the standards of conduct system producers bill daley ken mcdonald sound editor allyssa...

The STANDARDS of CONDUCT SYSTEMThe STANDARDS of CONDUCT SYSTEM

PRODUCERSPRODUCERSBill DaleyBill DaleyKen McDonaldKen McDonald

SOUND EDITORSOUND EDITORAllyssa Wheaton-RodriguezAllyssa Wheaton-Rodriguez

PRODUCTION DESIGNERPRODUCTION DESIGNERVickie SpinksVickie Spinks

INSTRUCTORSINSTRUCTORS

Bill DaleyBill DaleyKen McDonaldKen McDonaldBarbara CoenBarbara Coen

AWARDSAWARDSChris Chris KinnearKinnearEDITORSEDITORS

Bill DaleyBill DaleyKen Ken McDonaldMcDonaldBarbara CoenBarbara CoenPROPSPROPSWayne AbbottWayne AbbottErin AllenErin AllenTeri LairdTeri LairdDebbie HollandDebbie HollandSusan KenyonSusan KenyonWanda Wanda HolidayHoliday

CriticsCriticsBill CerboneBill CerboneKim MayfieldKim Mayfield

Office of General CounselOffice of General Counsel

• Keith Gottfried, General CounselKeith Gottfried, General Counsel• Bill Daley, Regional Counsel Bill Daley, Regional Counsel • Attorney-Advisor: Standards of Attorney-Advisor: Standards of

ConductConduct

The 14 PrinciplesThe 14 Principles

• The preamble to the Government-The preamble to the Government-wide Standards of Conduct contains wide Standards of Conduct contains what is commonly referred to as “The what is commonly referred to as “The 14 Principles” of Government Ethics.14 Principles” of Government Ethics.

• Upon these principles are built the Upon these principles are built the regulations, which will be illustrated regulations, which will be illustrated in the Questions and Answers to in the Questions and Answers to follow.follow.

• Public service is a public trust.Public service is a public trust.• Financial interests can’t conflict w/ duties.Financial interests can’t conflict w/ duties.• Don’t misuse nonpublic information.Don’t misuse nonpublic information.• Refuse gifts from Government clients.Refuse gifts from Government clients.• Put honest effort into your work.Put honest effort into your work.• Avoid committing Government w/o authority.Avoid committing Government w/o authority.• Don’t use public office for private gain.Don’t use public office for private gain.• Practice impartiality in Government duties.Practice impartiality in Government duties.• Protect and conserve Government property.Protect and conserve Government property.• Outside employment can’t conflict w/ Federal job.Outside employment can’t conflict w/ Federal job.• Disclose waste, fraud, abuse and corruption.Disclose waste, fraud, abuse and corruption.• Be a good citizen and pay just debts.Be a good citizen and pay just debts.• Adhere to Equal Opportunity laws and regulations.Adhere to Equal Opportunity laws and regulations.• Avoid the appearance of wrongdoing.Avoid the appearance of wrongdoing.

List of the14 Principles

HIHRTSHIHRTS

ReminderReminderPlease be sure to update HIHRTS Please be sure to update HIHRTS when major changes happen in your when major changes happen in your life: birth, adoption, marriage, life: birth, adoption, marriage, divorce, etc.divorce, etc.Do you need to change your Do you need to change your beneficiaries?beneficiaries?

IllustrationIllustration

• Rea Boote is a Hsg. Mgr. Officer and a Rea Boote is a Hsg. Mgr. Officer and a computer “wiz”. Rea completed a Fin. Discl. computer “wiz”. Rea completed a Fin. Discl. Statement (“450”) for 2006 but neglected to Statement (“450”) for 2006 but neglected to list her 25% ownership interest in Mousehouse, list her 25% ownership interest in Mousehouse, Inc., a software company. Rea has now been Inc., a software company. Rea has now been asked to serve on the tech. eval. panel (TEP) asked to serve on the tech. eval. panel (TEP) reviewing computer proposals for a new Pub. reviewing computer proposals for a new Pub. Hsg. system. Mousehouse, Inc., has submitted Hsg. system. Mousehouse, Inc., has submitted a proposal.a proposal.

• Can Rea serve on the TEP?Can Rea serve on the TEP?

AnswerAnswer

• NONO• Because award of the systems contract Because award of the systems contract

to Mousehouse, Inc., or to any other to Mousehouse, Inc., or to any other offeror will have a direct and predictable offeror will have a direct and predictable effect on Rea’s financial interest. Rea effect on Rea’s financial interest. Rea cannot participate on the TEP team cannot participate on the TEP team unless her disqualification has been unless her disqualification has been waived. waived.

