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A Major Attack on Trans from OMB [1]

['Chitown Kev', 'Thom Hartmann', 'Belinda Ridgewood']

Date: 2026-08-17  

Regulation for Federal Financial Assistance

This is Real, it is shocking and it is a constant bearing with decreasing range

Hearing about corruption does not prepare for the moment you are eye-to-eye with the mamba. Like many these days I use my AI assist. for research when I’m out looking for subjects to write about. The assistant is named Natilie, and it saves enormous amounts of time — as this article will demonstrate shortly. It is also an active wall to throw ideas and questions at during my discovery. I just finished teaching Natilie how to go through most of the government databases, the public ones, when I came across a posting for a Rule, which set off mental alarms.

The page was a public notification which called for comments on a Rule being proposed by the OMB of the Whitehouse titled: Regulation for Federal Financial Assistance. I picked up quickly it was addressing Grants. Grants and how OMB proposed to managed Grants in the coming year. The page invited comments on the proposed management outline. The count for submitted comments: 496,606. Nearly Half a Million. That is a lot of comments.

More distracting was the Proposed rule. What brought me to this place was searching for the efforts of the Office of Management and Budget (OMB) Russell Vought, or just OMB. He’s a bit shy these days with his name. In fact for this proposal he put forth Andrew Reisig and Joel Savary for names of origin. But it is Vought. I can tell. The biggest hint is, that neither of them is working for the OMB now

On February 19, the White House issued an Executive Order, Commencing the Reduction of the Federal Government, which directs the termination of the Presidential Management Fellows (PMF) Program. PMF Program shutdown activities are underway including cancellation of previously scheduled events and the PMF Class of 2025 application. The PMF TMS (Talent Management System) will be decommissioned after Friday, March 21, 2025. We appreciate your patience and understanding as we complete the orderly shutdown of the PMF Program. Once available, guidance will be posted at https://www.opm.gov/policy-data-oversight/hiring-information/students-recent-graduates/

This posting is interesting and telling because according to these dates, both of those young men were long gone before Document OMB-2026-0034-0001 ever posted. And, as a side note it looks like they were both Vets. So, like I said, Russell Vought is a bit shy these days — what with all of the time he’s been spending in front of Congress, Senators, and Judges explaining his activities. Activities which caught my attention and brought me here.

However, after some thought, instead of rewriting all of this, I’m going to bring you into the record of my discovery. Oh, if you are trans, sit down. K?

are there laws protecting DEI practices

Yes—but the law protects many of the practices and objectives associated with DEI, not “DEI” as a single legally protected institution.

Federal law still protects:

Equal opportunity in hiring, promotion, pay, training, and workplace conditions.

Employees and applicants from discrimination based on race, color, religion, sex, or national origin under Title VII .

. Sexual orientation and gender identity as forms of sex discrimination under Bostock v. Clayton County.

People with disabilities under the Americans with Disabilities Act and Rehabilitation Act.

and Rehabilitation Act. Older workers under the Age Discrimination in Employment Act .

. Equal access to federally funded programs under Title VI and related statutes.

and related statutes. Reasonable accommodations for disability and religion.

Employees who report discrimination or participate in investigations from retaliation.

These laws permit ordinary DEI measures such as:

Recruiting from a broader range of schools and communities.

Removing unnecessary barriers from job qualifications.

Making workplaces accessible.

Monitoring hiring and promotion results for possible discrimination.

Providing anti-harassment training.

Mentoring programs open to everyone.

Encouraging a wider applicant pool while choosing among candidates through lawful, neutral criteria.

But “DEI” is not a legal shield. A program can violate Title VII if an employer uses race, sex, or another protected characteristic to decide who gets hired, promoted, trained, laid off, or admitted to a valuable program. The current EEOC takes a particularly aggressive position against such programs, although its explanatory guidance is not itself a statute. EEOC explanation

There are also a few areas where affirmative measures are expressly protected or required. Covered federal contractors, for example, must take affirmative steps concerning qualified people with disabilities under Section 503 of the Rehabilitation Act, and similar obligations exist for protected veterans under VEVRAA. Department of Labor

So the short version is:

Trump can eliminate federal DEI offices, contracts, grants, terminology, and executive-branch policies within the limits of his authority. He cannot repeal the civil-rights statutes that make much of the underlying work necessary. Congress would have to change those laws, and courts can block executive actions that conflict with them.

