This bill requires the Comptroller General (GAO) to complete a full audit of the Board of Governors of the Federal Reserve System and the Federal reserve banks within 12 months of enactment and then deliver a detailed report to Congress within 90 days of completing the audit. It explicitly overrides limitations in 31 U.S.C. §714 that have restricted GAO audits of certain Federal Reserve activities and makes conforming edits to the Federal Reserve Act to change how “programs or facilities” and certain disclosure phrases are treated.
For compliance officers, counsel, and policy teams, the bill matters because it creates a near-term, mandatory oversight process with tight deadlines, expands the statutory scope of permissible audit and reporting, and changes statutory language that has been used to limit public disclosure of some Fed emergency facilities. Those shifts affect what information the Fed must prepare, how it will be shared with Members of Congress, and the potential for sensitive operational material to enter congressional records.
At a Glance
What It Does
The bill directs the Comptroller General to complete an audit of the Board of Governors and each Federal reserve bank within 12 months of enactment and requires GAO to submit a written report to Congress within 90 days after the audit is finished. It also removes specified limitations in 31 U.S.C. §714 and makes technical amendments to related provisions of the Federal Reserve Act.
Who It Affects
Primary obligations fall on the Board of Governors and the 12 Federal reserve banks, which must provide materials and access for the GAO review; secondary effects reach congressional oversight committees, market participants that rely on Fed confidentiality, and entities with exposure through Fed emergency facilities. GAO and committee staff will also bear increased workload to process and handle the audit and report.
Why It Matters
The statute explicitly overrides prior audit limits and alters definitions and disclosure language in the Federal Reserve Act, establishing a legal pathway for broader congressional access to Fed records. That changes the balance between transparency and the Fed’s historical confidentiality claims, creating new compliance and disclosure risks for the Fed and counterparties.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The bill starts by directing the Comptroller General to conduct a comprehensive audit of the Federal Reserve’s central governance (the Board of Governors) and each Federal reserve bank and to finish that audit within 12 months after the law takes effect. The audit mandate is framed as unconditional (“Notwithstanding section 714 of title 31…or any other provision of law”), which is the bill’s primary mechanism for overcoming prior statutory limits on GAO access.
After GAO finishes the audit, the bill requires GAO to produce a detailed report and submit it to Congress within 90 days. The report must contain the GAO’s findings, conclusions, and any recommended legislative or administrative actions.
The bill specifies distribution: the Speaker, majority/minority leaders of both chambers, the chairs and ranking members of relevant committees and subcommittees, and any Member of Congress who requests it — a broad sharing requirement that anticipates immediate congressional scrutiny.On the statutory-technical side, the bill removes certain language in 31 U.S.C. §714 — including striking the second sentence of subsection (b) and deleting subsection (f) — and adjusts cross-references in related subsections. It also amends subsection (s) of section 11 of the Federal Reserve Act to change the statutory phrasing around what constitutes a “program or facility” and to narrow or alter certain enumerations of information.
Those edits are modestly technical on their face but important in practice because they reshape which Fed programs can be said to be outside GAO’s audit reach and how information release provisions are written.Taken together, the act creates a short, mandatory timetable for a GAO audit, broad distribution and availability of the audit report to Members of Congress, and targeted statutory fixes that eliminate particular prior audit limitations and rework disclosure language in the Federal Reserve Act. The combination of an express override, short deadlines, and conforming edits means the Fed and its counterparties should expect both immediate document requests and a likely elevation of previously confidential operational details into congressional records.
The Five Things You Need to Know
The Comptroller General must complete a full audit of the Board of Governors and the Federal reserve banks within 12 months of enactment.
GAO must submit a detailed written report of the audit to Congress and make it available to key congressional leaders and any Member who requests it within 90 days after completing the audit.
The bill expressly overrides section 714 of title 31 (the statute that has governed GAO access to certain Fed records) by ordering the audit “notwithstanding” that section and by striking specified limiting language in §714(b) and subsection (f).
Section 2(d) makes technical changes to 31 U.S.C. §714 (cross-references and removal of subsection (f)) and amends subsection (s) of section 11 of the Federal Reserve Act to redefine how a “program or facility” is described and to alter certain information-release phrasing.
The report must include GAO’s findings, conclusions, and any legislative or administrative recommendations the Comptroller General deems appropriate; distribution includes committee chairs and ranking members and is available to any requesting Member of Congress.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Provides the act’s short name: the “Federal Reserve Transparency Act of 2025.” This is a formal header and has no operative effect beyond labeling the statute for citation.
