January 5, 1999
                                          DO-99-001

MEMORANDUM

TO:       Designated Agency Ethics Officials

FROM:     Stephen D. Potts
          Director

SUBJECT:  Employee Acceptance of Commercial Discounts and   
          Benefits


     As some of you may recall, Kay Richman, an Associate General 
Counsel in the Office of Government Ethics, participated in a panel
on employee acceptance of commercial discounts and benefits at the
Annual Government Ethics Conference held in September 1996.  The
following year, at the 1997 Ethics Conference, Kay returned with a
presentation on discounts that addressed a number of the issues
raised in 1996 and summarized developments to date in this area of
the law.  She has since reduced her presentation to writing, so we
thought we would share it with you for use in advising employees
regarding acceptance of discounts and benefits.  

Attachment