The Federal Reserve: Independence, Accountability, an Constitutional Debate

By: Owen Finn
Volume X – Issue I – Fall 2024

I. INTRODUCTION TO THE FEDERAL RESERVE

In the 1800s and early 1900s, public distrust in the banking system led to frequent bank runs and financial crises. Between 1863 and 1910, there had been three major banking panics and eight more localized panics in the United States. [1] In response, the Federal Reserve Act of 1913 was signed into law by Congress in order “to provide for the establishment of Federal reserve banks, to furnish an elastic currency, to afford means of rediscounting commercial paper, to establish a more effective supervision of banking in the United States, and for other purposes.” [2] The Federal Reserve Act lays out a central banking system with three key features: a central governing Board (called the Board of Governors today), a decentralized operating structure of twelve Reserve Banks, and a combination of public and private characteristics. [3] The twelve regional banks are spread across major cities like New York, Boston, Chicago, and Philadelphia.

The Fed is driven by two objectives. First, it aims to maintain stable prices, which means an annual inflation target of about 2%. Second, it seeks to achieve full employment; while the definition of full employment is up for debate, this typically means an unemployment rate of 4-5%. [4] The Fed works with Congress to set these targets. The Fed’s primary goal is to set interest rates at the optimal level to maintain low inflation and full employment. [5]

The Federal Reserve controls the three tools of monetary policy: open market operations, the discount rate, and reserve requirements.6 The Fed has three policymaking branches: the Board of Governors, the 12 Federal Reserve Banks, and the Federal Open Market Committee (FOMC). The Board of Governors, the governing body of the Fed, is responsible for the discount rate and reserve requirements. The Board consists of seven members, each of which is nominated by the president, to a fourteen-year term, and has been led by Fed Chair Jerome Powell since 2018. The Board of Governors reports to and is directly accountable to Congress.7 The FOMC is responsible for open market operations, such as setting interest rates and managing the money supply. The FOMC consists of twelve members: those on the Board of Governors, the president of the New York Fed, and four other regional presidents on a rotating basis. [8] Each regional president is appointed to a five-year term by their bank’s directors, subject to the approval of the Board of Governors. [9]

Although the Board of Governors are appointed by the president and approved by the Senate, the Federal Reserve operates mostly independently of the federal government. [10] Since its founding, presidents have had a long history of trying to influence the Fed, but it has mostly been left alone for the past two decades. Recently, some politicians, notably President-elect Donald Trump, have argued that the president should potentially have a say in setting interest rates. They argue the central bank’s actions must be tightly coordinated with government actions and the bank should have a higher degree of regulatory oversight. [11] Additionally, some argue that the Fed’s autonomy is unconstitutional because it violates the separation of powers doctrine of the Constitution. Because the Constitution gives Congress the power to coin money and regulate its value, some argue that Congress should be the sole controllers of monetary policy and they have no right to delegate it to an independent bureaucracy. [12] However, economists have argued that politicians prefer lower interest rates, which can lead to inflation. They highlight the Fed’s ability to act on data, rather than be influenced by politics. [13] If the president did have a direct influence on the Fed’s decisions, the effects would drastically change the state of economic policy.

II. THE FED’S AUTONOMY

Most policymakers and academics argue that the central bank’s independence, often referred to as CBI, is critical to its ability to control inflation and carry out monetary policy. Nearly all advanced economies are governed by independent central banks whose governing bodies decide monetary policy without political input, approval, or fear of reprisal. [14] As an independent agency, the Fed makes decisions based on the best available evidence and objective analysis, without taking politics into consideration. [15] Starting in the 1970s, empirical evidence shows that the trend of most advanced economies toward CBI has coincided with a long-term decline in inflation and well-anchored long-term expectations. [16]

The Fed must keep the country’s long-term interests at the forefront, but politicians may not be best suited to take a long-term perspective. If influenced by politics, policymakers could be pressured to overstimulate the economy through expansionary policy, which seeks to boost demand through monetary and fiscal stimulus. Although expansionary policy may lead to short-term political and employment gains, it is directly related to inflation and can cause higher prices later on. [17] Fed policies operate over a significantly longer period than politically motivated policies. Monetary policies may take months or even years to fully impact the economy, and policymakers must take this substantial lag into account with a long-term perspective. Overall, political interference in monetary policy could cause undesirable boom- bust cycles that lead to a less stable economy and higher inflation.18

CBI also contributes to the Fed’s credibility, which is important for maintaining long-term expectations. Central banks regularly commit to maintaining lower inflation in the long term and this commitment is generally seen as credible by the public, causing lower inflation expectations. [19] Political influence on the Fed could reduce its credibility due to the risk of short-term expansionary policies inconsistent with long-term price stability. When people have less trust in the Fed to fulfill its goals over the long term, it can create expectations of higher inflation.

