Decision

Advice letter: Tim Pitt, Head of UK Government Affairs, Bank of America

Published 19 March 2025

1. BUSINESS APPOINTMENT APPLICATION: Tim Pitt, former Director of Economic Policy, Prime Minister’s Office, 10 Downing Street – Paid appointment with Bank of America.

Mr Pitt sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Crown Servants (the Rules) on taking up an appointment with Bank of America.

The purpose of the Rules is to protect the integrity of the government. The Committee has considered the risks associated with the actions and decisions made during Mr Pitt’s time in office, alongside the information and influence a former senior adviser within No.10 may offer Bank of America. The material information taken into consideration by the Committee is set out in the annex.

The Committee considered whether this work was unsuitable given the overlap between Mr Pitt’s responsibilities as Director of Economic Policy, Prime Minister’s Office, 10 Downing Street, and Bank of America, a major global investment bank and financial services company. The Committee^{[footnote 1]} also considered the information provided by the department about his access to information and decision making in office.

The Committee has advised that a number of conditions be imposed to mitigate the potential risks to the government associated with this appointment under the Rules. There is provision in the government’s Rules to vary the length of the conditions applied^{[footnote 2]}. The Committee applies conditions for two years unless there are exceptional reasons to do otherwise. The Committee found there to be circumstances specific to this application which warrant the application of that provision. This advice is not an endorsement of this appointment in any other respect.

The Rules set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.

2. The Committee’s consideration

Bank of America is a global investment bank and financial services company based in the United States – it is the second-largest US banking institution and the second-largest in the world by market capitalisation. It has regularly been a client of registered consultant lobbyists since July 2022^{[footnote 3]} and previously, via its Merrill Lynch division^{[footnote 4]}. It is a member of the UK Finance trade association^{[footnote 5]}. 

Mr Pitt seeks to take on a role with Bank of America as its Head of UK Government Affairs. The role will involve keeping senior management informed on the UK political and legislative environment; acting as central support to senior management who represent the firm externally; developing and executing strategies on key legislative and regulatory issues for Bank of America’s businesses; co-ordinating responses, as needed, on consultation exercises from government entities; representing the firm at industry groups and trade association meetings and engaging with policymakers, including the UK government, to ensure the Bank of America’s key messages are effectively communicated.

Mr Pitt met several banks while in government, to discuss their views on UK and global economic trends. No commercially sensitive information was acquired as a result and Bank of America was not among the banks that he met.

Though Mr Pitt influenced economic policy in his role, policy for financial services was not within his purview and he was not responsible for decisions specific to Bank of America. As such, the Committee considered there is a low risk that the prospective role is, or could reasonably be perceived to be, offered as a reward for decisions or actions taken in office.

His role was to oversee economic policy at the highest level of policy-making. Owing to his position, he will have broad insight that would likely be of benefit to any organisation and particularly a firm with an interest in some investments closely linked to government’s policy decisions. The Cabinet Office confirmed that Mr Pitt had access to general information that could be of use to Bank of America, but is aware of no specific information that would offer the company an unfair advantage, and considered the information in any case to be time-bound and now either to have moved on or be in the public domain. The Committee agreed with the Cabinet Office that the risks associated with his access to information are limited given the range of economic developments – primarily the consequences of the general election and the 2024 budget – alongside the gap between commencing the Bank of America role and having access to information in government, which will be over seven months.

That said, the Committee’s view is that there remains a risk associated with Mr Pitt’s influence in government, particularly as he seeks to take up a role that operates in government relations. This could be construed as seeking to influence the UK government on Bank of America’s behalf – particularly when actively ‘engaging with policymakers’ to communicate the bank’s key messages. There is a significant risk he could use his contacts to lobby in-house with a major financial institution – contrary to the lobbying ban which applies to all former senior special advisers for two years on leaving office. Mr Pitt must avoid engaging in activity that could reasonably be seen as seeking to influence government decisions – including approaching the government, whether special advisers, other officials or ministers about its approach or policy on Bank of America’s behalf. 

