If I was a registered lobbyist within the 2 years before the date of my appointment, in addition to abiding by the limitations of paragraph 2, I will not for a period of 2 years after the date of my appointment:
(a) participate in any particular matter on which I lobbied within the 2 years before the date of my appointment;
(b) participate in the specific issue area in which that particular matter falls; or
(c) seek or accept employment with any executive agency that I lobbied within the 2 years before the date of my appointment.
... it seems clear that Lynn needs a waiver. Section (c) is particularly direct in its language. Another Obama appointee at the department of health and human services, Bill Corr, is a former anti-tobacco industry lobbyist whose prior employment could also require a waiver.
The Weekly Standard is predictably incensed at the notion of rules being "broken" -- but then, so is the Project on Government Oversight. The whistleblower-backing nonprofit group believes that Obama should withdraw Lynn rather than waive him through.
Sen. Claire McCaskill (D-MO) isn't so sanguine either. "I'm not going to object or vote no," the Obama ally said as she left the Senate chamber today, "[but] I feel so strongly that [Lynn] must take on the role of reformer."
Now I'm wondering what this means for possible procurement reform under Obama.
Late Update: Thanks to the commenters for noting that I'd omitted a crucial "anti-" prefix there. Bill Corr is indeed a former lobbyist for the Campaign for Tobacco-Free Kids, a group that opposes Big Tobacco's agenda.