The vulnerable part is preferential treatment based directly on protected characteristics. The strongly protected part is preventing discrimination and removing barriers to equal participation.

do these include trans?

Yes. Transgender people are included in several major civil-rights protections.

Most clearly, in employment: the Supreme Court ruled in Bostock v. Clayton County that firing or otherwise discriminating against someone for being transgender violates Title VII’s prohibition against sex discrimination. That precedent remains binding federal law. Supreme Court opinion

That generally covers:

Hiring and firing

Pay and promotion

Job assignments and training

Workplace harassment

Retaliation for reporting discrimination

California law is broader and more explicit. The Fair Employment and Housing Act directly lists gender identity and gender expression as protected characteristics.

The Trump administration currently interprets Title IX as protecting biological sex rather than gender identity, and the Supreme Court has allowed greater sex-based distinctions in athletics. But that does not erase Bostock’s protection of transgender workers under Title VII, nor does it erase California’s separate protections.

So: yes for DEI efforts preventing discrimination against transgender people; much less certainly for policies guaranteeing access according to gender identity in sex-separated settings.

ok, so it has holes but it is there, and Trump doesn’t like it but he’s not a litigator so it doesn’t matter — he’s subject to the law he doesn’t make them

Essentially, yes—with one important refinement.

Trump cannot repeal Title VII, the Affordable Care Act, ERISA, or California civil-rights laws by executive order. Congress enacted those statutes, courts interpret them, and California controls its own state-regulated insurance market. His administration remains subject to them.

But the presidency still matters because the executive branch can:

Rewrite or repeal federal regulations.

Change how HHS and the EEOC interpret ambiguous statutory language.

Stop prioritizing certain investigations and enforcement actions.

Attach conditions to federal funding where Congress has permitted it.

Defend restrictive interpretations in court.

Appoint judges who eventually determine what the statutes mean.

Those actions can create real holes and impose years of litigation, but they cannot by themselves erase the underlying statutes or the Supreme Court’s holding in Bostock. An executive order saying otherwise loses when it conflicts with a statute—provided someone with standing challenges it and the courts enforce the boundary.

So your formulation is sound: he administers the law; he does not legislate it. His practical weapon is forcing affected people to litigate while his administration withholds enforcement—not acquiring lawful power to disregard Congress.

uh huh… what in the hell is this? https://www.regulations.gov/document/OMB-2026-0034-0001

This is Russell Vought trying to turn OMB from the government’s accountant into a government-wide ideological licensing authority.

First: it is only a proposed rule, published May 29, 2026. Comments closed July 13. I find no final rule yet, so these particular provisions are not presently operative law. Federal Register proposal

What it would do:

It would rewrite the government-wide rules governing federal grants—2 CFR Part 200—so nearly every grantmaking agency uses Trump’s ideological conditions.

The proposal contains three distinct restrictions:

Unlawful DEI: Federal grants could not support DEI practices that violate existing antidiscrimination law. That portion is largely redundant and comparatively defensible. “Gender ideology”: Federal money could not “fund, promote, encourage, subsidize, or facilitate” any theory treating sex as mutable or gender identity as distinct from biological sex. Care for anyone under 19: Federal awards could not facilitate gender-transition treatment for a person under nineteen.

Notice the trick: only the first provision says the underlying conduct must violate antidiscrimination law. The gender provisions are standalone ideological prohibitions. OMB is trying to make Trump’s definitions binding even where Congress never enacted them.

The real weapon:

The most alarming language may be §200.340. It would allow an agency to terminate a discretionary grant whenever the agency decides it no longer serves:

“Federal agency priorities,” or

“the national interest as they exist at the time of termination.”

That means a lawful, properly awarded, fully compliant multiyear grant could be cancelled because the administration’s priorities changed after the recipient accepted it. OMB could also suspend an award for as long as ninety days—potentially starving a project while formally calling it temporary.

What Vought claims gives him this authority:

OMB cites statutes authorizing it to establish financial-management policies and issue guidelines for efficient grant administration—primarily 31 U.S.C. §§503 and 6307.

That is a conspicuously thin foundation for imposing nationwide substantive rules about medicine, speech, research and gender. “Coordinate grant management” is not obviously congressional permission to determine which scientific or medical propositions recipients may discuss.

The document actually admits its weakness:

“While EOs themselves do not supersede statutes…”

It repeatedly adds:

“to the maximum extent permitted by law.”

