# Temporary Presidential Designation of Acting Board Members of the Inter-American Foundation and the United States African Development Foundation

> Department of Justice Office of Legal Counsel · March 14, 2025

URL: https://www.frixlaw.com/law-library/cases/10823925

## Case

- **Court:** Department of Justice Office of Legal Counsel
- **Decided:** March 14, 2025
- **Precedential status:** Published
- **Opinion:** Opinion
- **Cited by:** 0 later opinions in the Frix Law Library

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## How later opinions describe it (automated extraction)

- noting that without such unity, the peo- ple lose their “two greatest securities” against public malfeasance, the “restraints of public opinion” and the “opportunity of discovering” any abuse of trust

## Opinion text

(Slip Opinion)

Temporary Presidential Designation of Acting Board
Members of the Inter-American Foundation and the
United States African Development Foundation
The President’s constitutional duty to “take Care that the Laws be faithfully executed”
authorizes him to designate acting Board members to temporarily manage the Inter-
American Foundation and the United States African Development Foundation.

March 14, 2025

MEMORANDUM OPINION FOR THE COUNSEL TO THE PRESIDENT

As part of his efforts to reduce the size of government, President Trump
issued Executive Order 14217, which instructed two agencies that allocate
foreign assistance—the Inter-American Foundation (“IAF”) and the
United States African Development Foundation (“ADF”)—to “reduce the
performance of their statutory functions and associated personnel to the
minimum presence and function required by law.” Exec. Order No. 14217
(Feb. 19, 2025). We were advised that the President removed the Board
members that headed those agencies after they failed to adequately com-
ply with that directive. The statutes that govern the foundations permit the
President to remove Board members at will but provide no mechanism to
designate acting Board members to continue to carry out the foundations’
statutory functions pending the appointment of new members.
You asked us whether, in these circumstances, the President has author-
ity to designate acting Board members to supervise the foundations’
operations temporarily before the President can appoint permanent Board
members with the Senate’s advice and consent. Consistent with advice
this Office has provided for decades, we confirmed that he does. When no
statute says otherwise, a President’s responsibility to “take Care that the
Laws be faithfully executed,” U.S. Const. art. II, § 3, grants him the
concomitant authority to designate acting officers through whom he can
temporarily maintain the constitutional chain of supervision over an
organization created by Congress to perform executive functions. The
President needs time to appoint new Board members through the advice-
and-consent process—particularly in the season of a presidential transi-
tion. He need not leave the foundations leaderless in the meantime.

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49 Op. O.L.C. __ (Mar. 14, 2025)

This memorandum memorializes the basis for the advice we gave you. 1

I.

The IAF and ADF are two of a number of small agencies created by
Congress and headed by boards composed of individuals whom the Presi-
dent appoints, by and with the advice and consent of the Senate. 22 U.S.C.
§ 290f(a), (g); id. § 290h-1(a); id. § 290h-5(a)(1).
The IAF “was created in 1969 . . . as an experimental U.S. foreign as-
sistance program.” Inter-American Foundation, U.S. Gov’t Manual,
https://usgovernmentmanual.gov/ (last visited Mar. 7, 2025). The IAF’s
organic act structures the agency as a “body corporate” and tasks it with
undertaking or sponsoring research, programs, and projects that aid de-
velopment in countries in the Western Hemisphere. See 22 U.S.C.
§ 290f(a)–(c). Congress has vested the power to manage the IAF in a
nine-member Board appointed by the President, by and with the advice
and consent of the Senate. Id. § 290f(g). Board members do not enjoy any
protection from at-will removal by the President—a power which is
presumptively incident to his power to appoint. See Authority of the
President to Remove the Staff Director of the Civil Rights Commission
and Appoint an Acting Staff Director, 25 Op. O.L.C. 103, 103 (2001)
(“Civil Rights Commission”). Each Board member generally serves a six-
year term and is eligible for reappointment. See 22 U.S.C. § 290f(g)
(allowing a Board member to serve the remainder of their predecessor’s
term if it has not expired). When a member’s term expires, the member
“shall continue to serve until his successor is appointed and shall have
qualified.” Id. The statute does not say whether or how the President may
fill vacancies on the Board with acting members.
The ADF was established in 1980 “to enable the people of African
countries to develop their potential, fulfill their aspirations, and enjoy
better, more productive lives.” African Development Foundation Act,
Pub. L. No. 96-533, § 504(a), 94 Stat. 3151, 3152 (1980). Congress struc-
tured it as a “body corporate” and tasked it with making grants, loans, and
loan guarantees to African entities and groups. 22 U.S.C. §§ 290h-1(a),
290h-3(a)(1). Like the earlier IAF statute, the ADF’s organic act vests

1 Our advice was limited to use of the President’s authority to designate acting mem-

bers of the Boards of IAF and ADF. We did not examine other agencies.

