OFFICE OF GOVERNMENT ETHICS

                             91 X 22

                      Letter to an Employee
                       dated July 8, 1991


     Thank you for your inquiry regarding the programs and
activities of the United States Office of Government Ethics.  The
Office has broad authority for setting government-wide policies
designed to prevent conflicts of interest.  These policies must be
implemented by the ethics officials within individual Departments
and agencies.

     You also asked for our comments on the question of whether a
Government employee may live with, and pay rent to, another
Government employee who works in the same agency and is within the
first employee's area of supervision.

     There is no statute or regulation which specifically prohibits
an employee from living with, or paying rent to, another employee.
Nevertheless, in some cases, concern for the appearance of a
conflict of interest may require an employee to recuse himself from
official matters involving a second employee or to take some other
appropriate remedial action.  In the case you describe, an agency
ethics official might properly determine that the supervisor recuse
himself from all agency matters which would affect the employee
with whom he is living.  Alternatively, in some situations, an
appearance of a conflict of interest may not be able to be
corrected unless one of the employees is reassigned to a different
office.  The facts of each particular case must be examined by the
agency ethics official before a determination can be made.

     If you have further questions related to the particular
situation described in your letter, we suggest that you direct them
to the ethics official at the agency involved.

                                   Sincerely,

                                   Stephen D. Potts
                                   Director