Obama-Administration-Report-Card

							                 Common Cause Democracy 21
       League of Women Voters Public Citizen U.S. PIRG


          Reform Groups Issue Report Card on the
      Obama Administration’s First Year Executive Branch
         Lobbying, Ethics and Transparency Reforms

                                     Summary
        This report card on the Obama Administration’s Executive Branch lobbying,
ethics and transparency reforms during its first year in office is being issued by Common
Cause, Democracy 21, the League of Women Voters, Public Citizen and U.S. PIRG.

        The report card is based on the changes in Executive Branch rules and
policies made by the Obama Administration in 2009, measured by what an
Administration can accomplish solely through its own Executive Branch actions and
in light of what past Administrations have done. Other issues, including the
overriding problem in Washington caused by the use of campaign money to buy
access and influence with federal officeholders, are not addressed in the report card
but are discussed below in the summary.

        President Obama began his efforts in this area by institutionalizing a role in the
White House for government reform issues, appointing Norm Eisen as Special Counsel to
the President for Ethics and Government Reform.

       On the first full day of his Administration, President Obama issued Executive
Order 13490, entitled “Ethics Commitments by Executive Branch Personnel.”

       The Executive Order went further than any previous presidential action on ethics
and lobbying reforms, establishing the strongest and most far reaching revolving door
provisions ever adopted by an Administration.

        The Executive Order was followed by a series of White House memoranda and
guidelines dealing with the relationship between special interests and the Executive
Branch, including new open government and transparency policies, new restrictions on
interests seeking government funds from executive agencies and new restrictions on
lobbyists serving on federal advisory panels.

       The new reforms implemented by the Obama Administration include:

       Revolving Door Lobbying Ban. Upon leaving government service, former
       Obama Administration appointees are prohibited from lobbying any covered
                                                                                        2

    official in the entire Executive branch for as long as President Obama is in office.
    The scope and length of coverage of these revolving door provisions go far
    beyond any such provisions ever previously adopted.

•   Open Government. The Administration adopted a series of precedent setting
    open government policies, resulting in new information being released to the
    public and posted on the Internet. This included information on White House
    meetings with private interests, policies to expedite information being provided in
    response to FOIA requests and information on interests seeking stimulus funding,
    government contracts and waivers from ethics rules. The Administration also
    issued a government wide “Open Government Directive” and established a
    National Declassification Center.

•   Reverse Revolving Door Restrictions. Individuals who served as lobbyists
    during the two-year period prior to joining the Obama Administration are
    prohibited from being appointed to any agency or department that they lobbied for
    two years after they join the Administration. They can serve in other agencies and
    departments of the executive branch, but are prohibited during the two year period
    from participating as government officials in any particular matter on which they
    lobbied or in the specific issue area in which the particular matter falls.

    All political appointees are prohibited for two years following their appointment
    from participating in any particular matter involving specific parties that is
    directly and substantially related to former employers or clients.

•   Lobbyist Gift Ban. Political appointees are prohibited from accepting gifts from
    lobbyists or organizations that employ or retain lobbyists. The Office of
    Government Ethics is directed to make the lobbyist gift ban applicable to all
    executive branch employees.

•   End Lobbyists Serving on Federal Advisory Boards. The White House has
    urged (but not mandated) agencies and departments not to appoint or reappoint
    registered lobbyists to serve on federal advisory boards and commissions.

•   Restrictions on Seeking Stimulus Funds. A pilot program that requires any
    person seeking government funds under the Recovery and Reinvestment Act to
    make all requests and comments regarding the grant in writing, once a written
    grant request has been submitted. All such requests and comments are required to
    be posted by the Executive Branch on the Internet within three days. Any other
    communications by a lobbyist about stimulus funds must be disclosed on the
    Internet by the agency or department receiving the communication.

•   Restrictions on Seeking Financial Bailout. Similar rules requiring written
    comments and requests were adopted for the financial bailout program. Such rules
    were adopted, however, well after the program was begun.
                                                                                            3

        The cumulative effect of the Administration’s actions has been to adopt the
strongest and most comprehensive lobbying, ethics and transparency rules and policies
ever established by an Administration to govern its own activities.

        These new rules and policies have begun the difficult process of challenging
Washington’s influence-culture. Washington lobbyists, special interests and campaign
contributions exercise enormous influence over government decisions at the great
expense of the American people. The Washington influence-culture fundamentally
undermines the integrity of our government and is a prime cause for the deep cynicism
that exists in our society about public policies and federal officeholders.