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Temporary Presidential Designations of IAF and ADF Board Members

management power in a seven-member Board appointed by the President,
by and with the advice and consent of the Senate, to serve six-year terms
(or the remainder of their predecessor’s term, if it had not expired). Id.
§ 290h-5(a)(1)–(2). If an ADF Board member’s term expires, they too
“continue to serve until a successor is appointed and shall have qualified.”
Id. § 290h-5(a)(2). And like the statute governing the IAF Board, the
statute governing the ADF Board does not restrict the President’s authori-
ty to remove Board members at will or address acting service during
Board vacancies. See id. § 290h-5.
On February 19, 2025, President Trump sought to align the IAF and the
ADF with his executive priorities by ordering that they “reduce the per-
formance of their statutory functions and associated personnel to the
minimum presence and function required by law.” Exec. Order No. 14217.
We understand that, after determining that the Board members were not
adequately complying with his order, the President removed most of the
members of each Board on February 24 and the remainder on February 26.
On February 28, you asked us whether the President has authority to
designate acting Board members notwithstanding the absence of specific
statutory authorization to do so. Consistent with the Office’s longstanding
view, we advised that the President’s constitutional duty to “take Care
that the Laws be faithfully executed,” U.S. Const. art. II, § 3, conveys that
authority. Later that day, the President designated Peter Marocco, the
Director of the Office of Foreign Assistance at the Department of State, as
an acting Board member and Chairman of each Board.

II.

It is well established that the “[e]xecutive has powers not enumerated in
the statutes—powers derived not from statutory grants but from the Con-
stitution. . . . These constitutional powers have never been specifically
defined, and in fact cannot be, since their extent and limitations are large-
ly dependent upon conditions and circumstances.” Request of the Senate
for an Opinion as to the Powers of the President “in Emergency or State
of War,” 39 Op. Att’y Gen. 343, 347 (1939). Such authority is most
commonly exercised “in the foreign affairs arena.” Clinton v. City of New
York, 524 U.S. 417, 445 (1998) (quoting United States v. Curtiss-Wright
Export Corp., 299 U.S. 304, 320 (1936)). But pockets of such inherent
authority exist in the domestic sphere as well. See, e.g., Youngstown Sheet

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49 Op. O.L.C. __ (Mar. 14, 2025)

& Tube Co. v. Sawyer, 343 U.S. 579, 637 (1952) (Jackson, J., concur-
ring); Swaim v. United States, 165 U.S. 553, 557–58 (1897); accord
Dames & Moore v. Regan, 453 U.S. 654, 673–75 (1981) (upholding
presidential action under a combination of a statutory authorization and
inherent presidential power).
The Constitution requires the President to “take Care that the Laws be
faithfully executed.” U.S. Const. art. II, § 3. Our Office has consistently
advised that this obligation conveys upon the President the concomitant
power to name acting officials when necessary to fulfill his constitutional
duties, at least where no statute precludes it. See Power of the President to
Designate Acting Member of the Federal Home Loan Bank Board, 1 Op.
O.L.C. 150, 151–53 (1977) (“Home Loan Bank Board”); Memorandum
for Neil Eggleston, Associate Counsel to the President, from Walter
Dellinger, Assistant Attorney General, Office of Legal Counsel, Re:
Appointment of an Acting Staff Director of the United States Commission
on Civil Rights at 2 (Jan. 13, 1994); Civil Rights Commission, 25 Op.
O.L.C. at 104.
We have never comprehensively defined the scope of the President’s
authority to designate acting officials to presidentially appointed positions
in the face of statutory silence. But the President’s authority to do so is
consistent with the Framers’ demand for “unity in the Federal Executive”
to guarantee “both vigor and accountability.” Printz v. United States, 521
U.S. 898, 922 (1997); The Federalist No. 70, at 427 (Alexander Hamil-
ton) (Jacob E. Cooke ed., 1961) (noting that without such unity, the peo-
ple lose their “two greatest securities” against public malfeasance, the
“restraints of public opinion” and the “opportunity of discovering” any
abuse of trust). This unity of leadership promotes “[d]ecision, activity,
secre[c]y, and d[i]spatch.” 3 Joseph Story, Commentaries on the Constitu-
tion of the United States § 1414, at 283 (1833). At the same time, because
the President cannot carry out the full scope of “the executive power” on
his own, courts have endorsed the view that “as part of his executive
power,” the President must be able to “select those who [are] to act for
him under his direction in the execution of the laws.” Myers v. United
States, 272 U.S. 52, 117 (1926); see also, e.g., Free Enter. Fund v. Pub.
Co. Acct. Oversight Bd., 561 U.S. 477, 492 (2010).
We have therefore advised that, at least where that authority is not lim-
ited by statute, the President may act to designate an official to temporari-

