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Adjacent Markets Urges Clear Framework for Prediction Market Index Products
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WASHINGTON, June 17 -- Adjacent Markets, New York, has submitted a public comment letter to the U.S. Commodity Futures Trading Commission concerning the agency's Notice of Proposed Rulemaking on prediction markets and event contracts. The company emphasizes the need for clear and balanced public interest determinations for event contracts, warning that overly restrictive rules could hinder future innovation in this growing sector.
Adjacent Markets develops prediction market index and reference rate products based on CFTC-regulated event contracts, seeking to establish neutral, structured financial
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WASHINGTON, June 17 -- Adjacent Markets, New York, has submitted a public comment letter to the U.S. Commodity Futures Trading Commission concerning the agency's Notice of Proposed Rulemaking on prediction markets and event contracts. The company emphasizes the need for clear and balanced public interest determinations for event contracts, warning that overly restrictive rules could hinder future innovation in this growing sector.
Adjacent Markets develops prediction market index and reference rate products based on CFTC-regulated event contracts, seeking to establish neutral, structured financialproducts similar to established index providers in equities. The firm advocates for explicit recognition by the commission that political event contracts and related indices fall outside the scope of enumerated activities subject to restrictive regulation. By doing so, clarity would be provided that could encourage broader institutional adoption.
The company's letter stresses the importance of neutral third-party index providers who operate with transparent methodologies and governance standards. This approach aims to reduce manipulation risks like those seen in prior financial scandals. Adjacent Markets points out the value prediction market indices bring by enabling hedging of political and election-cycle risks, benefiting sectors sensitive to policy changes.
Adjacent Markets highlights its own RED and BLUE political indices as examples of structured, transparent products that aggregate market-implied probabilities without involving unlawful or enumerated activities. The firm further urges the commission to require prediction market exchanges to maintain transparency in contract listings and settlement schedules.
Additionally, the letter calls for guidance on contract listing standards, methodology publication, governance controls, and procedures for handling disruptions to protect market integrity. The company views these measures as vital to fostering trust among investors, policymakers, and the public.
Adjacent Markets offers to consult with the commission on establishing neutral third-party standards to support the maturation of prediction market products under a principled regulatory framework.
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Read full text of letter here: https://www.regulations.gov/comment/CFTC-2026-1189-0013
Abeona Therapeutics Requests Reconsideration of CMS Decision on ZEVASKYN Payment Approval
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WASHINGTON, June 17 -- Abeona Therapeutics Inc., New York, has submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare & Medicaid Services seeking reconsideration of the agency's preliminary determination regarding payment for ZEVASKYN, a gene therapy designed to treat wounds associated with recessive dystrophic epidermolysis bullosa. Abeona contends that the treatment meets all required criteria for the New Technology Add-On Payment, disputing the agency's view that ZEVASKYN does not demonstrate substantial clinical improvement despite acknowledging
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WASHINGTON, June 17 -- Abeona Therapeutics Inc., New York, has submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare & Medicaid Services seeking reconsideration of the agency's preliminary determination regarding payment for ZEVASKYN, a gene therapy designed to treat wounds associated with recessive dystrophic epidermolysis bullosa. Abeona contends that the treatment meets all required criteria for the New Technology Add-On Payment, disputing the agency's view that ZEVASKYN does not demonstrate substantial clinical improvement despite acknowledgingits fulfillment of the newness and cost conditions.
Abeona's application for NTAP concerns ZEVASKYN's unique ability to promote healing in large, chronic, non-healing wounds in RDEB patients-conditions that current alternatives reportedly do not adequately address. The therapy involves a one-time surgical application of genetically modified cellular sheets over extensive wound areas that surpass the size coverage of competitor treatments such as VYJUVEK and FILSUVEZ, which require ongoing weekly dosing. The company highlighted that ZEVASKYN covers up to 495 square centimeters per treatment, compared to a maximum of 200 square centimeters for VYJUVEK and variable limitations for FILSUVEZ, underscoring that this capacity constitutes a clinically meaningful advancement for patients with severe wound phenotypes.
The letter outlines differences in mechanisms of action among these therapies, emphasizing ZEVASKYN's gene correction via an integrating gamma retroviral vector that provides durable integration of the COL7A1 gene into the genome of treated cells. Unlike VYJUVEK's non-integrating viral vector and FILSUVEZ's tree-bark extract with a non-corrective mechanism, ZEVASKYN's engineering allows for persistent gene expression after a single treatment, negating the need for repeated dosing. Abeona argues that the agency's comparison of these treatments neglects the foundational scientific distinctions and ensuing clinical outcomes.