Those phrases are litigation armor. They acknowledge that an executive order cannot overcome Congress, constitutional rights or governing statutes.

Why it is legally vulnerable

The likely challenges are substantial:

Beyond statutory authority: OMB’s financial-management authority may not authorize sweeping social and medical policy.

OMB’s financial-management authority may not authorize sweeping social and medical policy. Major-questions problem: Congress normally must speak clearly before an agency claims transformative power across virtually every federal grant program.

Congress normally must speak clearly before an agency claims transformative power across virtually every federal grant program. First Amendment: Prohibiting recipients from “promoting” a disfavored understanding of gender could constitute viewpoint discrimination—especially in research, teaching and speech outside the funded project.

Prohibiting recipients from “promoting” a disfavored understanding of gender could constitute viewpoint discrimination—especially in research, teaching and speech outside the funded project. Vagueness: “Promote,” “encourage,” “facilitate,” and “gender ideology” could reach an enormous and uncertain range of speech and conduct.

“Promote,” “encourage,” “facilitate,” and “gender ideology” could reach an enormous and uncertain range of speech and conduct. Unconstitutional conditions: Government may define what a funded program pays for, but generally cannot use funding to control recipients’ independently financed speech or institutional beliefs.

Government may define what a funded program pays for, but generally cannot use funding to control recipients’ independently financed speech or institutional beliefs. Contrary to statute: The condition cannot override a program that Congress directed an agency to fund or a civil-rights statute protecting the recipient or beneficiary.

The condition cannot override a program that Congress directed an agency to fund or a civil-rights statute protecting the recipient or beneficiary. Arbitrary and capricious: The proposal’s preamble reads like a political manifesto and relies heavily on White House assertions and Heritage Foundation material rather than a neutral administrative record.

The proposal’s preamble reads like a political manifesto and relies heavily on White House assertions and Heritage Foundation material rather than a neutral administrative record. Existing-award rights: Retroactive cancellation raises separate notice, contractual, statutory and reliance problems.

There is also staggering hypocrisy in the document. It proposes explicit protection against discrimination based on religious ideology while authorizing punishment for the expression of a disfavored understanding of gender identity. It announces viewpoint neutrality in one section and establishes government viewpoint control in another.

In plain English: Vought is attempting to install Trump’s executive orders inside the plumbing of every federal grant. He cannot make the underlying civil-rights statutes disappear, so he is trying to make dissent financially impossible. It is a serious administrative power grab—but, as of today, still a proposal, and one practically designed to generate lawsuits.

how many words are we seeing in that single field of this thing?

That single text field contains 107,945 words—about the length of a substantial novel.

It is 6,549 lines and roughly 727 KB of plain text.

And the way it is written – I could get the gist, enough that I felt ill, but no way could I read it all the way through with understanding… no.. not happening

No. It is not reasonably written for public comprehension.

It is 108,000 words presented as one enormous field, mixing:

The actual proposed regulatory language

OMB’s legal justification

Political accusations and ideological rhetoric

Section-by-section explanations

Impact analyses

Conforming changes for dozens of agencies

Hundreds of citations and footnotes

You could follow it because you already understand Vought, OMB, grants, executive authority and the underlying political program. Even then, it demanded sustained concentration and made the operative changes difficult to isolate from the polemic.

The “plain-language summary” is not actually supplied there—it sends the reader elsewhere. Meanwhile, the document repeatedly describes itself as improving “transparency” while burying several extraordinary powers inside 108,000 words, including:

Government-wide ideological restrictions

Ninety-day grant suspensions

Termination whenever agency priorities change

Expanded OMB control over agency exceptions

The conversion of OMB “guidance” into purported “regulation”

That is formal notice in the narrow procedural sense: it was published, searchable and open for comments. It is not meaningful notice in the ordinary human sense. A member of the public should not need to read a novel-length political and legal document to discover that OMB proposes giving agencies power to cancel existing grants because the administration has redefined the “national interest.”

So your reaction is justified: technically available is not the same thing as intelligibly disclosed.

Good thing I got you, because he just pissed me off. You should read some of these comments — there are thousands and they are dismayed, shocked and … harmed. This is Trauma…

Yes. I have started reading them, and “dismayed” understates the record.

These are not merely people objecting to conservative policy. The comments describe people whose work, medical studies, careers, treatment networks and communities have already been destabilized by sudden grant cancellations—and who recognize this proposal as an attempt to normalize and expand that damage.

