This bill amends the statutory authorities of the Federal Reserve Board, the Office of the Comptroller of the Currency, the FDIC, the National Credit Union Administration, and the Federal Housing Finance Agency to impose additional pre-rulemaking requirements when a regulation is intended to align with recommendations from certain non-governmental international organizations. For any rule that the agency determines would have a $10 billion-or-more aggregate effect on the U.S. economy over 10 years and that is intended to align with bodies such as the Financial Stability Board or the Basel Committee, the agency must provide Congress with notice, testimony, and a detailed economic analysis at least 120 days before proposing or finalizing the rule.
The bill also bars Federal banking regulators from engaging on climate-related financial risk with three named international bodies unless the regulator first files an annual report to the House Financial Services and Senate Banking committees describing the regulator’s participation in those organizations and a detailed accounting of the organizations’ governmental and non‑governmental funding. The measure is targeted at increasing congressional oversight and transparency of cross-border regulatory coordination.
At a Glance
What It Does
The bill prohibits specified Federal banking agencies from proposing or finalizing a ‘‘major covered rule’’—defined as a rule intended to align with recommendations from certain international bodies and expected to affect the U.S. economy by $10 billion or more over 10 years—unless the agency provides Congress with at least 120 days’ advance notice, testimony, and a detailed economic analysis covering costs, sectoral impacts, credit availability, GDP, and employment. It separately requires annual reports before regulators may engage on climate-related financial risk with three named international organizations.
Who It Affects
Directly affects five Federal banking regulators: the Board of Governors of the Federal Reserve System, the Comptroller of the Currency, the FDIC, the NCUA, and the FHFA. It also affects regulated banks, credit unions, government-sponsored entities, and trade associations that would be subject to any delayed or modified rulemaking aligning U.S. requirements with international standards.
Why It Matters
The bill creates new procedural hurdles and transparency obligations for any U.S. rulemaking that mirrors international recommendations, and conditions regulator engagement with certain international groups on annual disclosures—potentially slowing adoption of internationally coordinated standards and changing how agencies communicate and cooperate abroad.
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What This Bill Actually Does
The bill adds new procedural gates that apply whenever a U.S. Federal banking regulator is about to adopt a rule that it intends to align with recommendations from specific non-governmental international organizations. Those organizations are described in the text and include the Financial Stability Board, the Bank for International Settlements (through the Basel Committee on Banking Supervision), and the Network of Central Banks and Supervisors for Greening the Financial System.
If an agency judges a proposed rule will have an aggregate economic impact on the United States of $10 billion or more over the first ten years, and the rule is meant to conform to one of those bodies’ recommendations, the agency must give the House Financial Services Committee and the Senate Banking Committee 120 days’ advance notice. That notice must be accompanied by testimony and a detailed economic analysis projecting costs, effects by sector, impacts on credit availability, GDP, and employment.
The same advance-notice-plus-analysis requirement applies to the proposal stage and the finalization stage: an agency cannot propose or finalize a covered major rule without meeting the timing and analytic requirements. The bill inserts these requirements into the statutory bases for five agencies by amending the Federal Reserve Act, the statutory charter of the OCC, the Federal Deposit Insurance Act, the Federal Credit Union Act, and the FHFA’s authorizing statute.
Each agency retains the initial determination of whether a rule meets the $10 billion/10-year threshold and whether it is intended to align with an international recommendation.Separately, the bill restricts regulator engagement on climate-related financial risk: a Federal banking regulator may not meet or otherwise engage in a given calendar year with a ‘‘covered international organization’’ on climate-related financial risk unless it first files an annual report with the two congressional committees. That report must describe the regulator’s participation in the organization—including task forces or committees—and provide a detailed accounting of that organization’s governmental and non-governmental funding sources for the prior year.
The goal in text is transparency about who funds and directs international standard-setting activity before regulators participate in climate‑focused workstreams.
The Five Things You Need to Know
The bill defines a ‘‘major covered rule’’ as a rule that (1) an agency determines will affect the U.S. economy by $10,000,000,000 or more in aggregate over 10 years and (2) is intended to align or conform with a recommendation from specified non-governmental international organizations (named in the text).
An agency may not propose or finalize a major covered rule unless it delivers to the House Financial Services Committee and the Senate Banking Committee, at least 120 days beforehand, notice, testimony, and a detailed economic analysis including projections of costs, sectoral effects, credit availability, GDP, and employment.
The statutory insertion applies to five agencies by name: the Federal Reserve Board, the Office of the Comptroller of the Currency, the FDIC, the National Credit Union Administration, and the Federal Housing Finance Agency, each via amendments to their existing governing statutes.
Section 3 conditions any calendar-year engagement on climate-related financial risk with three named international bodies—the Financial Stability Board, the Network for Greening the Financial System, and the Basel Committee—on the regulator having filed an annual report describing its participation and a detailed accounting of those organizations’ governmental and non-governmental funding for the prior year.
The bill requires the agency itself to determine both that a rule meets the $10 billion/10-year impact threshold and that the rule is ‘‘intended to align or conform’’ with an international recommendation—there is no independent or judicial standard set in the text for those determinations.