Mandatory GAO audit within 12 months
Imposes an affirmative duty on the Comptroller General to complete an audit of the Board of Governors and each Federal reserve bank within 12 months of enactment and does so by saying the audit is required “notwithstanding” 31 U.S.C. §714 or any other law. Practically, this removes legal excuses grounded in §714 for denying GAO access during the statutorily prescribed audit window and forces the Fed to respond to GAO document and access requests tied to that audit.
Report content and distribution requirements
Requires GAO to deliver a written report within 90 days after completing the audit, detailing findings, conclusions, and recommendations. The bill prescribes broad distribution: both chamber leaders, committee and subcommittee chairs and ranking members of jurisdiction, and any Member of Congress who requests the report. That distribution provision increases the likelihood that sensitive audit findings will circulate widely within Congress and be used in oversight hearings, pressings for legislation, or public disclosure.
repeal of certain limitations in 31 U.S.C. §714
Directs removal of the second sentence of 31 U.S.C. §714(b). Although brief in text, this is material: §714 contains the federal statutory language that has historically limited GAO audits of some Fed operations. Striking the sentence removes a statutory limiting phrase and, together with the ‘‘notwithstanding’’ language in subsection (a), reduces legal barriers to GAO review of certain Fed activities previously shielded from audit.
Technical and conforming edits to 31 U.S.C. §714 and the Federal Reserve Act
Makes targeted edits: it deletes subsection (f) of §714 and adjusts cross-references in §714(d)(3) and (e). It also amends subsection (s) of section 11 of the Federal Reserve Act to change the text describing what qualifies as a “program or facility” and to narrow some previously enumerated disclosure phrases. These changes tidy up statutory references but also alter the legal scaffolding that supported audit exceptions and disclosure rules, which could affect future agency interpretations and litigation over access.
This bill is one of many.
Codify tracks hundreds of bills on Finance across all five countries.
Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Congressional oversight committees and individual Members of Congress — Gain a mandated GAO audit report and broad access to its findings, strengthening oversight leverage and evidentiary basis for hearings or legislative proposals.
- GAO and accountability advocates — Receive clear statutory authority and a tight deadline to review Fed operations previously subject to audit limitations, enhancing GAO’s role in financial oversight.
- Investors and market participants demanding transparency — Stand to get more structured public information and official findings about Fed programs and emergency facilities, which may reduce informational asymmetries over time.
- Taxpayers and public-interest watchdogs — Benefit from potential exposure of operational details, costs, or policy choices that bear on fiscal risk and the use of public credit or backstops.
Who Bears the Cost
- Board of Governors and Federal reserve banks — Will need to allocate staff time, legal resources, and document production capacity to comply with GAO requests on a compressed timetable.
- Private counterparties and third-party service providers to Fed facilities — May face increased risk that transaction-level information or contractual terms become part of audit records and circulate in Congress, lifting a layer of confidentiality.
- GAO and congressional staff — Must absorb substantial workload quickly; the statute imposes firm deadlines without authorizing extra resources, creating resource and scheduling strain.
- Potential litigation or compliance costs — The Fed or affected parties may litigate over document claims (e.g., confidentiality, privilege, or national-security exemptions), producing legal costs and delays.
Key Issues
The Core Tension
The bill squarely pits two legitimate goals against each other: increasing congressional transparency and accountability for Fed actions versus preserving operational confidentiality and central-bank independence needed to prevent market disruption. Expanding audit access improves oversight, but doing so without clear, binding protections for classified or market-sensitive data risks undermining the Fed’s ability to act effectively in crises and invites politicized uses of sensitive findings.
The bill resolves one statutory barrier by using a ‘‘notwithstanding’’ clause and targeted strikes in 31 U.S.C. §714, but it does not create a detailed framework for handling classified material, confidential counterparty data, or privileged deliberative records. That gap invites disputes: GAO will likely request operational details (counterparty identities, transaction terms) that the Fed historically treated as sensitive, and the statute does not specify how to segregate or protect legitimately classified or market-sensitive information prior to distribution to Members of Congress.
The technical amendments to the Federal Reserve Act adjust the statutory language describing ‘‘programs or facilities’’ and remove certain enumerated phrases, but those edits are terse. They could produce ambiguity about whether newly structured vehicles (special purpose vehicles, LLCs, or third-party conduits) fall within the scope of audit or disclosure exceptions.
Likewise, the bill’s rigid deadlines (audit in 12 months, report in 90 days thereafter) may be impractical if GAO encounters complex classified material or extensive third-party records; the statute provides no explicit extension mechanism or resource authorization for GAO to meet those deadlines without compromising thoroughness.
Finally, the law creates a political and governance tension: forcing audit access to operational details increases accountability but raises the risk of politicizing monetary policy and emergency interventions. The bill does not address safeguards against selective or premature release of findings that could affect market confidence or Federal Reserve independence, making implementation both legally and institutionally fraught.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.