Reading Room Document

Application of the conflict-of-interest law, 18 U.S.C. § 208, to a White House employee who is one of the beneficiaries, and one of the trustees, of a testamentary trust with a total value of approximately $250,000, most of which consists of real estate a

The document is a memorandum to the Honorable Philip W. Buchen, Counsel to the President, regarding the conflict-of-interest law and the application of a "blind trust" device for a White House employee who is a beneficiary and trustee of a testamentary trust. The conclusion reached in the document is that reliance on the exemption provision contained in 18 U.S.C. § 208(b) is recommended, with a waiver required from the official responsible for the employee's appointment. The document presents questions for review, such as the possibility of adopting a regulation categorically excepting certain financial interests and the use of a general waiver applicable to all activities of an employee. It also discusses the practical political considerations that may impact these approaches.

October 17, 1974