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Bill Daley

Ken McDonald

Chris Kinnear



Bill Daley

Ken McDonald

Barbara Coen

Allyssa Wheaton-Rodriguez


Vickie Spinks



Wayne Abbott

Erin Allen

Teri Laird

Debbie Holland

Susan Kenyon

Wanda Holiday

Bill Daley

Ken McDonald

Barbara Coen


Bill Cerbone

Kim Mayfield

office of general counsel
Office of General Counsel
  • Keith Gottfried, General Counsel
  • Bill Daley, Regional Counsel
  • Attorney-Advisor: Standards of Conduct
the 14 principles
The 14 Principles
  • The preamble to the Government-wide Standards of Conduct contains what is commonly referred to as “The 14 Principles” of Government Ethics.
  • Upon these principles are built the regulations, which will be illustrated in the Questions and Answers to follow.
list of the14 principles
List of the14 Principles
  • Public service is a public trust.
  • Financial interests can’t conflict w/ duties.
  • Don’t misuse nonpublic information.
  • Refuse gifts from Government clients.
  • Put honest effort into your work.
  • Avoid committing Government w/o authority.
  • Don’t use public office for private gain.
  • Practice impartiality in Government duties.
  • Protect and conserve Government property.
  • Outside employment can’t conflict w/ Federal job.
  • Disclose waste, fraud, abuse and corruption.
  • Be a good citizen and pay just debts.
  • Adhere to Equal Opportunity laws and regulations.
  • Avoid the appearance of wrongdoing.



Please be sure to update HIHRTS when major changes happen in your life: birth, adoption, marriage, divorce, etc.

Do you need to change your beneficiaries?

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

Mouse-house, Inc.

  • NO
  • Because award of the systems contract to Mousehouse, Inc., or to any other offeror will have a direct and predictable effect on Rea’s financial interest. Rea cannot participate on the TEP team unless her disqualification has been waived.
  • Financial interests can’t conflict w/ duties.
  • Ido Goodworks, a LR office employee, volunteers as a bd. member of Disability Employment Options (DEO), a non-profit org. which provides job opportunities for the physically challenged community. DEO has its own work center and has been awarded two manuf. contracts with the Air Force. As a part of her board duties, Ido has been asked to oversee these two contracts.
  • May Ido oversee these two Air Force contracts for DEO?
  • No
  • Certain criminal statutes limit representational activities by gov’t employees before federal departments, agencies, and/or courts.
  • Accordingly, as a HUD employee, Ido cannot represent DEO before the Air Force, either in person or by written communication which she 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 Counsel of HUD’s Houston Office and a huge tennis fan.
    • While attending the Houston Open, “Rah Rah” bumps into Developer Dan and his father.
    • Dan and “Rah Rah” have worked together for years on numerous FHA-insured multi-family and Sec 202/811 projects.
    • Dan’s father gives “Rah Rah” two tickets to the U. S. Open worth over $750, saying that he is retiring and moving to Italy in 3 days and has no use for the tickets.
  • Can “Rah Rah” keep the tickets?
  • NO
  • The value of the gift exceeds the $20 gift limit.
    • Standards of Conduct regulations prohibit accepting any gift given to an employee because of his official position, unless the item is excluded from the definition of gift or falls within one of the exceptions to the “no gift” rule.
  • Refuse gifts from Government clients.
  • Sam Showoff drew his boss, Paulo Plaitstrate, for the annual Christmas gift exchange.
    • Hoping to improve his performance rating from last year, Sam gives his boss a Cross pen and pencil desk set worth $35.00.
    • Suspecting the desk set might be worth over the $10 gift exchange limit, Paulo seeks advice from the HUD Ethics Counselor.
  • Can Paulo accept the desk set?
  • NO
  • Regs permit a subordinate to give his supervisor a gift costing $10 or less on occasions on which gifts are given, such as Christmas time; however, the desk set exceeds the $10 gift limit.
    • Paulo must return the desk set to Sam.
  • Refuse gifts from Government clients (employees).
  • Ray and Maria are getting married.
    • Both are HUD employees.
    • Ray is Director of FHEO.
    • Maria is Head of Admin Services.
    • The Happy Couple sent invitations to many HUD friends, including Oprahe, who works for Ray.
    • Oprahe bought Ray and Maria a silver-plated tea set worth over $125 as a wedding present.
  • May Ray accept the present?
  • YES
  • Ray may accept the present even though he is Oprahe’s supervisor.
    • Ray and Maria’s wedding is a special, infrequent occasion which is an exception to the general rule that an employee may not give a gift to her supervisor.
  • Refuse gifts from Government clients (employees).
  • Several Office of Public Housing (PH) employees accepted home dinner invitations from officials of the PHA they were reviewing.
  • Should the employees have accepted the dinner invitations?
  • NO
  • Even if a home meal could be accepted because it costs less than $20, the acceptance of a meal is inappropriate in some cases.
    • In this instance, acceptance of home dinner invitations by PH employees conducting reviews of PHAs is not permitted because of the appearance of loss of impartiality.
    • Remember, even though acceptance of gifts may be permitted by one of the exceptions to the general rule, it is NEVER inappropriate and frequently prudent for an employee to decline a gift offered by a prohibited source.
  • Avoid the appearance of wrongdoing.
  • I am a HUD employee in the San Antonio Office and about to become a first-time homebuyer!
    • I saw four houses in a home magazine that were in my price range, but they are HUD-owned homes.
  • May I purchase one of these properties?
  • YES


