As former President Trump’s transition team considers bypassing normal background checks on political appointees, observers, experts and lawmakers are warning about the consequences the plan could have on national security and who has access to government secrets .

Trump’s team presents a proposal to bypass the FBI’s standard vetting process for potential appointees during the transition period, The New York Times reported this week, opting instead — if he follows through on the suggestion — to hire a private firm to conduct the investigations. Trump, should he win the election, would then unilaterally appoint those people to their appointed positions upon taking office.

Experts acknowledge that the president has the authority to remove the FBI from the equation, and contract screening already occurs at some levels of government for employees who require security clearances. The actual decision to grant a clearance, however, is defined in statute as a government function and usually performed at the agency level or, for presidential advisers and staff, the White House Security Office. Trump replacing this process raised red flags.

“What matters is who makes the determination,” said Lindy Kyzer, director of content at ClearanceJobs.com. “If the president decides, he could bypass the entire White House staff office and appoint his own office or agency — or himself — to make the legal decision.”

A memo from Trump aides is circulating the proposal, he reported Timesit does not detail which appointees would go into the new process. Steve Cheung, a spokesman for the Trump campaign, told the newspaper that the former president has concerns about the Justice Department’s objectivity and will use “the full power of the presidency” to build his administration.

Each new administration must fill about 4,000 policy roles across government, about 1,200 of which require Senate confirmation. Confirmed positions outside the Senate can be installed much more quickly, provided those who need one have at least a provisional security clearance in hand. President Biden swore in 1,100 appointees on his first day in office; Trump did it for 500 when he started his first term.

While the standard process for selecting political appointees is outlined through a series of executive orders and interagency agreements rather than codified into law, experts cautioned that the rules exist for good reason.

“The prospect of President Trump’s team bypassing the FBI in the security clearance process for appointees is deeply troubling,” said Max Stier, president of the Partnership for Public Service, a good government group that runs the Center for Presidential Transitions. “The fundamental job of our government is to keep the public safe, and a president who circumvents law enforcement in vetting key appointees could put our country at grave risk.”

Rep. Jamie Raskin, D-Md., the top Democrat on the House Oversight and Accountability Committee, speculated that Trump aides are making the proposal because they would otherwise be ineligible to receive security clearances.

“Getting an FBI security clearance to receive our country’s most guarded secrets requires unquestioning loyalty to the United States, a test Trump and his cronies, who are the poster children of plutocratic globalization and ‘elite capture,’ I know it could never pass,” Raskin said.

The concerns go beyond just security clearance processing. Political appointees who require Senate confirmation must also disclose their personal financial interests and enter into ethics agreements before receiving legislative consideration.

“If Trump is willing to jeopardize national security by skipping the careful adjudication of security clearances for appointees, there is no reason to believe that he and his allies in the Senate will adhere to (that) traditional practice,” said Walter Shaub, former director of the Office of Government Ethics.

Without disclosed ethics agreements, Shaub added, hapless actors could try to pressure or lure appointees. Trump’s transition team has yet to agree on terms to formally work with the Biden administration on transition activities, including an ethics agreement for those staff.

“Had he skipped both the security and ethics clearance processes, the Senate could find itself voting on the nominations of individuals with unknown and dangerous ties to hostile foreign powers and unresolved conflicts of interest,” Shaub said. “National security would be jeopardized by either failure.”

Sean Michael Newhouse contributed to this report.