Before she became a federal employee in late March, Ivanka Trump already had a White House office, security clearance and government-issued communications devices. And it raised ethics concerns.
"Even though she's not a federal employee, she'll follow the restrictions that would apply if she were. She's taking these steps with advice of counsel and in consultation with the Office of Government Ethics," White House Press Secretary Sean Spicer said of Ivanka Trump on March 21.
But the White House didn't consult the Office of Government Ethics, at least according to the office's director.
That revelation comes in the form of a letter from director Walter M. Shaub Jr. to Democratic Sens. Elizabeth Warren and Tom Carper. It was in response to a request the senators sent in March. They wanted to know what rules Ivanka Trump would voluntarily follow and how the Office of Government Ethics would make sure she was complying.
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WASHINGTON, DC - APRIL 04: Ivanka Trump delivers remarks during an event at the Eisenhower Executive Office Building April 4, 2017 in Washington, DC. U.S. President Donald Trump also delivered remarks and answered questions from the audience during a town hall event with CEO's on the American business climate. Also pictured are U.S. Commerce Secretary Wilbur Ross (L) and Reed Cordish (R), from the Office of American Innovation.
(Photo by Win McNamee/Getty Images)
Ivanka Trump joins her father U.S. President Donald Trump as he meets with women small business owners at the White House in Washington, U.S., March 27, 2017. REUTERS/Jonathan Ernst
U.S. Secretary of Education Betsy DeVos and Ivanka Trump speaks during a visit to the Smithsonian?s National Air and Space Museum in Washington, U.S., March 28, 2017. REUTERS/Joshua Roberts
Ivanka Trump (R) joins her father U.S. President Donald Trump as he holds a meeting with experts on addressing human trafficking at the White House in Washington, DC, U.S. February 23, 2017. REUTERS/Jonathan Ernst
Schaeffler CEO Klaus Rosenfeld , Germany's Chancellor Angela Merkel and Ivanka Trump participate in a roundtable with U.S. President Donald Trump and German and U.S. business leaders at the White House in Washington, U.S. March 17, 2017. REUTERS/Jonathan Ernst
Trump Senior Advisor Jared Kushner (L), his wife Ivanka Trump and with chief economic advisor Gary Cohn depart a news conference by U.S. President Donald Trump and King Abdullah of Jordan at the White House in Washington, U.S., April 5, 2017. REUTERS/Kevin Lamarque
Ivanka Trump and her husband White House Senior Advisor Jared Kushner attend a news conference with Germany's Chancellor Angela Merkel and U.S. President Donald Trump in the East Room of the White House in Washington, U.S., March 17, 2017. REUTERS/Jonathan Ernst
WASHINGTON, DC - FEBRUARY 10: (L to R) Senior adviser Jared Kushner and Ivanka Trump enter before U.S. President Donald Trump and Japanese Prime Minister Shinzo Abe hold a joint press conference at the White House on February 10, 2017 in Washington, DC. The two answered questions from American and Japanese press. (Photo by Mario Tama/Getty Images)
U.S. President Trump Addresses Joint Session of Congress - Washington, U.S. - 28/02/17 - Carryn Owens (L), widow of Senior Chief Petty Officer William "Ryan" Owens, reacts as Ivanka Trump, daughter of U.S. President Donald Trump, and her husband Jared Kushner (R), applaud after Owens was mentioned by President Trump. REUTERS/Kevin Lamarque
Ivanka Trump stands as U.S. President Donald Trump makes a toast during the Governor's Dinner in the State Dining Room at the White House in Washington, U.S., February 26, 2017. REUTERS/Joshua Roberts
Ivanka Trump looks at Canadian Prime Minister Justin Trudeau (L) during U.S. President Donald Trump's roundtable discussion on the advancement of women entrepreneurs and business leaders at the White House in Washington February 13, 2017. REUTERS/Kevin Lamarque
U.S. President Donald Trump points out his daughter Ivanka Trump (2nd R), flanked by Alveda King (2nd L) and U.S. Senator Tim Scott (R-SC) (R), during his remarks after visiting the National Museum of African American History and Culture on the National Mall in Washington, U.S., February 21, 2017. REUTERS/Jonathan Ernst
U.S. first lady Melania Trump and Ivanka Trump watch as U.S. President Donald Trump speaks in the Oval Office of the White House, in Washington, DC, U.S. February 28, 2017. REUTERS/Joshua Roberts
White House Senior Advisor Jared Kushner (L) and his wife Ivanka Trump talk with Sara Netanyahu (front L) as she arrives for a joint press conference between U.S. President Donald Trump and Israeli Prime Minister Benjamin Netanyahu, at the White House in Washington, U.S., February 15, 2017. REUTERS/Carlos Barria
Ivanka Trump watches as Japanese Prime Minister Shinzo Abe U.S. and President Donald Trump speak during their joint news conference at the White House in Washington, U.S., February 10, 2017. REUTERS/Joshua Roberts
WASHINGTON, DC - MARCH 27: Claudia Mirza, co-founder and chief executive officer of Akorbi, from right, Ivanka Trump, daughter of U.S. President Donald Trump, Jessica Johnson, president of Johnson Security Bureau Inc., and President Trump listen during a meeting with women small business owners in the Roosevelt Room of the White House on March 27, 2017 in Washington, D.C. Investors on Monday further unwound trades initiated in November resting on the idea that the election of Trump and a Republican Congress meant smooth passage of an agenda that featured business-friendly tax cuts and regulatory changes. (Photo by Andrew Harrer-Pool/Getty Images)
Senior Advisor to the President, Jared Kushner (L), walks with his wife Ivanka Trump to board Marine One at the White House in Washington, DC, on March 3, 2017.
