CFPB Issues Ethics Guidance Regarding Former Federal Employees

The CFPB recently published additional guidance about how to maintain ethical actions and communications with former federal employees.  The ethical guidance intends to provide a clear framework for communicating with individuals who are moving from federal employment to the private sector who may be trying to leverage their knowledge of confidential information.

The guidance is aimed at protecting confidential information and reporting unethical actions taken by former employees.  For example, once a CFPB employee takes the steps to leave employment, any new non-public, supervisory, or confidential information cannot be shared with them. Additionally, any “potentially unlawful” communications from a former employee or any suspected disclosure of non-public CFPB information should be reported.  CFPB employees have been instructed to report any communications with former employees on behalf of a third party during their first year working elsewhere, and have been reminded that former federal employees cannot be given any preferential treatment.

If appropriate, the CFPB will refer ethical violations to civil or criminal authorities. If the former employee is an attorney, they may also be referred to applicable bar associations.