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Amid a transition season of bruising battles between progressives and the old guard over Biden’s Cabinet picks, Merrick Garland for Attorney General was one choice that sparked relatively little controversy. Three months into Biden’s presidency, however, Garland is quickly shaping up to be the most consequentially bad Cabinet pick. On any number of important metrics — sweeping out holdovers from the Trump administration and reversing its positions, preventing corporate capture, and acting aggressively to advance the public interest — Garland is failing.

Under Otting and Brooks’ leadership, the OCC rolled out rules contrary to its responsibility to maintain a federal banking system that is safe against systemic risks and provides aid to all customers. Now they’re all out of power — but Acting Comptroller, Blake Paulson, whose ascent was ensured by Brooks and Mnuchin, has demonstrated no desire to change course from the path set by Trump’s lackeys. That is why Biden needs to act quickly and appoint a Comptroller who recognizes the dangerous precedent set by the Trump administration.

Since the passage of the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA) of 2005, the bankruptcy process has been more onerous for poor debtors, who now must go through myriad additional hoops to prove their worthiness for financial relief. While many of the problems with our current bankruptcy system require legislative fixes, there is one thing that President Biden can do immediately to improve the system: fire and replace the Director of the Executive Office for US Trustees, Clifford J White, III.

Last May, as the country first erupted into protests over George Floyd’s murder at the hands of Minneapolis police officer Derek Chauvin, Biden promised that he would deliver “real police reform” if elected president. The country’s eyes are on Minnesota again this week after a police officer in a Minneapolis suburb shot and killed Daunte Wright, sparking a new wave of protests. This time, Biden need no longer speak in hypotheticals; he is President. Will his administration deliver?

Darla Pomeroy, who is married to an heir to the DuPont family fortune, was just named Senior Advisor to the Office of Domestic Finance at the US Treasury. While her record does not show any familiarity with financial regulatory policy, it reveals instead a history of a powerful corporation highly influential in Delaware placing a close ally in the administration.

The Education Department controls almost every aspect of regulating for-profits, from certifying the accrediting agencies to the enforcement of student protections like the gainful employment rule and the borrower defense rule.

As the end of his first 100 days nears, Biden has signed into law COVID relief legislation, published his inaugural budget proposal, and begun rolling back some of the damage wrought by the Trump years. On the campaign trail, Biden rightfully described Trump as an “existential threat”.

The U.S. Treasury Department announced today that John Morton would be appointed as its first Climate “Counselor,” tasked with organizing financial-related climate work across the executive branch’s financial regulators.

Despite pushback from progressives, Ricchetti has continued to hold a powerful advisory position in the Biden White House. His background in corporate lobbying and strong ties to the pharmaceutical industry are deeply troubling signs as the Biden Administration faces enormously consequential decisions about how to end the COVID-19 pandemic.

It is relatively well known, for example, that the Internal Revenue Service has long suffered from under-investments in its budget. Less appreciated, however, are independent facets within the IRS which, rather than being primarily burdened by budget constraints, have simply been forgotten. One such facet is the IRS Oversight Board (IRSOB), which is supposed to provide guidance to the president on the IRS Commissioner and develop long-term strategic plans for the agency. The Board has lacked the five members necessary for a quorum since 2015.

The world is currently at an inflection point – Western leaders can choose to continue blocking the TRIPS waiver and lock in a cycle of dependence or empower poorer countries to develop generic vaccines and build infrastructure that will safely put the pandemic behind us. Critiques of the TRIPS waiver claim that most poor countries lack the infrastructure to carry out vaccine operations – a paternalistic view that suggests that manufacturing capacity, supply chain management, and logistics are static in nature. The sooner we act, the more time poorer countries have to begin mobilizing resources needed to make generic vaccine development possible.

On the campaign trail, Biden was reluctant to criticize any aspect of the “Obama-Biden” administration’s record. Since taking office, however, he has made perfectly clear that he is aware of, and has learned from, many of its mistakes. Having watched how an anemic stimulus package in 2009 delivered a slow, faltering recovery and political carnage, the Biden administration chose to go big with its economic response. This initial, consequential departure has earned Biden accolades and prompted a “growing narrative that he’s bolder and bigger-thinking than President Obama” (a narrative Biden reportedly loves). But while Biden may be surpassing Obama legislatively, he is lagging behind him when it comes to the pace of nominations, delaying policy implementation and preventing his administration from reaching its full potential.

With his nomination of Katherine Tai, who has advocated for a worker-centered trade policy, Biden demonstrated his commitment to transforming the trade agenda in the Democratic party. Unfortunately, his choice of Sarah Bianchi to serve as deputy USTR could undermine these efforts:

As police terror continues to claim the lives of Black Minnesotans, Biden must use all the tools at his disposal to root out police misconduct and deliver on his campaign promises of racial justice. U.S. Attorneys, the local face of the Department of Justice, will be an important institution to leverage. But the remains of Trump’s influence on these offices through acting officials and assistants could thwart the administration’s goals.

President Biden announced last month that he would nominate Todd Kim to be the top environmental lawyer at the Department of Justice. It was a relatively quiet announcement, devoid of much fanfare, compared to the position’s enormous potential to shape environmental and climate policy for years to come.