Furthermore, Abeona challenges CMS's skepticism about ZEVASKYN's efficacy in reducing pain and itch, symptoms that significantly affect patient quality of life. The company references data from its VIITAL phase 3 trial, where pain reduction was a co-primary endpoint and itch a secondary endpoint, demonstrating statistically significant improvements over control wounds at 24 weeks. In contrast, data for competitor therapies showed weaker or inconsistent benefit regarding these symptoms. The letter stresses that these effects contribute additional dimensions of clinical improvement beyond wound healing alone.
Regarding durability, the company refutes the agency's suggestion that potential needs for future treatments diminish ZEVASKYN's sustained benefit. It clarifies that patients returning for treatments address distinct, previously untreated wounds rather than re-treatment of healed sites. Long-term follow-up data support continued presence of therapeutic gene expression and biological markers of healing over multiple years, including reports of durable wound closure and restoration of skin structures.
Abeona also addresses CMS's inquiries about the timeline of ZEVASKYN's commercial availability, clarifying there was no unwarranted delay beyond June 15, 2025, following its FDA approval on April 28, 2025. The interval involved essential patient identification, healthcare provider training, and payer engagement necessary for proper therapy administration and patient access.
The company contests the requirement for comparative safety data directly against available therapies, noting that such evidentiary standards exceed those mandated for NTAP determinations under Code of Federal Regulations 42 CFR 412.87(b)(1)(iii). They emphasize that relevant regulations do not mandate head-to-head trials to demonstrate safety or clinical advance.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1256-0986
FGA Action Urges Administration for Children and Families to Finalize Rule Restoring Local Control Over Head Start Staff Wages
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WASHINGTON, June 17 -- FGA Action, a policy organization, has expressed support for the U.S. Department of Health and Human Services' Administration for Children and Families proposed rule to remove federally mandated staff wage and benefit requirements included in the 2024 final rule for the Head Start Program. In a public comment letter, FGA Action argues that the proposed rule appropriately returns compensation decisions to local programs, better aligns the program's Performance Standards with the Head Start Act, and protects enrollment opportunities for children and families served by the program.
The
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WASHINGTON, June 17 -- FGA Action, a policy organization, has expressed support for the U.S. Department of Health and Human Services' Administration for Children and Families proposed rule to remove federally mandated staff wage and benefit requirements included in the 2024 final rule for the Head Start Program. In a public comment letter, FGA Action argues that the proposed rule appropriately returns compensation decisions to local programs, better aligns the program's Performance Standards with the Head Start Act, and protects enrollment opportunities for children and families served by the program.
Theorganization contends that the 2024 rule misinterpreted the relevant statutory provision, 42 U.S.C. Sec. 9848(a), which sets an upper limit on compensation as the average local wage for comparable work and establishes a floor at the federal minimum wage, but does not authorize a federally imposed wage floor or require programs to match public preschool salaries. FGA Action maintains that the proposal corrects this by removing the mandatory salary scale and wage increase requirements, thereby restoring the flexibility Congress originally intended when it enacted the statute.
FGA Action highlights the diversity of labor markets and cost-of-living conditions across communities served by Head Start, stating that a uniform federal wage mandate risks undermining local program adaptability. The group notes ACF's estimates that full implementation of the 2024 wage and benefit rules without additional congressional funding could lead to the loss of approximately 106,000 funded enrollment slots by 2031, impacting low-income families reliant on Head Start services.
Additionally, workforce data indicate improved retention and reduced under-enrollment since the 2024 rule was finalized, despite the wage and benefit mandates not yet taking effect. FGA Action asserts this progress supports maintaining current flexibility rather than imposing costly federal requirements.
The organization also supports the proposed severability of wage and benefit rules, underscoring that the proposal offers local programs sufficient notice and options to manage compensation without compromising program access. FGA Action encourages ACF to finalize the rule as drafted to preserve local control and protect Head Start enrollment.
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Read full text of letter here: https://www.regulations.gov/comment/ACF-2026-0364-0253
Deep Fission Urges Modernization of NRC Licensing Guidance for Advanced Reactors
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WASHINGTON, June 17 -- Deep Fission, Berkeley, California, submitted a public comment letter to the U.S. Nuclear Regulatory Commission regarding the draft report entitled "Guidelines for Preparing and Reviewing Applications Under 10 CFR Part 57." The company commended the Commission's efforts to modernize regulatory review practices in alignment with the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024 and Executive Order 14300, which aims to reform the Nuclear Regulatory Commission's mission and culture.
In its letter, Deep Fission acknowledges the
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WASHINGTON, June 17 -- Deep Fission, Berkeley, California, submitted a public comment letter to the U.S. Nuclear Regulatory Commission regarding the draft report entitled "Guidelines for Preparing and Reviewing Applications Under 10 CFR Part 57." The company commended the Commission's efforts to modernize regulatory review practices in alignment with the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024 and Executive Order 14300, which aims to reform the Nuclear Regulatory Commission's mission and culture.
