Those aren't even close to the only 2 choices. There's a whole range of possibilities.
Regardless of who appointed who, Obama has been at the helm for over 4 years. More than sufficient time for his appointed people and policies to have filtered throughout all organizations within the Executive.
And it doesn't have to be something nefarious. He could've just stated as an overall policy to increase scrutiny on certain things which may lead to fraud. And then the lower level employees enacted the policies to make that happen. If word never reached Obama, it could have been filtered out at any possible level of supervision, but then that leads to questioning why supervisors and leaders never passed it up and it directly reflects on his management.
And a whole range of possibilities in between...
it could also be (and likely is) exactly what the outgoing director said it was which was the decision of a couple of low level employees in one field office
I think even more important is that this so called scandal will open up the entire 501c4 section of the code to a lot more scrutiny which is completely valid
the code was written as follows:
The Statute IRC 501(c)(4) provides for exemption of:
Civic leagues or organizations not organized for profit but
operated
exclusively for the promotion of social welfare. Local associations of employees, the membership of which is limited to the
employees of a designated person or persons in a particular municipality
and the net earnings of which are devoted exclusively to charitable,
educational, or recreational purposes.
The statutory terms disclose that IRC 501(c)(4) embraces two general
classifications:
a. Social welfare organizations, and
b. Local associations of employees.
Later the IRS added contradictory language saying "primarily" so now we have a definition of exclusively that also means primarily
This confusion (caused by the IRS) leads to all kinds of problems in figuring out if a group is really qualified for this status
This status has been abused for decades and especially so in recent years