Biden Administration Foreign Policy Tracker: September

Welcome back to the Biden Administration Foreign Policy Tracker. Once a month, we ask FDD’s experts and scholars to assess the administration’s foreign policy. They provide trendlines of very positive, positive, neutral, negative, or very negative for the areas they watch.

As August drew to a close, Washington and Tehran were nearing a nuclear agreement that imposes even fewer constraints than the 2015 deal with Iran. The White House pushed ahead with the nuclear negotiations even as the Justice Department revealed an Iranian plot to assassinate former U.S. National Security Advisor John Bolton. Meanwhile, one of Tehran’s Iraqi proxy forces employed Iranian-provided drones to attack U.S. troops in eastern Syria. Tehran also continues to stonewall inspectors from the International Atomic Energy Agency (IAEA), who are investigating the presence of nuclear materials the clerical regime failed to disclose despite a binding obligation to do so under the Nuclear Non-Proliferation Treaty. The Biden administration’s determination to ignore Iran’s signs of bad faith suggests the White House may accept a nuclear deal based more on trust than on verification.

Will the Biden administration insist that Tehran address these concerns, or will it press the IAEA to stand down, as the Obama administration did to protect the original nuclear deal in 2015? Will President Joe Biden accept a deal that renders military sites off-limits to inspectors, like the original agreement? Come back next month to see if the White House was able to push the deal over the finish line, and whether the cost of doing so was trusting Tehran to honor its promises.

Previous Trend: Negative

U.S.-China relations deteriorated further after Beijing overreacted to House Speaker Nancy Pelosi’s decision to meet in Taipei with Taiwanese President Tsai Ing-wen. For the first time on record, China’s military conducted simulated attacks on Taiwan using the actual airspace and territorial waters where such an attack would likely originate during a conflict. These maneuvers revealed just how far China’s military capabilities have advanced since the 1996 Taiwan missile crisis, when U.S. forces outmatched the People’s Liberation Army. Presently, there is no indication that an invasion of Taiwan is imminent or that China has accelerated its reunification timetable. Nevertheless, the intelligence and lessons learned from this latest episode will pay major dividends for China as it seeks to coerce Taiwan into accepting that the path to “peace and prosperity” runs through Beijing, not Washington. Less clear is whether the Biden administration intends to leverage China’s belligerence to advocate for a stronger U.S. military presence in the Indo-Pacific, with the goal of shifting the balance of power back against Beijing.

This latest crisis is occurring as Chinese leaders grapple with China’s rapid economic slowdown — a development that risks undermining the Chinese Communist Party’s legitimacy mere months before Xi Jinping is expected to secure a third term as general secretary. A meeting between Xi and President Biden during the upcoming G-20 summit in Bali could provide an opportunity to de-escalate great-power tensions, although the two leaders will almost certainly remain at loggerheads over Taiwan.

Previous Trend: Positive

The Biden administration undertook a number of actions intended to implement a comprehensive approach to strengthening America’s cyber resilience.

On August 9, President Biden signed the CHIPS and Science Act into law, a $280 billion bipartisan package and the first step toward transforming U.S. competitiveness by reducing America’s reliance on foreign semiconductor supply chains. The bipartisan bill provides $52.7 billion over the next five years for domestic chipmakers, boosting semiconductor research and development, manufacturing, and workforce development. It also includes a significant plus-up in non-military investment in basic research and development.

In an effort to curb ransomware attacks, the State Department announced a $10 million reward for information on the Conti ransomware group, a Russian cybercriminal gang responsible for targeting over a thousand organizations last year alone.

The Treasury Department’s Office of Foreign Assets Control sanctioned Tornado Cash, a virtual currency mixer allegedly used to launder more than $7 billion since 2019. Tornado Cash is the second virtual currency mixer under U.S. sanctions, joining Blender.io, which Treasury sanctioned in May.

U.S. Cyber Command announced the culmination of its first “hunt forward” mission deployed to Croatia, establishing new partnerships and gaining new insights into malicious activities. With less than 70 days ahead of the midterm elections, such missions should aid in defending the U.S. electoral system from foreign interference and influence.