In its letter, Deep Fission acknowledges thetechnical expertise reflected in the draft guidance but critiques its underlying structure, which largely mirrors historic frameworks applied to conventional large light-water reactors (LWRs). According to the company, the guidance's focus on traditional safety topics may mislead reviewers into assessing areas irrelevant to advanced reactor safety assurance cases. Deep Fission's proposed approach emphasizes that a RIPB review should begin with high-level safety objectives followed by topic applicability determinations, thereby guiding reviewers to focus only on safety-significant items pertinent to the applicant's case.
Deep Fission referenced the Department of Energy's Reactor Pilot Program as an example of operationalized performance-based review frameworks. They highlighted DOE Standard STD-1271-2025, which applies four fundamental safety objectives-radioactive material confinement, nuclear reactivity control, fission and decay heat removal, and preservation of adequate radiation shielding-to evaluate safety assurance cases across diverse technologies. The company urges the Commission to integrate such high-level, technology-inclusive objectives into NRC reviews to move beyond prescriptive guidance.
The company also noted that the draft report does not address regulatory pathways for reactor designs previously authorized by the DOE or Department of Defense, as directed by Executive Order 14300. Deep Fission recommends leveraging prior federal authorizations by adopting presumptions of adequacy or focusing reviews on unresolved issues and new information to expedite licensing and avoid redundant evaluations. They incorporated by reference prior comments on rule language governing proven reactor reviews and interim guidance for regulatory staff.
Deep Fission further took issue with parts of NUREG-2271 related to accident consequence evaluation for sites with multiple independent reactors. The company expressed concern that the guidance's emphasis on plant-wide maximum hypothetical accident source terms could conflict with longstanding NRC policies separating independent and interconnected reactors and risk imposing regulatory penalties based solely on co-location. Deep Fission advocates aligning multi-unit accident evaluations with established approaches that avoid assuming material interdependence among independent reactors without evidence.
To advance a truly modern RIPB review framework under Part 57, Deep Fission suggested several recommendations: adding preliminary guidance that prioritizes applicability determinations before technical review; recognizing that some traditional review areas may not apply to certain designs; including an introductory chapter explaining the RIPB methodology; structuring each technical chapter to begin with applicability assessments; and employing an RIPB decision structure based on high-level safety objectives not only for Part 57 but also for previously authorized designs and staged licensing concepts under the Nuclear Energy Innovation and Modernization Act.
Deep Fission underscored that success for NUREG-2271 should be measured not by its breadth of guidance but by its ability to enable reviewers to reach safety findings efficiently through a fundamentally different decision-making framework suited to advanced reactors. The company concluded by affirming its commitment to collaborating with the Commission and NRC staff to promote regulatory and industry modernization consistent with legislative and executive mandates.
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Read full text of letter here: https://www.regulations.gov/comment/NRC-2025-0379-0124
Clearing House Urges Treasury to Modernize Federal Disbursement Systems
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WASHINGTON, June 17 -- The Clearing House Payments Co. LLC, New York, has submitted a public comment letter to the Bureau of the Fiscal Service of the U.S. Department of the Treasury in response to the agency's notice of proposed rulemaking focused on federal agency disbursement practices. As a key operator of the nation's payment system infrastructure, facilitating over $2 trillion in daily transactions, The Clearing House expressed support for Treasury's initiatives aimed at modernizing federal payments and reducing dependence on paper checks through enhanced electronic payment methods.
The
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WASHINGTON, June 17 -- The Clearing House Payments Co. LLC, New York, has submitted a public comment letter to the Bureau of the Fiscal Service of the U.S. Department of the Treasury in response to the agency's notice of proposed rulemaking focused on federal agency disbursement practices. As a key operator of the nation's payment system infrastructure, facilitating over $2 trillion in daily transactions, The Clearing House expressed support for Treasury's initiatives aimed at modernizing federal payments and reducing dependence on paper checks through enhanced electronic payment methods.
Theorganization highlighted the benefits of decreasing paper-based transactions, emphasizing reductions in fraud, operational inefficiencies, and related costs while strengthening the security and resiliency of federal disbursements. It recommended explicit recognition of "instant payment networks" within the definition of "electronic funds transfer" to promote real-time payment processing, transparency, and continuous operation around the clock. Instant payment systems, such as the RTP network operated by The Clearing House, offer advanced messaging capabilities that can improve reconciliation, fraud monitoring, and payment tracking, which are particularly valuable in emergency or urgent disbursement scenarios.
In its comments, The Clearing House also proposed broadening the scope of wire-transfer systems recognized in payment regulations to include private-sector networks like its CHIPS network, rather than limiting the definition solely to the Federal Reserve Banks' Fedwire Funds Service. This adjustment would better reflect the diversity and technological neutrality of the U.S. wholesale payment infrastructure and align with Treasury's modernization goals.
