CFPB Director Rohit Chopra issued a blog post, Ethics Guidance to Protect the Public Trust and Detect Revolving Door Misconduct which noted his “commit[ment] to setting the highest standards of ethics and integrity for CFPB employees.”  As evidence of that commitment, the Bureau has released Ethics Guidance for Engaging with Former Federal Employees. Among other things, the Ethics Guidance reminds staff to

report suspicious communications and activity by former employees to agency officials. This will allow the CFPB to detect activity by former employees and other government agencies who may be violating existing ethics and confidential information disclosure laws and regulations. For example, the guidance directs current employees to file reports with agency ethics officials if they learn a former employee may be illegally providing “behind the scenes” assistance to a party under investigation by the CFPB.

Chopra added that “[n]o regulated entity should feel the need to retain the services of a former government employee to meet its legal and regulatory obligations. At the CFPB, agency alumni will not get special treatment. In fact, it will be just the opposite. We will be applying heightened scrutiny to matters and decisions where a party has employed or retained the services of a former employee to ensure.”