Guardrails for Democracy: How Congress Can Reinforce Privacy Rights and Independent Oversight

This article was previously published as part of The Reconstruction Papers. The entire book is available in print and as a PDF.

Although the Founders envisioned Congress as the most powerful branch of the federal government, over the course of the last century, the presidency has accreted enormous power. The current Administration is an extreme example of a long-running trend, with each president building on the expanded powers of his predecessor. This trend has created norms accepted by multiple Congresses even when inconsistent with the constitutional allocation, reaching its nadir with the current Congress. The Framers’ belief expressed in Federalist 51 that “competing ambitions” would always incentivize each branch to counteract each other simply did not contemplate that the most powerful branch would cede its power to the executive.¹

Decisions by the Roberts Court have accelerated the accretion process. Its decision to immunize the president from criminal liability for acts performed in his official capacity removed a critical constraint.² The Court’s expansive view of the meaning of executive power in Article II of the Constitution threatens the existence of independent agencies.³ And its recent holding that the lower courts lack the power under the Judiciary Act of 1789 to issue nation-wide injunctions against even the most patently unlawful executive action gives the executive branch a potentially long runway for illegality.⁴

How can we rebalance the constitutional order? Ironically, it will take congressional action to protect the citizenry against its own future abdications. Assuming voters elect a Congress willing to do so, it can build on the legal structure created the last time such a crisis manifested. Laws made in response to Richard Nixon’s abuses of power successfully brought about norms observed by the executive branch for nearly half a century, no matter which party was in power. This article focuses on two such laws—the Privacy Act of 1974 (Privacy Act) and the Inspector General Act of 1978 (IG Act). The Privacy Act protects individuals from unauthorized use and/or dissemination of their private information. The IG Act assembled a group of independent watchdogs to ferret out “waste, fraud and abuse” with the authority to investigate legal and ethical violations, report to Congress, and make criminal referrals.

The Trump Administration’s violations of these laws, aided by Supreme Court decisions weakening presidential accountability, have exposed their vulnerabilities. Such violations include unauthorized access to and disclosure of the financial records of political enemies, using individuals’ personal data for unauthorized purposes, and mass retaliatory firings of inspectors general (IGs). This article advocates statutory changes achievable under the current constitutional framework; that is, they do not require either an about-face by the Supreme Court or a constitutional amendment. These changes aim to empower individuals to better protect their own civil liberties and strengthen the protections for government watchdogs, giving the citizenry, the Congress, and the courts a stronger role in checking and balancing the executive branch.

Strengthening the Privacy Act

The Privacy Act of 1974 is the most important bulwark against federal government misuse of the enormous amount of personal data it collects.⁵ This applies to information that can be used to confirm an individual’s identity, either alone or when combined with other information linkable to a specific individual. The Privacy Act limits access to and disclosure of such information to those with a need to know regarding the performance of their duties. Individuals harmed by unlawful disclosure may sue the agency in federal court, but only for actual damages. Actual damages mean pecuniary harm (e.g., out of pocket such as increased cost of credit or lost employment) but do not include reputational harm or emotional distress.

Courts may award damages under the Privacy Act only against the agency and not those who actually commit the violations. Damages may include attorney fees and costs. Interim relief is not available for disclosure violations, so individuals may still be harmed until judgment. The law authorizes statutory damages of $1,000 but the Supreme Court has interpreted the statute to require a plaintiff to prove the existence of actual damages to collect statutory damages.⁶ Privacy Act class actions can be brought under Federal Rule of Civil Procedure 23, subject to the rule’s procedural requirements, which the Supreme Court has consistently tightened.⁷

Individual liability under the Privacy Act only comes into play through its relatively lenient criminal penalties. Willful disclosure of information in violation of the Privacy Act is a misdemeanor and subject to a fine of up to $5,000. Privacy Act prosecutions are rare.⁸

These limited remedies are complemented by the obligations the Privacy Act and implementing rules place on agencies to police themselves.⁹ Federal agencies must strictly control employee access and use of personal information. Federal employees must only access personal information for authorized duties, report breaches, and face consequences (including removal) for violations. The inspector general for each agency reviews and reports to Congress on Privacy Act compliance.¹⁰

Privacy Act gaps

When officials override agency safeguards, Privacy Act remedies have been insufficient to stop ongoing harms or provide complete relief to a harmed individual. Recent events involving investigation of the President’s political enemies demonstrate the holes in the remedial framework. Beginning in August 2025, William Pulte, the head of the Federal Housing Finance Agency (FHFA), which regulates the secondary-housing mortgage market, made criminal referrals against individuals who had been publicly targeted by the president, posting about them on X. The FHFA director’s statutory authority does not include investigating mortgage fraud. According to the FHFA inspector general’s protocols,¹¹ the correct procedure would have been to refer any suspicious information to the agency’s inspector general for a professional and confidential investigation before a criminal referral could be made to the Department of Justice. Inspectors general do not make public the identity of those referred.