Looking ahead, the administration is expected to release its new National Cyber Strategy, developed by the Office of the National Cyber Director, by the end of September.

Previous Trend: Neutral

The Department of Defense (DoD) announced on August 24 approximately $3 billion in additional security assistance for Kyiv under the Ukraine Security Assistance Initiative (USAI). Among other capabilities, Ukraine will eventually receive six additional National Advanced Surface-to-Air Missile Systems (NASAMS), bringing the total to eight. Unfortunately, many of these USAI capabilities will not arrive for some time, as they first must be produced.

On August 8, the DoD announced a $1 billion package of security assistance for Ukraine, utilizing what is known as Presidential Drawdown Authority. This authority permits the Pentagon to quickly deliver equipment directly from DoD stocks. The $1 billion package represented the largest single drawdown of U.S. arms and equipment using this authority and was followed by a $775 million drawdown on August 19.

Despite this robust support for Ukraine, the administration has refused to provide Kyiv with the Army Tactical Missile System (ATACMS), fearing it could invite Russian escalation. President Vladimir Putin likely welcomes that restraint, as the ATACMS would allow Kyiv to strike key logistics nodes and other high-value targets beyond the range of Ukraine’s current precision-strike capabilities.

Secretary of Defense Lloyd Austin spoke twice in August with Israeli Minister of Defense Benny Gantz. On August 5, they discussed Israel’s conflict with Palestinian Islamic Jihad, a terrorist proxy of Tehran. On August 16, Austin “reiterated that the U.S. commitment to Israel’s security remains ironclad,” according to a Pentagon readout of the call. Gantz may have left that call with questions as the administration simultaneously seeks to finalize a deeply flawed nuclear deal with the Islamic Republic of Iran.

Previous Trend: Neutral

The Biden administration continued pursuing a plan to cap the per-barrel price of Russian oil exports, aiming to choke off the Kremlin’s key financial lifeline while avoiding a further spike in oil prices. The Treasury Department is warning that the price-cap mechanism must be implemented before year’s end, when an EU ban on most Russian oil imports as well as services facilitating Russian oil shipments will take effect, potentially roiling oil markets. U.S. officials continued their outreach to key partners such as India and Germany in an effort to secure buy-in. On Friday, Treasury Secretary Janet Yellen and her G7 counterparts reportedly will officially endorse the plan and promise to hash out the remaining details, although many European allies — not to mention India and China — remain skeptical.

On August 9–10, Secretary of Defense Lloyd Austin visited Latvia, where he met with his counterpart and the country’s president and prime minister. Fearing Russian aggression, Riga and other allies on NATO’s eastern flank are pressing for more U.S. troops, training, and weapons. In particular, they hope the United States will accelerate fulfillment of existing orders for American weaponry. Austin, the first sitting U.S. secretary of defense to visit Latvia in nearly three decades, stressed U.S. plans, announced in June, to “enhance our rotational deployments in the region and intensify our training with our Baltic allies.” The Latvian Defense Ministry said in late July that U.S. military officials would provide advice on a new training facility and military base Riga is set to build.

Previous Trend: Negative

President Biden praised Qatar for being one of three Arab countries that helped bring to an end a short round of clashes between Israel and Palestinian Islamic Jihad in Gaza in early August. Biden, however, failed to call Doha out for the role its state-controlled media — especially the Al Jazeera network — play in stoking hatred of Israel and Jews.

Qatar’s double dealing put its Foreign Ministry’s spokesperson, Majed al-Ansari, in an awkward position when he went on Al Jazeera to boast about his country’s mediation role, only to find himself forced to admit — live on air — that Qatar’s diplomacy included talking to Israel, an act that Al Jazeera routinely describes as being shameful and anathema.

Biden was right to praise Egypt and Jordan — countries that enjoy peaceful ties with Israel — for helping to end the clashes in Gaza. Yet there is no reason to commend Qatar, which funds Hamas and dozens of antisemitic organizations around the world.

Recognition by the U.S. president should be reserved for America’s allies who play constructive roles in global affairs, not ones who speak from both sides of their mouths.

