Former President Donald Trump and his team still have not taken critical steps toward preparing for a potential presidential transition if he wins the White House, with nonpartisan experts and Democrats raising alarms with just 13 days to go before Election Day.

Trump’s team has blown past a pair of key deadlines for the transition, breaking with precedent in a way that could ultimately pose challenges for a peaceful transfer of power.

By September 1, both the Trump and Harris campaigns were expected to sign a memorandum of understanding with the General Services Administration that gives them access to office space, communications, equipment and IT support. The campaigns are also expected to submit an ethics plan and to identify the initial people who would need security clearances to begin receiving classified information during a transition.

By October 1, both campaigns were expected to sign a separate memorandum of understanding with the White House detailing the terms of access to agencies, including personnel, facilities and documents.

As of Wednesday, Trump’s team has failed to sign either memorandum or submit an ethics plan, while Harris’s team has completed those tasks.

Max Stier, president of the nonprofit, nonpartisan Partnership for Public Service, cautioned that poor transition planning could prevent a potential Trump second term from addressing threats on day one.

“It presents a significant challenge to their ability to do the preparation work that is essential for them to be ready to pick up the baton without dropping it, if, indeed, former President Trump is reelected,” Stier told CNN.

Rep. Jamie Raskin, a Maryland Democrat who is the ranking member of the House Oversight Committee, warned in a new letter to Trump and his vice presidential nominee, Sen. JD Vance of Ohio, on Wednesday that their actions “depart from well-established norms of the federal government and demonstrate a spectacular disregard for the successful continuation of the essential institutions of American democratic government.”

Raskin said that without the memoranda in place, the transfer of power is endangered and could “threaten our national security.”

That has been a problem in the past: In 2000, as a recount in Florida and a Supreme Court fight unfolded, neither George W. Bush’s nor Al Gore’s teams were participating in a transition, something the 9/11 Commission Report found was a contributing factor to the September 11, 2001, terror attacks.

Without those memoranda signed, the outgoing Biden team would be unable to brief and share information with an incoming Trump team.

“It is such an important period for whoever the next president is to meet with federal agencies to understand the issues facing them and start building trust and collaboration with the individuals there, and that that might be my greatest concern, is that that you would want to see a smooth process that benefits everyone in sharing information,” said Valerie Boyd, director of the Center for Presidential Transition at the Partnership for Public Service.

Stier added, “Not having the MOUs in place means you don’t have the engagement with the government resources that are fundamental to being ready. And that’s a problem – a big problem.”