The two are travelling with US President Donald Trump to Florida. / AFP PHOTO / MANDEL NGAN (Photo credit should read MANDEL NGAN/AFP/Getty Images)
Ivanka Trump takes her seat at the beginning of the third working session of the G20 meeting in Hamburg, Germany, July 8, 2017. REUTERS/Ludovic Marin/POOL
Ivanka Trump, Assistant to President Donald Trump, gestures to the crowd next to Treasury Secretary Steven Mnuchin prior to the Congressional Baseball Game at Nationals Park in Washington, U.S., June 15, 2017. REUTERS/Aaron P. Bernstein
Ivanka Trump and White House senior advisor Jared Kushner listen to U.S. President Donald Trump's public speech at Krasinski Square, in Warsaw, Poland July 6, 2017. REUTERS/Carlos Barria
U.S. Secretary of State Rex Tillerson and Ivanka Trump attend the 2017 Trafficking in Persons Report (TIP) Ceremony at the State Department in Washington, U.S., June 27, 2017. REUTERS/Yuri Gripas
Ivanka Trump and International Monetary Fund (IMF) Managing Director Christine Lagarde attend the Women?s Entrepreneurship Finance event during the G20 leaders summit in Hamburg, Germany July 8, 2017. REUTERS/Carlos Barria
MasterCard CEO Ajay Banga (L) speaks with Ivanka Trump as tech company leaders gather at a summit of the American Technology Council at the Eisenhower Executive Office Building in Washington, U.S. June 19, 2017. REUTERS/Jonathan Ernst
Ivanka Trump prays as she touches the Western Wall, Judaism's holiest prayer site, in Jerusalem's Old City May 22, 2017. REUTERS/Heidi Levine/Pool
Assistant to the president Ivanka Trump speaks during an event celebrating National Military Appreciation Month and National Military Spouse Appreciation Day at the Eisenhower Executive Office Building in Washington, U.S., May 9, 2017. REUTERS/Joshua Roberts
Ivanka Trump, daughter and adviser of U.S. President Donald Trump, visits the Holocaust Memorial in Berlin, Germany, April 25, 2017. REUTERS/Michael Sohn/Pool
Ivanka Trump takes part in a conversation with Administrator of the Small Business Administration Linda McMahon at the US Institute of Peace in Washington, U.S., May 1, 2017. REUTERS/Kevin Lamarque
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In his response to the request, Schaub said he reached out to Ivanka Trump's lawyer and the White House's ethics official on March 24 — three days after Spicer said Shaub's office had been consulted.
Shaub said he expressed his office's "view that Ms. Trump appeared to meet the legal standard to be considered an employee covered by the executive branch ethics rules." And he said both the people he contacted "seemed open to the possibility of recognizing" her as an official employee.
Five days later, Ivanka Trump became an unpaid federal employee, serving as assistant to the president.
Since Ivanka Trump is now an executive branch employee, Shaub said she'll need to file both entrant and periodic financial disclosure reports.
The entrant financial disclosure document was due at the end of April, but the White House can grant as much as a 45-day extension.
White House ethics officials will review the reports for any conflicts of interest and work with Ivanka Trump to remedy any that may arise. Once that's complete, the Office of Government Ethics then reviews the disclosure.
She also can't participate in "particular matters that would directly and predictably" affect her "financial interests" — which would include Trump family businesses and any other companies she has an ownership stake in.
There are a number of ways she can avoid conflicts of interest: She can recuse herself from certain matters, divest of her stakes in companies or create a blind trust.