Technical corrections only. The diff primarily updates the bill's header information to reflect its progression through Congress, including new sponsors and reporting details. The substantive legislative text of the bill remains identical between v1 and v2, with no policy changes.
American FIRST Act of 2025
- Sponsor
- Rep. Loudermilk, Barry [R-GA-11]
- Committees
- Financial Services Committee (primary)
- Last action
- Feb 25, 2026
Bottom line
The American FIRST Act significantly increases transparency and congressional oversight over how U.S. federal banking regulators engage with international financial standard-setting bodies, aiming to ensure domestic accountability for global regulatory agreements.
What it actually does
This bill mandates that the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) provide extensive annual reports to Congress detailing their interactions with global financial regulatory or supervisory forums. These reports must include information on memberships, purposes, funding, organizational structures for engagement, standard-setting issues, positions taken, meeting outcomes, adopted policies, anticipated domestic regulatory changes for implementation, and economic impact analyses of such changes. Additionally, it requires the Federal Reserve Chair to provide biannual congressional testimony specifically on these international interactions.
Proponents argue
Proponents argue that the bill enhances accountability and transparency, ensuring that unelected international bodies do not unduly influence U.S. financial regulation without proper congressional oversight. They believe it protects American regulatory sovereignty by requiring detailed justifications and economic impact analyses for implementing international standards, preventing agreements from being adopted domestically without public and legislative scrutiny.
Opponents contend
Opponents might contend that while transparency is valuable, the extensive reporting requirements could burden agencies, potentially slowing down critical international cooperation on financial stability. They might argue that such detailed public disclosures of negotiating positions could weaken the U.S.'s influence in global forums, making it harder to shape international standards effectively or engage in sensitive diplomatic discussions.
The bill is relatively short and clearly structured, making it accessible for an informed reader to understand its core requirements.
Section 2(a) (amending 12 U.S.C. 247)
Annual Reporting by the Federal Reserve Board on Global Financial Forum Interactions
This provision amends the Federal Reserve Act to require the Board of Governors of the Federal Reserve System to include a detailed description of its interactions with global financial regulatory or supervisory forums in its annual report to Congress. This includes listing memberships, purposes, funding sources, organizational structure for engagement, standard-setting issues under discussion, positions taken by Board representatives, summaries of meetings, the text of any adopted policies, anticipated statutory or regulatory changes needed for implementation, and economic impact analyses for any implementing actions.
Supporters argue
Supporters argue this provision ensures the Federal Reserve is accountable to Congress and the American public for its participation in international financial standard-setting, preventing the adoption of global rules that may not align with U.S. interests or undergo proper domestic scrutiny.
Critics contend
Critics might argue that such detailed public reporting of negotiating positions could compromise the Federal Reserve's effectiveness in international forums, potentially reducing its ability to influence global standards or engage in sensitive diplomatic discussions.
Tradeoffs
This provision balances the desire for transparency and domestic accountability with the need for effective international cooperation and diplomatic flexibility in financial regulation.
Section 2(b) (amending 12 U.S.C. 14)
Annual Reporting by the Office of the Comptroller of the Currency (OCC) on Global Financial Forum Interactions
This section amends the Revised Statutes to require the Comptroller of the Currency's annual report to Congress to include detailed information on its interactions with global financial regulatory or supervisory forums. The required information mirrors that for the Federal Reserve, covering membership, purposes, funding, organizational structure for engagement, standard-setting issues, positions taken, meeting summaries, adopted policies, anticipated changes for implementation, and economic impact analyses for implementing actions.
Section 2(c) (amending 12 U.S.C. 1827(a))
Annual Reporting by the Federal Deposit Insurance Corporation (FDIC) on Global Financial Forum Interactions
This section amends the Federal Deposit Insurance Act to require the FDIC's annual report to Congress to include the same detailed information on its interactions with global financial regulatory or supervisory forums as mandated for the Federal Reserve and OCC. This encompasses membership, purposes, funding, organizational structure, standard-setting issues, positions taken, meeting summaries, adopted policies, anticipated changes for implementation, and economic impact analyses for implementing actions.
Section 3 (amending 12 U.S.C. 247b)
Biannual Congressional Testimony by Federal Reserve on Global Financial Forum Interactions
This section amends the Federal Reserve Act to require the Chair of the Board of Governors of the Federal Reserve System to provide biannual testimony to Congress not only on monetary policy but also specifically on the conduct of interactions at global financial regulatory or supervisory forums. This ensures regular, direct engagement between the Fed Chair and Congress on international regulatory activities.
Requires an economic impact analysis and a justification for why the expected costs of implementing actions are at least offset by the expected benefits related to economic, national security, financial stability, or other national interests for any rules or guidance adopted to implement agreements of global financial regulatory forums.
Section 2(a)(3)(B)(x), 2(b)(2)(J), 2(c)(3)(B)(x)
Why it matters:While technically part of the reporting requirements, its placement within a detailed list could lead a casual reader to overlook its significant implications for the domestic implementation of international agreements. It's a substantive hurdle disguised as a reporting detail.
Case for: Proponents argue this ensures rigorous cost-benefit analysis and prevents the adoption of international standards that are not demonstrably beneficial to U.S. interests, thereby protecting regulatory sovereignty and economic welfare.
Case against: Critics might contend that quantifying the benefits of financial stability or national security in monetary terms is inherently difficult, potentially creating bureaucratic delays or subjective justifications that hinder timely and effective adoption of globally beneficial standards.
Estimated impact: This provision could significantly increase the analytical burden on federal banking agencies and potentially slow down the domestic implementation process for international financial standards.
Defines 'global financial regulatory or supervisory forum' to include specific bodies like the Bank for International Settlements, Basel Committee on Banking Supervision, Financial Stability Board, International Association of Insurance Supervisors, and the Network of Central Banks and Supervisors for Greening the Financial System, while explicitly excluding international financial institutions and treaty-based organizations.
Section 2(a)(3)(C), 2(b)(3), 2(c)(4)
Why it matters:This is standard legislative drafting practice to define terms at the end of a section. However, the specific inclusions and exclusions are crucial for understanding which international engagements are subject to the new reporting requirements and which are not.
Case for: Proponents argue that a clear definition provides certainty to agencies and Congress about the scope of oversight, focusing resources on the most impactful non-treaty-based international bodies.
Case against: Critics might suggest that by explicitly excluding certain types of international organizations, the bill could create loopholes, allowing other significant international influences on U.S. financial regulation to remain outside the enhanced transparency regime.
Estimated impact: This definition precisely delineates the scope of the bill's transparency requirements, affecting the workload of agencies and the oversight capacity of Congress regarding specific international bodies.