The first posting was a mortgage-fraud accusation against Federal Reserve Member Lisa Cook, which included information from her mortgage files. Immediately after the posting, the President purported to fire Cook. Because the Federal Reserve Act limits the removal of Federal Reserve governors to “cause,” she sued to obtain an injunction against the firing and was successful in securing preliminary relief, up to and including in the Supreme Court, where her case was argued on January 12, 2026 and is awaiting decision.¹² The statutory “cause” requirement was the only reason Cook was able to obtain immediate relief. The Privacy Act does not authorize it, and neither her lawsuit nor the Privacy Act authorizes her to hold Pulte responsible for her reputational harm.

Pulte subsequently announced two more criminal referrals of the president’s opponents for mortgage fraud: New York Attorney General Leticia James and Senator Adam Schiff. The former was indicted in the Eastern District of Virginia, but the court dismissed the indictment in November 2025, finding the US Attorney who single-handedly obtained¹³ it was invalidly appointed. The Justice Department attempted to reindict James but its attempts were rejected by two separate grand juries in December 2025.¹⁴ With respect to Schiff, it has been widely reported that in October 2025, the U.S. Attorney for the District of Maryland informed the Department of Justice there was insufficient evidence to charge Schiff with mortgage fraud.¹⁵ No charges have been filed and the Justice Department is now investigating actions of Pulte and Justice Department official Ed Martin relating to the investigation.¹⁶

According to a complaint filed by Representative Eric Swalwell, on November 13, 2025, Pulte referred a mortgage fraud claim against him to the DOJ but leaked information to the press before the department physically received the referral. On November 25, 2025, Swalwell filed a complaint against Pulte in his official capacity as the head of FHFA, Fannie Mae, and Freddie Mac for violations of the Privacy Act and the First Amendment. It was dismissed without prejudice on the parties’ stipulation on March 23, 2026.¹⁷ No charges have been filed.

While these referrals were in process, Pulte was removing personnel responsible for ensuring his compliance with legal and ethical requirements. As described in a document request to Pulte from Ranking Member Robert Garcia of the House Committee on Government Oversight, after installing himself as chairman of Fannie Mae, Pulte fired its ethics team. The letter further alleges that the Administration subsequently fired the FHFA’s acting inspector general for communicating with Congress about his oversight efforts.¹⁸

What Congress can do under current law

Democrats on the House Banking Committee requested that the Government Accountability Office (GAO) review the actions of Pulte and FHFA,¹⁹ and on December 1, 2025, GAO agreed to do so.²⁰ It is the investigative arm of Congress, which audits federal programs, evaluates government performance, and provides objective information to Congress. GAO reports may contain recommendations for executive action, but the office cannot enforce them. Furthermore, the office of Management and Budget (OMB) informed GAO that agencies will only cooperate with GAO audits to the extent that they do not unduly impede implementation of the president’s priorities²¹ and the agencies have since ignored a number of GAO data requests.²² Congress can enforce GAO recommendations directly through legislation, or indirectly by tying agency funding to implementation of the recommendations. It also has impeachment authority over federal officers under Article II, Section 4 of the Constitution.

Upgrading the Privacy Act

None of the individuals whose statutory privacy rights appear to have been violated can obtain relief against any individual, and the available damages are limited. Nor can they get interim relief against ongoing violations. These cases exemplify why the Privacy Act should be amended to give individuals more control over remedying violations. First, in addition to the agency, the law should hold its officers, employees or contractors, or any other persons who engage in intentional or reckless violations civilly liable to their victims. Individuals found liable for such violations should be barred from seeking indemnity from the US government, both for damages and attorney fees. This provides an important deterrent. Although the president may be immune, he must act through his subordinates. If they face significant liability and defense costs, it may inhibit bad behavior; unlike federal criminal convictions, civil damages awarded to individuals are not subject to the presidential pardon power, which Article II, Section 2 limits to “offenses against the United States.”

