Audit Report: DOE-OIG-26-06

December 18, 2025

Opportunities Exist to Improve the Loan Programs Office’s Management of Conflicts of Interest for Federal Employees

The Loan Programs Office’s (LPO) mission is to be the premier public financing partner that accelerates high-impact energy and manufacturing investments to advance the economic future of the United States. The LPO received $385 billion in loan authority through the Infrastructure Investment and Jobs Act, Inflation Reduction Act, and related legislation, of which approximately $31 billion in loans were included in the audit’s scope.

The LPO’s Federal employees and contractors assist with loan application processing by reviewing loan applications with expertise in legal, engineering/ technical, market analysis, and financial/credit aspects.

Given the significant amount of loan authority and congressional interest, we performed this audit to determine whether the LPO was managing conflicts of interest (COI) for its Federal employees, as required.

We found that the LPO did not always manage COI for Federal employees, as required. Although we did not identify issues with required ethics training, the LPO did not always ensure compliance with Federal Government ethics regulations. Specifically, the LPO did not always: (1) identify or mitigate instances of potential COI and the appearance of loss of impartiality; (2) ensure outside positions were disclosed or approved; (3) provide accurate or sufficient information to the Department of Energy’s Office of the General Counsel; (4) properly vet Federal employees for potential COI; and (5) file financial disclosure reports timely with required information.

These issues occurred because the LPO did not comply with ethics regulations and internal policies. We also found that the lack of a COI standard operating procedure and a designated ethics official in its legal division contributed to the LPO’s COI and impartiality issues identified.

Our audit results show that the LPO could not provide reasonable assurance that it managed COI and/or the appearance of loss of impartiality concerns. Given the importance and sensitivity of the LPO’s mission, it is critical for LPO Federal employees to be impartial and free from COI with companies conducting business with the LPO. Any real or apparent COI may undermine public trust, accountability, and the LPO’s integrity.

To address the issues identified in this report, we made three recommendations that, if fully implemented, should help ensure that potential COI and the appearance of loss of impartiality in performing official duties are mitigated for LPO Federal employees.