Ethics Update: Change to Post-Employment Rules, Effective April 2, 2014
As a reminder, employees covered by the one-year cooling-off period are prohibited, for one year after leaving the agency, from knowingly making, with the intent to influence, any communication to or appearance before, any officer or employee of the SEC on behalf of any other person (except the United States) in connection with any matter on which such person seeks official action by any officer or employee of the SEC, even if the person never worked on the matter.
This ban is part of the federal government's criminal post-employment statute, 18 U.S.C. 207(c). It does not restrict the former employee's employment; it is merely a ban on representing parties before the SEC.
In the past, the SEC had exemptions in place that excluded many SK-level employees from being covered by this post-employment statute. However, after the exemption is withdrawn on April 2, 2014, any SEC employees whose base pay (excluding locality or any other increase) is more than $156,997.50* will become subject to the one-year cooling-off period. This change mostly will affect SEC staff at the SK-15, SK-16, and SK-17 levels, but you should check your base pay to confirm applicability.
Please contact the Ethics Office with any questions.
*$156,997.50 is the pay threshold applicable as of January 12, 2014http://www.sec.gov/about/offices/ethics/postemploymentcoolingoff.htm