► Financial interests can’t conflict w/ dutiesFinancial interests can’t conflict w/ duties ..

Mouse-Mouse-house, Inc.house, Inc.


• Ido Goodworks, a LR office employee, Ido Goodworks, a LR office employee, volunteers as a bd. member of Disability volunteers as a bd. member of Disability Employment Options (DEO), a non-profit org. Employment Options (DEO), a non-profit org. which provides job opportunities for the which provides job opportunities for the physically challenged community. DEO has its physically challenged community. DEO has its own work center and has been awarded two own work center and has been awarded two manuf. contracts with the Air Force. As a part manuf. contracts with the Air Force. As a part of her board duties, Ido has been asked to of her board duties, Ido has been asked to oversee these two contracts.oversee these two contracts.

• May Ido oversee these two Air Force May Ido oversee these two Air Force contracts for DEO?contracts for DEO?

AnswerAnswer

• NoNo• Certain criminal statutes limit representational Certain criminal statutes limit representational

activities by gov’t employees before federal activities by gov’t employees before federal departments, agencies, and/or courts.departments, agencies, and/or courts.

• Accordingly, as a HUD employee, Ido cannot Accordingly, as a HUD employee, Ido cannot represent DEO before the Air Force, either in represent DEO before the Air Force, either in person or by written communication which she person or by written communication which she signs.signs.

ALERT: Ido can represent herself or her family before federal gov’t and/or federal courts.

► Outside activities can’t conflict w/ Federal job.


• ““Rah Rah” Boom Di Ay is the Chief Rah Rah” Boom Di Ay is the Chief Counsel of HUD’s Houston Office and a Counsel of HUD’s Houston Office and a huge tennis fan.huge tennis fan.– While attending the Houston Open, “Rah Rah” bumps While attending the Houston Open, “Rah Rah” bumps

into Developer Dan and his father.into Developer Dan and his father.– Dan and “Rah Rah” have worked together for years on Dan and “Rah Rah” have worked together for years on

numerous FHA-insured multi-family and Sec 202/811 numerous FHA-insured multi-family and Sec 202/811 projects.projects.

– Dan’s father gives “Rah Rah” two tickets to the U. S. Dan’s father gives “Rah Rah” two tickets to the U. S. Open worth over $750, saying that he is retiring and Open worth over $750, saying that he is retiring and moving to Italy in 3 days and has no use for the tickets.moving to Italy in 3 days and has no use for the tickets.

• Can “Rah Rah” keep the tickets?Can “Rah Rah” keep the tickets?

AnswerAnswer

• NONO• The value of the gift exceeds the The value of the gift exceeds the

$20 gift limit. $20 gift limit. – Standards of Conduct regulations Standards of Conduct regulations

prohibit accepting any gift given to an prohibit accepting any gift given to an employee because of his official employee because of his official position, unless the item is excluded position, unless the item is excluded from the definition of gift or falls from the definition of gift or falls within one of the exceptions to the within one of the exceptions to the “no gift” rule.“no gift” rule.

►Refuse gifts from Government clients.Refuse gifts from Government clients.


• Sam Showoff drew his boss, Paulo Sam Showoff drew his boss, Paulo Plaitstrate, for the annual Christmas gift Plaitstrate, for the annual Christmas gift exchange.exchange.– Hoping to improve his performance rating Hoping to improve his performance rating

from last year, Sam gives his boss a Cross from last year, Sam gives his boss a Cross pen and pencil desk set worth $35.00.pen and pencil desk set worth $35.00.

– Suspecting the desk set might be worth over Suspecting the desk set might be worth over the $10 gift exchange limit, Paulo seeks the $10 gift exchange limit, Paulo seeks advice from the HUD Ethics Counselor.advice from the HUD Ethics Counselor.

• Can Paulo accept the desk set? Can Paulo accept the desk set?

AnswerAnswer

• NONO• Regs permit a subordinate to give his Regs permit a subordinate to give his

supervisor a gift costing $10 or less on supervisor a gift costing $10 or less on occasions on which gifts are given, such occasions on which gifts are given, such as Christmas time; however, the desk as Christmas time; however, the desk set exceeds the $10 gift limit.set exceeds the $10 gift limit.– Paulo must return the desk set to Sam.Paulo must return the desk set to Sam.

