Project 2025 Tracker / What’s done, what’s next

26. Trade · Notable · Contested — excluded from counts

Bar U.S. pension funds from investing in Chinese stocks

Attempted

Printed page 789 26. Trade · from “The Case for Fair Trade”

“Prohibit U.S. pension funds from investing in Communist Chinese stocks.”

What has happened

  1. Attempted

    The Department of Labor's only ERISA fiduciary rulemaking in the window points the other way. RIN 1210-AC38, implementing EO 14330 on alternative assets, proposes that section 404(a)(1)(B) "does not require or restrict any specific type of designated investment alternative", gives fiduciaries "maximum discretion", and treats a foreign-adversary investment as off limits only where it is already illegal - an OFAC SDN listing or the Trading With the Enemy Act. Chinese stocks that are not sanctioned are not touched. Nineteen months after the memorandum told Labor to publish updated foreign-adversary fiduciary standards, this is what Labor published instead.

  2. Attempted

    Section 2(l)(iii) of the America First Investment Policy memorandum directs exactly this: restore "the highest fiduciary standards as required by [ERISA], seeking to ensure that foreign adversary companies are ineligible for pension plan contributions", and section 3(c) tells the Secretary of Labor to "publish updated fiduciary standards ... for investments in public market securities of foreign adversary companies". Section 2(j) adds that the review will consider restrictions on investment in publicly traded securities "from sources including pension funds, university endowments, and other limited-partner investors". Nothing has been published.

Research log

What was searched, and what didn’t count as evidence

Research notes

The second event is dated on a rule that is contrary to the ask rather than toward it, and is attached as Evidence in the frontmatter under the settled rule in playbook 3b: where the record moves the other way, the dated Primary source rides with the event rather than sitting in the body. The Status stays at attempted because the February 2025 directive stands and has not been withdrawn.

Federal thrift savings were checked separately: seventeen Federal Register documents mention the Thrift Savings Plan in the window, all of them Federal Retirement Thrift Investment Board housekeeping (loan reamortization, Roth in-plan conversions, breakage) and none about the international fund’s China exposure.

Action
restrict
Object
U.S. pension fund investment in Chinese stocks
ID
2082