Previous Trend:  Positive

As U.S.-China tensions escalated over Taiwan, regional reactions were decidedly mixed. As expected, Japan and Australia joined the United States in calling on Beijing to “immediately cease its military exercises” around Taiwan, while at the same time reaffirming their commitments to their “respective one China policies.” New Delhi chose not to sign the Australia-Japan-U.S. statement even though India is a part of the Quadrilateral Security Dialogue, or Quad, whose unofficial purpose is to counter China’s malign influence. While ASEAN member states Indonesia, Singapore, Vietnam, Malaysia, Thailand, and Cambodia all released individual statements about the crisis, none expressed support for Taiwan. Pakistan, Bangladesh, Maldives, Nepal, and Sri Lanka all conveyed similar sentiments. Troublingly, only one of Taiwan’s four remaining diplomatic partners in the region — the Marshall Islands — expressed support for Taiwan, while the remaining three — Nauru, Palau, and Tuvalu — all stayed silent.

All told, the Biden administration’s nascent Indo-Pacific strategy, principally aimed at undercutting Beijing’s regional influence, appears to be falling flat. The administration urgently needs to re-examine the reasons why so many countries in the region, friends and foes alike, chose to side with Beijing over Taipei. Chief among those reasons is China’s deepening economic ties across Southeast Asia. This reassessment of Indo-Pacific diplomacy should be incorporated into the White House’s long-delayed National Security Strategy, which is reportedly being rewritten to emphasize Russia alongside China following Moscow’s invasion of Ukraine.

Previous Trend: Very Negative

In late July, the administration condemned blatantly antisemitic remarks by Miloon Kothari, one of three members of the UN Human Rights Council’s Commission of Inquiry into Israel. Yet the Biden administration still has not signaled whether it will introduce a resolution to terminate the commission’s mandate when the council reconvenes in September.

Relatedly, the administration has yet to signal its preferred candidate to replace UN High Commissioner for Human Rights Michelle Bachelet, who is stepping down following criticism of her recent visit to China, during which she echoed Beijing’s false claims about the treatment of its Uyghur minority. Bachelet’s departure creates an opening to appoint a successor who will hold China accountable for abuses while getting rid of the double standard applied to Israel.

Separately, the Biden administration may be quietly expanding a diplomatic campaign to defeat a Russian candidate for the top post at the International Telecommunication Union (ITU). Unlike the more public campaign to strip Russia of membership in the Human Rights Council, the administration has been silent on the upcoming ITU election despite Chinese and Russian ambitions to dominate the body and its standards-making organs.

Finally, despite ongoing Iranian terror plots to kill Americans, including former White House officials and Iranian dissidents, the Biden administration will reportedly issue visas to Iranian President Ebrahim Raisi and his delegation to attend the UN General Assembly in September.

Previous Trend: Very Negative

The Biden administration and Tehran edged closer to a nuclear agreement that would be even shorter and weaker than the 2015 deal. Under the new agreement, Washington would lift sanctions on Iranian economic sectors tied to the Islamic Revolutionary Guard Corps (IRGC), while Tehran would freeze production of uranium enriched to 20 and 60 percent purity. That exchange would occur prior to a review by Congress, which under U.S. law is entitled to 30 days to review and potentially vote on any nuclear agreement with Iran. If fully implemented, the deal reportedly would enable foreign companies to do business with potential IRGC affiliates, while providing direct sanctions relief for key IRGC financiers inside Iran.

Meanwhile, Tehran would retain its advanced centrifuges, enabling the regime to quickly produce a nuclear weapon. The agreement would also maintain the old deal’s “sunset” clauses. The UN arms embargo on Iran already expired in 2020, and a UN prohibition on Iranian missile testing will lapse next year. Key nuclear sunsets begin in 2024. In addition, an International Atomic Energy Agency investigation into undeclared Iranian nuclear activities may be ignored or pressured to close.