Acting on data and analysis, taking a long-term perspective, and upholding the Fed’s credibility all contribute to CBI's efficiency. The Fed’s policy decisions are meant to be separate from the government, and policy moves do not have to be ratified by the President or anyone else in the federal government. [20] The Fed has enjoyed this form of autonomy since the Monetary Accord of 1951 was passed into law.

Congress sets the goals of monetary policy, and the bank is responsible for fulfilling them. The Fed demonstrates its commitment to achieving its goals by being transparent about policy strategy and economic outlook. To uphold accountability, the Fed releases extensive reports on the economy to Congress semi-annually and the FOMC releases a statement after each of its eight-yearly meetings that explains the Committee’s policy decision and reports the vote on that decision. [21] Transparency allows the government to hold the bank accountable and also increases the effectiveness of policy; by providing clarity about the aims of future monetary policy and about how the central bank would react under various economic circumstances, the Fed “reduces uncertainty and--by helping households and firms anticipate central bank actions--amplifies the effect of monetary policy on longer-term interest rates.” [22] The bank and the federal government must work together to achieve economic goals, and the clarity afforded by Fed transparency increases the ability of policymakers to influence economic growth and inflation.

III. THE FED AND THE PRESIDENT

The Fed did not always have the level of autonomy it has today. It was originally intended to be independent of the government, but the executive branch significantly influenced monetary policy decisions in the four decades following the Fed’s 1913 creation. The Secretary of the Treasury and the Comptroller of the Currency were members of the Fed’s Board of Governors and presided over meetings. [23] When the US entered WWI in 1917, the Fed’s main function was financing the war effort by offering loans to banks at a discounted rate to stimulate demand for Treasury bonds. [24]

During his 1920s presidency, Herbert Hoover attempted to use his political influence to encourage the Fed to raise interest rates, yet interest rates were cut. [25] In 1929 the stock market crashed and Hoover pressured the Fed to cut interest rates; instead, the Fed “raised rates, froze borrowing, and tipped the country and the world into the Great Depression.” [26] The Fed’s contractive policies prolonged and contributed to the severity of the decline, and if Hoover had more power over the Fed, the economy may have fared better during this era. The White House and Congress took over monetary policy from 1933 until the Fed’s independence was officially recognized in 1951. [27]

When the US entered WWII in 1941, the Fed was again used to finance war efforts more cheaply. The Fed cooperated with the Treasury and kept rates low to stimulate the economy and allow the government to run up substantial debt at a lower cost. [28] According to then-Fed Chair Marriner Eccles, the Fed “merely executed Treasury decisions.” [29] After the war ended in 1945, interest rates were kept low to support the government in repaying the substantial war debt. Climbing inflation and the Fed’s frustration with the fiscal demands of the Treasury led to a congressional intervention and the Treasury-Federal Reserve Accord of 1951. [30] The Accord affirmed separation between the Fed and Treasury, granting the Fed authority over interest rates and autonomy in its monetary policy decisions. [31]

While many politicians have tried and succeeded in influencing the central bank even after the Accord, the central bank has closely guarded its independence. It has mostly been left alone for the past 25 years, but Donald Trump abandoned this norm. As president, he often expressed his frustrations with Fed Chair Powell; Trump repeatedly called for lower interest rates while Powell either kept rates the same or raised them on various occasions. [32] Trump has defended his criticism of Powell and the Fed, saying that “it’s fine for a president to talk (about interest rates)... it doesn’t mean that (the Fed) has to listen.” [33]

Trump has expressed a desire to eventually reform the Fed. It is unclear what exactly he has in mind, but several proposals from Trump allies and staffers have been made public. Trump’s running- mate, JD Vance, has made clear that they believe public opinion should determine monetary order, saying “if the American people don’t like our interest rate policy, they should elect somebody different to change that policy. Nothing should be above democratic debate in this country.” [34] Additionally, Trump allies argue that the president should be consulted on interest rate decisions as a member of the rate-setting committee; the Fed chair would meet with the president and negotiate with the FOMC to steer policy on the president’s behalf. [35] Although Fed experts and at least some Trump advisors do not expect the president-elect to attempt to remove Powell before the end of his term in 2026, there is no statute about whether a president could remove a Fed chair. [36] No president has attempted to remove a Federal Reserve chairman from their role before, but Trump could be the first to legally test this power if his unhappiness with Powell continues.

