The Lacuna Project

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Agency

Federal Reserve Board of Governors

Findings that rest on exhibits naming this entity

  • POL-1.11: Libgober finds that, in Federal Reserve rulemaking under Dodd-Frank, meetings with the Board and written comments were associated with abnormal stock returns in the tens of billions, and meetings were worth more.
  • POL-8.1: In November 1910 six men met at the Jekyll Island Club in Georgia to write a plan to reform the banking system, and the meeting was kept secret until the 1930s. The Federal Reserve History essay states that the technical details of the 1913 Federal Reserve Act closely resembled the Aldrich plan and that the major differences were the political and decision-making structures.
  • POL-8.2: Each Reserve Bank board has nine directors: three Class A chosen by and representing the stockholding banks, three Class B elected by the member banks to represent the public, and three Class C designated by the Board of Governors. Since the Dodd-Frank Act of 21 July 2010, the Class B and Class C directors appoint the Reserve Bank president, with Board approval, and the Class A directors take no part.
  • POL-8.3: A member bank must subscribe Reserve Bank stock equal to 6 percent of its paid-up capital and surplus, half paid in, and may not transfer or pledge it. Since 1 January 2016 a member bank above an inflation-adjusted $10 billion in assets (the Fed reports $12.8 billion for 2025) receives a cumulative dividend of the lesser of 6 percent and the 10-year Treasury high yield, and smaller banks receive 6 percent.
  • POL-8.4: GAO's Table 8 totals $16,115 billion of loans across the Fed's broad-based emergency programs by adding every renewal of overnight loans without adjusting for term, and GAO found that loans outstanding peaked above $1 trillion in late 2008. Senator Sanders's release of 21 July 2011 described the audit as uncovering "$16 trillion in secret loans."
  • POL-8.5: GAO reported that JPMorgan Chase was both a borrower and a vendor in the Fed's emergency programs while its chief executive served as a Class A director of the Federal Reserve Bank of New York. The New York Fed's releases name Jamie Dimon, JPMorgan Chase's chief executive, as a Class A director from January 2007, reelected in February 2010 for a term ending December 2012.
  • POL-8.6: GAO identified at least 18 current and former directors from 9 Reserve Banks who were affiliated with institutions that used at least one emergency program, including 11 Class A directors who served between 2008 and 2010, and wrote that member-bank representatives on Reserve Bank boards create an appearance of a conflict of interest. GAO also found no evidence of systemic bias toward favoring particular institutions in the emergency programs.
  • POL-8.7: Stephen Friedman resigned as Class C director and chairman of the New York Fed on 7 May 2009, writing that he had remained on the board under a Board of Governors waiver after Goldman Sachs became a bank holding company. The New York Fed's general counsel stated that Friedman's purchases of Goldman shares in December 2008 and January 2009 did not violate any Federal Reserve statute, rule or policy.
  • POL-8.8: From 2008 to 2010 the New York Fed paid BlackRock fees across seven contract lines that sum to $212.0 million in GAO's tables. Four of the lines, worth $194.5 million, were awarded noncompetitively: Maiden Lane ($107.6 million), Maiden Lane III ($50.0 million), Maiden Lane II ($24.1 million) and Citigroup valuation ($12.7 million).
  • POL-8.10: The Fed's trade-level workbook records $8,434,795,268 of ETF purchases by the Secondary Market Corporate Credit Facility between 12 May and 23 July 2020. BlackRock-sponsored ETFs were 48.9 percent of the total, Vanguard 34.2 percent and State Street 15.6 percent.
  • POL-8.11: Section 4019 of the CARES Act, signed 27 March 2020, bars from section 4003 transactions any entity in which the President, Vice President, an executive department head, a Member of Congress or a family member holds at least 20 percent. Section 4019 does not address Federal Reserve vendors, and section 4026 requires the Board to report each new facility to Congress within seven days.
  • POL-8.12: On 7 April 2020 Senators Cramer and Cruz and 15 Republican colleagues asked that BlackRock act without regard to investment policies it adopted for its own funds. On 22 April 2020 Representatives Garcia, Tlaib, Pressley and six Democratic co-signers asked for the contracts, BlackRock's conflict policies and documents on how the programs affect BlackRock's own ETFs.
  • POL-8.13: A staff analysis by the Democratic majority of the House Select Subcommittee on the Coronavirus Crisis reported that bonds the Fed bought through the Secondary Market Corporate Credit Facility came from companies that laid off more than one million workers. Chair Powell answered on 23 September 2020 that the Fed bought small amounts across about 800 issuers because it did not want to decide which companies to buy from.
  • POL-8.14: The Fed's Office of Inspector General found that Chair Powell and Vice Chair Clarida did not violate the trading rules then in effect, that Dallas Fed President Kaplan violated no rule, and that Boston Fed President Rosengren did not report multiple 2020 trades on his disclosure form, and it found insufficient evidence for a law-enforcement referral in each case. On 4 September 2024 the OIG reported that Atlanta Fed President Bostic violated the FOMC blackout rule, the disclosure policies, the prohibited-holdings policy and the preclearance rule, and no insider-trading or federal conflict-of-interest law.
  • POL-8.15: On 21 October 2021 the Board announced rules that prohibit purchases of individual securities by Federal Reserve policymakers and senior staff. In April 2023 the OIG found that hundreds of System staff with access to Class I FOMC information are not subject to the policy's additional controls.
  • POL-8.16: In September 2022 most Reserve Banks suspended remittances to the Treasury and began a deferred asset, which was $243.5 billion on 31 December 2025 and $235.5 billion on 30 June 2026. The Reserve Banks paid dividends on member-bank stock throughout: $1.5 billion in 2023, $1.623 billion in 2024 and $1.688 billion in 2025.
  • POL-8.17: Greg Becker, chief executive of Silicon Valley Bank, served as a Class A director of the Federal Reserve Bank of San Francisco from 1 January 2019 while the Fed supervised the bank. The OIG wrote that his board service "created an appearance of a conflict of interest for the System" and reported hearing of no influence on supervision.

