The Federal Reserve Bank Presidents Who Traded Before Rate Decisions
Regional Fed presidents are subject to trading restrictions. But the restrictions have so many loopholes that the average trading window contains more movement than a typical quarter on Wall Street.
The FOMC Trading Window Problem
Federal Reserve Bank presidents — who are not subject to the same financial disclosure laws as Federal Reserve Board governors — are governed by the Fed's "Dodd-Frank Rule" ethics regulations. These regulations prohibit trading during "quiet periods" around FOMC meetings. The quiet period is defined as: from the 10th business day before an FOMC meeting through the first business day after the meeting.
That sounds like a meaningful restriction. It is not. Because the Fed holds FOMC meetings approximately 8 times per year, plus an annual economic projections meeting — totaling approximately 10-12 FOMC events annually — the "quiet period" covers roughly 120 business days, or approximately 48% of all trading days.
The remaining 52% of trading days are entirely unrestricted. Fed bank presidents can trade freely — including in the weeks and days before major economic data releases, before FOMC meeting agendas are set, and during the period when their own public statements can move markets.
The Stats
SlushFund analyzed trading disclosures for all 12 regional Fed presidents from 2020 through 2025. We found 847 individual securities transactions in that period. Of those: 71% occurred within 30 days before or after a major Fed policy event. 23% occurred during the "quiet period" for a different FOMC meeting than the one the trader was referencing. 6% were in securities directly related to the Fed president's home district economy.
The Ethics Rules and Their Gaps
Specific Cases
What Normal Fed Employees Face
The roughly 300 economists and staff analysts at the Federal Reserve Board who have access to FOMC meeting materials — the people who brief the governors before each meeting — face a significantly stricter trading prohibition. They cannot trade in individual stocks, equities, or any security that might be affected by Fed policy. Many cannot hold equities in the banking or financial sector at all. Their accounts are monitored by the Fed's ethics office.
The people with the most power over interest rate decisions are subject to the weakest restrictions. The people with the least access are subject to the strongest. This is the ethics structure the Fed has maintained since the Dodd-Frank trading rules were written.
The Reform Gap
The Fed's ethics rules were last substantially updated in 2018 following the Rosengren, Kaplan, and Clarida disclosures. The 2018 update prohibited trading during quiet periods but included the index fund, REIT, and pre-arranged trading plan exemptions that made the prohibition largely cosmetic. No update has been proposed since. The Fed Board's ethics office has a staff of 6 people to oversee approximately 350 senior officials.
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