Project 2025, an organized effort not directly affiliated with Trump but overseen by several former Trump advisors, offers some additional insight into what a Trump presidency could mean for the Fed. The project calls for increased operational effectiveness by dropping the Fed’s mandate on full employment and “limiting the Fed’s mandate to the sole objective of stable money” [37]. The project argues that the dual mandate contributes to recessions rather than fixes them, and the Fed should focus on restraining inflation. [38] It also supports a Congressional limit placed on the Fed’s balance sheet to shrink it to what existed historically before the 2008 financial crisis. [39] The Fed’s asset ownership has blown up from less than $1 trillion before 2008 to nearly $9 trillion today. Project 2025 argues that a lack of oversight of the types and amount of assets purchased by the Fed has led to politically favored markets and subsidizing federal deficits; for example, the Fed’s purchase of mortgage securities contributes to rising housing costs. [40] Overall, Project 2025 proposes restricting the Fed’s open market operations to Treasuries, winding down the Fed’s balance sheet, and eliminating the dual mandate. For better or worse, these initiatives would grant the executive branch significantly more control over monetary policy.

Powell and most economists maintain that central bank independence is essential to the Fed’s credibility and economic performance. Historically, political influences on the Fed have led to runaway inflation and boom-bust cycles. An independent central bank is the norm within the global economy. [41] Still, the U.S. Constitution does not explicitly grant the government the power to create a central bank. Later cases granted Congress this power, but those who follow a strict interpretation of the Constitution could argue that Congress never had the authority to create a central banking system like the Fed, and monetary policy should be controlled by Congress alone. [42]

IV. THE FED AND THE CONSTITUTION

In response to Richard Nixon’s controversial presidency and the Watergate scandal, Congress enacted the Ethics in Government Act of 1978. The Act created a special court responsible for the appointment of an "independent counsel" to investigate,. and, if necessary, prosecute government officials, including the President, for certain violations of federal criminal laws. [43] The Attorney General and the Department of Justice could not intervene in any matters under the independent counsel's control. [44] The constitutionality of this Act was challenged in Morrison v. Olson, specifically whether or not a special counsel with the "full power and independent authority to exercise all investigative and prosecutorial functions and powers of the Department of Justice [and] the Attorney General" could operate independently of the President. [45]

In his dissent of Morrison v. Olson, Supreme Court Justice Antonin Scalia argues that the appointment of an independent counsel violated the separation of powers doctrine of the constitution because: (1) the operations in question are a purely executive power and (2) the statute deprives the executive branch of exclusive control over that power. [46] The conduct of criminal prosecutions is an executive power, and appointing an independent outside of presidential supervision deprives the executive branch of at least some of this power. Article XXX of the Massachusetts Constitution of 1780 states "the legislative department shall never exercise the executive and judicial powers, or either of them: The executive shall never exercise the legislative and judicial powers, or either of them…” [47] Justice Scalia emphasizes in his dissent that “this does not mean ‘some’ of the executive power, but all of the executive power.” [48] All legislative power is given to the legislative branch, all judicial power is given to the judicial branch, and all executive power is given to the executive branch. Because the independent counsel removed some of this power from the president (and the attorney general) and authorized it to someone they had limited discretion over, Scalia argued that the council was unconstitutional and substantially disrupted the balance of power between the branches of government.

The Court conceded that criminal prosecutions were an executive function and that the independent counsel deprived the executive branch of exclusive control. [49] Still, the majority decided that control over the independent counsel was not central to the executive branch's functions, and the president could perform his full duties without full control. The majority also emphasized that the attorney general could remove the independent counsel for good cause, and the attorney general is under presidential supervision. However, when the statute came up for renewal in 1999, the majority opinion was widely condemned. Attorney General Janet Reno of the Clinton administration described it as “structurally flawed… within our constitutional framework” and instead supported Justice Scalia’s dissent. [50]

The special counsel in Morrison v. Olson has similarities to the present-day Fed. The main difference is that the special counsel performed executive functions, while the Fed performs legislative functions. Using the same framework that Justice Scalia used in Morrison, delegating monetary policy to the Fed could be unconstitutional if: (1) monetary policy is a purely legislative power and (2) an independent central bank like the Fed deprives the legislative branch of exclusive control over that power. Article 1 Section 8 of the Constitution establishes the Enumerated Powers of Congress, and Clause 5 gives Congress the exclusive power to coin money and the authority to regulate every aspect of currency. [51] The Constitution does not explicitly authorize Congress to charter a central bank, and having one could be viewed as depriving Congress of exclusive control over monetary policy. Additionally, while the Fed is under Congressional supervision, it operates mostly independently. Officials are nominated by their regional bank’s Board of Directors rather than the government, and once appointed, it can be difficult for the government to remove them.