The Clearing House advised against operational models that rely solely on a single payment rail or operator, asserting that maintaining access to multiple payment systems operated by both private sector entities and the Federal Reserve would enhance resiliency and reduce risks related to concentration. The letter noted the importance of this approach in mitigating disruptions caused by cyber incidents, natural disasters, or surges in payment volumes. Treasury's recognition of the need for operational flexibility and redundancy in disaster and contingency situations was affirmed, with a call to maintain and potentially expand use of multiple payment infrastructures for automated clearing house (ACH), wire, and instant payments.
The organization underscored the role of a strong regulatory and supervisory framework when evaluating potential payment service providers, suggesting that robust oversight would contribute significantly to the resiliency and security of federal payment operations. Such oversight, it stated, should heavily influence Treasury's selection processes.
In addition to operational recommendations, The Clearing House offered detailed textual revisions to the proposed regulation, codified as part 208 under Title 31 of the Code of Federal Regulations, which governs federal payments. Among the suggested changes was to clarify the regulation's scope by expressly excluding tax-related payments made under the Internal Revenue Code from mandatory electronic disbursement while extending most other provisions to cover those payments more comprehensively.
The Clearing House's proposed regulatory refinements also included eliminating the specific reference to "Fedwire" in favor of the broader term "wire-transfer systems" to incorporate all relevant payment systems regardless of operator. The organization advised against embedding certain regulatory requirements within illustrative definitions, such as account requirements in part 210, recommending instead that such mandates be located in appropriate sections to avoid regulatory confusion.
Further recommendations sought to modify waiver provisions related to electronic payment mandates, defining specific situations in which paper check payments would be permissible without Treasury approval, such as hardship cases involving mental impairments or geographic limitations impacting electronic fund transfers, disaster payments, national security concerns, and payments to recipients on Indian lands lacking supporting infrastructure.
The Clearing House also endorsed procedures for agencies to request and manage waivers for payments not typically subject to electronic transfer requirements, highlighting the need for Treasury to retain authority to revoke waivers that lead to excessive reliance on non-electronic payment methods. This oversight would help uphold Treasury's objective of advancing electronic disbursement.
Additionally, the letter emphasized the importance of Treasury-sponsored accounts, like Direct Express and U.S. Debit Cards issued by designated financial agents, for facilitating electronic payments. The Clearing House advocated for ensuring these accounts meet consumer protection standards and remain accessible at reasonable costs.
On recipient responsibilities, the organization pointed out the need for agencies to establish processes enabling recipients to provide necessary information for electronic fund transfer payments to financial institution accounts, prepaid accounts, or Treasury-sponsored accounts. Agencies would also be expected to provide Treasury with relevant information concerning payment identifiers used in federal intragovernmental transfers.
The Clearing House called for vigilant Treasury monitoring of agency compliance with electronic payment regulations, including the tracking of enrollment efforts and waiver approvals or denials. It acknowledged Treasury's authority to assess charges on agencies when payments fail to comply with electronic funds transfer mandates, recognizing that such payments are processed more timely compared to paper checks.
The letter concluded with an affirmation of willingness to discuss the proposed regulatory revisions further and encouraged Treasury to weigh the importance of leveraging both private and public sector payment infrastructures. The Clearing House reinforced that such collaboration would promote a more resilient, efficient, and secure federal payment system that meets the needs of agencies and recipients alike.
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Read full text of letter here: https://www.regulations.gov/comment/FISCAL_FRDOC_0001-0294
Children Now Opposes Head Start Wage and Benefit Rule Rescission
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WASHINGTON, June 17 -- Children Now, a research, policy, and advocacy organization in Oakland, California, has expressed opposition to the U.S. Department of Health and Human Services' notice of proposed rulemaking titled "Restoring Flexibility to Support Head Start Program Access." The public comment letter from argues that the proposal to rescind current wage and benefit standards for Head Start educators jeopardizes the quality and stability of this essential early learning program serving children living in poverty.
The organization highlights that children enrolled in Head Start face numerous
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WASHINGTON, June 17 -- Children Now, a research, policy, and advocacy organization in Oakland, California, has expressed opposition to the U.S. Department of Health and Human Services' notice of proposed rulemaking titled "Restoring Flexibility to Support Head Start Program Access." The public comment letter from argues that the proposal to rescind current wage and benefit standards for Head Start educators jeopardizes the quality and stability of this essential early learning program serving children living in poverty.
The organization highlights that children enrolled in Head Start face numerouschallenges, including housing instability, food insecurity, and limited healthcare access, factors that shape brain development during critical early years. According to Children Now, maintaining stable, qualified teachers is key to fulfilling Head Start's promise to improve developmental outcomes, particularly given that children in these programs often come from the most economically and socially vulnerable circumstances.