Section-by-Section Breakdown
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Short title
Simple placement: designates the bill as the ‘‘Ensuring U.S. Authority over U.S. Banking Regulations Act.’
120‑day notice and economic analysis for Fed rules aligning with international recommendations
This provision inserts a new paragraph into section 10 of the Federal Reserve Act that blocks the Board from proposing or finalizing a ‘‘major covered rule’’ without providing the two congressional committees with 120 days’ advance notice, testimony, and a detailed economic analysis. Practically, the Fed must produce quantitative projections across multiple macro and sectoral metrics before it can proceed with rules it determines to be sufficiently large and internationally aligned—adding a statutory timeline and analytic checklist to the Fed’s rulemaking playbook.
Same procedural gate applied to other Federal banking regulators
The bill adds parallel language to the statutory authorities of the Comptroller of the Currency, the FDIC, the NCUA, and the FHFA. Each agency’s statute is amended to require the same 120‑day advance notice, witness testimony, and detailed economic analysis for any major covered rule. Because the text places the determination of ‘‘major covered rule’’ with the agency, the practical effect is to standardize an internal threshold and external notification requirement across multiple regulators, producing consistent procedural expectations but leaving substantive determinations to each agency’s judgment.
Concrete impact threshold and scope-limiting definition
Across the agency amendments the bill defines ‘‘major covered rule’’ by two elements: (1) an agency determination that the rule would have an aggregate $10 billion-or-more effect on the U.S. economy over 10 years, and (2) that the rule is intended to align or conform with a recommendation from a listed non-governmental international organization. This dual test narrows the new obligations to economically significant rulemakings that are explicitly tied to international standards, rather than every regulatory change that is informed by international practice.
Annual reporting requirement before climate-related engagement
Section 3 bars Federal banking regulators from meeting with or otherwise engaging with three specified international organizations on the topic of climate-related financial risk in any calendar year unless the regulator has provided an annual report to the two congressional committees. The report must list the regulator’s activities within the organization (including committees and task forces) for the prior year and must disclose the organization’s governmental and non‑governmental funding sources. This creates a pre-condition for agency participation in climate-focused multilateral workstreams centered on transparency of organizational funding and participation.
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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
- House Financial Services and Senate Banking committees — The bill gives these committees statutory access to early notice, testimony, and detailed economic analysis for large rules aligned with international recommendations, strengthening congressional prerogatives to scrutinize cross-border regulatory influence and to shape outcomes before rules are proposed or finalized.
- Domestic regulated institutions (large banks, credit unions, and mortgage entities) — They gain earlier visibility into the agencies’ rationale and economic projections for any major rule that would align U.S. requirements with international recommendations, which can translate into more time to prepare compliance programs and coordinate industry comments.
- Taxpayers and domestic-focused policymakers — The bill increases transparency about international bodies’ influence on U.S. banking rules and requires disclosures about those bodies’ funding sources, which may help policymakers assess foreign or private-sector influence on standards that affect U.S. financial stability.
Who Bears the Cost
- Federal banking regulators — Agencies must produce detailed, multi-metric economic analyses and provide committee testimony at least 120 days in advance, adding staffing, modeling, and coordination burdens and potentially slowing rulemaking timetables.
- Regulated firms (especially those in cross-border business) — Slower adoption of harmonized international standards could increase regulatory divergence, create interim uncertainty, and raise compliance costs where firms must navigate differing timing or thresholds across jurisdictions.
- International standard-setting organizations and multilateral cooperation — The conditions and disclosure requirements could reduce the willingness of some international bodies to share models or lower U.S. participation in collaborative workstreams—potentially increasing coordination costs and complicating global responses to cross-border risks.
Key Issues
The Core Tension
The central tension is between congressional oversight and national control on one hand, and timely, coordinated international rulemaking on the other: the bill increases transparency and legislative control over U.S. adoption of international recommendations, but those same controls can slow or deter the cross-border cooperation that many regulators rely on to manage globally interconnected financial risks.
The bill’s primary operational pivot rests on two agency-determined judgments: whether a rule meets the $10 billion/10‑year impact threshold and whether it is ‘‘intended to align or conform’’ with an international recommendation. That places substantial discretion with the agency making the determination while also creating scope for dispute about whether an agency has properly classified a rule as ‘‘covered.’” In practice, agencies will need to develop internal templates and analytic capacity to produce the required projections; absent additional funding or guidance, smaller agencies or offices could be stretched thin, and the quality and comparability of economic analyses across agencies could vary.
The climate-engagement reporting requirement raises its own trade-offs. It forces transparency around organizational funding and a regulator’s participation, but the bill does not specify standards for what level of funding or particular funding sources would be problematic.
Moreover, conditioning engagement on a prior report does not prevent agencies from participating in ongoing technical work between reports; it simply requires an annual snapshot. Finally, the statutory 120‑day pre-notice window could materially delay regulators’ ability to respond to fast-moving risks or to adopt standards coordinated with international counterparts—delays that could have their own stability costs if they hinder rapid alignment during crisis periods.
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