        President Obama deserves high praise for the ethics, lobbying and transparency
rules put in place for the Executive Branch during his first year in office. Overall, our
organizations give the Administration very high grades for its Executive Branch reforms
during 2009.

        At the same time, however, it must be recognized that the overriding issue that
has to be addressed in order to change the way business is done in Washington is the
corrupting role of campaign money in influencing federal officeholders and government
decisions.

       In 2009, the Obama Administration took no steps to address this fundamental
problem for our democracy.

       In 2010 and beyond, the overriding test for the Obama Administration’s attempt
to change Washington’s ways will be its efforts to reform the nation’s campaign finance
laws and the enforcement of those laws. To date, such an effort has been absent from the
Obama Administration’s agenda.

       As a recent article in Politico (December 22, 2009) noted:

       Washington’s influence industry is on track to shatter last year’s record $3.3
       billion spent to lobby Congress and the rest of the government – and that’s with a
       down economy and about 1,500 fewer registered lobbyists in town, according to
       data collected by the Center for Responsive Politics.

      In the end, in order to take on “Washington’s influence industry,” the Obama
Administration must take up the battle for fundamental campaign finance reform.

      At stake here is nothing less than the right of the American people to a
government free from corruption and influence buying.

       Fundamental reform of the nation’s campaign finance laws requires:

           •   Repairing the existing presidential public financing system;
           •   Establishing a new public financing system for congressional races, and
                                                                                           4

           •   Creating a new campaign finance enforcement system to replace the failed
               Federal Election Commission.

        At the heart of creating new financing systems for presidential and congressional
elections is the need to empower and engage widespread citizen participation in financing
these elections through small “non-influence seeking” contributions.

        An enormous opportunity exists today to dramatically change the way we finance
federal elections by combining the use of the Internet with small contributions and
multiple public matching funds to greatly increase the role of citizens in funding our
elections – and to concomitantly decrease the role of special interest influence money.

       This approach is central to the core campaign finance reforms for presidential and
congressional elections that must be achieved to effectively change Washington.

       In addition, campaign finance laws that are not properly enforced have limited
impact. This is a major problem of immediate consequence for the 2010 elections.

         The six-member Federal Election Commission is an “enforcement” agency that
has been taken over by three rogue Republican Commissioners, who are ideologically
opposed to the campaign finance laws, who have consistently thwarted enforcement of
the laws and who have repeatedly taken positions to gut and undermine the laws. As a
result, the three Republican Commissioners have signaled to all participants in the 2010
congressional elections that the campaign finance laws will not be enforced as long as
they continue to serve on the FEC.

       One of the three Republican FEC Commissioners, Don McGahn, is a lame duck,
whose term expired last April and who is not eligible for reappointment. Since his term
has expired, McGahn should not even be on the Commission at this time. But he can
continue to serve indefinitely until he is replaced by President Obama.

      It is essential for the President to promptly appoint a replacement for
Commissioner McGahn and to then pursue systemic changes that will create a real
campaign finance enforcement agency.

       These are the priority government reforms challenges and opportunities facing
President Obama as he begins his second year in office. We look forward to President
Obama providing strong leadership on these critical campaign finance reforms and to
working with the Obama Administration and congressional leaders to achieve these
goals.
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    Executive Branch Reforms in the Obama Administration’s First Year

      The report card below details seven areas in which the Administration has
implemented government reforms and provides a grade for each area. The areas
and grades discussed below include the following:

                           •    Revolving Door Lobbying Ban, A
                           •    Open Government, A
                           •    Reverse Revolving Door Restrictions, A
                           •    Lobbyist Gift Ban, B
                           •    End Lobbyists Serving on Federal Advisory Boards, B
                           •    Restrictions on Seeking Stimulus Funds, B
                           •    Restrictions on Seeking Financial Bailout, No Grade

     1.       Revolving Door Lobbying Ban.

       President Obama’s Ethics Executive Order, issued on January 21, 2008, prohibits
any appointee of the Obama Administration, after leaving the Administration, from
lobbying for compensation any covered executive branch official for the duration of the
Obama Administration.

       Under this prohibition, the ban applies to lobbying all senior officials in the entire
executive branch, and if President Obama is re-elected the ban would extend through two
presidential terms.