► Refuse gifts from Government clients (employees).Refuse gifts from Government clients (employees).


• Ray and Maria are getting married.Ray and Maria are getting married.– Both are HUD employees.Both are HUD employees.– Ray is Director of FHEO.Ray is Director of FHEO.– Maria is Head of Admin Services.Maria is Head of Admin Services.– The Happy Couple sent invitations to many The Happy Couple sent invitations to many

HUD friends, including Oprahe, who works for HUD friends, including Oprahe, who works for Ray.Ray.

– Oprahe bought Ray and Maria a silver-plated Oprahe bought Ray and Maria a silver-plated tea set worth over $125 as a wedding tea set worth over $125 as a wedding present.present.

• May Ray accept the present?May Ray accept the present?

AnswerAnswer

• YESYES• Ray may accept the present even Ray may accept the present even

though he is Oprahe’s supervisor.though he is Oprahe’s supervisor.– Ray and Maria’s wedding is a special, Ray and Maria’s wedding is a special,

infrequent occasion which is an exception infrequent occasion which is an exception to the general rule that an employee may to the general rule that an employee may not give a gift to her supervisor.not give a gift to her supervisor.

► Refuse gifts from Government clients (employees).Refuse gifts from Government clients (employees).


• Several Office of Public Housing (PH) Several Office of Public Housing (PH) employees accepted home dinner employees accepted home dinner invitations from officials of the PHA invitations from officials of the PHA they were reviewing.they were reviewing.

• Should the employees Should the employees have accepted the have accepted the dinner invitations?dinner invitations?

AnswerAnswer

• NONO• Even if a home meal could be accepted Even if a home meal could be accepted

because it costs less than $20, the because it costs less than $20, the acceptance of a meal is inappropriate in acceptance of a meal is inappropriate in some cases.some cases.– In this instance, acceptance of home dinner invitations by In this instance, acceptance of home dinner invitations by

PH employees conducting reviews of PHAs is not PH employees conducting reviews of PHAs is not permitted because of the appearance of loss of impartiality.permitted because of the appearance of loss of impartiality.

– Remember, even though acceptance of gifts may be Remember, even though acceptance of gifts may be permitted by one of the exceptions to the general rule, it is permitted by one of the exceptions to the general rule, it is NEVER inappropriate and frequently prudent for an NEVER inappropriate and frequently prudent for an employee to decline a gift offered by a prohibited source.employee to decline a gift offered by a prohibited source.

► Avoid the appearance of wrongdoing.Avoid the appearance of wrongdoing.


• I am a HUD employee in the San Antonio I am a HUD employee in the San Antonio Office and about to become a first-time Office and about to become a first-time homebuyer!homebuyer!– I saw four houses in a home magazine that I saw four houses in a home magazine that

were in my price range, but they are HUD-were in my price range, but they are HUD-owned homes.owned homes.

• May I purchase one of these properties?May I purchase one of these properties?

AnswerAnswer

• YESYES

* * NoticeNotice! This reference also applies to employees’ immediate family members, including spouse, child, parent, sibling or roommate of a HUD employee. HUD Housing Notice 05-10

ALERT! RULE CHANGED IN 2005!

• But you must follow the procedures set forth in HUD But you must follow the procedures set forth in HUD Housing Notice 05-10, which contains restrictions on Housing Notice 05-10, which contains restrictions on employees purchasing HUD-owned propertiesemployees purchasing HUD-owned properties

► Don’t misuse nonpublic information.Don’t misuse nonpublic information.


• Clu Less, an owner of an FHA insured Clu Less, an owner of an FHA insured development with his first HUD insured loan, development with his first HUD insured loan, asks Marsha Mello, a HUD project manager, to asks Marsha Mello, a HUD project manager, to recommend an auditor familiar with HUD recommend an auditor familiar with HUD requirements to do his required audited requirements to do his required audited financial statements. financial statements.

• Can Marsha provide Clu Less with a list of the Can Marsha provide Clu Less with a list of the business names and phone numbers of business names and phone numbers of auditors who she knows have worked on HUD auditors who she knows have worked on HUD projects?projects?

AnswerAnswer

• Yes.

• However, employees must act impartially and not give preferential treatment to any private organization or individual. Marsha should tell Clu Less that she cannot recommend a particular auditor. However, she can provide him with a list of auditors.

► Practice impartiality in Government duties.