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

* Notice! 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

  • Don’t misuse nonpublic information.
  • Clu Less, an owner of an FHA insured development with his first HUD insured loan, asks Marsha Mello, a HUD project manager, to recommend an auditor familiar with HUD requirements to do his required audited financial statements.
  • Can Marsha provide Clu Less with a list of the business names and phone numbers of auditors who she knows have worked on HUD projects?
  • 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 Commerce and HUD are developing a small business workshop. As its share of the work HUD…
    • Developed the concept of the workshop
    • Initiated contact with principal parties
    • Arranged for printing and reproduction of conference materials
    • Will coordinate the event in terms of topics, timing, speakers, promoting to potential attendees
    • Will participate as a speaker/lecturer
  • Alfred E. Newperson, the NO office manager, is worried that it might be considered a “co-sponsored” event, thus requiring Regional Director approval and Regional Counsel concurrence.
  • Would this be considered a “co-sponsored” event?

HUD is co-sponsoring the small business workshop with the non-Fed entities.

Alfred will need to obtain approval of the Regional Director and concurrence of the Regional Counsel in order 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.
  • Mercedes, TX is holding the City’s 3rd Annual Rio Grande Valley Hispanic Business Exposition
    • As a participant at the Expo, HUD will:
      • Have a booth.
      • Be listed in promotional material.
      • Pay $200 “co-sponsor” fee.
  • IS HUD a “CO-SPONSOR” of the Expo?
  • NO
  • Hosting a booth, paying a “co-sponsor” fee and being listed in the promotional materials is not enough involvement to cause HUD to be a “co-sponsor” of the event.
    • HUD did not jointly develop the Expo w/the City
    • HUD’s participation in the event is not “substantive.”
  • This event will be treated as a “widely-attended gathering” sponsored by a “prohibited source.”
    • With written approval from the Dept. Ethics Official (Bill Daley) and ADMIN approval of the $200 fee, HUD may set up a booth and be listed in the promo material.
  • Avoid committing Government w/o authority.
  • Peter, Paul and Mary, HUD employees, would like to attend the Governor’s Housing conference sponsored by the Arkansas Dev. Fin. Auth. (ADFA).
    • ADFA has agreed to waive the $80 registration fee.
  • May the employees accept the fee waivers?
  • Employees may attend and accept the waivers of the conference fees provided:
    • Sponsor’s offer must be unsolicited.
    • Employees’ attendance must further operations or programs of the Dept.
    • Since the sponsor is “prohibited source”, the Regional Counsel must approve the waiver of conference fees in writing.
  • Refuse gifts from Government clients.
  • Barbara Brownie, a HUD employee, is selling Girl Scout cookies as a fund raiser. She asked you if she could set up a cookie display on the office break room table.
  • Is Barbara permitted to solicit sales of Girl Scout cookies in this manner?
  • NO
  • While HUD employees are on official duty or in the Federal workplace, they may not sell items such as church or school fund- raising material, cookies or lottery tickets. Solicitations of pledges for walk-a-thons or similar events are likewise prohibited. However, you may:
    • Conduct fund-raiser before and after core work hours, on non-work time, and in non-HUD space
    • Post notices of the fund-raiser on the employee bulletin boards located in the office
  • Don’t use public office for private gain.
  • Kant Sing is employed as a lawyer for HUD. He tries out for American Idol, but Simon says his voice needs a LOT of work. During a break Randy asks Kant Sing if he would draft a will for him, because he is afraid some rejected contestant may get violent.
  • May Kant Sing do legal work for Randy without getting approval from anyone at HUD?
  • NO