       In addition, senior officials who leave the Obama Administration may not make
any requests for official action from the agency in which they served for two years after
leaving their positions.1

        The new revolving door provisions vastly expand the current statutory restrictions
of a one-year ban on senior officials making direct lobbying contacts with their former
agency and a two-year ban on cabinet officials from lobbying any covered officials in the
executive branch.2

       The revolving door from government official to lobbyist creates the opportunity
for government officials to capitalize on their public office for personal gain and
undermines the integrity of the federal government.

        Public officials may be influenced in official actions by the implicit or explicit
promise of a lucrative job in the private sector with an organization seeking to shape
public policy on matters of economic importance to the organization or seeking a
government contract or grant. Equally troubling is the problem of public officials-turned-
lobbyists having special access to executive branch officials not available to others,

1
          Executive Order 13490 (Jan. 21, 2009), §1 (4) and (5).
2
          18 U.S.C. §207.
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access that can be sold by the former official to the highest bidder among industries
seeking to lobby. In previous administrations, more than a quarter of very senior
executive officials reportedly have spun through the revolving door to become paid
lobbyists.3

       The Administration’s revolving door ban squarely addresses these problems by
preventing former senior executive branch officials from taking a lobbying job to
influence the Obama Administration.

       A survey by the Public Affairs Council suggests that the new revolving door
policy may be enhancing a recent trend in Washington toward a decline in the number of
corporate lobbyists in Washington DC who have had previous congressional or executive
branch experience. Those with previous congressional experience dropped from 50
percent in 2006 to 37 percent as of [Need Date]; those with executive branch experience
dropped from 35 percent in 2006 to 24 percent as of [Need Date].4 ]

Grade: A, for establishing the most far reaching revolving door provisions ever
adopted.

    2.       Open Government.

       The Obama Administration has taken a series of unprecedented steps to
implement Executive Branch transparency in its first year that go well beyond any efforts
undertaken by previous administrations.

        For the first time ever, visits to the White House by CEOs, lobbyists and others on
official business are being posted on-line and available to the public and media.
Providing Internet disclosure of outside meetings with government officials is under
consideration for all senior executive branch officials. The Administration has posted
waivers to its ethics policy on the Internet and posted information about written and oral
contacts with executive branch officials regarding efforts to obtain stimulus funds and
financial bailout assistance. Most federal government contracts are being posted on-line.

      The Obama Administration also has made a very important change regarding the
Freedom of Information Act (FOIA) by ordering agencies and departments to adopt a
presumption of disclosure for information requested under FOIA. This should make it
much easier for citizens and the media to obtain information under FOIA.

         In a reversal of an Executive Order adopted by President Bush, the
Administration also has restored the practice of having only a sitting President able to
restrict citizen and media access to presidential records by claiming executive privilege
over these records. Former Presidents no longer have this authority.

3
         Elizabeth Brown, More than 2,000 Spin Through the Revolving Door (Center for Public Integrity,
2005).
4
         Public Affairs Council, “This Revolving Door Is Slowing Down,” Public Affairs Perspective
(2009), available at: http://pac.org/blog/revolving-door.
                                                                                              7



       There have been some shortcomings in the Administration’s transparency policies
however. For example, problems in obtaining timely release of records and timely
information on White House visits need to be corrected.

        Most recently, the Obama Administration issued an “Open Government
Directive” that instructs all federal departments and agencies to take immediate, specific
steps to open their operations to the public, and establishes long-term goals with
timetables to for further increased public access to government information.5 The
Administration also established a National Declassification Center to increase the
declassification of government documents..

        President Obama announced at the beginning of his term a commitment to
establishing an unprecedented level of openness in government. The President has made
unprecedented progress in pursuing this transparency goal and his Administration has
placed the use of technology and the Internet in the forefront of its efforts to make
government information easily and quickly accessible to citizens and the media.
.

Grade: A, for establishing an unprecedented Executive Branch open government policy
in its first year, with further transparency breakthroughs expected to come.


    3.       Reverse Revolving Door Restrictions.

         The most innovative and controversial new ethics policy of the Obama
Administration is the nation’s first-ever “reverse” revolving door lobbyist restrictions: an
effort to screen out conflicts of interest among appointees to the federal government in
order to prevent special interests from “capturing” the agencies that regulate them. The
policy has drawn strong adverse reactions from many in the Washington lobbying
community.