Children Now points out that the proposed rule follows a series of federal actions that have destabilized Head Start funding and administration. They cite stagnant federal funding for multiple years, delayed grant competitions, and operational disruptions that have forced layoffs and hindered recruitment efforts. The commission overseeing Head Start is thus seen as responding ineffectively to workforce shortages by proposing to roll back compensation standards instead of increasing support.
The advocacy organization stresses that while educators have met rising expectations-for example, with three-quarters of lead teachers holding bachelor degrees-wages have failed to keep pace. Head Start lead teachers' average annual earnings have remained stagnant in real terms since 2013 and lag significantly behind salaries in comparable early education positions, especially in California, where cost of living pressures worsen retention problems.
Children Now underscores that turnover in Head Start classrooms undermines child development because the relationships formed between teachers and children are critical to social-emotional growth and school readiness. High turnover is thus not merely an administrative issue but a developmental concern impacting the most vulnerable children.
The letter asserts that rescinding wage standards will not alleviate workforce issues because labor market pressures remain unchanged, and removing the federal floor reduces visibility into compensation shortfalls. The organization calls on the agency and Congress to increase funding to support the existing workforce standards and protect program quality and access.
Additionally, Children Now warns against using deregulation as a substitute for funding, emphasizing that other program standards-such as mental health supports and safety protections-are essential to effective early learning. They urge withdrawal of the proposed rule and urge stable federal grant administration and tailored technical assistance for high-cost states facing workforce challenges.
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Read full text of letter here: https://www.regulations.gov/comment/ACF-2026-0364-0229
Banking Associations Urge Treasury to Expand Electronic Payments and Enhance Fraud Protections
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WASHINGTON, June 17 -- The Bank Policy Institute, the Clearing House Association and the Consumer Bankers Association jointly submitted a public comment letter to the U.S. Department of the Treasury Bureau of the Fiscal Service addressing proposed rulemaking on federal agency disbursements. The financial industry organizations expressed support for Treasury's proposed reductions in federal government payments made by paper check, emphasizing the importance of modernizing payment infrastructure to combat fraud and improve security for American taxpayers.
The associations highlighted that paper
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WASHINGTON, June 17 -- The Bank Policy Institute, the Clearing House Association and the Consumer Bankers Association jointly submitted a public comment letter to the U.S. Department of the Treasury Bureau of the Fiscal Service addressing proposed rulemaking on federal agency disbursements. The financial industry organizations expressed support for Treasury's proposed reductions in federal government payments made by paper check, emphasizing the importance of modernizing payment infrastructure to combat fraud and improve security for American taxpayers.
The associations highlighted that paperchecks remain vulnerable to fraud, citing data that in 2024, check fraud accounted for 32% of overall fraud losses. Treasury-issued checks are particularly targeted due to their distinctive mailing and the expedited availability of funds following deposit. The letter characterized the move toward electronic payments as crucial to reducing theft and losses to both the government and financial institutions.
While Section 208.3 of the proposed regulation mandates that federal payments be made electronically except under specific exceptions, the associations encouraged Treasury to broaden the use of private-sector payment networks alongside traditional Federal Reserve Bank systems. They recommended that Treasury explore payment platforms such as The Clearing House's Electronic Payments Network (EPN) and Real-Time Payments (RTP), as well as Early Warning Service's disbursements via Zelle, to provide alternative, resilient, and efficient payment rails that could mitigate service disruptions.
In addition to expanding payment methods, the groups advocated for Treasury to invest in advanced fraud detection and identity verification processes for government-issued electronic payments. They proposed enhanced use of identity document verification, biometric authentication, and multi-factor authentication such as FIDO passkeys to protect recipients' government benefit accounts accessed through portals like the Internal Revenue Service or Social Security Administration. The letter also stressed the need for prompt notification of suspected fraudulent payments to relevant agencies and law enforcement.
The letter addressed limitations posed by current regulations under the Expedited Funds Availability Act (EFAA) and Regulation CC that preclude exception holds on electronic payment deposits, recommending that Treasury encourage regulatory authorities to permit holds when there is reasonable suspicion of fraud. These changes would facilitate more effective fraud screening while maintaining payment system efficiency.
Regarding prepaid payment methods, the associations urged Treasury to advance safer distribution by provisioning funds directly to digital wallets authenticated to recipient identities. Given the widespread use of smartphones and digital wallets among consumers, this approach offers faster, more secure access than mailed physical prepaid cards, which remain vulnerable to theft and fraud. For mailed cards still issued, the letter called for strong digital authentication and secure card activation protocols minimizing reliance on publicly available information.
The comments concluded by recognizing Treasury's leadership in reducing paper check usage and the importance of continued collaboration between government and industry to enhance the security and efficiency of federal payments. The associations offered to further discuss their recommendations to aid Treasury's efforts to modernize the management of federal agency disbursements.