Exhibits naming this entity

  • Exhibit 684 2020. Libgober, Quarterly Journal of Political Science 15(4):449-481: Meetings, Comments, and the Distributive Politics of Rulemaking
  • Exhibit 779 1913, as amended (page opened 10 November 2026). Board of Governors of the Federal Reserve System: Federal Reserve Act, Section 4 (Reserve Bank organization and directors), as published by the Board of Governors
  • Exhibit 780 1913, as amended (page opened 10 November 2026). Board of Governors of the Federal Reserve System: Federal Reserve Act, Section 5 (stock in Federal reserve banks), as published by the Board of Governors
  • Exhibit 781 1913, as amended by Pub. L. 114-94 (page opened 10 November 2026). Board of Governors of the Federal Reserve System: Federal Reserve Act, Section 7 (division of earnings), as published by the Board of Governors
  • Exhibit 782 21 July 2010. U.S. Congress: Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111-203, sections 1103, 1107 and 1109
  • Exhibit 783 4 December 2015. U.S. Congress: Fixing America's Surface Transportation Act, Public Law 114-94, section 32203 (dividends of Federal reserve banks)
  • Exhibit 784 July 2011. U.S. Government Accountability Office: Federal Reserve System: Opportunities Exist to Strengthen Policies and Processes for Managing Emergency Assistance (GAO-11-696)
  • Exhibit 786 October 2011. U.S. Government Accountability Office: Federal Reserve Bank Governance: Opportunities Exist to Broaden Director Recruitment Efforts and Increase Transparency (GAO-12-18)
  • Exhibit 788 7 May 2009. Stephen Friedman: Letter of Stephen Friedman to William C. Dudley, resigning as Class C Director and Chairman, Federal Reserve Bank of New York
  • Exhibit 794 30 December 2021. Board of Governors of the Federal Reserve System: Secondary Market Corporate Credit Facility transaction-specific disclosures (Section 11(s)), workbook released 30 December 2021
  • Exhibit 795 27 March 2020. U.S. Congress: Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116-136, sections 4003, 4019, 4020 and 4026
  • Exhibit 796 7 April 2020. U.S. Senate (Cramer, Cruz and 15 colleagues): Letter from Senators Cramer, Cruz and 15 Republican colleagues to Secretary Mnuchin and Chairman Powell on CARES Act implementation
  • Exhibit 797 22 April 2020. U.S. House of Representatives (Garcia, Tlaib, Pressley and co-signers): Letter from Reps. Garcia, Tlaib, Pressley and six Democratic co-signers to Secretary Mnuchin and Chairman Powell on BlackRock's contracts with the Fed
  • Exhibit 798 23 September 2020. House Select Subcommittee on the Coronavirus Crisis (Democratic majority staff): Select Subcommittee on the Coronavirus Crisis, "Prioritizing Wall Street: The Fed's Corporate Bond Purchases During the Coronavirus Pandemic," staff analysis
  • Exhibit 799 23 September 2020. U.S. House of Representatives, Select Subcommittee on the Coronavirus Crisis: Hybrid hearing with the Federal Reserve Chair Jerome H. Powell, Select Subcommittee on the Coronavirus Crisis, Serial No. 116-119
  • Exhibit 800 21 July 2011. Office of Senator Bernie Sanders: Senator Sanders, "The Fed Audit" (press release)