• Louisiana State University, Baton Rouge Chamber of Louisiana State University, Baton Rouge Chamber of Commerce and HUD are developing a small business Commerce and HUD are developing a small business workshop. As its share of the work HUD…workshop. As its share of the work HUD…– Developed the concept of the workshopDeveloped the concept of the workshop– Initiated contact with principal partiesInitiated contact with principal parties– Arranged for printing and reproduction of conference Arranged for printing and reproduction of conference

materialsmaterials– Will coordinate the event in terms of topics, timing, speakers, Will coordinate the event in terms of topics, timing, speakers,

promoting to potential attendeespromoting to potential attendees– Will participate as a speaker/lecturerWill participate as a speaker/lecturer

• Alfred E. Newperson, the NO office manager, is worried Alfred E. Newperson, the NO office manager, is worried that it might be considered a that it might be considered a “co-sponsored” event, thus thus requiring Regional Director approval and Regional Counsel requiring Regional Director approval and Regional Counsel concurrence.concurrence.

• Would this be considered a “co-sponsored” Would this be considered a “co-sponsored” event?event?

AnswerAnswer

• YESYES– HUD is co-sponsoring the small business workshop HUD is co-sponsoring the small business workshop

with the non-Fed entities.with the non-Fed entities.– Alfred will need to obtain approval of the Regional Alfred will need to obtain approval of the Regional

Director and concurrence of the Regional Counsel in Director and concurrence of the Regional Counsel in order for HUD to proceed as the event’s co-sponsororder for HUD to proceed as the event’s co-sponsor..

* Requires a minimum 1 week lead-time if there is not Co-sponsorship Agreement. Requires 3-4 weeks or longer lead-time if a Co-sponsorship Agreement is required – Co-sponsorship Agreements need HQ concurrence.

► Avoid committing Government w/o authority.Avoid committing Government w/o authority.


• Mercedes, TX is holding the City’s 3rd Mercedes, TX is holding the City’s 3rd Annual Rio Grande Valley Hispanic Annual Rio Grande Valley Hispanic Business Exposition Business Exposition – As a participant at the Expo, HUD will:As a participant at the Expo, HUD will:

• Have a booth.Have a booth.• Be listed in promotional material.Be listed in promotional material.• Pay $200 “co-sponsor” fee.Pay $200 “co-sponsor” fee.

• IS HUD a IS HUD a “CO-SPONSOR”“CO-SPONSOR” of the Expo? of the Expo?

AnswerAnswer

• NONO• Hosting a booth, paying a “co-sponsor” fee and being Hosting a booth, paying a “co-sponsor” fee and being

listed in the promotional materials is not enough listed in the promotional materials is not enough involvement to cause HUD to be a “co-sponsor” of the involvement to cause HUD to be a “co-sponsor” of the event.event.– HUD did not jointly develop the Expo w/the CityHUD did not jointly develop the Expo w/the City– HUD’s participation in the event is not “substantive.”HUD’s participation in the event is not “substantive.”

• This event will be treated as a “widely-attended This event will be treated as a “widely-attended gathering” sponsored by a “prohibited source.”gathering” sponsored by a “prohibited source.”– With written approval from the Dept. Ethics Official With written approval from the Dept. Ethics Official

(Bill Daley) and ADMIN(Bill Daley) and ADMIN approval of the approval of the $200 fee, $200 fee, HUD may set up a booth and be listed in the promo HUD may set up a booth and be listed in the promo material.material.

► Avoid committing Government w/o authority.


• Peter, Paul and Mary, HUD employees, Peter, Paul and Mary, HUD employees, would like to attend the Governor’s would like to attend the Governor’s Housing conference sponsored by the Housing conference sponsored by the Arkansas Dev. Fin. Auth. (ADFA).Arkansas Dev. Fin. Auth. (ADFA).– ADFA has agreed to waive the $80 ADFA has agreed to waive the $80

registration fee.registration fee.

• May the employees accept the fee May the employees accept the fee waivers?waivers?

AnswerAnswer

• PROBABLYPROBABLY• Employees may attend and accept Employees may attend and accept

the waivers of the conference fees the waivers of the conference fees provided:provided:– Sponsor’s offer must be unsolicited.Sponsor’s offer must be unsolicited.– Employees’ attendance must further Employees’ attendance must further

operations or programs of the Dept.operations or programs of the Dept.– Since the sponsor is “prohibited source”, Since the sponsor is “prohibited source”,

the Regional Counsel must approve the the Regional Counsel must approve the waiver of conference fees in writing.waiver of conference fees in writing.

► Refuse gifts from Government clients.Refuse gifts from Government clients.