         Industries have in the past “captured” regulatory agencies by securing
appointments for their representatives to the agencies themselves – in effect, hiring the
fox to guard the henhouse. A classic early example of the reverse revolving door is the
Interstate Commerce Commission, established in 1887 to regulate the railroad “robber
barons.” Instead, it was quickly captured by the railroads, which then used the agency to
stifle competition and fix prices.

        During the Administration of President George W. Bush, reverse revolving door
appointments were widespread. The Bush Administration reportedly installed more than
100 top officials in regulatory agencies who were lobbyists or representatives of the
industries they were appointed to oversee.


5
         The President, OPEN GOVERNMENT: A PROGRESS REPORT TO THE AMERICAN PEOPLE (December
2009).
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       J. Stevens Griles, a coal industry lobbyist, for example, was appointed Deputy
Secretary of Interior, where he worked on energy-related issues of great interest to his
former clients. Philip Cooney, a lobbyist at the American Petroleum Institute, entered
government service and promptly began editing government climate research studies to
downplay the dangers of global warming. Ann Veneman, a former lobbyist for large agri-
business, was appointed Bush’s Agriculture Secretary. When Creekstone Farms decided
voluntarily to test all its cows for mad cow disease so that it could export to Japan,
Venemen reportedly said “no” - the major beef producers feared that consumers would
demand they follow suit.6

        The Obama Administration’s reverse revolving door policy is intended to prevent
conflicts of interest that may arise when an individual is appointed to an agency that
oversees his or her former employers or clients.

        Under the policy, individuals who had served as lobbyists during a two-year
period prior to joining the Obama Administration are prohibited from being appointed to
serve in any agency or department they lobbied during that two-year period, for two years
after they join the Administration. Former lobbyists are also prohibited from participating
as government officials in any particular matter on which they lobbied or in the specific
issue area in which the particular matter falls. A waiver policy is provided to provide
some flexibility in implementing this unprecedented policy.

        This policy, however, does not address the same potential conflicts that could
arise where former officials of private sector groups, other than lobbyists, are appointed
to senior positions in departments and agencies that regulate their former employers.

        The policy also requires that all appointees to the Obama Administration for a
period of two years following their appointment recuse themselves from any particular
matter involving specific parties that is directly and substantially related to former
employers or clients, subject to a waiver of the recusal.

        The Administration is posting waivers to the recusal requirement on-line for
public scrutiny and, to date, very few waivers appear to have been granted by the White
House or executive agencies.

        The Administration should, however, take the additional step of posting recusal
arrangements for appointees on the Internet to provide public accountability for the
proper implementation of the recusal policy. Currently, most agencies are requiring the
use of FOIA to obtain this information. Information on the recusal arrangements for
appointees should be easily available to the public.

Grade: A, for establishing the first-ever reverse revolving door policy.


6
         Revolving Door Working Group, A MATTER OF TRUST: HOW THE REVOLVING DOOR UNDERMINES
PUBLIC CONFIDENCE IN GOVERNMENT – AND WHAT TO DO ABOUT IT (October 2005), available at:
http://www.cleanupwashington.org/documents/RevovDoor.pdf.
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    4.       Lobbyist Gift Ban.

        The Ethics Executive Order issued by the Obama Administration requires
appointees to agree that they will not accept gifts of any value from lobbyists or
organizations that employ or retain lobbyists. The lobbyist gift ban comes in addition to
strict Executive Branch restrictions that already exist on gifts from anyone for
government officials.

      The lobbying gift ban is consistent with a similar gift ban enacted for members of
Congress under the Honest Leadership and Open Government Act of 2007 (HLOGA).

        The Office of Government Ethics (OGE) is also instructed to extend the lobbyist
gift ban to all employees of the executive branch and a process for accomplishing this is
underway.7

        A series of exceptions are provided from the executive branch gift ban similar to
the exceptions provided for members of Congress. For example, gifts based on a personal
relationship, such as wedding presents, or a meal provided at widely attended events are
exempt from the ban.

       The gift ban is designed to help prevent influence buying and the appearance of
influence buying by those with business pending before the executive branch. Unlike the
HLGOA gift ban for members of Congress, however, the executive branch gift ban
exempts travel from its coverage.

