January 15, 1993


MEMORANDUM FOR DESIGNATED AGENCY ETHICS OFFICIALS

FROM:          STEPHEN D. POTTS
               DIRECTOR

SUBJECT:  Applicability of the Clinton Administration ethics 
          guidelines


     Attached for your information and use in counseling 
individuals who may be concerned about the potential applicability 
of the Clinton Administration ethics guidelines is a copy of a 
letter from President-elect Clinton's Transition Office to 
Secretary Card who is heading President Bush's Transition Office.   
This letter makes clear that the Clinton Administration ethics 
guidelines will not apply to individuals in career positions, 
regardless of their pay grade, nor to the non-career personnel who 
may be asked to stay on after January for a brief period. It will 
only apply to individuals appointed to senior, non-career positions 
by the Clinton-Gore Administration. 

     Please make an effort to provide this information to employees 
of your agency to alleviate any unnecessary concerns or questions 
of theirs.


Attachment


_________________________________________________________________________

              Office of the President-Elect
                and Vice President-Elect




                                January 7, 1993


Honorable Andrew H. Card, Jr.
Secretary of Transportation
Department of Transportation
400 7th Street, SW
Washington, DC 20590

Dear Secretary Card:

       We have heard that there is considerable concern inside government--on 
the part of both career and non-career personnel--about the scope of coverage 
of Clinton Administration ethics guidelines.  To allay that concern, we would 
like to suggest that the Office of Personnel Management be asked to issue the
following notice, drafted by our Transition Counsel, to all government 
personnel:

          In response to number inquiries from current government employees
     concerning the coverage of the ethics pledges the Clinton-Gore
     Administration will require of its appointees, the President-elect's
     Transition has advised the Office of Personnel Management of the 
     following:

          The ethics pledges that will be required of senior appointees of the
     Clinton-Gore Administration, which will impose new restrictions on the
     activities such senior employees may engage in after they leave government
     service, will have no applicability to individuals in career positions,
     regardless of their pay grade, nor to the non-career personnel who may be
     asked to stay on after January for a brief period. The new restrictions 
     will apply only to persons appointed to senior, non-career positions by 
     the Clinton-Gore Administration.


       We are aware that many senior administration officials--career and
non-career--are trying to solidify their plans for the future. We feel 
strongly that this statement might clarify an important issue in their plans.

       Thank you for your continuing assistance.

                                      Sincerely,



          Mark D. Gearan                      Alexis Herman


            P.O. Box 8086, Little Rock, AR 72203-8086  501-374-3322
         1120 Vermont Avenue, N.W., Washington, DC 20270  202-973-2600