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B-103987 1 (1977-04-20)

handle is hein.gao/gaobadzdp0001 and id is 1 raw text is: \ COMPTROLLER GENERAL OF THE UNITED STATES WASHINGTON, D.C. 20548 B-103987 A 1 The Honorable John D. Dingell, Chairman Subcommittee on Energy and Power Interstate and Foreign Comerce Committee House of Representatives Dear Mr. Chairman: By letter dated October 26, 1976, this Office responded to a request from you and former Representative Ren Rechler that we review the proposed regulations of the Department of the Interior and the Federal Energy Ad- ministration to implement section 522 of the Energy Policy and Conservation Act, 42 U.S.C. I 6392 (Supp. V, 1975), concerning conflicts of interest. Thereafter, by letter dated November 4, 1976, you provided a copy of our response, along with additional comments, to the Secretary of the Interior for his consideration in finalizing his Department's conflict of interest regulations. Your letter also directed the Secretary to; Please provide us a copy of the regulations when promulgated together with a statement of the actions taken to carry out the GA's recommendations, Please also provide a copy thereof to the GAO for review and comnt to us. By letter dated February 8, 1977, Mr. Richard R. Hite, Acting Assistant Secretary, Administration and Management, sent us a copy of the Department of the Interior's revised conflict of interest regulations appearing at 41 Fed. Reg. 56100 (December 23, 1976) as well as copies .of two additional letters stating the actions taken by the Department in response to the comments made on its proposed tonflict of interest regulations. We bave reviewed the Department's final regulations, and we believe that all our concerns have been properly met. Among the comments made on the Department's proposed regulations was a recomendation that they be revised to make it clear that under section 522 of the Act, all officers and employees are required to file financial disclosure statemants unless they are specifically exempted, We note that 43 C.F.R. 9 20.735-20(b) now follows this recommendation. It was also recommended that non-policymaking positions be affirmatively identified by reviewing the position's functions rather than by simply using the GS-13 grade level as a division point between policymaking da

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