Statutory damages should be available once a violation is proved. And because reputational harm often follows a Privacy Act violation (and may be a motivating factor), available damages should be expanded so that reputational harm, including mental distress, can be compensated. Interim relief should be available so that if there is sufficient evidence a Privacy Act breach occurred, adverse consequences can be halted while the case proceeds.

To address the types of harm that systemic privacy violations can cause to large groups, class actions are necessary. They are an important vehicle for stopping and remedying large-scale violations of privacy, especially in light of the Robert Court’s recent ruling that lower courts cannot issue nationwide injunctions in individual suits.²³ Again, recent actions by the Trump Administration provide a clear example of the need for such relief. In July 2025, the Department of Agriculture demanded that the states turn over millions of records for participants in the Supplemental Nutrition Assistance Program (SNAP), including SSNs, birth dates and benefit payments, and threatened to withhold funding from noncompliant states. Twenty-two states and the District of Columbia sued under the Administrative Procedures Act (APA), which authorizes a court to set aside agency action that is arbitrary, capricious or not in conformance with law. The complaint alleged that the demand was inconsistent with the SNAP Act and Privacy Act. On October 15, 2025, the court issued a preliminary injunction forbidding the federal government to withhold funding from states that refused to comply with the data requirement, finding the demand unauthorized by the SNAP Act. The court expanded the order on February 26, 2026, to encompass new USDA demands.²⁴

Only a class action could provide relief to residents of the twenty-eight states that chose to comply with the USDA demand. However, as noted above, the Roberts Court has been tightening the requirements for certifying a class under the class action rule to make them more cumbersome. In fact, Justices Samuel Alito and Clarence Thomas have expressed hostility to class actions as an alternative to nationwide injunctions, warning that courts should not use class actions as a “loophole” to get around the decision that this relief is unavailable under the Judiciary Act.²⁵ (Of course, if one law provides relief that another doesn’t, it is hardly a loophole.)

The Privacy Act should be amended to authorize streamlined class actions for victims of systemic access/disclosure violations and provide for class-wide injunctive relief to stop ongoing violations. If the class is sufficiently numerous with common issues of fact and law the court should certify the class (i.e., find the proposed class appropriate) and, if liability is found, award statutory damages to each class member. To prevent class actions from becoming too cumbersome from numerous individualized damage claims, class members with actual damages could bring their own damages actions after liability to the class is established.

The criminal liability provisions should be strengthened by making willful violations a felony, as with disclosure violations under the Tax Code,²⁶ and by raising the fine significantly to six figures. Finally, if a violation is found, the agency IG, or the GAO if there is no IG, should be required to perform a privacy audit and report to Congress on measures needed to prevent recurrence. Agency heads should be required to regularly report to Congress on implementation of remedial measures as part of the annual budget cycle.

Strengthening IG independence

IGs play an important role in agency compliance with the Privacy Act as well as other laws. In addition to auditing and reporting on agency compliance, they receive and investigate whistleblower complaints, handling them in the strictest confidence to prevent retaliation.²⁷ If an IG referral had been made of the alleged tips Pulte claimed to have received and been subjected to a professional investigation, none of the cases he publicized likely would have seen the light of day.

The FHFA did not have a permanent IG at the time, however. One of the Trump administration’s first acts, in January 2025 was to fire eighteen inspectors general.²⁸ Although the IG Act requires agency officials to provide information for audits and investigations, the president also fired inspectors general who notified Congress when agency officials violated this provision, including the FHFB’s acting inspector general as noted above. Many IG positions have not been filled and have acting officials in them, or no one at all.²⁹

After Trump summarily fired five inspectors general in his first administration, Congress amended the IG Act to require the president to advise the legislature of specific reasons for the termination thirty days before it takes effect.³⁰ As all the 2025 terminations violated this law, a group of inspectors general brought suit in the DC District Court and sought immediate injunctive relief of reinstatement. Although the court was sympathetic and praised the contributions of these inspectors general, she refused to grant the relief on the grounds that the president could simply send the letter and then fire them again in thirty days.³¹ Thus, the 2022 amendments were reduced to a nullity.