In McCulloch v. Maryland (1819), the Supreme Court ruled that Congress had the power to establish a national bank under the Necessary and Proper Clause, the last enumerated power. This clause is used to expand Congressional power by allowing Congress to make all laws that are “necessary and proper” to carry out their responsibilities. While the government can carry out its enumerated powers without a central bank, making it seem unnecessary, this case redefined necessary to mean “appropriate and legitimate” and found that the federal government chartering a bank fit within this description. Stretching the limits of the federal government past its explicitly delegated powers can be a slippery slope. How far can the Necessary and Proper Clause stretch federal power? How unconstitutional is too unconstitutional?

V. CONCLUSION

Politicizing the Federal Reserve could be harmful regardless of which party is in charge. Keeping inflation down while maximizing employment can lead to the Fed making decisions that increase the risk of recession in the short run for better outcomes in the long run. [52] Through an independent central bank, economists and other experts may resist political influences and act on data to better address long-term economic objectives and execute policies that are politically unpopular but serve a greater public interest. [53]

Most experts agree that an independent Fed can manage monetary policy more effectively than one subject to politics. The problem is that the Fed’s powers are derived from Congress’s enumerated powers. The Tenth Amendment states ‘all powers not delegated to the United States, by the Constitution, nor prohibited by it to the States, are reserved to the States or to the people.’ [54] As it is currently, Fed leadership is mostly chosen by the regional banks’ directors, rather than the President, Congress, or the public. Further, the writers of the Constitution debated and rejected delegating the power to charter corporations, yet the ruling in McCulloch v. Maryland granted Congress this power less than fifty years later. [55]

The McCulloch v. Maryland ruling was based on implied powers granted through the Necessary and Proper Clause. A loose definition of “necessary” opens the door to seemingly unlimited government power; virtually anything could be seen as legitimate or helpful to certain government endeavors. [56] Ironically, during the ratification debates, opponents of the Constitution were worried that the Necessary and Proper Clause would be construed in this way. [57] The writers of the Constitution assured people that the government's powers would be limited and specific. Under this type of limited government promised by supporters of the Constitution during ratification, there likely would not be a central bank. [58]

The Fed must perform a balancing act between constitutionality and effectiveness. On the one hand, political influences have historically had a negative impact on inflation and an independent Fed can better regulate monetary policy. On the other hand, the government currently has extremely limited discretion over Fed leadership and how the bank manages monetary policy. Additionally, whether or not the Constitution enables Congress to delegate monetary policy to a central bank is a bit of a gray area. President-elect Trump may attempt to exert his influence on the Fed, potentially making it more aligned with the language of the Constitution. However, it is unclear what specific actions Trump would take and how they would affect the Fed’s effectiveness. Still, the fact that the Federal Reserve Bank was mostly left unbothered by presidents for the past few decades does not mean that future presidents will refrain from trying to influence monetary policy. [59] At least some reform is needed; the Fed's top-down approach in managing monetary policy over the last 40 years, while enhancing economic growth, has also led to significant income inequality. [60] For better or worse, I expect the Fed’s independence to be subject to debate as future presidents fight for more control over monetary policy.

Endnotes

[1] Jessie Romero, “Jekyll Island: Where the Fed Began,” Richmond Federal Reserve, 2015, https://www.richmondfed.org/-/media/RichmondFedOrg/publications/research/econ_focus/2015/q1/pdf/federal_reserve.pdf.

[2] Federal Reserve Act, Pub. L. No. 63-43, 38 Stat. 251 (1913). Accessed via Lexis+, https://plus.lexis.com/document?crid=9c10036d-4ae1-4a11-a18f-b08ccfde4d2d&pddocfullpath=/shared/document/statutes-legislation/urn:contentItem:5C9D-VN70-01XN-S46P- 00000-00&pdsourcegroupingtype=&pdcontentcomponentid=173014&pdmfid=1530671&pdisurlapi=true#/document/e8c1c 7cc-5c79-4ee4-81cf-1b3bcfac9339.

[3] “The Fed Explained: What the Central Bank Does,” 2021, https://www.federalreserve.gov/aboutthefed/files/the-fed-explained.pdf.