        Under HLOGA, Congress severely restricted trips paid for by lobbyists or
organizations that employ or retain lobbyists, as part of its gift ban. Such lobbyists and
lobbying organizations are prohibited from paying for trips taken by members of
Congress, with the only exception being for trips involving attendance at or participation
in a “one-day event.”

        Free “vacation” trips arranged and paid for by lobbyist Jack Abramoff and his
associates were a key part of the notorious Abramoff scandals and were an important
factor in Congress adopting new rules to end lobbyist-funded travel junkets. Then-
Senator Obama strongly supported these congressional restrictions.

        Current guidelines on privately-sponsored travel for executive branch officials
prohibit such trips if they would cause a reasonable person to question the integrity of the
agency’s programs or operations.8 This standard is too subjective to provide the
necessary protections against abuse, and therefore, the travel rules for executive branch
officials need to be strengthened.



7
         Robert Cusick, “Lobbyist Gift Ban Guidance,” DO-09-007, Office of Government Ethics (Feb. 11,
2009).
8
         41 CFR §304-5.3.
                                                                                                    10

        In one case from an earlier Administration, for example, Nancy Nord, former
head of the Consumer Product Safety Commission (CPSC), routinely accepted trips from
toy manufacturers, including at least one flight on a corporate jet, despite the fact the
CPSC was in charge of regulating these manufacturers.

         The antiquated reporting system for executive branch travel, furthermore, makes
it difficult to monitor such trips and determine whether they are proper. Only the
Department of Defense travel records are posted on-line and this is done by Northwestern
University’s Medill School of Journalism9 – which previously initiated on-line disclosure
of congressional travel, until HLOGA mandated that the Clerk of the House and
Secretary of Senate post such travel records.

       One analysis of paper records for executive branch travel, based on information
obtained from OGE, found 5,557 privately-sponsored executive branch trips were
reported for the period October 1, 2008 through March 31, 2009, with a total cost of more
than $9 million. The Department of Health and Human Services reported the highest
number of trips, with 2,996 privately-sponsored trips during that time period.10

       The Obama Administration should strengthen the rules and reporting
requirements for privately-funded, executive branch travel.

Grade: B, for promulgating a lobbyist gift ban for Administration appointees on top of
existing gift restrictions for Executive Branch officials; additional steps needed to
strengthen the gift rules governing private financing of executive branch travel.

    5.      End Lobbyists Serving on Federal Advisory Boards.

       In a move that also has drawn strong criticism from some in the Washington
lobbying community, President Obama has urged federal departments and agencies to not
appoint or re-appoint registered lobbyists to serve on federal advisory boards and
commissions. The policy represents a request, but not a mandate, from President Obama.

       There are 915 executive branch advisory boards and commissions currently in
existence with a total of approximately 60,000 members. Each board and commission is
created by and accountable to the specific department or agency they advise.

         As such, there is no central database of how many lobbyists serve on these
advisory groups and it hard to obtain this information, but the number is considered to be
substantial. In one case, where the information is available, among the 16 Industry Trade
Advisory Committees (ITAC) that give business a voice in U.S. trade policy, for
example, there are 130 registered corporate lobbyists on the committees – about a third of
the total membership.

9
         The Department of Defense travel records from 1998 through 2007, in which private groups
sponsored 22,000 trips valued at $26 million, are available at:
http://www.publicintegrity.org/investigations/pentagon_travel/
10
         Data compiled by Vanessa Lugo, research assistant, Public Citizen.
                                                                                                     11



        The new policy is designed to address the direct conflicts that lobbyists are
most likely to have in serving on these boards and commissions. While the policy
does not deal with potential conflicts that individuals other than lobbyists may have
in serving on the boards and commissions, as a practical matter it represents about
as much as probably can be done in this area.

        Since the goal of the advisory boards is to obtain advice from individuals
with expertise and experience in the areas involved, by definition people with
potential conflicts are going to be serving on the boards and commissions. This issue
is instead addressed policies that apply to the boards and commissions.

        The Federal Advisory Committee Act of 1972 (FACA) imposes certain guidelines
on advisory boards and commissions. FACA requires that agencies publish a charter for
each advisory group declaring its purpose, that the committee be “balanced in terms of
points of view represented,” and that business be conducted in open meetings and
documents made available to the public.11

        There is no easy way to determine whether these guidelines are being met. One
study of health advisory committees found, for example, that the advisory groups were
entirely controlled by the business sector with no public health interests represented.12
The 2009 annual report of the Global Markets Advisory Committee noted that the
committee’s official purpose is “avoiding unnecessary regulatory and operational
impediments to conducting global business.” All of this committee’s members are also
industry representatives and corporate lobbyists.13

       Some affected corporate lobbyists consider the new policy barring lobbyists to be
the equivalent of a “brain drain” for the government.