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Read full text of letter here: https://www.regulations.gov/comment/FISCAL_FRDOC_0001-0298
Black Child Development Institute of Ohio Opposes Proposed Rule to Weaken Head Start Workforce Protections
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WASHINGTON, June 17 -- The Black Child Development Institute, Beachwood, Ohio, submitted a public comment letter to the U.S. Department of Health and Human Services regarding the Office of Head Start's proposed rule, titled Restoring Flexibility To Support Head Start Program Access. The organization expressed opposition to the plan, highlighting concerns that loosening wage and benefit requirements will destabilize the Head Start workforce and diminish quality early education services for Black children and families.
The Institute emphasized that the Head Start program is essential for providing
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WASHINGTON, June 17 -- The Black Child Development Institute, Beachwood, Ohio, submitted a public comment letter to the U.S. Department of Health and Human Services regarding the Office of Head Start's proposed rule, titled Restoring Flexibility To Support Head Start Program Access. The organization expressed opposition to the plan, highlighting concerns that loosening wage and benefit requirements will destabilize the Head Start workforce and diminish quality early education services for Black children and families.
The Institute emphasized that the Head Start program is essential for providingcomprehensive supports including early learning, health screenings, nutritious meals, and family engagement opportunities, particularly for low-income Black families who disproportionately rely on these services. The letter detailed how the workforce provisions implemented in the 2024 rule sought to address long-standing challenges such as low wages, high staff turnover, and burnout, all of which undermine program quality.
Eliminating wage comparability requirements threatens to reverse improvements made to stabilize educator compensation and retention. The Institute pointed out that Head Start lead teachers earn significantly less than their Kindergarten counterparts despite similar qualifications, a disparity that contributes to recruitment difficulties. Weakening wage and benefit protections could lead to reduced staff numbers, larger ratios of children to teachers, and diminished care for children with special needs.
Further concerns addressed in the letter focused on the disproportionate impact on Black women, who constitute nearly 29% of the Head Start workforce. Lower wages and fewer benefits would exacerbate economic inequities and caregiving burdens within this community, thereby increasing turnover rates and disrupting the continuity of care vital for children's social-emotional growth and learning outcomes.
The comment letter also underscored that workforce instability negatively affects children's developmental environments by interrupting the trusted adult relationships that foster identity, confidence, and overall well-being. The proposed rule's attempts to "restore flexibility" were described as ignoring existing waiver options and shifting funding burdens onto local programs and educators rather than addressing chronic Head Start underfunding.
The Black Child Development Institute of Ohio urged the Administration for Children and Families to preserve the 2024 workforce provisions and withdraw the proposed rule to protect the stability and quality of Head Start services. The letter called for increased federal investments to improve recruitment, retention, and compensation, as well as centering the voices of those most affected by policy changes.
According to the organization, investments in the Head Start workforce are crucial for securing equitable early childhood outcomes, family stability, and the overall well-being of Black children served by the program.
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Read full text of letter here: https://www.regulations.gov/comment/ACF-2026-0364-0255
Arizona Early Childhood Alliance Urges Caution on Proposed Changes to Head Start Standards
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WASHINGTON, June 17 -- The Arizona Early Childhood Alliance, Phoenix, submitted a public comment letter to the U.S. Department of Health and Human Services Administration for Children and Families concerning the proposed rulemaking to remove wage and benefit requirements from Head Start Performance Standards. The alliance emphasized the importance of maintaining workforce quality to support positive outcomes for children served by the Head Start program.
The organization highlighted longstanding evidence showing that child development outcomes, including language, cognitive, and social-emotional
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WASHINGTON, June 17 -- The Arizona Early Childhood Alliance, Phoenix, submitted a public comment letter to the U.S. Department of Health and Human Services Administration for Children and Families concerning the proposed rulemaking to remove wage and benefit requirements from Head Start Performance Standards. The alliance emphasized the importance of maintaining workforce quality to support positive outcomes for children served by the Head Start program.
The organization highlighted longstanding evidence showing that child development outcomes, including language, cognitive, and social-emotionalgrowth, are linked to teacher qualifications, compensation, and workforce stability. The alliance pointed out that cutting personnel-related costs could undermine these positive impacts and weaken the program's core features, which include comprehensive support and family engagement.
Arizona's fiscal data was cited to illustrate challenges, showing underinvestment in early childhood education compared to K-12 funding, and persistent gaps in workforce development funding. The alliance stressed that local flexibility must be balanced with protections to avoid disparities, particularly in rural and high-poverty areas where recruitment and retention are more difficult.
While acknowledging fiscal pressures faced by grantees, the alliance urged ACF to ground final rules in research and data demonstrating the critical role of a well-supported workforce in fulfilling Head Start's mission to break cycles of poverty and ensure equitable early learning opportunities.