[4] James McBride, Anshu Siripurapu, and Noah Berman, “What Is the U.S. Federal Reserve?,” Council on Foreign Relations, August 15, 2024, https://www.cfr.org/backgrounder/what-us-federal-reserve#:~:text=It%20is%20responsible%20for%20managing,purchases%20to%20boost%20financial%20markets.

[5] Jordan Weissmann, “Could Donald Trump Break the Fed?,” The Atlantic, August 21, 2024, https://www.theatlantic.com/politics/archive/2024/08/donald-trump-federal-reserve-independence/679535/.

[6] “Federal Open Market Committee,” The Fed - Federal Open Market Committee, September 2024, https://www.federalreserve.gov/monetarypolicy/fomc.htm.

[7] “The Fed Explained: What the Central Bank Does,” 2021.

[8] “The Fed Explained: What the Central Bank Does,” 2021.

[9] Presidential Search Frequently Asked Questions, https://www.newyorkfed.org/medialibrary/media/aboutthefed/presidential-search/faqs.pdf.

[10] Dan Blystone, “Why Is the Federal Reserve Independent?,” Investopedia, December 27, 2023, https://www.investopedia.com/articles/investing/041515/why-federal-reserve-independent.asp.

[11] Dan Blystone, “Why Is the Federal Reserve Independent?,” Investopedia, 2023.

[12] Alex Pollock, “How Does the Federal Reserve Fit into Our Constitutional Order?,” The Federalist Society, January 2024, https://fedsoc.org/commentary/fedsoc-blog/how-does-the-federal-reserve-fit-into-our-constitutional-order.

[13] Alex Pollock, “How Does the Federal Reserve Fit into Our Constitutional Order?,” The Federalist Society, 2024.

[14] “The Importance of Central Bank Independence,” The White House, May 23, 2024, https://www.whitehouse.gov/cea/written-materials/2024/05/22/the-importance-of-central-bank-independence/#_ftn1.

[15] Chair Jerome H. Powell, Testimony on the Semiannual Monetary Policy Report to the Congress, Board of Governors of the Federal Reserve System, July 10, 2019, https://www.federalreserve.gov/newsevents/testimony/powell20190710a.htm.

[16] “The Importance of Central Bank Independence,” The White House, May 23, 2024.

[17] The Investopedia Team, “Expansionary Fiscal Policy: Risks and Examples,” Investopedia, June 2024, https://www.investopedia.com/terms/e/expansionary_policy.asp.

[18] Chair Ben S. Bernanke, “Central Bank Independence, Transparency, and Accountability,” Board of Governors of the Federal Reserve System, May 26, 2010, https://www.federalreserve.gov/newsevents/speech/files/bernanke20100525a.pdf.

[19] Chair Ben S. Bernanke, “Central Bank Independence, Transparency, and Accountability,” 2010.

[20] Dan Blystone, “Why Is the Federal Reserve Independent?,” Investopedia, December 27, 2023.

[21] Chair Ben S. Bernanke, “Central Bank Independence, Transparency, and Accountability,” 2010.

[22] Chair Ben S. Bernanke, “Central Bank Independence, Transparency, and Accountability,” 2010, p. 12.

[23] Stephen Slivinski, “The Evolution of Fed Independence,” Richmond Federal Reserve, 2009, https://www.richmondfed.org/-/media/richmondfedorg/publications/research/econ_focus/2009/fall/pdf/federal_reserve.pdf.

[24] Stephen Slivinski, “The Evolution of Fed Independence,” 2009.

[25] Bill Schmick, “Presidents Have a Long History of Fed Bashing,” The Berkshire Eagle, August 19, 2024, https://www.berkshireeagle.com/business/presidents-history-bashing-fed-chair/article_f27531be-5e3a-11ef-a48a-c764f061aae7.html.

[26] Bill Schmick, “Presidents Have a Long History of Fed Bashing,” 2024, p. 6.

[27] Stephen Slivinski, “The Evolution of Fed Independence,” 2009.

[28] Ashley Kloenhamer, Esq, “Feature the U.S. Department of the Treasury and the Federal Reserve System,” Lexisnexis, 2022.

[29] Stephen Slivinski, “The Evolution of Fed Independence,” 2009, p. 2.

[30] Stephen Slivinski, “The Evolution of Fed Independence,” 2009.

[31] Ashley Kloenhamer, Esq., “Feature the U.S. Department of the Treasury and the Federal Reserve System,” 2022.