        While there are no doubt many highly qualified lobbyists serving on these
advisory groups, lobbyists do not have a monopoly on expertise. There are many
qualified people for government service in the country, both inside and outside the
Beltway. The Department of Commerce and the U.S. Trade Representative are already
recruiting new members for the 16 ITACs to replace the lobbyists currently on the
advisory groups, with a stated goal of ensuring “a diverse membership among industry
sectors, small, medium and large-sized companies, product lines, geographic areas and
demographic groups.”14



11
         5 U.S.S. App. 2.
12
         Joe Brenner, “Public Health Representation in U.S. Trade Negotiations Advisory Process,” Center
for Policy Analysis on Trade and Health (April 8, 2005).
13
         Keith Epstein and Ben Protess, “CTFC Gets Derivatives Advice from Industry Insiders,”
Huffington Post ((Nov. 18, 2009).
14
         U.S. Department of Commerce, “Minority Business Opportunity to Participate on Industry Trade
Advisory Committees,” Press Release (Nov. 23, 2009) at:
http://www.mbda.gov/?section_id=9&bucket_id=1010&content_id=6460&well=entire_page
                                                                                                  12

Grade: B for establishing useful policy, although not at the level of importance of other
steps taken.

     6.     Restrictions on Seeking Stimulus Funds.

         On March 20, 2008, President Obama issued a memorandum to provide
restrictions on lobbying executive agencies for grants and contracts under the Recovery
and Reinvestment Act of 2009 (the $787 billion “stimulus package”).15 The effort
represented a pilot project and after questions were raised about the scope of its coverage
being limited to lobbyists, revisions were made in the policy on July 24. The revised
policy was expanded to cover all persons who seek specific funds from the stimulus
package, and not just lobbyists.16 At the same time, the scope of the coverage of the
restrictions were narrowed to just cover funds being sought in a competitive bidding
process and only after a formal bid had been submitted.

        The March memorandum was issued at a time when lobbying firms were gearing
up to secure funds from the executive branch agencies charged with distributing the $787
billion stimulus package enacted by Congress.17

        Under the policy, as revised, any person who seeks to obtain stimulus funds in a
competitive bidding process is prohibited from making oral communications with
executive branch officials regarding such funds, once a formal application has been
submitted in the competitive bidding process. Any communications made during this
period about the bid for funds must be made in writing and must be posted on the Internet
within three days by the Executive Branch department involved.

        Any other communications about stimulus funds that are made by lobbyists, and
are not covered by the competitive bidding rules, must be disclosed on the Internet by the
executive branch department to which the communication was made.

        The rules include exceptions for communications on purely logistical issues and
oral communications that take place at a widely attended event. Oral communications
that concern general policy matters also are not covered.

        The policy does not prevent individuals and organizations from lobbying for
stimulus funds, but is intended instead to provide transparency and public accountability
for those who are competing for stimulus funds.




15
        The President, “Memorandum of March 20, 2009: Ensuring Responsible Spending of Recovery
Act Funds,” 74 Federal Register 12531 (March 25, 2009).
16
        Peter Orzag, Director, Office of management and Budget, Updated Guidance Regarding
Communications with Registered Lobbyists About Recovery Act Funds, M-09-14 (July 24 2009)
17
        Mark Niquette and Marla Matzer Rose, “Lobbyists Gear Up to Snag Stimulus,” Columbus
Dispatch (March 30, 2009).
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Grade: B, provides important new transparency and accountability for persons seeking
funds from the government, but, to date, remains a pilot project with no indication
Administration is prepared to establish government-wide policy.

   7.     Restrictions on Seeking Financial Bailout.

        The same policy that applies to persons seeking stimulus funds has been adopted
to also apply to persons seeking special projects from Emergency Economic Stabilization
Act funds, known as TARP or “bailout” funds. The policy, however, was only adopted
after the program was well on its way to be implemented.

Grade: No Grade, provides transparency and public accountability for persons seeking
TARP funds, but comes far too late in the process.