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

  • Outside employment can’t conflict w/ Federal job.
  • Peggy Parent is a “sponsor” of her son’s Little League team.
  • To help the team, Peggy has been asked to make 30 copies of the team’s roster and 30 copies of the permission slips that the parents must sign.
  • Can Peggy use the office copier to produce the required copies?
  • NO
  • Making 60 copies on the office copier is an inappropriate use of HUD’s policy on “Limited Personal Use” of government office equipment, including Information Technology.
    • The notice authorizes limited use of the office copier as long as only small amounts of paper, toner, etc. are involved.
    • Employees should consult with their supervisor if there is any question of appropriate use of office equipment or information technology.
  • Protect and conserve Government property.


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



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

  • Protect and conserve Government property.
  • Tobi Tyrant, my supervisor, sometimes asks me to do personal favors, such as run to the Post Office or Credit Union, pick up Tyrant’s son from football practice, or wash out Tyrant’s mug after I bring Tyrant the morning coffee.
  • Can Tyrant require me to perform these non-job related duties?
  • NO
  • A supervisor may not use his or her supervisory or management position to seek a favor from a subordinate.
  • This would violate the prohibition against using public office for private gain.
  • Don’t use public office for private gain.
  • I have been asked for a letter of recommendation by someone I worked with for several years while I was working in Single Family.
    • She is moving to Tulsa soon and will be seeking employment there.
  • Can I give her a letter of recommendation on HUD letterhead using my HUD title?
  • YES
  • You may write her a letter of recommendation using your HUD letter head and your official title based on personal knowledge of her ability and/or character.
    • You may also include examples of your work together, to illustrate your recommendation.
  • Don’t use public office for private gain.
  • The two West Texas towns of Angus & Longhorn are vying for limited SHP moneys under HUD’s 2006 SuperNOFA.
    • “Desperate Dan,” the Angus City Mgr., knows that he must win approval of the City’s application to keep his job.
    • Dan calls his CPD rep, Peggy Pleaser, and asks her the amount of rival Longhorn’s funding request.
  • Should Peggy furnish Dan with the information he is seeking?
  • NO
  • Disclosure of the amount of assistance requested by any applicant at any time during the selection process is a violation of the HUD Reform Act of 1989.
  • Other disclosures which are impermissible at any timeduring the selection process are:
    • Any applicant’s relative standing
    • Any info contained in an application

ALERT: If in doubt, ASK!

