PolicyBrief
H.R. 6550
119th CongressDec 10th 2025
American Financial Institution Regulatory Sovereignty and Transparency Act of 2025
IN COMMITTEE

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
R

Barry Loudermilk

Representative

GA-11

LEGISLATION

New Bill Demands Federal Bank Regulators Detail Global Meetings, Positions, and Funding in Annual Reports

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.

The Global Financial Transparency Mandate

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:

  • Forum Details: Who funds the forum (where the money comes from), who the members are, and how the forum’s goals align with U.S. law.
  • Internal Organization: An organizational chart showing which staff members handle the international work—a level of detail that lets Congress see exactly who is doing what.
  • Positions Taken: A description of the positions the U.S. representatives took during negotiations, including the rationale, objectives, and potential impacts of those positions. This is the equivalent of requiring the agencies to publish their internal debate notes.
  • Implementation Costs: A description of any anticipated changes to U.S. laws or regulations needed to implement the forum’s policies, along with a required economic impact analysis justifying that the expected benefits outweigh the expected costs.

The Real-World Impact: More Oversight, More Paperwork

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.

The Trade-Off: Transparency vs. Agility

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.