Christopher M. Pilkerton — profile dossier

Pandemic-program role: SBA's General Counsel and, until Jovita Carranza was confirmed, its Acting Administrator. He moved to the White House in March 2020, just as the CARES Act created PPP, so he authored none of the COVID loan rules.
Institution · office: SBA · Office of the General Counsel / Office of the Administrator · Type: political
Tenure (relief-relevant): General Counsel June 2017 – March 2020; Acting Administrator Apr 13, 2019 – Jan 14, 2020.

The job (role mechanics)

Level / appointment: PAS (Presidential appointment, Senate-confirmed); SBA General Counsel, Executive Schedule Level IV (5 U.S.C. 5315; general counsels sit at EX-IV). He additionally served as Acting Administrator (Apr. 13, 2019 – Jan. 14, 2020) under the Vacancies Reform Act while remaining GC. Joined SBA June 12, 2017.
Reports to: The SBA Administrator (as GC); as Acting Administrator, to the President.
Core responsibility: Chief legal officer of the agency: final legal advisor to the Administrator, supervises the Office of General Counsel, serves as Regulatory Policy Officer, and signs SBA's rules; as Acting Administrator, exercised the agency head's authorities.
Pay: Executive Schedule Level IV; ProPublica records his SBA salary at $179,000 (the EX-IV statutory rate was $172,500 in 2021; he was in role 2017–2020). Sources: Pay: Executive Schedule Level IV; ProPublica records his SBA salary at $179,000 the EX-IV statutory rate was... (original: projects.propublica.org · stored capture); Ex Pdf 6009Adaafdb86580 (original: opm.gov · stored capture).
Expectations / mandate: Provide the agency's legal advice, manage OGC, clear and sign rulemakings (size standards, 504/CDC, HUBZone, disaster declarations), and, while Acting Administrator, lead the agency pending a confirmed Administrator.
Tenure norm: Serves at the pleasure of the President (political). His actual tenure: GC June 2017 – March 2020; Acting Administrator Apr. 13, 2019 – Jan. 14, 2020 (then moved to the White House).

Who they are

Christopher Michael Pilkerton (b. July 6, 1973) is a Republican political appointee, financial-services lawyer, and former prosecutor who served as SBA's General Counsel and Regulatory Policy Officer and, for nine months, as the agency's Acting Administrator. ProPublica's "Trump Town" database of political appointees notes he came from J.P. Morgan Chase (a lender that makes SBA-backed loans) and agreed to a two-year recusal.¹²³ As of late 2025 he is a Senate-confirmed Assistant Secretary of the Treasury for Investment Security, leading CFIUS.⁴

Education

B.A., Fairfield University (1995); J.D., Catholic University of America, Columbus School of Law (1999); M.P.A., Columbia University School of International and Public Affairs (2003); certificate in data analytics, Cornell; AI/ML certificate, MIT; Fulbright Teaching Scholar at Jagiellonian University, Poland.²⁴³

Career before the pandemic

He began as an Assistant District Attorney in Manhattan (Special Narcotics Prosecutor; Money Laundering and Tax Crimes units, ~1999–2004), then Senior Counsel in the SEC's Division of Enforcement (insider trading, accounting fraud). He was a partner at two financial-services law firms (Ruddy Gregory; Butzel Long), sat on the board of NASDAQ Futures, Inc., and was a Compliance Director / VP at J.P. Morgan Chase (~2013–2017), where Fortune named him a "Hero of the Fortune 500" for Ebola-orphan relief work. He joined SBA in June 2017.²³¹

Role in the pandemic relief programs

Pilkerton's General Counsel tenure ended in March 2020, the same month the CARES Act (signed March 27, 2020) created PPP and expanded EIDL. By then he had moved to the White House. The COVID PPP/EIDL interim final rules were issued under Administrator Jovita Carranza, who had taken office Jan. 14, 2020. A Federal Register term-search for "Pilkerton" in 2020 returns only five documents, none of them the PPP or EIDL COVID rules.⁵ His pandemic-relief connection is from the White House side (Opportunity Now / economic-recovery policy for underserved communities).⁶³