[32] Rebecca Ballhaus, “Trump Says Federal Reserve ‘Doesn’t Know What It Is Doing,’” Wall Street Journal, June 24, 2019,https://www.wsj.com/articles/trump-says-federal-reserve-doesn-t-know-what-it-is-doing-11561381446?mod=article_inline.

[33] Rashard Rose, “Trump backs off earlier claims that he should directly control interest rates,” CNN, August 20, 2024, https://www.cnn.com/2024/08/20/business/trump-federal-reserve-independence/index.html.

[34] Anna Gordon, “Trump and Vance Want More Control Over the Federal Reserve. Economists Are Worried,” Time, August 12, 2024, https://time.com/7010213/donald-trump-federal-reserve-politics/.

[35] Andrew Restucciam, Nick Timiraos, and Alex Leary, “Trump Allies Draw Up Plans to Blunt Fed’s Independence,” Wall Street Journal, April 26, 2024, https://www.wsj.com/economy/central-banking/trump-allies-federal-reserve-independence-54423c2f.

[36] Antonio Pequeño, “Can Trump Fire Jerome Powell? Fed Chairman Says He Won’t Resign If Trump Asks,” Forbes, November 2024, https://www.forbes.com/sites/antoniopequenoiv/2024/11/07/can-trump-fire-jerome-powell-fed-chairman-says-he-wont-resign-if-trump-asks/.

[37] Project 2025, “Mandate for Leadership 2025: The Conservative Promise,” The Heritage Foundation, 2023, https://static.project2025.org/2025_MandateForLeadership_FULL.pdf, p. 732.

[38] Project 2025, “Mandate for Leadership 2025: The Conservative Promise,” 2023.

[39] Project 2025, “Mandate for Leadership 2025: The Conservative Promise,” 2023.

[40] Project 2025, “Mandate for Leadership 2025: The Conservative Promise,” 2023, p. 734.

[41] “The Importance of Central Bank Independence,” The White House, May 23, 2024.

[42] Justin Walton, “Why Do Some People Claim the Federal Reserve Is Unconstitutional?,” Investopedia, October 2021, https://www.investopedia.com/ask/answers/082115/why-do-some-people-claim-federal-reserve-unconstitutional.asp#toc-congress-seeks-transparency-and-accountability.

[43] "Morrison v. Olson," Oyez, https://www.oyez.org/cases/1987/87-1279.

[44] Morrison v. Olson," 487 U.S. 654 (1988)

[45] Morrison v. Olson," 487 U.S. 654 (1988)

[46] Morrison v. Olson," 487 U.S. 654 (1988)

[47] Morrison v. Olson," 487 U.S. 654 (1988)

[48] Morrison v. Olson," 487 U.S. 654 (1988)

[49] Morrison v. Olson," 487 U.S. 654 (1988)

[50] Adrian Vermeule, “Morrison v. Olson Is Bad Law,” Lawfare Media, June, 2017, https://www.lawfaremedia.org/article/morrison-v-olson-bad-law.

[51] U.S. Constitution, art. 2, sec. 1, cl. 3.

[52] Anna Gordon, “Economists Worry About Trump’s Push to Politicize the Fed,” Time, August, 2024,https://time.com/7010213/donald-trump-federal-reserve-politics/.

[53] Dan Blystone, “Why Is the Federal Reserve Independent?,” Investopedia, 2023.

[54] U.S. Constitution, art. 2, sec. 1, cl. 3.

[55] Michael Maharrey, “Hamilton vs. Jefferson: Is the Federal Reserve Constitutional?,” LinkedIn, April, 2024, https://www.linkedin.com/pulse/hamilton-vs-jefferson-federal-reserve-constitutional-money-metals-qj8we/.

[56] Michael Maharrey, “Hamilton vs. Jefferson: Is the Federal Reserve Constitutional?,” 2024.

[57] Michael Maharrey, “Hamilton vs. Jefferson: Is the Federal Reserve Constitutional?,” 2024.

[58] Michael Maharrey, “Hamilton vs. Jefferson: Is the Federal Reserve Constitutional?,” 2024.

[59] Bill Schmick and Drew Angerer, “Presidents Have a Long History of Fed Bashing,” The Berkshire Eagle, August 19, 2024, https://www.berkshireeagle.com/business/presidents-history-bashing-fed-chair/article_f27531be-5e3a-11ef-a48a-c764f061aae7.html.

[60] Bill Schmick and Drew Angerer, “Presidents Have a Long History of Fed Bashing,” August, 2024.

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