This bill mandates detailed annual reporting to Congress by the Federal Reserve, OCC, and FDIC regarding their interactions with global financial regulatory forums.
Barry Loudermilk
Representative
GA-11
The American Financial Institution Regulatory Sovereignty and Transparency Act of 2025 (American FIRST Act) mandates that key federal banking agencies—the Federal Reserve, OCC, and FDIC—provide Congress with detailed annual reports on their interactions with global financial regulatory bodies. These reports must thoroughly document the purpose, membership, standards discussed, and positions taken within these international forums. Additionally, the Federal Reserve must specifically address these global interactions during its biannual congressional testimony.
The newly introduced American Financial Institution Regulatory Sovereignty and Transparency Act of 2025, or the American FIRST Act, is a major procedural shakeup aimed squarely at the three top federal bank regulators: the Federal Reserve Board (Fed), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC).
In short, this bill mandates that these agencies must provide Congress with an unprecedented level of detail about their involvement in global financial regulatory forums. Think of it as requiring the Fed, OCC, and FDIC to open their international homework binders and show their work, their funding, and their thought process behind every decision made on the global stage.
Currently, the Fed, OCC, and FDIC participate in organizations that set global banking standards—like the Basel Committee on Banking Supervision or the Financial Stability Board. These standards often influence the rules that govern domestic banks, affecting everything from how much capital a bank must hold to how mortgages are handled. This bill aims to bring that process out of the shadows and into the congressional spotlight.
Under Section 2, all three agencies must now include a massive new section in their annual reports to Congress detailing their interactions with these global forums. This isn't just a list of meetings; it requires specific disclosures on:
For the average person, this bill doesn't change interest rates or immediately alter bank fees. Its impact is entirely procedural, but it’s significant for the people who write the rules. If you work in banking compliance or policy, this is a huge deal because it dramatically increases the administrative burden on the federal agencies you deal with every day.
For example, if the Basel Committee proposes a new rule on bank capital requirements, the Fed can’t just agree to it and start the U.S. rulemaking process. Under this bill, the Fed must first spend significant time and resources producing a detailed, public economic analysis justifying the rule’s cost versus its benefit before they can even propose implementing it domestically. This level of required pre-analysis and public disclosure is intended to boost transparency, but it could also put the brakes on how quickly the U.S. can adopt necessary global standards.
Furthermore, Section 3 requires the Federal Reserve to dedicate a portion of its biannual congressional testimony specifically to these international interactions. This means the Fed Chair will be spending time on Capitol Hill not just talking about inflation and interest rates, but also explaining the minute details of international banking committee meetings.
On one hand, the American FIRST Act delivers on its promise of transparency. Congress and the public gain a clear, documented look at how U.S. regulators influence, and are influenced by, global financial standard-setters. This is a big win for oversight, as it makes it much harder for agencies to quietly adopt international rules without public and congressional scrutiny.
On the other hand, this level of mandated detail—especially the requirement to publicly disclose positions and rationales—could make the agencies less effective at the negotiating table. International negotiations often require a degree of flexibility and strategic ambiguity. Forcing regulators to publish their playbook and cost-benefit analysis before they even finalize a deal might slow down the process and potentially weaken the U.S. position in critical global financial discussions. It’s a classic trade-off: more transparency, but potentially less agility for the regulators tasked with keeping the global financial system stable.