CONFLICT OF INTEREST PROBLEMS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP78-03089R000100020037-3
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 2
• Document Creation Date: December 16, 2016
• Document Release Date: April 19, 2005
• Sequence Number: 37
• Publication Date: February 12, 1969
• Content Type: MEMO

Approved For Relea 2005/04/27: CIA-RDP78-03089R000t 020037-3
OGC 69-0270
12 February 1969
MEMORANDUM FOR: Chairman, Task Force on Investment
Retirement Plan
SUBJECT: Conflict of Interest Problems
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1. of CA Staff met with me today at his
request. of the Office of General Counsel was
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present during the meeting. I
I asked to see me because he
had heard rumors of an Agency sponsored plan to invest in mutual
funds.
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He said that he had two reasons for wanting to
talk to me: first, that the existence of such a plan might pre-empt
much of his potential clientele and, second, that he might be able to
offer some assistance.
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2. I told that I could understand his concern about
the potential loss of customers and that I felt sure there were a number
of other employees in his position who would share that concern. I
agreed that there was no way to predict whether the existence of an
Agency sponsored investment retirement plan would hurt or help his
own sales. In any event, he did not dispute the Agency's right to
offer a plan to its employees, although he did ask whether it was
legal and questioned how we would go about choosing the investment
manager or fund. On his second point of offering assistance, I made
it very clear that this is the sort of thing which we are going to have
to be very careful to avoid. I said that we would exercise great care
to see that no one on the Task Force or in a position to influence the
Task Force had any personal interest in the selection of the particular
investment medium or manager, or might even appear to have such an
interest. I said that if any person influencing the plan or its investments
could benefit therefrom, there would be an obvious conflictof interest
that could not be condoned. He accepted this with good grace and
certainly understands the problem whether or not he did before he
talked to me.
OGCAOpsoReatiFtr lease 2005/04/27: CIA-RDP78-03089R000100020037-3
 Approved For ReleW 2005/04/27: CIA-RDP78-03089R000lZ020037-3
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3. After making the above points, I explained the origin of the
idea to offer an investment retirement plan, what we have done so far,
and the problems we foresee. I also was quite specific in stating that
we had not yet decided on an investment medium and that, whereas
TVA had used mutual funds and we might well do the same, we intend
to investigate other possibilities including, particularly, the
independently managed investment portfolio.
4. I was very open withi bout what we have done
and what we are planning to do because the existence of the Task Force
and the possibility of an Agency sponsored investment retirement plan
is becoming a matter of general knowledge throughout the Agency. For
these reasons and because at least one other Agency employee who
sells mutual funds has been involved officially with the Task Force, I
think it will be necessary for the Task Force to answer employee
inquiries fully or risk charges of improper influence on its deliberations
and recommendations.
5. I suggest that each member of the Task Force be asked to
report any approaches by employees who are engaged in investment
sales or management and that all such contacts be made a matter of
record in the bi-weekly reports by the Chairman.
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Approved For Release 2005/04/27 : CIA-RDP78-03089R000100020037-3