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Read full text of letter here: https://www.regulations.gov/comment/ACF-2026-0364-0257
Independent Community Bankers Urges OCC to Deny Payward National Trust Company's Charter Application
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WASHINGTON, June 17 -- The Independent Community Bankers has submitted a public comment letter urging the Office of the Comptroller of the Currency to deny the application filed by Payward Inc., Cheyenne, Wyoming, for a National Trust Bank Charter for its subsidiary, Payward National Trust Company. The application proposes that PNTC will primarily provide services related to digital assets, including custody services, staking support, trading activities, and collateral management.
ICBA contends that Payward's application fails to meet the statutory and regulatory requirements for a national bank
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WASHINGTON, June 17 -- The Independent Community Bankers has submitted a public comment letter urging the Office of the Comptroller of the Currency to deny the application filed by Payward Inc., Cheyenne, Wyoming, for a National Trust Bank Charter for its subsidiary, Payward National Trust Company. The application proposes that PNTC will primarily provide services related to digital assets, including custody services, staking support, trading activities, and collateral management.
ICBA contends that Payward's application fails to meet the statutory and regulatory requirements for a national bankcharter under the National Bank Act (NBA) and OCC regulations. The organization identified five core areas of concern that are individually sufficient grounds for denial: deficiencies in compliance and control functions, significant concentration risk, inappropriate affiliate transactions, lack of independent governance, and difficulties in ensuring an orderly resolution in the event of bank failure.
A fundamental legal issue cited by ICBA involves the OCC's reliance on Interpretive Letter 1176 (IL 1176) and the National Bank Chartering Rule to support the application. ICBA argues that IL 1176 was issued without the notice-and-comment procedures mandated by the Administrative Procedure Act (APA), rendering it legally invalid and depriving it of binding authority. The letter asserts that the OCC's reliance on this interpretive letter to permit PNTC to engage in activities beyond traditional fiduciary functions contradicts the provisions of the NBA and relevant court decisions, particularly a Third Circuit ruling that confines national trust banks to fiduciary activities authorized under 12 U.S.C. Sec. 92a.
Beyond procedural concerns, ICBA states that the publicly available record for the application lacks sufficient detail to allow meaningful public comment, citing that nearly all substantive documents, including the business plan, legal permissibility analysis, and compliance programs, are confidential. This opacity, ICBA argues, impairs the ability of stakeholders to assess whether PNTC's operations will be safe, sound, and lawful.
Regarding compliance and control functions, the letter emphasizes that PNTC would depend heavily on Payward's compliance infrastructure, which has previously exhibited failures. These include a 2022 $362,158 enforcement settlement with the U.S. Treasury's Office of Foreign Assets Control (OFAC) for violating sanctions against Iran due to inadequate transaction monitoring, and a 2023 $30 million settlement with the Securities and Exchange Commission (SEC) over unregistered crypto-asset staking services. ICBA expresses concerns that the application gives no public indication these material weaknesses have been remediated or that PNTC will effectively manage related risks.
ICBA also highlights the significant concentration risk facing PNTC as a single-sector bank focused entirely on volatile digital assets. The organization points out that PNTC would have no traditional banking business lines to mitigate downturns in the crypto market. The affiliation with Payward compounds this risk, as the parent's financial position, including a nearly 90 percent decline in adjusted EBITDA and delay of a planned Initial Public Offering in the first quarter of 2026, closely mirrors crypto asset price fluctuations. Consequently, Payward's ability to support PNTC during market stress would be limited precisely when assistance would be most needed.
The letter further critiques the application's dependence on complex and extensive affiliate transactions. PNTC's business model relies heavily on dealings with Payward affiliates for services related to trading, settlement, and staking. ICBA warns that the application fails to provide evidence that these transactions can comply with statutory limits on affiliate dealings or that conflicts of interest arising from such arrangements can be effectively managed. The lack of transparent market prices for these bespoke services raises additional challenges in ensuring compliance with federal affiliate transaction rules.
On governance, ICBA finds PNTC's proposed board insufficiently independent, noting that four out of six directors would be Payward insiders, including the proposed chief executive officer who also runs a major Payward institutional client division. This governance structure, ICBA argues, risks undue influence by the parent company and fails to meet OCC standards requiring objective oversight. Unlike other banks owned by bank holding companies subject to consolidated Federal Reserve supervision, PNTC would lack regulatory backstops on its parent, as Payward is not a bank holding company. Additionally, key management roles for compliance and risk are held simultaneously by individuals serving Payward affiliates, exacerbating potential conflicts.
