Biden senior advisor Anita Dunn has to divest investment portfolio worth between $16.8 million and $48.2 million to avoid conflicts

Dunn's newly released financial disclosures, which are 93 pages long, show extensive stock, options, bond and private equity holdings — a fortune she and her husband, veteran attorney Bob Bauer, have amassed over the years. Bauer is a high-powered lawyer who served in the White House under the Obama administration; Dunn is a founding member of the consulting firm SKDK where she was paid $738,715 over the last roughly 2½ years, according to the White House. The disclosure form also provides insight into her extensive client list at SKDK.

White House spokesman Chris Meagher told CNBC in an email Thursday that Dunn will need to divest her holdings and is recused from all matters involving SKDK and her past clients. She also won't be able to attend any meetings involving them for two years, pursuant to the Biden-Harris ethics pledge, he said. The form discloses transactions over the two calendar years preceding her May 9 appointment, Meagher added.

"The ethics rules require White House officials to recuse from matters that conflict with their financial interests. When officials have a large scope of duties and an even larger stock portfolio, sunlight is the best disinfectant," Kedric Payne, vice president and general counsel of the watchdog Campaign Legal Center, said after reviewing her disclosure.

Dunn worked for the president as one of his senior advisors from January 2021 through that August before returning for a brief stint this March. She was considered a special government employee for both posts who was exempt from disclosing her assets publicly. She wasn't required to file a public disclosure form until her most recent appointment in May.

She returned as President Joe Biden's public poll numbers were in flux and the administration was struggling with a panoply of vexing global and domestic crises, including Russia's invasion of Ukraine, the computer chip shortage, rising gas prices and sky-rocketing inflation. Biden also announced he was nominating Judge Ketanji Brown Jackson to the Supreme Court in late February.

The disclosure also shows dozens of stock holdings acquired by Dunn and her husband, including call and put options tied to the S&P 500, corporate and municipal bonds, and a plethora of individual stocks held in numerous brokerage accounts. Those brokerage accounts show investments in corporate giants such as Amazon, Alphabet, Boeing, Bank of America, Chevron, Dow, KKR and Morgan Stanley. The couple's portfolio is diverse and includes at least $500,000 tied up in a hedge fund.

Ethics requirements for White House officials and lawmakers don't require precise values, relying instead on a fairly wide range. Based on her disclosure form, H. Jude Boudreaux, a senior financial planner at The Planning Center, estimated her and her husband's holdings to be worth between $16.8 million and $48.2 million. Boudreaux is a certified financial planner at The Planning Center. Lee Baker, a certified financial planner at Apex Financial Services, estimated Dunn and her spouse to have a net worth between $18 million and $38 million in assets. Their properties aren't listed on the form or included in calculating their net worth.

The couple held between $1,000 and $15,000 in corporate bonds issued by Lockheed Martin, Phillip Morris, Target, Bank of America, Apple and Boeing, among others — all companies that have frequent and multiple issues requiring federal oversight. The pair held between $15,001 and $50,000 in debt issued by numerous other corporations, including Cisco Systems, Oracle, Wells Fargo, Duke Energy, Visa and Amazon. They also have numerous accounts or mutual fund holdings that are valued at more than $500,000, apiece. Dunn additionally held between $1 million and $5 million of stock in marketing firm Stagwell, which she received after it acquired SKDK in 2015.

They also made tens of thousands of dollars exercising put options in the iShares Core S&P 500 Index, which could create conflicts of interest with "every single company" in the S&P 500, according to Walter Shaub, who used to run the Office of Government Ethics in the Obama administration and briefly served in the Trump administration.

"Options are not exempt from the conflict of interest statute under any circumstance. That means that she came into government with a conflict of interest with every company whose stock she wrote an option for and with every company in the referenced indexes," Shaub said after reviewing Dunn's financial disclosure. He said she needs to divest all of the options or recuse herself for every issue "affecting any company in the S&P 500 and any other company whose stock is the subject of an option she held."

The power couple also held numerous municipal bonds that were used for state and local infrastructure and school projects across America, including in Burlington County, New Jersey; Clark County, Nevada; the Klein County Independent School District in Texas; and Miami Dade County, Florida, to name a few. The Biden administration has been doling out hundreds of billions, if not trillions, of dollars to local, city and state agencies and schools to upgrade transportation infrastructure, high-speed internet access and invest in other public works projects.

SKDK is within the top 25 paid Democratic political vendors in the country, according to nonpartisan campaign finance watchdog OpenSecrets. Data shows that during the 2020 election cycle, SKDK was paid more than $65 million by Democratic-aligned campaigns. Biden's campaign paid over $2 million for SKDK's services last cycle, according to OpenSecrets data.

In an interview Thursday on MSNBC's "Morning Joe," she previewed the president's upcoming agenda as the White House reaps victories with the expected passage of the Inflation Reduction Act and getting the CHIPS and Science Act signed into law.

"So, addressing the continued opioid crisis that we have in this country is one of those things that he believes we should work together on and that we can work together on," Dunn said in the Thursday interview on MSNBC. "Cancer, and ending cancer as we know it. Again, something very bipartisan that he believes everyone should work on together and that he will continue to push. And he will also continue to work towards an economy that really does work for the working people in this country."

Micron, one of Dunn's former clients, announced shortly after the CHIPS bill was signed that it will invest $40 billion between now and 2030 to manufacture chips in the U.S. Meagher noted that Dunn didn't have anything to do with its announcement earlier this week and stopped working for Micron before she rejoined the White House.

Other clients include AT&T, the American Clean Power Association, Lyft, Pivotal Ventures, Pfizer, Salesforce and Reddit.

Pivotal Ventures is an investment office founded by Melinda French Gates, who divorced billionaire Bill Gates last year. French Gates has repeatedly visited the Biden led White House, including as recently as April, according to White House visitor logs. Meagher said that the French Gates meetings weren't organized by Dunn but noted that her prior work for Pivotal was focused on issues related to paid family leave.

Salesforce hasn't been a client of Dunn's since 2020 and it was for a media training project, Meagher said. Salesforce CEO Marc Benioff and his family privately met with Biden in mid-March, according to the visitor logs. Meagher did not respond when asked if Dunn helped set up that meeting, and Salesforce didn't return a request for comment.

Most of the other clients mentioned in this story didn't return requests for comment. A spokeswoman for Reddit declined to comment.

Alexander Byers, a spokesman for AT&T, told CNBC that SKDK "has provided us with strategic communications advice for more than a decade," but Dunn wasn't the account lead. She provided periodic advice, he said.