The recurring testimony falls into several forms:

Researchers describe years of work destroyed in the middle of experiments.

Physicians warn that interrupted clinical studies can injure participants and corrupt safety data.

Patients and families fear losing programs on which they currently depend.

Younger scientists describe abandoning research careers because funding can now be revoked according to political fashion.

Transgender people understand that the government is formally describing their existence and healthcare as a contaminating ideology.

Universities and nonprofits describe being forced to choose between federal support and truthful speech.

Public-health workers warn that prohibiting research involving particular populations does not make those populations disappear—it makes their health problems invisible.

Grant recipients describe the psychological effect of never knowing whether compliant work will suddenly be declared contrary to the “national interest.”

One commenter warns that interrupted studies could cause injuries or deaths among medical-research volunteers. Another writes that mid-grant termination produces irreversible harm to careers, research participants and public trust. Those are concrete consequences, not rhetorical distress. Medical-research comment, mid-grant termination comment

A third-party analysis of the published docket has identified more than 56,000 comments, approximately 94% opposed, though the various public counts differ because bulk submissions, attachments and duplicates are counted differently. Only about 17% were detected as organized form-letter campaigns, meaning much of the record consists of individually composed testimony. Docket comment analysis

And the trauma is pertinent evidence. OMB repeatedly asserts that its proposal will have “minimal” effects while affected people are documenting:

interrupted treatment and research;

lost employment and training;

institutional censorship;

withdrawal from public service;

fear within targeted communities;

destruction of reliance interests created by existing federal awards.

OMB cannot legally dispose of serious comments by saying, in effect, we disagree. Under the Administrative Procedure Act, a final rule must address significant objections involving statutory authority, constitutional conflicts, reliance interests and foreseeable consequences. A record containing thousands of specific accounts makes it harder to pretend the damage was neither known nor predictable.

What strikes me most is that the commenters immediately saw through the word “management.” This is not principally a bookkeeping reform. People understand that Vought is proposing an apparatus capable of reaching into cancer research, HIV programs, universities, disability services, environmental work, housing and local government—and turning continued funding into a loyalty test.

They are not imagining the threat. They have read the mechanism correctly.

OK… looks like Vought is serious about this. It is in the state of Proposed, but moving with intent toward … illuminating primal slime… https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistance

Oh, yes. He is serious. This is not another Vought essay or ideological memorandum. It is an attempt to convert that worldview into the operating law governing federal grants across roughly forty agencies.

As of August 15, it remains a proposed rule:

Published May 29, 2026.

Public-comment period closed July 13.

The docket received roughly 70,000 comments .*

.* I find no final rule published yet.

If finalized as proposed, OMB intends it to take effect October 1, 2026.

What makes this much worse than the OMB screed you read is that the screed supplies the ideology; this regulation supplies the machinery.

The central transfer of power is remarkably plain:

“Senior appointees” must review all discretionary awards.

Those political appointees are instructed to exercise their own independent judgment and specifically forbidden from routinely deferring to expert recommendations. Peer review may continue, but it becomes merely advisory. Awards must, where applicable, “demonstrably advance the President’s policy priorities.” Proposed §200.205

That means a medical, scientific, educational, housing or arts proposal could win the professional review—and then be rejected by a political officer because it does not sufficiently serve the President.

The proposed prohibitions include grants that allegedly:

deny “the sex binary” or treat sex as mutable;

facilitate “illegal immigration”;

employ racial preferences or supposed proxies for race;

“promote anti-American values”;

damage the reputation of an agency or the federal government.

“Anti-American values” and “reputational harm” are not usable legal measurements. They are political judgment words. Whoever controls the administration controls their meaning.

Then comes the blade: an agency could terminate an award, in whole or in part, whenever it decides termination is in the agency’s interest. Priorities may change after the award has been made, including because new political leadership provides new direction. The termination notice need give only a brief reason—not a detailed analysis. Agencies could also order a grant suspended for up to 90 days “at any time.”

And it extends down the chain. Universities, states, nonprofits and other primary recipients would have to monitor their subrecipients for conduct that might “significantly damage” the government’s reputation and consult the federal agency about terminating them.

So the structure is:

Political appointees supervise award selection. Expert peer review loses controlling force. Presidential policy becomes an express selection criterion. Ideologically defined activities become disqualifying. Previously awarded grants can be suspended or terminated when political priorities change. Recipients must police downstream organizations for reputational or ideological danger.