  • Exhibit 801 Page opened 10 November 2026. Board of Governors of the Federal Reserve System: Federal Reserve Board FAQ: Is the Fed's emergency lending audited by the Congress? Is information about the Fed's emergency lending provided to the public?
  • Exhibit 802 Page opened 10 November 2026. Board of Governors of the Federal Reserve System: Federal Reserve Board FAQ: Who owns the Federal Reserve?
  • Exhibit 803 21 October 2021. Board of Governors of the Federal Reserve System: Federal Reserve Board announces a broad set of new rules on investment and trading by Federal Reserve policymakers and senior staff
  • Exhibit 804 18 January 2024 (closing memorandum issued 11 July 2022). Federal Reserve Board Office of Inspector General: Report of Investigation on the Closing of 22-0028-I Board Trading Activity (Powell, Clarida)
  • Exhibit 805 18 January 2024 (closing memorandum issued 11 July 2022). Federal Reserve Board Office of Inspector General: Report of Investigation on the Closing of 22-0030-I Reserve Bank Trading Activity (Kaplan, Rosengren)
  • Exhibit 806 4 September 2024. Federal Reserve Board Office of Inspector General: Report of Investigation on the Closing of 23-0020-I Federal Reserve Bank of Atlanta President's Trading Activity
  • Exhibit 807 26 April 2023. Federal Reserve Board Office of Inspector General: The Board Can Further Enhance the Design and Effectiveness of the FOMC's Investment and Trading Rules (2023-SR-B-006)
  • Exhibit 808 13 January 2023. Board of Governors of the Federal Reserve System: Federal Reserve Board announces preliminary 2022 financial information for the Reserve Banks
  • Exhibit 809 12 January 2024. Board of Governors of the Federal Reserve System: Federal Reserve Board releases preliminary 2023 financial information for the Reserve Banks
  • Exhibit 810 Issued March 2026. Board of Governors of the Federal Reserve System: Federal Reserve Banks Combined Financial Statements as of and for the years ended December 31, 2025 and 2024
  • Exhibit 811 28 August 2026. Board of Governors of the Federal Reserve System: Federal Reserve Banks Combined Quarterly Financial Report, June 30, 2026 (unaudited)
  • Exhibit 813 28 April 2023. Board of Governors of the Federal Reserve System: Review of the Federal Reserve's Supervision and Regulation of Silicon Valley Bank (Vice Chair for Supervision Barr)
  • Exhibit 814 25 September 2023. Federal Reserve Board Office of Inspector General: Material Loss Review of Silicon Valley Bank (2023-SR-B-013)
  • Exhibit 815 Essay (events 20-30 November 1910). Federal Reserve Bank of Richmond for the Federal Reserve Board (Federal Reserve History): The Meeting at Jekyll Island (Federal Reserve History essay by Gary Richardson and Jessie Romero)
  • Exhibit 936 Last updated 5 January 2024 (page opened 10 November 2026). Board of Governors of the Federal Reserve System: Federal Reserve Board: Overview: Federal Reserve System Boards of Directors
  • Exhibit 937 February 2013. Board of Governors of the Federal Reserve System: Roles and Responsibilities of Federal Reserve Directors