• Barbara Brownie, a HUD employee, is selling Girl Scout Barbara Brownie, a HUD employee, is selling Girl Scout cookies as a fund raiser. She asked you if she could set up a cookies as a fund raiser. She asked you if she could set up a cookie display on the office break room table.cookie display on the office break room table.

• Is Barbara permitted to solicit sales of Girl Scout Is Barbara permitted to solicit sales of Girl Scout cookies in this manner?cookies in this manner?

AnswerAnswer

• NONO• While HUD employees are on official duty or in While HUD employees are on official duty or in

the Federal workplace, they may not sell items the Federal workplace, they may not sell items such as church or school fund- raising such as church or school fund- raising material, cookies or lottery tickets. material, cookies or lottery tickets. Solicitations of pledges for walk-a-thons or Solicitations of pledges for walk-a-thons or similar events are likewise prohibited. similar events are likewise prohibited. However, you may:However, you may:– Conduct fund-raiser before and after core work Conduct fund-raiser before and after core work

hours, on non-work time, and in non-HUD spacehours, on non-work time, and in non-HUD space– Post notices of the fund-raiser on the employee Post notices of the fund-raiser on the employee

bulletin boards located in the officebulletin boards located in the office

► Don’t use public office for private gain.Don’t use public office for private gain.


• Kant Sing is employed as a lawyer for Kant Sing is employed as a lawyer for HUD. He tries out for American Idol, but HUD. He tries out for American Idol, but Simon says his voice needs a LOT of Simon says his voice needs a LOT of work. During a break Randy asks Kant work. During a break Randy asks Kant Sing if he would draft a will for him, Sing if he would draft a will for him, because he is afraid some rejected because he is afraid some rejected contestant may get violent. contestant may get violent.

• May Kant Sing do legal work for Randy May Kant Sing do legal work for Randy without getting approval from anyone at without getting approval from anyone at HUD?HUD?

AnswerAnswer

• NONO

If Kant Sing wants to do paid or unpaid work If Kant Sing wants to do paid or unpaid work for anyone in the same professional field that for anyone in the same professional field that he works in for HUD, then he must obtain prior he works in for HUD, then he must obtain prior written approval from the Regional Counsel. written approval from the Regional Counsel. Applies to attorneys, architects, accountants, Applies to attorneys, architects, accountants, appraisers, etc.appraisers, etc.

► Outside employment can’t conflict w/ Federal job.Outside employment can’t conflict w/ Federal job.


• Peggy Parent is a “sponsor” of her son’s Little Peggy Parent is a “sponsor” of her son’s Little League team. League team.

• To help the team, Peggy has been asked to To help the team, Peggy has been asked to make 30 copies of the team’s roster and 30 make 30 copies of the team’s roster and 30 copies of the permission slips that the parents copies of the permission slips that the parents must sign.must sign.

Can Peggy use the office copier to Can Peggy use the office copier to produce the required copies?produce the required copies?

AnswerAnswer

• NONO• Making 60 copies on the office copier is an Making 60 copies on the office copier is an

inappropriate use of HUD’s policy on “Limited inappropriate use of HUD’s policy on “Limited Personal Use” of government office equipment, Personal Use” of government office equipment, including Information Technologyincluding Information Technology..– The notice authorizes limited use of the office copier as The notice authorizes limited use of the office copier as

long as only small amounts of paper, toner, etc. are long as only small amounts of paper, toner, etc. are involved.involved.

– Employees should consult with their supervisor if there is Employees should consult with their supervisor if there is any question of appropriate use of office equipment or any question of appropriate use of office equipment or information technology. information technology.

► Protect and conserve Government property.Protect and conserve Government property.


•Alwayz Anoptimist receives an email telling Alwayz Anoptimist receives an email telling him that he can make big bucks promoting a him that he can make big bucks promoting a product of Sam Scamartist called, “Diet Like a product of Sam Scamartist called, “Diet Like a Duck”. All he has to do is forward daily emails Duck”. All he has to do is forward daily emails to his fellow employees describing the product to his fellow employees describing the product and giving Sam’s website. Alwayz doesn’t have and giving Sam’s website. Alwayz doesn’t have a home computer, but doesn’t think it would a home computer, but doesn’t think it would take much time at work to do this.take much time at work to do this.

• Can Alwayz take the job?Can Alwayz take the job?

AnswerAnswer

No. No.