  • Practice impartiality in Government duties.
  • The little old lady who lives in a shoe has so many kids she needs a second job to supplement her HUD salary.
    • Elf Furniture of Fairytale City has offered her a part-time sales position working 25 hours a week.
  • May the “Little Old Lady” accept the offer of 25 hours per week?
  • YES
  • As long as “Little Old Lady’s” part-time job does not interfere with her duty hours or her HUD work performance.
    • Generally, part-time employment up to 20 hours will be approved.
    • More than 20 hours may also be approved; however, if the employee begins to sleep at work, it would be evident that the part-time job is impairing the employee’s ability to perform her duties.
  • Outside employment can’t conflict w/ Federal job.
  • Scarlett O’Hare is the Field Office Director of HUD’s New Orleans office.
    • Scarlett has been asked to serve as a member of the Housing Advisory Committee of the Louisiana Mortgage Finance Authority (LMFA).
    • LMFA is a State Housing Finance Agency that administers many of HUD’s programs for the State as well as being a HUD contractor.
  • Is there a problem with Scarlett joining the Committee?
  • YES
  • Since Scarlett’s responsibilities include overall supervision of HUD’s housing programs and HUD contracting within the New Orleans office jurisdiction.
    • Scarlett cannot join the Committee.
    • However, Scarlett can be the HUD liaison to the Committee if her supervisor agrees, and she follows procedures (Ethics Letter 98-1 is available from Regional Counsel).
  • Outside activities can’t conflict w/ Federal job.
  • My favorite Uncle died and left me 325 shares of FNMA (“Fannie Mae”) securities.
  • Can I keep the securities as a part of my investment portfolio?
  • NO
  • FNMA securities which are involuntarily acquired must be reported to the Regional Counsel within 30 days of acquisition.
  • You have 90 days to divest yourself of the securities.
  • Financial interests can’t conflict w/ duties.
  • Dorothy, a HUD employee, and her husband, Toto, are one month away from acquiring 4 units of rental property.
    • All units are rented and all the tenants’ rents are assisted with Section 8 rental payments.
    • Can Dorothy and her husband complete the acquisition of this property?
  • NO
  • An agency employee shall not directly or indirectly receive, acquire or own any Sec. 8 subsidy payment made to or on behalf of a tenant of property owned by the employee: 5 CFR § 7501.104(a)(5).
    • However, Dorothy and her husband can keep an involuntarily acquired property which houses a Sec. 8 tenant, and the tenant can continue to receive assistance.
    • If the Sec. 8 tenant moves out, they cannot replace the tenant with another Sec. 8 recipient.
  • Financial interests can’t conflict w/ duties.
  • Betsy Broker is an investigator in FHEO.
    • She has a valid Oklahoma real estate license.
    • She would like to sell real estate on a part-time basis for members of her family and Church.
    • Alice, a woman at Betsy’s Church, would like Betsy to sell her restaurant, “Cow on a Bun”.
  • Is this permissible?


  • YES
  • The standards of conduct prohibit active participation in or conduct of a business related to real estate, including real estate brokerage.
  • This reg has been interpreted to permit Betsy to participate in a real estate transaction provided she does NOT:
      • advertise her services,
      • engage in multi-family property transactions,
      • engage in more than two real estate transactions per year,
      • engage in any HUD or FHA transactions
    • Therefore, it would be permissible for Betsy to assist Alice in the sale of her restaurant and receive a fee.
  • Outside employment can’t conflict w/ Federal job.
  • As a Dept. employee, can I sponsor a “meet the candidate” reception for a State
  • Senator ?
  • Yes, Federal employees can sponsor “meet the candidate” meetings and receptions in their home or elsewhere. However, we may not sponsor a fund raiser in our homes or elsewhere. We may attend them and such events may be sponsored by our spouses in any location.
  • Can an employee be a delegate to the Republican National Convention?
  • Yes, you are permitted to hold office in a political party.
  • Is it okay for the office management and other staff members to attend a reception in honor of a Congressperson?
  • Yes, but if during duty day, must take annual leave.
  • Be a good citizen and pay just debts.
  • “Risky” Biznes is the PIH Dir. in HUD’s Albuquerque Office.
    • Last week, “Risky” began employment nego. w/ the Albuquerque HA for the position of Executive Director.
    • “Risky” is scheduled to lead a mgmt. review of the HA in 2 weeks.
  • Is there a problem here?
  • YES
  • “Risky” is seeking other employment w/ HUD-related entities while still employed by the Department.
  • Accordingly, “Risky” must:
    • Immed. disqualify himself from all Albuquerque HA matters and related supervisory duties.
    • Inform his supervisor of his need for disqualification.

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

  • Outside employment can’t conflict w/ Federal job.
  • During discussions with Builder Bob concerning the plans and specifications submitted by him for approval by HUD, Bob offered me a job.
  • May I resign my position with HUD and immediately accept a position with Bob in the builder’s architectural and engineering department to prepare plans and specifications?
  • Yes
  • Federal law does not bar former gov’t employees from employment with any pvt. or public employer after Gov’t service.
  • As a former HUD employee, however, you should not act as Builder Bob’s rep. to HUD on the particular matter in which you participated; however, you could work on the plans and specs. for the project in Bob’s office to comply with HUD’s requirements.
  • Public service is a public trust.
when in doubt
When in Doubt?

Contact your Agency Ethics Official to Resolve a Question or Conflict