The Biden administration is moving forward with the nuclear negotiations even as Tehran continues to orchestrate and inspire attacks against Americans. On August 10, the Justice Department leveled charges against an IRGC member for plotting to assassinate former National Security Advisor John Bolton. Author Salman Rushdie suffered an Iranian-inspired stabbing in mid-August. Finally, Iran-backed militias launched drones and rockets at U.S. forces in Syria on August 15, prompting the U.S. military to conduct several retaliatory strikes.

Previous Trend:  Neutral

Israeli apprehension over an expected nuclear deal with Iran has weighed heavily on relations between Jerusalem and Washington.

On August 23, Iran’s nuclear program dominated discussions between Israeli National Security Advisor Eyal Hulata and his American counterpart, Jake Sullivan, in Washington.

Israeli Defense Minister Benny Gantz held a similar meeting with Sullivan the following day. Gantz also met with the head of U.S. Central Command and thanked him for American support and cooperation with Israel on security matters.

But on August 28, Israeli Prime Minister Yair Lapid called for a “credible military threat” to improve the expected “bad agreement.” “If an accord is signed,” Lapid warned, Israel will not “be obligated by it. We’re not a party to it, and it won’t limit our activities.”

Meanwhile, multiple sources say Lapid, who wants to speak with President Biden on the sidelines of the UN General Assembly in September, has been unable to secure a phone call with the president. Mossad chief David Barnea, who warned the Iran deal is “based on lies” and will be “very bad for Israel,” is expected to visit Washington next week.

In early August, the Iranian proxy Palestinian Islamic Jihad (PIJ) launched over a thousand rockets at Israel during a three-day round of fighting. Welcoming the ceasefire on August 7, Biden reiterated his support for Israel’s security and noted that PIJ rockets possibly killed Palestinians. However, Biden’s call to investigate future deadly incidents could place constraints on Israeli counterterrorism operations.

Previous Trend: Positive

The United States and South Korea demonstrated their commitment to military readiness against a potential North Korean attack by resuming their annual exercise, now named Ulchi Freedom Shield, at full scale on August 22. This is the first step to reversing the decline in combined readiness caused by COVID-19 and the 2018 decision to cancel or scale back bilateral military exercises. So far, Pyongyang has responded with predictably harsh rhetoric and two cruise missiles fired into the West Sea. The exercise follows the August 17 meeting of the Korean Integrated Defense Dialogue, where Washington and Seoul reaffirmed their commitment to enhanced military cooperation throughout the Indo-Pacific.

Meanwhile, speculation about a potential seventh North Korean nuclear test continues. Kim Jong Un may be refraining from nuclear testing to gain economic support from China, which likely hopes for quiet ahead of its upcoming 20th Party Congress, where Xi Jinping is expected to secure a third term as leader.

On August 15th, Korean Liberation Day, South Korean President Yoon Suk-yeol unveiled an “audacious initiative” for engaging North Korea. The plan envisions economic incentives in return for North Korean steps toward denuclearization, but offers few details. Washington expressed support for the initiative, indicating the allies are completely aligned. Along with the United Nations, they continue to call on Pyongyang to denuclearize, while Yoon promises Seoul will not seek nuclear weapons.

However, the Yoon administration is expressing concern that the U.S. Inflation Reduction Act, which President Biden signed into law on August 16, could hurt South Korean industry. A South Korean pundit disparagingly called it a return to “America First.”

Previous Trend: Neutral

After a series of foreign policy failures in Latin America over the last few months, the Biden administration made headway in countering corruption and other illicit activity in the region. The State Department on August 12 sanctioned Paraguayan Vice President Hugo Velazquez and his advisor Juan Carlos Duarte for their “involvement in significant corruption.” Shortly thereafter, Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson made a three-day trip to Brazil, where he discussed issues ranging from corruption to drug trafficking to terrorist financing. Together, the sanctions and Nelson’s visit went a long way in signaling U.S. seriousness about combating corruption in the Western Hemisphere.

Meanwhile, despite protests from Caracas, Argentina retains custody of an American-made plane that Iran sold to Venezuela last year in violation of U.S. export controls. While the Biden administration moved too slowly in requesting seizure of the aircraft, which Argentina grounded in June, Argentine courts approved the eventual request, and FBI officials inspected the plane in mid-August.