An employee may not conduct An employee may not conduct a business at the office. An a business at the office. An employee’s computer and employee’s computer and email system are to be used to email system are to be used to perform work related perform work related functions. This would not fall functions. This would not fall within HUD’s exception for within HUD’s exception for limited personal use. limited personal use.

► Protect and conserve Government property.Protect and conserve Government property.


• Tobi Tyrant, my supervisor, sometimes Tobi Tyrant, my supervisor, sometimes asks me to do personal favors, such as asks me to do personal favors, such as run to the Post Office or Credit Union, run to the Post Office or Credit Union, pick up Tyrant’s son from football pick up Tyrant’s son from football practice, or wash out Tyrant’s mug practice, or wash out Tyrant’s mug after I bring Tyrant the morning coffee. after I bring Tyrant the morning coffee.

• Can Tyrant require me to Can Tyrant require me to perform these non-job related duties? perform these non-job related duties?

AnswerAnswer

• NONO• A supervisor may not use his or her A supervisor may not use his or her

supervisory or management position to supervisory or management position to seek a favor from a subordinate.seek a favor from a subordinate.

• This would violate the prohibition This would violate the prohibition against using public office for private against using public office for private gain.gain.

►Don’t use public office for private gain.Don’t use public office for private gain.


• I have been asked for a letter of I have been asked for a letter of recommendation by someone I recommendation by someone I worked with for several years while worked with for several years while I was working in Single Family.I was working in Single Family.– She is moving to Tulsa soon and will She is moving to Tulsa soon and will

be seeking employment there.be seeking employment there.

• Can I give her a letter of Can I give her a letter of recommendation on HUD recommendation on HUD letterhead using my HUD title?letterhead using my HUD title?

AnswerAnswer

• YESYES• You may write her a letter of You may write her a letter of

recommendation using your HUD recommendation using your HUD letter head and your official title letter head and your official title based on personal knowledge of based on personal knowledge of her ability and/or characterher ability and/or character..– You may also include examples of You may also include examples of

your work together, to illustrate your your work together, to illustrate your recommendation.recommendation.

► Don’t use public office for private gain.Don’t use public office for private gain.


• The two West Texas towns of Angus & The two West Texas towns of Angus & Longhorn are vying for limited SHP Longhorn are vying for limited SHP moneys under HUD’s 2006 SuperNOFA.moneys under HUD’s 2006 SuperNOFA.– ““Desperate Dan,” the Angus City Mgr., Desperate Dan,” the Angus City Mgr.,

knows that he must win approval of the knows that he must win approval of the City’s application to keep his job.City’s application to keep his job.

– Dan calls his CPD rep, Peggy Pleaser, and Dan calls his CPD rep, Peggy Pleaser, and asks her the amount of rival Longhorn’s asks her the amount of rival Longhorn’s funding request.funding request.

• Should Peggy furnish Dan with the Should Peggy furnish Dan with the information he is seeking?information he is seeking?

AnswerAnswer• NONO

• Disclosure of the amount of assistance Disclosure of the amount of assistance requested by any applicant at any time during requested by any applicant at any time during the selection process is a violation of the HUD the selection process is a violation of the HUD Reform Act of 1989Reform Act of 1989..

• Other disclosures which are impermissible Other disclosures which are impermissible at any time during the selection process are:during the selection process are:– Any applicant’s relative standingAny applicant’s relative standing– Any info contained in an applicationAny info contained in an application

ALERT: If in doubt, ASK!

► Practice impartiality in Government duties.Practice impartiality in Government duties.


• The little old lady who lives in a shoe The little old lady who lives in a shoe has so many kids she needs a second has so many kids she needs a second job to supplement her HUD salary.job to supplement her HUD salary.• Elf Furniture of Fairytale City has offered her Elf Furniture of Fairytale City has offered her

a part-time sales position working 25 hours a part-time sales position working 25 hours a week.a week.

• May the “Little Old Lady” accept May the “Little Old Lady” accept the offer of 25 hours per week?the offer of 25 hours per week?

AnswerAnswer• YESYES

• As long as “Little Old Lady’s” part-As long as “Little Old Lady’s” part-time job does not interfere with her time job does not interfere with her duty hours or her HUD work duty hours or her HUD work performance.performance.– Generally, part-time employment up to 20 Generally, part-time employment up to 20

hours will be approved.hours will be approved.– More than 20 hours may also be approved; More than 20 hours may also be approved;

however, if the employee begins to sleep at however, if the employee begins to sleep at work, it would be evident that the part-time work, it would be evident that the part-time job is impairing the employee’s ability to job is impairing the employee’s ability to perform her duties.perform her duties.