Documents written or signed

As Acting Administrator and General Counsel his name appears in the signature blocks of dozens of SBA Federal Register actions in 2019 — size-standards rules, the 504/CDC corporate-governance rule, HUBZone and mentor-protégé rules, and numerous EIDL-style disaster declarations (FR term-search returns ~64 documents for 2019).⁷ Contemporaneous SBA statements were issued in his name (e.g., the Feb. 6, 2020 USMCA statement).⁸ He later testified before Congress (2023) as a private-sector witness for Accion Opportunity Fund.⁹

Career after / where they are now

March 2020 – Jan 2021: Executive Director of the White House "Opportunity Now" initiative / Senior Policy Advisor.⁶³ Afterward: co-author of the policy book Underserved (Simon & Schuster); Chief Legal and Regulatory Strategy Officer at Accion Opportunity Fund (a CDFI); co-founder of Small Business Corps; Executive-in-Residence at Georgetown and Johns Hopkins; and a 2024 M-RCBG Senior Fellow at the Harvard Kennedy School studying PPP and comparative pandemic stimulus.¹⁰⁶ In December 2025 the Senate confirmed him as Assistant Secretary of the Treasury for Investment Security (CFIUS); his Treasury bio also lists prior service as Treasury General Counsel.⁴¹¹ He was sworn in Jan. 5, 2026.⁴

Sources held in this archive

Original source documents and archived captures

Sources (first-party)

ProPublica "Trump Town," staffer entry "Christopher Michael Pilkerton" (SBA; joined June 12, 2017; General Counsel; $179,000; recusal note re: J.P. Morgan Chase). Pay: Executive Schedule Level IV; ProPublica records his SBA salary at $179,000 the EX-IV statutory rate was... (original: projects.propublica.org · stored capture) ↩
SBA official bio, "Chris Pilkerton" (General Counsel). SBA official bio, "Chris Pilkerton" General Counsel (original: sba.gov · stored capture) ↩
Wikipedia, "Chris Pilkerton" (sourced overview; dates, firms, board). Wikipedia, "Chris Pilkerton" sourced overview; dates, firms, board (original: en.wikipedia.org · stored capture) ↩
U.S. Department of the Treasury, official bio, "Chris Pilkerton," Assistant Secretary for Investment Security. U.S. Department of the Treasury, official bio, "Chris Pilkerton," Assistant Secretary for Investment Security (original: home.treasury.gov · stored capture) ↩
Federal Register API, documents matching "Pilkerton," 2020 (5; none are PPP/EIDL COVID rules). https://www.federalregister.gov/api/v1/documents.json?conditions[term]=Pilkerton&conditions[publication_date][year]=2020 ↩
National Association of Counties, bio "Chris Pilkerton" (White House Opportunity Now). National Association of Counties, bio "Chris Pilkerton" White House Opportunity Now (original: naco.org · stored capture) ↩
Federal Register API, documents matching "Pilkerton," 2019 (~64). https://www.federalregister.gov/api/v1/documents.json?conditions[term]=Pilkerton&conditions[publication_date][year]=2019 ↩
SBA, "Acting Administrator Pilkerton's Statement on USMCA," Feb. 6, 2020. SBA, "Acting Administrator Pilkerton's Statement on USMCA," Feb. 6, 2020 (original: sba.gov · stored capture) ↩
U.S. Senate Small Business Committee hearing (Apr. 2023), Pilkerton written testimony as Chief Legal Officer, Accion Opportunity Fund. Oversight Of SBA S Implementation Of Final Rules To Expand Access To C 60180d66aae5f531 (original: sbc.senate.gov · stored capture) ; House witness bio (June 13, 2023): Hhrg 118 Sm00 Bio Pilkertonc 20230613 Pdf 655ecf953cf564ba (original: congress.gov · stored capture) ↩
Harvard Kennedy School, M-RCBG Senior Fellow / study-group bio (PPP focus, faculty sponsor Jason Furman). Harvard Kennedy School, M-RCBG Senior Fellow / study-group bio PPP focus, faculty sponsor Jason Furman (original: hks.harvard.edu · stored capture) ↩
U.S. Senate, nomination PN246-13, 119th Congress (Treasury Assistant Secretary). U.S. Senate, nomination PN246-13, 119th Congress Treasury Assistant Secretary (original: congress.gov) ↩