Mr Pitt specified that these activities would be carried out by other senior personnel for the duration of conditions imposed and it is significant that Bank of America confirmed these arrangements as noted in the annex below. However, given the focus of the role on government relations, there remains a risk of a perception that he would be offering Bank of America unfair access to, and influence within, government. Therefore, the Committee’s advice is that Mr Pitt should have no direct engagement with the UK government on Bank of America’s behalf. Any contact initiated by the government would not be contrary to the Rules or the Committee’s advice.

3. The Committee’s advice 

The Cabinet Office asked the Committee to consider the provision in the government’s Rules to vary the length of the conditions applied^{[footnote 6]}, as it did in relation to some previous Special Advisers in post for a matter of weeks in the summer of 2022. 

The Committee applies conditions for two years unless there are exceptional reasons to do otherwise. The circumstances here are significantly different, but are unusual given that Mr Pitt was in government for only seven months and he seeks to continue in the government affairs profession he was in for the four years prior to joining No.10. Further, as above there are limited risks associated with his time in office given the significant movement in economic policy and the change in government.

The Cabinet Office recommended that the conditions should apply for a period of 14 months, which is twice his time in government service at No.10. The Committee agreed that any suspicion Mr Pitt would be providing an unfair advantage, or unfairly influencing the government, as a result of the seven months he spent in No.10 could reasonably fall away within 14 months, significantly longer than he was in post.

The Committee’s advice is therefore that the time limited conditions apply for 14 months. It would also draw to Mr Pitt’s attention that he has an ongoing duty of confidentiality and the condition below which prevents him from drawing on privileged information is not time limited. 

It is significant that Bank of America confirmed its adherence with the Committee’s advice and in particular that Mr Pitt would not be involved in any lobbying of the UK government, which would fall to others within Bank of America.   The Committee advises under the government’s Business Appointment Rules that Mr Pitt’s role with Bank of America should be subject to the following conditions: 

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;
• for 14 months from his last day in Crown service, his should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Bank of America (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or ministerial contacts to influence policy, secure business/funding or otherwise unfairly advantage Bank of America (including parent companies, subsidiaries, partners and clients);
• for 14 months from his last day in Crown service, he should not provide advice to Bank of America on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to the work of the UK government or any of its arm’s length bodies; and
• for 14 months from his last day in Crown service, he should not have any engagement on behalf of Bank of America (including parent companies, subsidiaries, partners and clients) with the UK government.

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; they are separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests^{[footnote 7]}. It is an applicant’s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee’s advice.

By ‘privileged information’ we mean official information to which a minister or Crown servant has had access as a consequence of his or her office or employment and which has not been made publicly available. Applicants are also reminded that they may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code/Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/Minister ‘should not engage in communication with government (Ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place - with a view to influencing a Government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office’.

Mr Pitt must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as, depending on the circumstances, it might be necessary for him to seek fresh advice. 

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - Material Information 

4.1 The role 

Bank of America is a US-based global investment bank and financial services company. Bank of America is the second-largest banking institution in the United States and the second-largest in the world by market capitalisation. It has regularly been a client of registered consultant lobbyists since July 2022^{[footnote 8]} and previously, via its Merrill Lynch division^{[footnote 9]}. It is a member of the UK Finance trade association^{[footnote 10]}.

In his paid, full-time role, Mr Pitt stated the role of Head of UK Government Affairs is to:

• keep top management appraised of the UK political and legislative environment to inform the firm’s strategy; 
• act as central support to senior management who represent the firm externally;
• develop and execute strategies on key legislative and regulatory issues for Bank of America’s businesses;
• co-ordinate responses, as needed, on consultation exercises from government entities;
• represent the firm at industry groups and trade association meetings; and
• engage with policymakers, including HMG, to ensure the firm’s key messages are effectively communicated.

Mr Pitt stated that the offer of employment was received from Bank of America after he was recommended to the prospective employer by a longstanding friend for whom the employer is a client.