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Temporary Presidential Designations of IAF and ADF Board Members

ly perform the duties of a presidentially appointed position where leaving
the position vacant would have “the effect of seriously impeding [the
agency’s] functions,” Home Loan Bank Board, 1 Op. O.L.C. at 152–53,
including the agency’s function of carrying out statutory obligations
consistent with presidential directives, cf. Civil Rights Commission,
25 Op. O.L.C. at 105 & n.3; Youngstown Sheet & Tube Co., 343 U.S. at
637 (Jackson, J., concurring). This limited authority allows the President
to fulfill his constitutional responsibility to ensure that an agency per-
forms its statutorily required functions, which persists even during the
time it takes for the President to appoint agency leadership through the
advice-and-consent process.
Although questions about the President’s inherent power to designate
officials to act in the place of a Senate-confirmed officer can and do arise
throughout an Administration, they are particularly important during
periods of presidential transition. At that time, “[a] president is responsi-
ble for about 4,000 political appointments, 1,200 of which require
[S]enate confirmation.” 2 That reality presents a challenge. On the day he
enters the office, the President must seek to appoint personnel to imple-
ment the agenda that he was elected to execute. At the same moment, he
must assume supervision over agencies with leadership ranks that are
either vacant or filled with persons not of his own choosing.
The President cannot ease the burden of this constitutional duty by del-
egating his authority to appoint. As this Office has previously explained,
“the President’s power to appoint officers requiring Senate confirmation
must be exercised by the President and may not be delegated.” Assign-
ment of Certain Functions Related to Military Appointments, 29 Op.
O.L.C. 132, 134 (2005) (“Military Appointments”). That is because “[t]he
power to appoint and remove [is] discretionary in character,” Depart-
mental Clerks—Delegation of Power, 21 Op. Att’y Gen. 355, 356 (1896),
and only the President is empowered to exercise that discretion, Memo-
randum for the Attorney General, Re: The Power of the President to
Delegate Certain Functions at 407 (n.d. ca. 1955) (“[T]he power of re-
moval is incident to the power of appointment. The latter power not being
delegable, neither is the former.” (citation omitted)). At the outset of an

2 Presidentially Appointed Positions, Ctr. for Presidential Transition (Apr. 14, 2021),

https://presidentialtransition.org/wp-content/uploads/sites/6/2020/12/Presidentially-
Appointed-Positions.pdf.

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49 Op. O.L.C. __ (Mar. 14, 2025)

Administration, it may take considerable time to exercise that discretion
as the President must find, vet, prepare, and then personally appoint these
many officials once the Senate has provided its advice and consent.

III.