There remains room for improvement, however. On August 11, the United States Commission on International Religious Freedom released a report detailing the increasing crackdown on religious liberty in Nicaragua. As the regime of Daniel Ortega intensifies its crackdown against Catholic organizations, the United States should consider issuing sanctions or other measures to impose costs for this repression.

Finally, Russia, China, Cuba, and other countries held war games in Venezuela. While the games themselves were underwhelming, they reflect growing Russian and Chinese influence in the Western Hemisphere — something Washington has yet to figure out how to address.

Previous Trend: Very Negative

In an August 31 phone call with Israel’s prime minister, President Biden “emphasized the importance of concluding the maritime boundary negotiations between Israel and Lebanon in the coming weeks,” according to a White House readout. A White House official told Al Arabiya that reaching an agreement, which would enable Lebanon to drill for offshore gas, is a “key priority” for the administration.

U.S. energy envoy Amos Hochstein visited Israel at the beginning of August but has not yet conveyed Jerusalem’s latest proposals to Beirut. Hochstein reportedly had expressed his desire to conclude negotiations by September, when Israel’s Karish offshore gas field is scheduled to go online. Hezbollah had issued a threat, which Hochstein amplified, that it would disrupt production at Karish unless Israel first conceded to Lebanon’s demands.

Hochstein reportedly also spoke with the French about the role of TotalEnergies in Lebanon, which commissioned the French energy giant to drill in Lebanese waters. An immediate start to drilling is a core Hezbollah demand in the negotiations.

Meanwhile, the Biden administration has agreed to renew the mandate of the UN Interim Force in Lebanon (UNIFIL) despite the force’s utter failure to implement its mandate. The UN secretary-general’s latest report on the subject highlighted how the Lebanese Armed Forces (LAF), at the behest of Hezbollah, have obstructed UNIFIL’s mission. Regardless, the Biden administration continues to send the LAF equipment it barely can maintain without additional foreign assistance, ensuring additional U.S. funds will follow, on top of the administration’s plan to send monthly cash stipends to augment LAF salaries.

Previous Trend: Negative

Russian forces continue to illegally occupy the Zaporizhzya Nuclear Power Plant (ZNPP) in Ukraine, where they are committing atrocities against ZNPP workers and endangering nuclear safety. On August 25, Ukrainian President Volodymyr Zelenskyy reported that due to Russian shelling, two operating ZNPP reactors had been completely disconnected from Ukraine’s electrical grid. Zelenskyy said the plant was relying on a backup diesel power generator to avert a “radiation disaster.” The International Atomic Energy Agency (IAEA) confirmed the following day that the reactors had been reconnected to the grid. Zelenskyy’s announcement followed a letter from a bipartisan group of 26 nonproliferation experts urging President Biden to prioritize working toward an IAEA visit to the plant. After intense discussions with Ukraine and Russia, an IAEA team visited ZNPP on Thursday, and the agency’s director general announced it will maintain a permanent presence at the plant.

Elsewhere, Russia prevented states parties to the Nuclear Non-Proliferation Treaty (NPT) from agreeing to a final consensus document at the treaty’s review conference. Moscow, the lone holdout, insisted that the document be stripped of language condemning the situation at ZNPP.

The United States, Iran, and other world powers are inching closer to reviving a shorter, weaker version of the 2015 nuclear deal. Washington claimed Tehran had dropped its insistence that the IAEA terminate an investigation into the Islamic Republic’s nuclear activities. However, an outlet close to Iran’s supreme leader stated that Rafael Grossi, the IAEA’s director general, “is still the main obstacle to the finalization” of a nuclear deal because he refuses to bow to pressure to close the probe absent Tehran’s full cooperation.

