According to a lawyer and former staffer for the Office of Congressional Ethics, to be unlawful such a letter would need to threaten action or be written on congressional stationery, not campaign letterhead, and/or the bank would have to have business pending before a Frelinghuysen committee. The progressive lobbying group Citizens for Responsibility and Ethics in Washington (CREW) opined that "whether or not letter breaks a criminal statute is one issue, but the very clear issue is that it appears that a member of Congress might be using his power to threaten someone's employment because of their political activities." Richard W. Painter, a professor of law at the University of Minnesota and former chief White House ethics lawyer to President George W. Bush, described Frelinghuysen's actions as "not illegal but an awful thing to do."