Here, we advised that the President’s inherent powers under the Take
Care Clause would extend to designating acting members of the Boards of
IAF and ADF to manage the agencies temporarily.
To start, no statute specifically governs the President’s authority to des-
ignate acting Board members for either the IAF or ADF. Although the
foundations’ authorizing statutes impose certain criteria for whom the
Senate will consider for service, they do not provide for the designation or
appointment of temporary Board members. 22 U.S.C. § 290f(g); id.
§ 290h-5(a)(1).
Nor does the Federal Vacancies Reform Act of 1998 (“FVRA”),
5 U.S.C. §§ 3345–3349d, govern the President’s authority here. The
FVRA expressly excludes from its reach officers who are “appointed by
the President, by and with the advice and consent of the Senate to any
board, commission, or similar entity that (A) is composed of multiple
members; and (B) governs an independent establishment or Government
corporation.” Id. § 3349c(1). Because the Boards of both the IAF and
ADF manage Government corporations and their members are appointed
by the President with the Senate’s advice and consent, see 22 U.S.C.
§ 290f(a), (g), (n); id. § 290h-1(a); id. § 290h-5(a)(1), the FVRA does not
limit the President’s authority to designate acting Board members. The
FVRA underscores this by expressly stating that “[s]ections 3345 through
3349b of the Act shall not apply” to positions on boards like those that
govern the foundations. 5 U.S.C. § 3349c(1). Under this express exclu-
sion, the mechanisms for acting service set out in 5 U.S.C. § 3345 do not
apply to vacancies on such multi-member boards. The strict time limits
for acting service described in 5 U.S.C. § 3346 do not apply. Section
3347, which directs that the FVRA is generally “the exclusive means” for
filling vacant positions at other agencies, does not apply. Id. § 3347. Nor
does any of section 3348, including that statute’s prohibition on the per-
formance of duties vested exclusively in the vacant office by anyone other
than an acting officer serving “in accordance with sections 3345, 3346,
and 3347” or the agency head. 5 U.S.C. § 3348(b), (d). Ultimately, the

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Temporary Presidential Designations of IAF and ADF Board Members

FVRA nowhere dictates how the President must designate temporary
officers to fill vacancies on a multimember board like those that run the
IAF and ADF. And under our Office’s longstanding advice, that statutory
silence does not impliedly preclude the President from making an acting
designation. See, e.g., Civil Rights Commission, 25 Op. O.L.C. at 104.
To be sure, subsections 3348(b)(1) and (d)(1) arguably could be read to
suggest that Congress placed agencies led by multimember boards outside
the scope of the FVRA in order to preclude the President from designating
acting Board members. Subsection 3348(b)(1) states that an office requir-
ing presidential appointment and Senate confirmation “shall remain
vacant” “[u]nless an officer or employee is performing the functions and
duties in accordance with sections 3345, 3346, and 3347.” 5 U.S.C.
§ 3348(b)(1). And subsection 3348(d)(1) provides in turn that “an action
taken by” someone “not acting under section 3345, 3346, or 3347 . . . in
the performance of any function or duty of a vacant office to which this
section and sections 3346, 3347, 3349, 3349a, 3349b, and 3349c apply
shall have no force and effect.” Id. § 3348(d)(1). That language could be
interpreted as stripping acting Board members of the position and power
necessary to perform Board functions and duties if their service is not
pursuant to and consistent with the FVRA.
But sections 3348(b)(1) and 3348(d)(1) “must [be] place[d] . . . in con-
text”—including in the context of each other—and “interpret[ed] . . . to
create a symmetrical and coherent regulatory scheme.” Food & Drug
Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120, 121 (2000).
Here, reading sections 3348(b)(1) and (d)(1) to preclude the President
from designating and empowering acting Board members under any
circumstances would clash with the language of section 3349c, which
provides that section 3348 does not apply to vacancies described in sec-
tion 3349c. Moreover, it is unlikely that Congress would alter the consti-
tutional balance of powers in so subtle a manner. See, e.g., Biden v. Ne-
braska, 600 U.S. 477, 496, 506–07 (2023); Gregory v. Ashcroft, 501 U.S.
452, 461 (1991). Rather, Congress would “clearly specif[y] the procedure
to be used in handling a vacancy.” Status of the Vice Chairman of the
Federal Reserve Board, 2 Op. O.L.C. 394, 396 (1978). Under the usual
constitutional balance, the President enjoys the power to designate acting
Board members to ensure that his ability to manage agencies is not seri-
ously impeded while permanent appointees are nominated and confirmed.
See Home Loan Bank Board, 1 Op. O.L.C. at 152–53. Nothing in section
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49 Op. O.L.C. __ (Mar. 14, 2025)