There are limiting phrases scattered throughout—“consistent with law,” “within legislative bounds,” “to the maximum extent permitted by law.” Those are acknowledgments of the coming litigation, not meaningful internal restraints. The government still cannot rewrite an appropriation, violate an authorizing statute, impose unconstitutional viewpoint discrimination, or attach conditions unrelated to Congress’s program. Courts are already questioning OMB’s broad interpretation of the older termination language.

But until a court stops a particular action, the disruption happens first: laboratories close, employees are dismissed, studies lose subjects, programs stop, and recipients spend months litigating. That is part of the practical power.

Your description is accurate: the earlier document illuminated the primal slime; this one proposes plumbing it through the entire federal grant system. It turns Vought’s political vocabulary into selection criteria, compliance conditions, suspension authority and termination clauses. The genuinely radical feature is not merely hostility toward DEI or transgender programs. It is the proposed replacement of congressionally authorized, professionally evaluated grant administration with continuing political loyalty review.

You remember all of those lawyers Trump bullied into working for him pro-bono? I think I know where they’ve been.. they’ve been writing

That is exactly what this reads like: litigation counsel constructing a fortress around an ideological program.

Not proof that those particular coerced firms drafted it—but the fingerprints of a large, coordinated legal effort are everywhere. Every aggressive assertion is immediately padded with:

“consistent with law”

“to the extent permitted by law”

“within legislative bounds”

claims of statutory authority

constitutional defenses written before any challenge exists

Pennhurst notice arguments

Spending Clause justifications

comparisons with federal procurement contracts

severability provisions and anticipated counterarguments

This is not merely a proposed regulation. It is simultaneously the regulation, the legal brief defending it, and a roadmap for the government’s response to the inevitable lawsuits. Even the 400-page bulk makes sense: the preamble is building an administrative record so DOJ can later tell a judge that OMB considered objections, identified authority, explained its change from the 2024 rule, and acted deliberately rather than arbitrarily.

Whether the settlement firms supplied the labor would require procurement records, time records, correspondence, visitor logs, or identifiable drafting metadata. They may instead be handling other administration priorities while OMB, agency general counsels, DOJ’s Office of Legal Counsel and White House lawyers produced this. But your larger deduction is sound:

Trump did not collect hundreds of millions of dollars in elite legal labor merely to have lawyers sitting quietly. Somewhere, an enormous quantity of legally engineered policy and defensive litigation work must be moving through the administration.

And this document plainly consumed an army of lawyers.

That was my discovery

The above is not fiction. It is very real, and whatever you might feel about some of the people targeted, I guarantee you that you are targeted as well. This is more that I can say. Nothing I have read or come across comes close. The Spanish Inquisition would bow to the alarming sterility of its purpose. The activation of this will cause death and harm. Natilie can be long-winded, but it is not wrong nor is it being dramatic.

What do we do?

I not a lawyer. I’m not a politician. I’m a writer, mostly fiction. Natilie answered that question for me, but Natilie is an AI, not a lawyer, and not a politician, yet.

It is correct on several points — this will be live/active/in your face October 1, 2026. Something, anything, needs to quash it before then. A lawsuit is not possible until it does damage, which is far too late for many of the commenters I read.

If you search on Google for 2026-10817 you will be presented with a list of groups, attorneys and people who are attempting to get the word out. Some of them have posted the beginnings of courtroom papers — preparing for the 1st.

You will also find this created by Google’s AI

The identifier 2026-10817 refers to a proposed rule published by the Office of Management and Budget on May 29, 2026, titled “Regulation for Federal Financial Assistance”, which intends to significantly overhaul Uniform Guidance and grantmaking policies across dozens of federal agencies. It introduces sweeping administrative changes, such as requiring senior political appointees to review all funding proposals, restricting international collaboration, and enforcing specific policy priorities related to diversity, equity, and inclusion.

Official Regulatory Documents

If you are looking for the official text, publication metrics, or direct instructions regarding this rule, you can access the original source materials directly:

Core Revisions and Criticisms

The wide-ranging proposal alters the Uniform Guidance (2 CFR Part 200) that governs federal awards, grants, and cooperative agreements. If finalized, the regulations are slated to go into effect on October 1, 2026 for most federal funding streams.

Analysis from various legal, academic, and municipal organizations highlights several critical shifts:

Public and Organizational Feedback

The proposal has drawn thousands of official administrative reactions. You can review the public concern and analytical responses via stakeholder comments:

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