(CNN) The Environmental Protection Agency's top ethics watchdog clarified his earlier analysis of whether Administrator Scott Pruitt's rental arrangement broke the federal gift rule, saying he didn't have all the facts when evaluating the lease, according to a memo provided to CNN.
The official also made clear that he didn't evaluate whether Pruitt had violated other ethics rules, according to the memo obtained by the Campaign Legal Center and shared with CNN.
Last week, Designated Agency Ethics Official Kevin Minoli determined that Pruitt's rental was within federal ethics regulations regarding gifts, which despite being issued after the fact seemed to clear Pruitt of wrongdoing. His conclusion was based on the assumption that Pruitt followed the lease terms as written.
The new document makes clear that the old opinion doesn't cover facts that were excluded from the legal contract between Pruitt and the landlord.
"Some have raised questions whether the actual use of the space was consistent with the terms of the lease. Evaluating those questions would have required factual information that was not before us and the Review does not address those questions," Minoli wrote in the memo.
When reached by CNN, Minoli confirmed the authenticity of the document but wouldn't comment further.
CNN reviewed the lease, which was attached to Minoli's memo. The agreement states that the tenant is limited to "one bedroom that cannot be locked. All other space is controlled by the landlord."
"This memo reassures Friday's memo from EPA career ethics officials, who determined that the condo lease was lawful, based on market information for similar rentals on Capitol Hill," said EPA spokesperson Liz Bowman.
"As we have explained in regard to earlier inquiries, there is no connection between decisions Administrator Pruitt has made at EPA and any place he has lived. Any attempt to draw that link is patently false."
Minoli's clarification came after Walter Shaub, the former head of the Office of Government Ethics who now runs the Campaign Legal Center's government ethics program, sent the agency watchdog a series of questions.
Pruitt has been facing criticism for renting a room in a condo from Vicki and Steven Hart, lobbyists whose firm has lobbied the EPA on behalf of an Oklahoma energy company, ABC News and Bloomberg reported. His daughter also reportedly lived there while she was interning in Washington.
"If it turns out Pruitt's daughter was staying in the other room, that's not covered by the ethics opinion because it's outside the scope of the lease," Shaub said. "It would raise a factual question as to whether the landlord knew and permitted his use of the second room, which would be a gift."
In addition, Minoli says he didn't consider whether Pruitt may have violated the impartiality rule. That regulation, Shaub said, would prohibit Pruitt from meeting with anyone from the landlord's lobbying firm.