3348(d)(1) or any other section of the FVRA disrupts that usual balance,
clearly or otherwise.
Instead, we read section 3348(b) and 3348(d)(1) to work together to
ensure that, where the FVRA applies, it provides the exclusive method by
which an individual may fill an office in an acting capacity, unless one of
the alternative methods for temporary service described in 5 U.S.C.
§ 3347(a) is available. Section 3348(b)(1) prevents anyone except the
agency head from performing the exclusive functions and duties of the
vacant office; section 3348(d)(1) invalidates any action taken by someone
other than a properly serving acting officer (or the head of the agency) in
the performance of those functions and duties. We do not read these two
subsections to indirectly override the express exclusion in 5 U.S.C.
§ 3349c or otherwise foreclose the President’s ability to act through his
constitutional authority when Congress has not provided a method for
naming acting officers. Instead, by passing an exclusion as broad as that
found in section 3349c, Congress declined to delineate the bounds of
acting service in positions for which it has deemed the FVRA inapplica-
ble, thereby “enabl[ing] . . . measures on independent presidential respon-
sibility.” Youngstown Sheet & Tube Co., 343 U.S. at 637 (Jackson, J.,
concurring). 3
The foundations are Executive Branch entities that exercise executive
power under the supervision of the President. 22 U.S.C. § 290f(a), (g); id.
§ 290h-1(a); id. § 290h-5(a)(1). One of the primary functions of both
agencies is to fund development projects with a combined budget of nearly
$100 million. See Further Consolidated Appropriations Act, 2024, Pub.
L. No. 118-47, div. F, tit. III, 138 Stat. 460, 746. The power to control this

3 Under this reading, the cross reference to section 3349c in section 3348(d)(1) is not

surplusage. The reference to section 3349c clarifies that the FVRA reaches all offices
filled through the advice-and-consent process that are not subject to the carve-out con-
tained in section 3349c. But even if the cross reference was surplusage, “[l]awmakers
sometimes repeat themselves—whether out of a desire to add emphasis, a sense of belt-
and-suspenders caution, or a lawyerly penchant for doublets (aid and abet, cease and
desist, null and void),” King v. Burwell, 576 U.S. 473, 502 (2015) (Scalia, J., dissent-
ing)—particularly when any reasonable interpretation of the statute would result in some
amount of surplusage, see, e.g., Bufkin v. Collins, 145 S. Ct. 728, 742 (2025) (“[W]hen
both interpretations involve the same redundancy, the canon against surplusage simply
does not apply.” (citing Marx v. Gen. Revenue Corp., 568 U.S. 371, 385 (2013))). For the
reasons discussed above, the tension in the statute makes this one of those instances.

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Temporary Presidential Designations of IAF and ADF Board Members

funding reflects a significant exercise of sovereign power on behalf of the
United States—particularly as these foundations’ statutory functions
implicate foreign affairs, an area long understood as being within the
President’s core constitutional functions. See Application of the Anti-
Terrorism Act of 1987 to Diplomatic Visit of Palestinian Delegation, 46
Op. O.L.C. __, *6–8 (Oct. 28, 2022) (discussing some of the President’s
constitutional foreign affairs powers).
If both the IAF and the ADF were left without any Board members, the
foundations’ accountability while carrying out their statutory functions in
accordance with the policies set by the President would be seriously
impeded. Under the governing statutes, it is the Boards that direct how the
foundations exercise the executive power delegated to the foundations.
22 U.S.C. § 290f(e)(5), (i); id. § 290h-4(a)(7); id. § 290h-5(a)(1). Accord-
ingly, to satisfy Article II, the Boards must be staffed by members who
are “accountable” to the President through the threat of removal. Free
Enter. Fund, 561 U.S. at 483. And, if there are no Board members, then
there is no one whom the President can hold to account for the founda-
tions’ exercise of executive power.
If the President could not task a politically accountable official to fill
the agencies’ leadership positions in an acting capacity, the President
functionally could not exercise his Take Care authority with respect to the
IAF and ADF. That is particularly true here, as the current vacancies were
occasioned by what we understand as the Boards’ failure to adequately
comply with the President’s directives. Cf. English v. Trump, 279 F. Supp.
3d 307, 327, 329 (D.D.C. 2018) (finding that “it poses a serious constitu-
tional problem” under the Take Care Clause for “the CFPB’s Director [to
have] unchecked authority to decide who will inherit the potent regulatory
and enforcement powers of that office, as well as the privilege of insula-
tion from direct presidential control, in the event he resigns”). That loss of
presidential control over the leadership of the foundations and the execu-
tive power that they exercise would seriously impede each foundation’s
ability to function in accordance with the direction of the Chief Executive.
Although Congress has not expressly provided for how leadership of
these foundations would be staffed in a period of transition with numerous
Board member vacancies (in the FVRA or otherwise), the President’s
acting designations here are consistent with Congress’s acknowledgment
in the FVRA that the Executive Branch might require more flexibility to