Mr Pitt confirmed that he and Bank of America will ensure he observes any restrictions advised by the Committee in carrying out his duties. Bank of America confirmed, in writing, its understanding of and agreement to comply with the Committee’s advice, stating that:

‘We have noted the four specific conditions that you seek to impose on Tim Pitt… On our part, we can confirm that the Bank acknowledges them and will not do anything that encourages or induces him to breach those obligations in carrying out his role. 

We also confirm that for the relevant restricted period, which we understand to be until July 2025, we will not ask him personally to engage directly in lobbying activities for the Bank as they relate to the UK Government – any such activities will be carried out by other Bank personnel.’

4.2 Dealings in office

Mr Pitt informed the Committee that he did not meet with Bank of America; neither did he have access to sensitive information; nor was he involved in any decisions specific to Bank of America. He noted that he had met several banks while in government, not including Bank of America, to discuss their views on UK and global economic trends. No commercially sensitive information was acquired as a result.

4.3 Departmental Assessment 

The Cabinet Office confirmed the details in Mr Pitt’s application, including that he made no decisions specific to Bank of America or its competitors. The Cabinet Office said that he would have mainly provided advice to his minister regarding macro policy rather than advocating for policy that would have singularly improved the prospects of the prospective employer.

The Cabinet Office noted that Bank of America had held a contract with the Department for Education, as Lead Sales Advisor for the Income Contingent Repayment Student Loan Monetisation Programme, from March 2018 to June 2021. The contract’s value was £1,950,000.

The Cabinet Office, as owner of the government’s Business Appointment Rules, asked the Committee to consider the unusual circumstances of this case – where Mr Pitt was in post for seven months. The Cabinet Office said that it would be disproportionate to the risks in Mr Pitt’s case to apply the conditions for the standard two-year period. The Cabinet Office recommended to the Committee that conditions apply for 14 months, notwithstanding that Mr Pitt has ongoing duty of confidentiality that is not time bound. 

Regarding the applicant’s request for the length of time that conditions apply to him to be reduced owing to his shorter time within government (seven months) and that he is returning to his role in government affairs, the Cabinet Office:

• stated it believes that mitigations should be proportional to the risks;
• acknowledged that his seniority is significant when considering conditions, but considered it also highly relevant
• that he was in post for a short period of time;
• argued that this, together with the change of government after the General Election, engaged the caveat in the Rules that the length of conditions ‘…may be reduced and/or modified by the Advisory Committee if they consider this to be justified by the particular circumstances of an individual application’;
• recommended that conditions therefore apply for 14 months – or twice the length of time the applicant was in government – rather than the usual two years.

The Cabinet Office additionally noted that the company had previously held UK government contracts. Therefore, to prevent the risk, real or perceived, of a former senior UK government official leveraging his knowledge of government or contacts within government to win public contracts, the applicant should be restricted from bidding or advising for bids for UK government contracts for the same length of time as it recommends for the lobbying ban – 14 months rather than two years, on the grounds of his short period in government.

Therefore, the Cabinet Office’s overall recommendation was that the standard conditions should apply for 14 months rather than two years.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Eric Pickles; Michael Prescott; The Baroness Thornton and Mike Weir. Andrew Cumpsty was absent. ↩

2. www.gov.uk/government/publications/business-appointment-rules-for-crown-servants/business-appointment-rules-for-crown-servants ↩

3. orcl.my.site.com/CLR_Client_Profile?Id=a084J00000F3RibQAF ↩

4. orcl.my.site.com/CLR_Client_Profile?Id=a082400000CyYVlAAN ↩

5. www.ukfinance.org.uk/membership/find-member ↩

6. www.gov.uk/government/publications/business-appointment-rules-for-crownservants/business-appointment-rules-for-crown-servants ↩

7. All Peers and Members of Parliament are prevented from paid lobbying under the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩

8. orcl.my.site.com/CLR_Client_Profile?Id=a084J00000F3RibQAF ↩

9. orcl.my.site.com/CLR_Client_Profile?Id=a082400000CyYVlAAN ↩

10. www.ukfinance.org.uk/membership/find-member ↩