May l> 2017

Melinda.Loftin
Designated Agency Etbics'.Offtcial

and Director, Ethics Offi~
U.S. Department of the Interior
1849 C Street, NW, MS 7346

Washington, DC 20240
Dear Ms. Loftin:

The purpose ofthis letter is to describe the steps that I will take to avoid any actual or
apparentconflict ofinterestin the event that I am confinned for the position of Deputy Secretmy.
of the Department of the Interior.
As required by 18 U.S.C. § 208(a» lwill not participate personally and substantially in

any particular matter in which I lrnow that I have a financial interest directly and predictably
affected by the matter, or in which I know that a person whose interests are imputed to me has a
financial interest directly and predictably affected by the matter, unless I first obtain a written
waiver, pursuant to 18 U.S.C., § 208(bXI), or qualify for a regulatory exemption, pursuant to
18 U.S.C. § 208(b)(2). I understand that the interests of the following persons are imputed to
me: any spQuse or minor child of min~; any general partner of a partnership in which I am a
limited or general pa.$,er;_ ~ organization in which I serve as officer, director, trustee, general
partner or employee; and any person or organization with which I am negotiating or have an
arrangement concerning prospective employment.

Upon confirmation, I will withdraw from the partnership of Brownstein Hyatt Farber and
Schreck, LLP, and all. related entities. Pursuant to the 2012 Equity holders Agreement of
Brownstein Hyatt Farber and Schreck, LLP, and BHFS-E PC, I will receive a pro rata
partnership. distribution based on the value of my partnership interests for setvices performed in
2017 through: the date of my·withdrawal. This payment will be based solely on the firm's
earnings through the date of my withdrawal from the partnership. I currently have a capital
account with the firm. If the finn will not refund the account before I enter into Federal service,
I will forfeit the account. Fora period of one year after my withdrawal, I also will not participate
personally and substantially in any particular matter involving specific parties in which I know
the firm is a party or represents a party, unless I am first authorized to participate, pursuant to 5
C.F.R § 2635.502(d). In addition, I will not.participate personally and substantially in any
particular matter involving specific parties in which I know a fonner client of mine is a party or
represents a party for a period of one year after I last provided seIVice to that client, unless I am
first authorized to participate, pursuantto 5 C.F.R. § 2635.502(d).
My term with the Virginia Board of Grune and Inland Fisheries has expired and I have
resigned from my position with the Center for Environmental Science Accuracy and Reliability.
For a period of one year after termination of my position with each of these entities, I will not
participate personally and substantially in any particular matter involving specific parties in

 which 1 know that entity is a party or represents a party, unless I am first authorized to
participate, pursuant to 5 C.F.R. § 2635.502(d).
I will divest my interest in the T. Rowe Price Virginia Tax-Free Bond Fund; within 90
days of my confirmation. Until I have completed this divestifure, I will not participate
personally and substantially in any particular matter that to my knowledge has a direct and
predictable effect on the financial interests of any holding ofthe T. Rowe Price Virginia TaxFree Bond Fund that is invested in the Virginia municipal bonds sector, unless l first obtain a
written waiver, pursuant to 18 U.S.C. § 208(b)(l), or qualify for aregulatory e~emption,
pursuant to 18U.S.C. § 208(b)(2).
If I have a managed account or otherwise use the services of an investment professional
during my appointment, I will ensure that the account manager or investment profe$sion~

obtains my prior approval· on a case-by-c~se basis for:the purchase of any assets 0$.~rthan cash,
cash equivalents, investment funds that qualify for the exemption at 5 C.F.R § 2640.20l(a), or
obligations of the United States.

I understand that I may be eligible to request a Certificate of Divestiture. for qualifying
assets and that a Certificate of Divestiture is effective only if obtained prior to:divestiture.
Regardless of whether I receive a Certificate of Divestiture, lwill ensure that all divestitures
discussed in this agreement occur within the agreed upon timeframes and that ·all proceeds are
invested in non-conflicting assets.
If I am confirmed as Deputy Secretary of the Department of the Interior, lam awareJhatl
am prohibited by 30 U.S.C. § 121 l{f) from holding a financial interest in any sutface or
underground coal mining operation. Additionally, lam aware that my position is-subject to the

prohibitions against holding any financial interest in federal lands or resources administered or
controlled by the Department of the Interior extended to me by supplemental regulation
5 C.F.R. § 3501.103.
I understand that as an appointee lwill be required to sign the Ethics Pledge (Exec. Order
no. 13770) and that I will be bound by the requirements and restrictions therein in add.ition to the
commitments I have made in this ethics agreement

I will meet in person with you during the first week of my service in the position·of
Deputy Secretary in order to complete the initial ethics briefing required under 5 C.F.R
§ 2638.305. Within 90 days of my confirmation, I will document my compliance with this ethics
agreement by notifying you in writing when I have.completed the steps describedi11·this ethics
agreement.

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 I have been advised thatthis ethics agreement will be posted publicly, consistent with
5 U.S. C. § 552, on the website of the U.S. Office of Government Ethics with ethics agreements
of other Presidential nominees who file public financial disclosure reports.

David L. Bernhardt

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