Ethics Approval for HUD official Lois Starkey's Severance Package from a Trade Association

In this email chain, a top ethics lawyer at the Housing and Urban Development Department said it was permissible for employee Lois Starkey to continue accepting severance pay from the Manufactured Housing Institute.

Starkey, Lois A

From: Starkey, Lois A -
sent: Monday, November 20, 2017 1:59 PM
To: Dannen Pamela

Subject: FW: Question-GuidanceNeeded

Pamela: . See below, with the entire email chain regarding the ethics inquiry.

Lois Starkey, Program Analyst . .
Dl??ce of Manufactured Housing-Programs, HUD

From: Starkey, Lois A

Sent: Tuesday, August 01, 2017 11:28 AM

To: Baxter, Daniel <>

Ceylon, Lindsey A Slye, Brandi Banner, Pamela

Subject: RE: Question?Guidance Needed

Thank you,lall, for the prompt response to my inquiry.

Lois Starkey

From: Baxter, Da niei 9 .

Sent: Tuesday, August 01, 2017 10:17 AM

To: Starkey, Lois A <Lois.A.Starkey@hud.eoy> - .
Cc: Allen, Lindsay A Siye, Brandi'M
Subject: FW: Question-Guidance Needed


You have asked whether it is permissible for you to accept severance pay from your previous employer, Manufactured
Housing institute totaling two months of your annual salary to he paid over 4 months. The last payment will be
'Septemo'er 15, 2017. You began work at HUD on July 24, 201?. Another employee who left your previous organization
around the sometime that you did aiso received the same severance package. On occasion, the Mt! I does contact the
Of?ce of Manufactured Housing Programs with questions and'concerns and also meets with the Administrator of OMHP,
However, you do not work directly with MHI. Based 'on this information, you are permitted to receive the payments

agreed upon in your severance package from MHI- since it appears they are based on your prior work and not your
position at HUD. -

Because your office works with MHI on occasion, please keep in mind the following regulations regarding your conduct
With respect to your former employer. The Standards of Ethical Conduct raguletion at C.F.R. 2635.502 prohibits

Q??ioe ofihe Genera! wazsel

- Sent: Tuesday, August 01, 2017 9:30 AM
'To: Siye, Brandi @?hu?.gov> i -

. -- -

,empioyee. Please iet us {mow if you have any Questions:

em pioyee from participating in? a particular "matter'inwiving seeoi?o hordes if it is likeiy to have a direct and predictable

effect on the ?nanoial interest of e'member of the employee's household .or knows that person. With whom she has a
oovered'reiationship is or redresehts a party to such matter and'vrhe re the?empioy'ee det?rm?ines that the circumstances
would cause a reasonable person with knoivledge of the relevant facts to ouestibn tier imhartieiity. A particular matter-
imroiving speci?c parties inciudee speti?c matters such as grants and contracts Where there are identi?able parties. An

- employee has a covered reiationship with a- person for whom the employee has, within the last-year, served as an


Acting Deputy Assistant General Counsei
Ethics and-Appeais Division

US. Depot-omen! ofHousing and Urban Development


This commur?cation, along with any attachments, is covered by federai end-state law governing electronic communications and may comaln confidential and
iegaiiy privileged information. Ifthe reader-of this

message 15 not the intended recipient, you are hereby noti?ed that any dissemination, distribution, use; or
copying of this rgesage or pardon moreof ls strictly prohibited. If you hate received this memge in error, please reply immediately to the sender and delete this
message. Than you.

From-Starkey, Lois A

Subject: Question-Guidance Needed

{Slot directly: The work i impacts the standards and regulations that members (manufacturers, retailers)
are reqhired to meet. .. .

From: siye, Brandi
Sent: Tuesday, August 01, 2017 9:28 AM

'To: Starkey, Lois A <Lois.A Sta?rite hud. ow .
Subject: RE: Question-Guidance Needed

Does any of the work that you perform affect Nil-ii? if so, how?

From: Starkey, Lois A . .

Sent: Tuesday, August 01, 2017 9:16 AM

To: SIVE, Brandi 1
Subject: RE: Question-Guidance Needed

?Yes, on occasion, MHI staff meet with the'Administrator of OMHP or contact OMPH with questions, concerns, etc. Hi
staff participates in meetings hosted by such asthe Manufactured Housing Consensus Committee, and the

an. i

From: Siye, Brandi

Sent: Tuesday, August 01, 2017 8:52 AM

To: Starkey, LoisA is.A.Starkev hud?ow
Subject: FW: Question-Guidance Needed

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