One of the first things President Obama did after he took office was sign an executive order setting rules on lobbying and serving in his administration. It included a general ban on appointments for people who had lobbied on related issues during the prior two years. We rated it Promise Kept.

But there was also a waiver clause, and when it became apparent that the administration would use waivers to employ former lobbyists in positions where they would have broad authority, we moved the meter to Compromise.

Since then, we've gotten many e-mail from readers on this issue, and we've been monitoring the developments to see if former lobbyists have received jobs in the administration.

Some appointments appear to follow his promise.This includes former lobbyists who haven't actively lobbied in two years, such as Attorney General Eric Holder . It includes people who lobbied on issues different from what they now do, such as Agriculture Secretary Tom Vilsack , who lobbied for the National Education Association.

But there are two appointments that appear to contradict Obama's promise. Mark Patterson, it has been widely reported, has been named chief of staff for the Treasury Department. Patterson is a former vice president for the financial giant Goldman Sachs , and was registered to lobby there from 2005 to 2008. (See public filings compiled by the nonpartisan Center for Responsive Politics.) And Goldman Sachs received $10 billion in money from the TARP program and is considered a key player in the financial industry.

According to the terms of Obama's executive order, we can only surmise that Patterson is receiving a waiver of some sort. We asked the White House press office and the Treasury Department what kind of waiver Patterson received and what its terms were. We received no response. Treasury Secretary Tim Geithner appoints the chief of staff and the position is not subject to Senate approval.

We've also learned new details about nominee William J. Lynn, who has been nominated to be an undersecretary at the Defense Department, even though he used to lobby for the defense contractor Raytheon . That position requires confirmation by the Senate.

Sen. Charles Grassley, R-Iowa, raised questions about Lynn's nomination in a letter to Peter Orszag, director of the White House's Office of Management and Budget. Under the terms of the executive order Obama signed, it's Orszag's office that dispenses waivers for former lobbyists.

In a four-page letter, Grassley wrote that the Lynn nomination undermined Obama's stated goal of closing the "revolving door" for lobbyists working in government:

"Mr. Lynn was a registered Raytheon lobbyist for six years. His lobbying reports clearly indicate that he lobbied extensively on a very broad range of DOD programs and issues in both the House and Senate and at the Department of Defense. If confirmed, Mr. Lynn would become the top operations manager in the Pentagon. He would be the final approval authority on most — if not all — contract, program and budget decisions. Surely, a number of Raytheon issues would come across his desk. ... Based upon President Obama's statements made during the presidential campaign and leading up to and following the signing of the Executive Order, I simply cannot comprehend how this particular lobbyist could be nominated to fill such a key position at DOD overseeing procurement matters, much less be granted a waiver from the ethical limitations listed in the Executive Order."

Grassley concluded that more waiver information needs to be made public: "Please bring transparency and accountability to Mr. Lynn's waiver and all future waivers of the Executive Order by providing details about why waivers have been granted and the criteria used to determine them."  (Read Grassley's full letter .)

We asked the White House press office whether more information on the waivers would be made public, and if we could anticipate waiver information to be included in the online database of ethics and lobbying information that Obama promised during the campaign. Again, we received no response.

Orszag did respond to Grassley's questions, however. His letter of response began by hailing Obama's executive orders as "some of the strictest rules ever imposed on executive branch personnel ... roundly praised by commentators and good government advocates as the toughest ever of its kind."

He then reviewed Lynn's particular qualifications: undersecretary of defense (comptroller) under President Clinton; assistant to the secretary of defense for budget; legislative counsel for defense and arms control to Sen. Edward Kennedy; senior fellow at the National Defense University.

Finally, Orszag enumerated details about Lynn's waiver. It requires Lynn to divest his Raytheon stock within 90 days of his appointment and outlines additional detail on particular stock programs. The waiver also requires that he not participate "personally and substantially" in any matter in which Raytheon is a party for one year, unless he receives prior authorization. It says Lynn will not seek permission to participate in any of six programs for which he personally lobbied. Those programs include "the DDG-1000 surface combatant, the AMRAAM air-to-air missile, the F-15 airborne radar, the Patriot Pure Fleet program, the Future Imagery Architecture, and the Multiple Kill Vehicle."

In conclusion, Orszag wrote, "We do not believe the ethics compliance process described above will hinder Mr. Lynn from doing his job. The process strikes a reasonable balance under the circumstances." (Read Orszag's full letter .)

As of this writing, the Senate has not yet voted on Lynn's confirmation.

When asked about Lynn on Jan. 22, White House spokesman Robert Gibbs said a waiver process is necessary and that Lynn is "somebody who obviously is superbly qualified."

We understand that the examples we've examined here are just two positions out of thousands that the president has to appoint. However, they don't seem consistent with Obama's promise. Indeed, we can't find any mention of waivers prior to Election Day.

We've received numerous e-mails from readers making reasonable arguments that we should rate this a Promise Broken, but we want to wait and see what happens with the nominees. We are leaving this one as a Compromise and will keep a close eye on what happens.