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49 Op. O.L.C. __ (Mar. 14, 2025)

fill vacant positions during a presidential transition. In particular, the
FVRA provides for a reset of the acting-service period for positions to
which it applies during the sixty-day period following the inauguration of
a new President. See 5 U.S.C. § 3349a(b); Federal Vacancies Reform
Act’s Application to a Vacancy for Which Prior Presidents Submitted
Multiple Nominations, 46 Op. O.L.C. __, *2–3 (Oct. 21, 2022). As we
have recognized, precisely because “[a] new presidential administration
will have hundreds of Senate-confirmed positions to fill, many of which
may well have been vacant for substantial periods of time in the prior
administration,” this extension both “encourag[es] prompt nominations
and enabl[es] continuity of acting service in Senate-confirmed positions.”
Id. at *10.
True, the President’s designation of a single acting Board member stops
short of fully constituting the Board. But a Board’s less-than-full mem-
bership does not mean that its “power is suspended so that it can be exer-
cised by no delegee.” New Process Steel v. NLRB, 560 U.S. 674, 684 n.4
(2010). To the contrary, our office has “assume[d] that many, especially
routine, functions of the Board [that has lost a quorum] have been dele-
gated to subordinate officers,” save for “important decisions that [the
Board] has reserved to itself.” Home Loan Bank Board, 1 Op. O.L.C. at
150; accord Amended and Restated Bylaws of African Development
Foundation, § 3.04(e) (approved Oct. 13, 2009) (specifying that “[a]
majority of the Directors holding office shall constitute a quorum for the
transaction of business”). Temporarily designating a single acting Board
member on each Board will thus enable the President to exert some con-
trol over the foundations, their employees, and their exercise of the execu-
tive power during this time of transition.

IV.

This is not to say that Mr. Marocco’s acting service may continue in-
definitely. Where there is no express statutory limit on the length of an
acting official’s tenure, we have advised that the President should submit
a nomination for that position to the Senate “[w]ithin a reasonable time
after the occurrence of” the vacancy. Continuing Service of Deputy Direc-
tor of OMB as Acting Director During Vacancy, 1 Op. O.L.C. 287, 287
(1977) (“OMB”). Since we provided our advice on the acting designa-

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Temporary Presidential Designations of IAF and ADF Board Members

tions, we have been informed that the President has nominated one indi-
vidual to both Boards and may nominate additional individuals.
Our view is that acting designations in these circumstances are well
within the scope of the President’s inherent authority to designate acting
officials to “keep the Government running.” Legality of Designation of
Certain Acting Officials by the Secretary of Energy, 2 Op. O.L.C. 113,
117 (1978). In other contexts, we have advised that aspects of acting
service not directly regulated by statute should be measured by their
reasonableness, including consideration of “the specific functions being
performed by the [a]cting [official]; the manner in which the vacancy was
created (death, long-planned resignation, etc.); the time when the vacancy
was created (e.g., whether near the beginning or the end of a session of
the Senate); whether the President has sent a nomination to the Senate;
and particular factors affecting the President’s choice . . . or the Presi-
dent’s ability to devote attention to the matter.” OMB, 1 Op. O.L.C. at 290
(citations omitted). Here, the President’s intention to promptly make
nominations (which has now been partially effectuated), the pressures
associated with the early weeks of a fresh presidential Administration, and
the immediate actions needed from the foundations to ensure compliance
with presidential directives counsel in favor of these acting designations.

V.

Consistent with our Office’s longstanding position, the President has
the authority to temporarily designate acting members of the IAF and
ADF Boards of Directors.

LANORA C. PETTIT
Deputy Assistant Attorney General
Office of Legal Counsel

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10823925. Public record. Not legal advice.