Finally, ICBA describes significant challenges in the resolution and receivership of a failed uninsured crypto-asset custodian like PNTC. The OCC's established receivership framework, designed for trust banks with slower decline trajectories, is ill-suited to a fast-moving, highly volatile crypto asset business. Complex issues involving cryptographic key management, tracking customer assets in pooled blockchain addresses, and contingent claims on staked or collateralized assets would complicate receivership operations. The heavy reliance on Payward affiliates for essential services could further impair an orderly wind-down if those affiliates face concurrent distress.
The ICBA requests the OCC to deny the charter application or, alternatively, to release redacted versions of critical confidential materials, extend the public comment period, and hold a public hearing to thoroughly examine the legal, prudential, and public interest implications. The letter serves as a comprehensive challenge to the application's compliance with banking law and soundness standards, emphasizing risks to the national banking system, competitors, and consumers.
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Read full text of letter here: https://www.regulations.gov/comment/OCC-2026-0628-0003
American Council on Education Challenge Education Department on Foreign Gifts Disclosure Rules
Carter Struck
WASHINGTON, June 17 -- The American Council on Education has expressed concerns to the U.S. Department of Education Federal Student Aid office regarding proposed revisions to the foreign gifts and contracts disclosure requirements under Section 117 of the Higher Education Act. These associations emphasized that while compliance with national security obligations is critical, the department's current and proposed policies concerning donor information collection and public disclosure exceed statutory authority and pose constitutional issues.
The associations representing a broad spectrum of colleges
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WASHINGTON, June 17 -- The American Council on Education has expressed concerns to the U.S. Department of Education Federal Student Aid office regarding proposed revisions to the foreign gifts and contracts disclosure requirements under Section 117 of the Higher Education Act. These associations emphasized that while compliance with national security obligations is critical, the department's current and proposed policies concerning donor information collection and public disclosure exceed statutory authority and pose constitutional issues.
The associations representing a broad spectrum of collegesand universities nationwide noted that Section 117 mandates institutions to report foreign gifts and contracts to help mitigate risks of malign foreign influence and protect research security. They acknowledged the importance of national security initiatives, including the efforts underpinning National Security Presidential Memorandum 33 and prior executive orders aimed at bolstering transparency around foreign funding in American higher education. However, the coalition asserts that the department is overreaching in its detailed data collection and disclosure practices.
A central point of contention lies in the requirement for institutions to report the names of individual foreign donors and the department's intent to publish such sensitive personal information on a new foreign funding portal. The higher education community argues that this demand is unauthorized by the statute, which mandates reporting of aggregate financial data by donor country but does not explicitly require disclosure of individual donor identities. They maintain that this policy violates statutory limits, and invoking legal precedents, assert that such disclosure could infringe on First Amendment protections related to freedom of association and may expose donors to harm or retaliation.
The associations referenced notable Supreme Court rulings that restrict compelled disclosure of nonprofit donors, warning that publicizing donor identities could discourage legitimate contributions and chill support for academic institutions. They pointed to examples of political dissidents, advocates of democracy, and donors at risk of violence who could suffer severe consequences if their donations were made public. The groups urged the department to allow donor identities to remain confidential unless Congress enacts amended legislation explicitly authorizing such disclosure, and recommended that existing confidentiality provisions continue to be honored.
Concerns were also raised about a new certification requirement in which an individual submitting Section 117 reports must certify the institution's compliance with the law. The associations challenged this additional certification as unsupported by the governing statute and potentially creating undue personal liability for submitting officials. They called for removal of that clause from the final information collection request.
The department's updated foreign funding portal, launched in 2025 to increase transparency, was critiqued for its presentation of data which can be misleading without appropriate context. The associations highlighted issues such as the dashboard showing cumulative figures without annual breakdowns, outdated or inconsistent classification of donor countries, and conflation of legitimate funding with entities banned by U.S. authorities-potentially implying illegal or improper contributions. They urged improvements in user interface and data clarity to ensure the public and policymakers receive accurate and meaningful information.
Additionally, the higher education community flagged challenges related to the reporting workload and administrative expenses associated with Section 117 compliance. Surveys indicate substantial staff hours are dedicated annually by institutions in compiling and submitting disclosures, with potentially greater burdens on smaller colleges.
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The letter was signed by:
Ted Mitchell, President
On behalf of:
AAMC (Association of American Medical Colleges)
American Association of Colleges and Universities
American Association of Collegiate Registrars and Admissions
American Association of State Colleges and Universities
American Council on Education
Association of American Law Schools
Association of Jesuit Colleges and Universities
Association of Public and Land-Grant Universities
Career Education Colleges and Universities
Council for Advancement and Support of Education
Council of Graduate Schools
Council of Independent Colleges
EDUCAUSE
Hispanic Association of Colleges and Universities
NAFSA: Association of International Educators
National Association of College and University Business Officers
National Association of Independent Colleges and Universities
National Association of Student Financial Aid Administrators
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Read full text of letter here: https://www.regulations.gov/comment/ED-2026-SCC-1354-0006
