And for Trump, there’s another complication: His Cabinet is stacked with wealthy executives whose vast and complex financial portfolios must be combed for potential business conflicts and then untangled before they receive Senate confirmation hearings. They include Rex Tillerson, the Exxon Mobil CEO nominated to be secretary of state; Steve Mnuchin for treasury secretary; Andrew Puzder for labor secretary; Wilbur Ross for commerce secretary; and Betsy DeVos as education secretary.

“With these billionaires, it’s going to take a lot more time,” said Richard Painter, who served as the chief ethics lawyer in the Bush White House from 2005 to 2007. Painter recalled that when he joined the government 12 years ago, it took him half a day to fill out the initial financial disclosure form. “But,” he said, “I was just a law professor. I have mutual funds. I don’t even own any individual stocks, and it’s really a pretty boring report.”

By comparison, when Painter helped shepherd Hank Paulson to confirmation as treasury secretary in 2006, it took the Goldman Sachs CEO and a team of pricey outside lawyers two-and-a-half weeks to complete the same form. The task of vetting and then preparing ethics agreements for Trump’s nominees now falls to the Office of Government Ethics, a relatively small federal agency with about 80 employees and an annual budget of $16 million. The office reviews each nominee’s financial disclosure report for potential conflicts of interest and then instructs them what assets they must unload, among other steps they may have to take, to comply with the law once they take office. The result is a signed agreement that is sent to the Senate and posted publicly. Tillerson, for example, is expected to have to divest himself completely from Exxon Mobil, including forgoing any stock options to which he may be entitled.

While the office has been preparing for the presidential transition for months, it is likely to struggle to complete work for Trump’s Cabinet in time for them all to be in place by inauguration. “It’s a huge challenge for the office. Huge challenge,” Painter said. “They need more funding.” (The OGE, despite a late-November flurry of tweets directed at Trump, does not comment on individual reports, which are made public only when they are complete.)

By this time eight years ago, several of Obama’s Cabinet picks had signed ethics agreements, said Norman Eisen, a senior fellow at the Brookings Institution who served as the president’s ethics lawyer during the transition and his first years in the White House. None of Trump’s nominees have them yet. “They are behind,” Eisen said.

With a 59-seat Democratic majority in 2009, the Senate confirmed six members of Obama’s Cabinet on the day he was inaugurated and another four within the next week. Republicans control the chamber now, and they want to have a similar number of Trump nominees in place when he takes office. Democrats, however, are worried that Republican leaders will try to rush through several nominees whose thin public record and thicket of potential financial entanglements deserve more time for scrutiny. Last month, the senior Democrats on 16 Senate committees demanded that no Trump nominee should receive a confirmation hearing until he or she has cleared an FBI background check, submitted a signed ethics agreement, and answered follow-up questions from committee members.