(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.

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