Force 

Congressional Relations Team 

Congressman Pete Stark 

February1993-June1993 

September 1989 - May 199a 
Legislative Assistant and District Aide 

EDUCATION 

• B.A., Psychology; June 1989 University of California, Irvine 

• - ·- ---------
Request for Schedule C Appointing Authority 

A9ency Name: COMMODITY FUTURES TRADING COMMISSION 

POC: SELINA SWALES Phone:(202) 418·5803 

Request No: CT220001 Request T ype: APPOINTMENT 

Candidat e :STEVEN ADAMSKE Grade/Step: I 

Position No: CTOT00060 Title: DIRECTOR 

Print Date: 121oa12021 

Fax: (202) 418-5803 

Position: REGULAR C 

Salary: $230,000 

Serles: 00301 Desc: MISCELLANEOUS ADMINISTRATION AND PROGRAM 

Date PO certified as Schedu le C per 5 CFR 213.3301 (a): 1210512021 

Oraantzatton ID: 100 

Supervisor Ho:CTEX00171 

Org. Name: OFFICE OF PUBLIC AFFAIRS 

Supv. Title: CHAIRPERSON ACTING 

Supervisor Name: BEHHAM, ROSTIN 

GEO Location: DISTRICT OF COLUMBIA 

Supv. Position Type:PRESIDENTIAL WITH SENATE 

Schedule C Certification Statement 

Under 5 CFR 213.3301(a), the position listed above is excepted from the competitive service because of its confidential or 

policy-determining character. Per 5 CfR 213.3301 (b), I certi fy that the Schedule C appointment for this position, was not 

created solely or primarily for the purpose of detailing the appointee to the White House. 

Department I Agency Head or Designee: 

Signature: DAVID GILLERS Olgilel!y Sll,OIICI bV DAVID GILLERS Data: 2021.12 08 14:50:29 -05'00' 

Agency White House Liaison 

Name: ______________ ____ ____ _ 

Signature: _____ _ _ ___ _ ___ ______ _ _ _ 

OPM USE ONLY 

Date Signed: ___ __ _ 

Phone: 

Date Signed: _____ _ 

QI Approved 0 Disapproved 0 Return without Action 

OPM Approving Official: __ -._/ t1_-t!A_ ~ _ __ ,,_,~,-¥--tf.-~--.--------- Date Signed: 12/09/2021 

Email to: Sentor Executive Resource Services at SE~ PM.GOV 

Source: Office of Personnt-1 M11na1ement Report 1019, Version March 2018