The McDade Amendment (28 U.S.C. 530B) was passed by Congress in 1998 specifically to make DOJ attorneys subject to the same state bar ethics rules as every other lawyer in America. This proposed rule would effectively nullify that protection — giving the Attorney General's own office the power to intercept and delay any independent ethics investigation before it begins.
Under the proposed §77.5, the AG claims a "right of first review" over all bar complaints against current and former DOJ lawyers. State bars that refuse to suspend their investigations face active DOJ opposition. The Office of Professional Responsibility — which would conduct the DOJ's own review — reports directly to the Attorney General.
Courts cannot fix this after April 6. Your written comment enters the official federal record, even if anonymous, and must be addressed before the rule can be finalized. This is the only mechanism available right now.