Roughly half of the inspectors general are appointed by the president and confirmed by the Senate (known as “PAS” positions).³² These include positions at the Cabinet agencies and major independent agencies. At smaller agencies, the agency head appoints the IG. All IGs are subject to general supervision of the agency head, although only the president can fire one who is PAS.³³ Under the Federal Vacancies Reform Act (VRA),³⁴ if a PAS position becomes vacant in the first sixty days after a presidential transition, an acting official can serve for up to 300 days. After the first sixty days of a presidential transition, an acting official can only serve for 210 days. If the time limits pass without a nomination, nobody can serve in this capacity until a nomination is submitted to the Senate. (A nomination tolls the running of the time limits.) The purpose of the VRA is to incentivize the president to nominate candidates for major offices and preserve the Senate’s advisory role in the appointment process, rather than allow him to bypass the Senate by appointing acting officials.

Upgrading the IG Act

The VRA works reasonably well for positions a president wants to fill, but provides a perverse incentive to presidents who do not like having watchdogs in their agencies. The high number of vacant IG offices that exist now (some of which have existed across administrations) shows that the VRA approach does not work well for IGs. Fortunately, there is a model that could be adapted for temporary IG appointments; namely the interim US attorney appointment statute.³⁵

To guard against the politicization of local US attorney offices, Congress offered an alternative method for appointment of interim US attorneys. This appointment method co-exists with the VRA method. Under this law, when a US attorney position becomes vacant, the Attorney General can make an interim appointment, but only for 120 days. Once that time period ends, if there is no Senate-confirmed US attorney in place, the district court for that district may appoint an interim to serve until a permanent official is confirmed. Over the past year, the courts have rebuffed numerous efforts by the Attorney General to evade the time limits in the interim US attorney statute and the VRA.³⁶

The courts can make these appointments because the Appointments Clause of Article II of the Constitution authorizes the courts to appoint “inferior officers.” According to the Supreme Court, an inferior officer is one who reports to someone below the level of the president.³⁷ US Attorneys report to the Attorney General and hence are inferior officers, as the Justice Department conceded in United States v. James.³⁸ IGs report to their agency head and thus should also be considered inferior officers, especially since, unlike US attorneys, IGs only make recommendations and provide information; they do not make policy or administer laws.

Because independence is integral to the function of an inspector general, if an IG position remains vacant for a lengthy period of time, there is a strong case for placing interim appointment authority with a neutral judiciary. As with US attorneys, interim appointments by the president (for PAS IGs) or the agency head (for all other IGs) should be limited to 120 days. After that, if no IG has been appointed, the district court serving the location where the agency is headquartered should appoint an interim.

The IG Act prescribes specific criteria for the appointment of an IG (i.e., “without regard to political affiliation and solely on the basis of integrity and demonstrated expertise in accounting, auditing, financial analysis, law, management analysis, public administration, or investigations”) that a court can follow.³⁹ In making a selection, the court should consult with the Committee of Inspectors General for Integrity and Efficiency (CIGIE), the oversight organization established by the IG Act.⁴⁰ The interim should serve until a permanent IG is confirmed, unless the district court removes the interim or the IG resigns or becomes incapable (in which case the district court should appoint a successor until there is a confirmed IG). Sole power of appointment and removal should rest with the district court.

Since, as noted above, the rationale behind the VRA does not apply well to IGs, the interim IG provision should be the only method for appointing an interim. Placing full responsibility for interim IG appointments with the courts will preserve IG independence and better incentivize a president to make appointments that can get through the Senate.

Finally, recent events demonstrate the need for a clear enforcement mechanism for district court appointments. After the disqualification of the invalidly appointed interim US attorney in the James case, the district court appointed an interim US attorney. The Justice Department promptly fired the new interim via a social media post by Acting Deputy Attorney General Blanche that displayed a lack of familiarity with the text of the Appointments Clause.⁴¹ The interim US attorney’s statute is silent on removal of court appointees, and there is no guidance in the statute to resolve the current impasse.

Whatever the merits of the argument that the president retains removal power over federal prosecutors, IGs are notably different. An IG’s quasi-legislative role of advising Congress on agency activities does not fit well within even the Roberts Court’s capacious definition of executive power. Interim IGs therefore are good candidates for not only using the judicial appointment power over inferior officers but for making it exclusive as well. An interim IG law should protect that power by mandating that an appointment order be directed to the attorney general and the Justice Department and demanding their cooperation with the appointee. Violation of the order would be reported by the appointee, and the order would be enforceable by the usual court remedies, up to and including contempt.

