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Request for Public Comments Regarding Prohibition on Use of Reputation Risk by Regulators
America First Policy Institute (AFPI) is pleased to submit its comments on the Federal Deposit Insurance Corporation’s (FDIC) and Office of Comptroller of the Currency (OCC), collectively referred to here as “the agencies,” proposed rule that would prohibit the use of reputation risk from their supervisory programs. AFPI supports the agencies proposed rule as it will ensure that regulators are prohibited from pressuring financial institutions to deny or terminate banking privileges for political, religious, or other non-pecuniary reasons. Accordingly, removing reputation risk will strengthen the safety and soundness of the financial system by protecting financial institutions and their customers from regulatory overreach.
Setting the Bearings for A Rocky Road Ahead
On October 10, 2025, the Chinese Communist Party (CCP) introduced new export controls for both critical minerals[1] (CMs) and rare earth elements[2] (REEs). The CCP implemented a new rule that specifies exports that are used in U.S. military equipment, or those with dual-use applications for military assets, even those containing as little as 0.1% of REEs, are prohibited from being sent to the United States. In response, the Trump Administration moved to secure the United States' national security interests by proposing a 100% tariff on all Chinese goods by November 1, 2025. After Chairman Xi and President Trump met at APEC 2025, China announced that it would delay its export controls for a year, with the U.S. agreeing to do the same on its tariffs.
The Impacts of America First Trade Deals
In 2024 the United States ran a $1.2 trillion goods trade deficit, the largest on record and equal to roughly 4.1% of GDP. For context, prior to the turn of the century, the goods deficit typically hovered around 1.5% of GDP. The widening gap particularly during the last two decades reflects growing trade imbalances and the steady offshoring of U.S. manufacturing, which have left supply chains, and thereby U.S. economic security, vulnerable during times of uncertainty.
How Steel Tariffs Protect American Jobs: Todd Leebow on Fixing the U.S. Steel Industry
America First Policy Institute Supports President Trump in Supreme Court Tariff Authority Case
Washington, D.C.—Today, the America First Policy Institute (AFPI) released a statement in support of President Donald J. Trump in Learning Resources, Inc. v. Trump. The case, argued today before the U.S. Supreme Court, challenges the tariff authority exercised during his administration. The amicus brief filed by AFPI explains that Congress expressly granted the President broad discretion to regulate imports under the International Emergency Economic Powers Act (IEEPA). The full brief is available here.