• Scarlett O’Hare is the Field Office Director of Scarlett O’Hare is the Field Office Director of HUD’s New Orleans office.HUD’s New Orleans office.– Scarlett has been asked to serve as a member of the Scarlett has been asked to serve as a member of the

Housing Advisory Committee of the Louisiana Housing Advisory Committee of the Louisiana Mortgage Finance Authority (LMFA).Mortgage Finance Authority (LMFA).

– LMFA is a State Housing Finance Agency that LMFA is a State Housing Finance Agency that administers many of HUD’s programs for the State as administers many of HUD’s programs for the State as well as being a HUD contractor.well as being a HUD contractor.

• Is there a problem with Scarlett joining the Is there a problem with Scarlett joining the Committee?Committee?

AnswerAnswer

• YESYES• Since Scarlett’s responsibilities include overall Since Scarlett’s responsibilities include overall

supervision of HUD’s housing programs and supervision of HUD’s housing programs and HUD contracting within the New Orleans office HUD contracting within the New Orleans office jurisdiction.jurisdiction.– Scarlett cannot join the Committee.Scarlett cannot join the Committee.– However, Scarlett can be the HUD liaison to the However, Scarlett can be the HUD liaison to the

Committee if her supervisor agrees, and she follows Committee if her supervisor agrees, and she follows procedures (Ethics Letter 98-1 is available from procedures (Ethics Letter 98-1 is available from Regional Counsel). Regional Counsel).

► Outside activities can’t conflict w/ Federal job.Outside activities can’t conflict w/ Federal job.


• My favorite Uncle died and left me 325 My favorite Uncle died and left me 325 shares of FNMA (“Fannie Mae”) shares of FNMA (“Fannie Mae”) securities.securities.

• Can I keep the securities as a part of my Can I keep the securities as a part of my investment portfolio?investment portfolio?

AnswerAnswer

• NONO• FNMA securities which are involuntarily FNMA securities which are involuntarily

acquired must be reported to the Regional acquired must be reported to the Regional Counsel within 30 days of acquisition.Counsel within 30 days of acquisition.

• You have 90 days to divest yourself of the You have 90 days to divest yourself of the securities. securities.

► Financial interests can’t conflict w/ duties.Financial interests can’t conflict w/ duties.


• Dorothy, a HUD employee, and her Dorothy, a HUD employee, and her husband, Toto, are one month away husband, Toto, are one month away from acquiring 4 units of rental property. from acquiring 4 units of rental property. – All units are rented and all the tenants’ rents All units are rented and all the tenants’ rents

are assisted with Section 8 rental payments. are assisted with Section 8 rental payments.

– Can Dorothy and her husband complete the Can Dorothy and her husband complete the acquisition of this property?acquisition of this property?

AnswerAnswer

• NONO• An agency employee shall not directly or An agency employee shall not directly or

indirectly receive, acquire or own any Sec. 8 indirectly receive, acquire or own any Sec. 8 subsidy payment made to or on behalf of a subsidy payment made to or on behalf of a tenant of property owned by the employee: tenant of property owned by the employee: 5 5 CFR § 7501.104(a)(5).CFR § 7501.104(a)(5).– However, Dorothy and her husband can keep an However, Dorothy and her husband can keep an

involuntarily acquired property which houses a Sec. involuntarily acquired property which houses a Sec. 8 tenant, and the tenant can continue to receive 8 tenant, and the tenant can continue to receive assistance.assistance.

– If the Sec. 8 tenant moves out, they cannot replace If the Sec. 8 tenant moves out, they cannot replace the tenant with another Sec. 8 recipient. the tenant with another Sec. 8 recipient.

► Financial interests can’t conflict w/ duties.Financial interests can’t conflict w/ duties.


• Betsy Broker is an investigator in FHEO. Betsy Broker is an investigator in FHEO. – She has a valid Oklahoma real estate She has a valid Oklahoma real estate

license.license.– She would like to sell real estate on a part-She would like to sell real estate on a part-

time basis for members of her family and time basis for members of her family and Church.Church.

– Alice, a woman at Betsy’s Church, would like Alice, a woman at Betsy’s Church, would like Betsy to sell her restaurant, “Cow on a Bun”.Betsy to sell her restaurant, “Cow on a Bun”.

• Is this permissible?Is this permissible? MOO

AnswerAnswer

• YESYES• The standards of conduct prohibit active participation in The standards of conduct prohibit active participation in

or conduct of a business related to real estate, including or conduct of a business related to real estate, including real estate brokerage.real estate brokerage.