Term appointments with cause removal

If the IGs challenging their removal had been protected from removal by a cause requirement, the district court likely would have granted reinstatement. Historically, Congress has protected the independence of federal officials by providing some form of cause requirement for their termination, usually coupled with a term appointment.⁴² Coupling a cause requirement with a fixed term limit balances independence with accountability and should be adopted for IGs. Assuming IGs are inferior officers, such a change should pass constitutional muster in most cases.

However, for independent agencies headed by boards or commissions whose members are themselves protected by a “cause” requirement, the Supreme Court has held that there cannot be a double layer of “cause” protection for their subordinates because it violates the separation of powers.⁴³ Ironically, if, as expected by many this term, it strikes down the cause protection for heads of independent agencies,⁴⁴ this problem will vanish. So long as IGs report to agency heads who are removable at will by the president, there should be no constitutional issue with giving them cause protection. If the Supreme Court upholds cause protection for independent agency heads, such protection will not be available to their IGs. The Court should decide the issue by July 1, 2026.

Terms for federal officials range from fourteen years for members of the Board of Governors of the Federal Reserve⁴⁵ to seven for members of the Federal Trade Commission⁴⁶ and five for other regulatory agencies such as the Securities and Exchange Commission.⁴⁷ For all of the agencies mentioned, member terms are staggered in addition to being fixed. A fixed term would serve the interests of both independence of the IG and continuity for the agency. Without staggering, the lower end of the range used for multimember boards would likely not maintain sufficient independence or continuity. At the same time, having long terms that are renewable diminishes accountability. Balancing these interests, this article recommends a single ten-year term for IGs to avoid having an unmanageable number of vacant positions during a presidential transition.

Conclusion

In this Congress, a bill proposed in the Senate to modernize the Privacy Act would also authorize injunctive relief and nonpecuniary damages while increasing criminal penalties.⁴⁸ A proposed amendment to the IG Act would disqualify a president’s political appointees from becoming IGs⁴⁹; another would add a cause requirement for IG dismissals except for independent agencies and create an IG for the Executive Office of the President.⁵⁰

A bill aimed at acting IGs would authorize an appellate judge to appoint an interim when there is no deputy eligible for automatic interim appointment under the VRA, and make clear that the judicial appointment is exclusive.⁵¹ The reforms advocated in this article could strengthen these proposals by ensuring that recently exposed gaps in the Privacy Act and IG Act are completely filled. Engaging with Congress to make them a reality could contribute significantly to resetting checks and balances for the protection of privacy and government oversight.

