residence, and therefore should not be classed as part of a federal building, legal experts point out that "[i]t's still illegal under the Hatch Act for any White House staffer to participate in executing a campaign photo op/video segment in the White House". This could also lead to investigations for staffers that may have aided Secretary of State Mike Pompeo (but not Pompeo himself) in his convention activities as he delivered a speech while on official business in Jerusalem. As of mid-October 2020, 14 members of the Trump administration had been accused by Citizens for Responsibility and Ethics in Washington of Hatch Act violations to promote the incumbent's re-election. By the beginning of November it was up to 16. Senator Elizabeth Warren's staff released a report in which they "counted more than 54 violations of the Hatch Act by 14 administration officials dating back to 2017, as well as nearly 100 additional pending investigations for alleged violations by 22 officials." On November 5, 2020, the United States Office of Special Counsel opened an investigation into the campaign's use of the White House for campaign purposes. In January 2021, emails from before the election were reported to feature a "top" Interior department official instructing staff to reference the president's account in each post on social media. Biden Administration In March 2021, Housing and Urban Development Secretary Marcia Fudge violated the Hatch Act by signaling support for Democratic candidates for the upcoming 2022 Ohio Senate election. Secretary Fudge received a warning from the Office of Special Counsel for the comments, which said, "If in the future she engages in prohibited political activity we will consider such activity to be a willful and knowing violation of the law that could result in further action." In October 2021, White House Press Secretary Jen Psaki was alleged to have violated the Hatch Act by the watchdog Citizens for Responsibility and Ethics in Washington after she indicated that President Joe Biden supported the candidacy of Democrat Terry McAuliffe in the 2021 Virginia gubernatorial election. The watchdog had previously warned, in a letter to the Biden Administration, that Psaki's statement of support in February 2021 for California Governor Gavin Newsom in the 2021 California gubernatorial recall election, while not a Hatch Act violation since the election was not yet certain to occur, was "closer than necessary to the situations the Hatch Act does contemplate". In March 2022,