• This reg has been interpreted to permit Betsy to This reg has been interpreted to permit Betsy to participate in a real estate transaction provided she does participate in a real estate transaction provided she does NOT:NOT:

• advertise her services,advertise her services,• engage in multi-family property transactions,engage in multi-family property transactions,• engage in more than two real estate transactions per engage in more than two real estate transactions per

year,year,• engage in any HUD or FHA transactionsengage in any HUD or FHA transactions

• Therefore, it would be permissible for Betsy to assist Therefore, it would be permissible for Betsy to assist Alice in the sale of her restaurant and receive a fee.Alice in the sale of her restaurant and receive a fee.



1.1. As a Dept. employee, can I sponsor a “meet the As a Dept. employee, can I sponsor a “meet the candidate” reception for a State candidate” reception for a State Senator ?Senator ?

• Yes, Federal employees can sponsor “meet the Yes, Federal employees can sponsor “meet the candidate” meetings and receptions in their home candidate” meetings and receptions in their home or elsewhere. However, we may not sponsor a or elsewhere. However, we may not sponsor a fund raiser in our homes or elsewhere. We may fund raiser in our homes or elsewhere. We may attend them and such events may be sponsored by attend them and such events may be sponsored by our spouses in any location.our spouses in any location.


2.2. Can an employee be a delegate to the Can an employee be a delegate to the Republican National Convention?Republican National Convention?

• Yes, you are permitted to hold office in a Yes, you are permitted to hold office in a political party.political party.

3.3. Is it okay for the office management and other Is it okay for the office management and other staff members to attend a reception in honor staff members to attend a reception in honor of a Congressperson?of a Congressperson?

• Yes, but if during duty day, must take annual Yes, but if during duty day, must take annual leave.leave.

► Be a good citizen and pay just debts.Be a good citizen and pay just debts.


• ““Risky” Biznes is the PIH Dir. in HUD’s Risky” Biznes is the PIH Dir. in HUD’s Albuquerque Office.Albuquerque Office.– Last week, “Risky” began employment nego. Last week, “Risky” began employment nego.

w/ the Albuquerque HA for the position of w/ the Albuquerque HA for the position of Executive Director.Executive Director.

– ““Risky” is scheduled to lead a mgmt. review Risky” is scheduled to lead a mgmt. review of the HA in 2 weeks.of the HA in 2 weeks.

• Is there a problem here?Is there a problem here?

AnswerAnswer

• YESYES• ““Risky” is seeking other employment w/ HUD-Risky” is seeking other employment w/ HUD-

related entities while still employed by the related entities while still employed by the Department.Department.

• Accordingly, “Risky” must:Accordingly, “Risky” must:– Immed. disqualify himself from all Albuquerque HA Immed. disqualify himself from all Albuquerque HA

matters and related supervisory duties.matters and related supervisory duties.– Inform his supervisor of his need for Inform his supervisor of his need for

disqualification.disqualification.

_ All Albuquerque HA matters must be routed to _ All Albuquerque HA matters must be routed to “Risky’s” supervisor.“Risky’s” supervisor.



• During discussions with Builder Bob During discussions with Builder Bob concerning the plans and specifications concerning the plans and specifications submitted by him for approval by HUD, submitted by him for approval by HUD, Bob offered me a job.Bob offered me a job.

• May I resign my position with HUD and May I resign my position with HUD and immediately accept a position with Bob immediately accept a position with Bob in the builder’s architectural and in the builder’s architectural and engineering department to prepare engineering department to prepare plans and specifications?plans and specifications?

AnswerAnswer

• YesYes• Federal law does not bar former gov’t Federal law does not bar former gov’t

employees from employment with any pvt. or employees from employment with any pvt. or public employer after Gov’t service. public employer after Gov’t service.

• As a former HUD employee, however, you As a former HUD employee, however, you should not act as Builder Bob’s rep. to HUD on should not act as Builder Bob’s rep. to HUD on the particular matter in which you participated; the particular matter in which you participated; however, you could work on the plans and however, you could work on the plans and specs. for the project in Bob’s office to comply specs. for the project in Bob’s office to comply with HUD’s requirements.with HUD’s requirements.

► Public service is a public trust.Public service is a public trust.

When in Doubt?When in Doubt?

Contact your Agency Contact your Agency Ethics Official to Resolve Ethics Official to Resolve

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