1. Madison, James, “Federalist No. 51” in The Federalist Papers, ed. Clinton Rossiter (New York: Signet Classic, 2003), 323.
2. Trump v. United States, 603 U.S. 593 (2024).
3. E.g., Seila Law, LLC v. Consumer Financial Protection Bureau, 591 U.S. 207 (2020).
4. Trump v. Casa, 606 U.S. 831 (2025).
5. 5 U.S.C. § 552a et seq.
6. Doe v. Chao, 540 U.S. 614 (2004).
7. E.g., Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011).
8. See “Overview of the Privacy Act: 2020 Edition, Criminal Penalties," Office of Privacy and Civil Liberties, Department of Justice.
9. See id., Agency Requirements.
10. See Privacy and data protection policies and procedures, 42 U.S.C. § 2000ee-2(d).
11. See Freedom of Information Act Response of Office of Inspector General, FFHFA to Democracy Forward (October 22, 2025).
12. The record of all proceedings is available under Supreme Court Docket No. 25A312 (docketed Sept. 18, 2025).
13. United States v. James, 2025 WL 3266931 (E.D. Va. Nov. 24, 2025).
14. United States v. James, Order (E.D. Va. Dec. 15, 2025).
15. See e.g., Ryan J. Reilly, Kristin Welker, Michael Kosnar, and Carol E. Lee, “The Adam Schiff Criminal Investigation Has Stalled, Sources Say,” NBC News, Oct. 23, 2025.
16. See “Document Shows DOJ Examining the Handling of Mortgage Fraud” investigation into Sen. Schiff, PBS News, November 20, 2025.
17. The case file in Swalwell v. Pulte et al.
18. Hon. Robert Garcia, letter to Hon. William Pulte, November 19, 2025.
19. Senator Elizabeth Warren et al., letter to Hon. Gene Dodaro, November 17, 2025.
20. A. Nicole Clowers, GAO, letter to Congressional Requestors, December 1, 2025.
21. Mark Paoletta, OMB General Counsel, letter to Edda Perez, GAO General Counsel, May 30, 2025.
22. E.g., GAO, Impoundment Control Act of 1974: Review of the President’s Special Message of June 3, 2025, B-337581 (June 17, 2025).
23. See Trump v. Casa, supra note 4.
24. See State of California et al. v. U.S. Dept of Agriculture, Case 25-CV-0631-MMC, Order Granting in Part Plaintiff States’ Motion to Enforce or Expand Preliminary Injunction (Feb. 26, 2026).
25. See Trump v. Casa, supra note 4, 601 U.S. at 868 (concurring opinion of Alito, J., joined by Thomas, J.).
26. See 26 U.S.C. § 7213, Unauthorized Disclosure of Information.
27. See 5 U.S.C. § 407.
28. See U.S. Senate Committee on the Judiciary, “Grassley, Durbin Seek Presidential Explanation for IG Dismissals,” Jan. 28, 2025.
29. See Council of the Inspectors General on Integrity and Efficiency (hereinafter “Council”), “Inspector General Vacancies.”
30. See Bob Bauer and Jack Goldsmith, “Inspector General Reform in the NDAA,” Lawfare (December 23, 2022).
31. See Storch v. Hegseth, Case 1:2025cv0415 (D.D.C.), Order Denying Plaintiffs’ Motion for Preliminary Injunction (Sept. 24, 2025.
32. See Council, supra note 29, “Inspectors General.”
33. See Council, supra note 29, “Mission.”
34. See Government Accountability Office, “FAQs on the Vacancies Act.”
35. 28 U.S.C. § 546.
36. District courts have invalidated interim U.S. attorney appointments under either and/or both laws in at least six cases. See e.g., U.S. v. James, supra note 14. The one appeal to have been decided to date upheld the district court’s invalidation of the appointment of the interim U.S. Attorney for the District of New Jersey. U.S. v. Giraud, 3rd Circuit No. 25-2635 (December 2025), rehearing denied, January 2026.
37. See Edmond v. United States, 520 U.S. 651 (1997).
38. See United States v. James, 2:25-cr-00122-JKW (E.D. Va.), Order and Opinion Dismissing Indictment at note 1 (November 24, 2025).
39. 5 U.S.C. § 403(a).
40. See 5 U.S.C. § 424.
41. See Anna Stolley Persky, “DOJ Fires U.S. Attorney Hours after Judges Appoint Him,” ABA Journal (Feb. 23, 2026). The same thing happened with the court-appointed interim U.S. Attorney for the Northern District of New York. See Jonah Bromwich, “US Attorney Chosen to Replace Trump Pick is Quickly Fired by White House,” New York Times (Feb. 11, 2026). In contrast, after losing its appeal of the New Jersey district court’s disqualification order, which was followed by the district court’s invalidation of a novel triumvirate structure for leadership, DOJ appears to have acquiesced in the March 23, 2006 court appointment of a new interim U.S. Attorney. See Matt Friedman and Ry Rivard, “Judges Appoint Career Prosecutor as New Jersey U.S. Attorney in Apparent End to Standoff,” Politico (March 23, 2026).
42. See Katy Bortz, “Humphrey’s Executor and Threats to Independent Government Agencies,” League of Women Voters (September 25, 2025).
43. See Free Enterprise Fund v. Public Company Oversight Board, 561 U.S. 477 (2010).
44. See Ballotpedia, “Trump v. Slaughter.”
45. See Board of Governors of the Federal Reserve System, “Board Members.”
46. See Federal Trade Commission, “Commissioners.”
47. See U.S. Securities and Exchange Commission, “SEC Commissioners.”
48. See Privacy Act Modernization Act of 2025, S. 1208, 119th Cong., 1st sess. 2025.
49. See Inspector General Independence Act, S. 3687, 119th Cong., 2d sess. 2026.
50. See Inspector General Act of 2025, H.R. 3735, 119th Cong., 1st sess. 2025.
51. See Independent Acting Inspector General Act of 2025, H.R. 4587, 119th Cong., 1st sess. 2025.