Previous Trend: Positive

On August 24, Ukraine’s independence day and the six-month anniversary of Russia’s full-scale invasion of its neighbor, President Biden announced an almost $3 billion military aid package for Kyiv. Among other things, the package includes six NASAMS air defense systems, in addition to the two announced earlier this year, which the Pentagon expects to arrive “within the next two to three months.” These systems can help protect Ukrainian cities from Russian missiles. Unlike presidential drawdowns, which pull materiel directly from U.S. stocks, this package involves contracts with producers, meaning it is designed to support Ukraine over the medium to long term. The new package brings the total U.S. security assistance for Ukraine to almost $13 billion since February.

In drawdown packages announced on August 1, 8, and 19, the administration unveiled a total of $2.3 billion in assistance, including additional GMLRS munitions for Ukraine’s U.S.-provided HIMARS rocket artillery. However, the Pentagon still refuses to publicly specify how many GMLRS it has sent Ukraine, while Ukrainian officials reportedly have complained about not receiving enough. The White House also refuses to provide longer-range missiles for Ukraine’s HIMARS, denying Kyiv a potent capability that could aid its ongoing counteroffensive by enabling Ukrainian forces to strike high-value military targets far behind the front lines, including key nodes in Russia’s rail-dependent logistics system. On the positive side, the administration revealed it had provided Ukraine with AGM-88 High-speed Anti-Radiation Missiles adapted to fire from Ukrainian MiG-29 fighters. These missiles can degrade Russian air defenses, thus giving greater freedom to Ukraine’s own aircraft.

Previous Trend: Negative

Nearly one month after a U.S. airstrike killed al-Qaeda leader Ayman al-Zawahiri in the Afghan capital of Kabul, the Taliban claimed it cannot find evidence that Zawahiri was present or died in the attack. Two weeks after Zawahiri’s death, the Biden administration indicated it would not release $3.5 billion in frozen funds belonging to Afghanistan’s central bank. But one week after that, the administration sought to reopen talks with the Taliban to release the funds. Resistance to Taliban rule is growing in northern Afghanistan even though the Biden administration refuses to support violent opposition to the Taliban. To address the burgeoning resistance, the Taliban appointed Mullah Abdul Qayyum Zakir as its military commander in the restive central Afghan province of Panjshir. Zakir, who was held at the Guantanamo Bay Detention Facility for six years, is considered to be one of the Taliban’s most effective military commanders.

Al-Shabaab, al-Qaeda’s branch in East Africa, launched a coordinated two-day-long suicide assault on a hotel frequented by Somali politicians and security officials. The United States has responded to the increasing insecurity in Somalia by stepping up airstrikes against al-Shabaab. Further south, the Islamic State’s Central Africa Province assaulted a prison in the Congolese city of Butembo and released more than 800 prisoners.

Previous Trend: Negative

On August 15, Iran-backed militias launched a wave of drone attacks on the U.S. garrison at al-Tanf in eastern Syria, near the Iraqi border. A week later, the U.S. military struck nine storage bunkers in eastern Syria where Iran-backed militias were storing ammunition and other military hardware. Colin Kahl, the U.S. under secretary of defense for policy, told reporters that American forces waited to hit back until they were certain that Tehran was clearly responsible. “We have Iran dead to rights on attribution,” Kahl said, noting that parts from the drones used in the attacks can be “traced directly back to Tehran.”

The militias responded to the American strikes by conducting rocket attacks on a pair of U.S. bases in northeastern Syria, known as Green Village and Conoco. Three American service members suffered minor injuries. Further skirmishes followed, resulting in the death of four militia fighters. Kahl portrayed the back-and-forth as “a demonstration the United States will not hesitate to defend itself against Iranian and Iran-backed aggression when it occurs.”

Yet a forceful U.S. response has been the exception, not the rule, in the aftermath of almost a dozen attacks on U.S. troops in Syria over the past year. Nor is it clear the latest operations will have any lasting deterrent effect. Apparently, the Biden administration prefers to tolerate the militias’ harassment rather than mount a response that risks a disruption of ongoing nuclear talks with Iran — a pattern also visible in the administration’s tepid response to Tehran’s attempted assassination of former U.S. National Security Advisor John Bolton, which the Justice Department revealed in August.

Previous Trend: Neutral

Deputy Secretary of the Treasury Wally Adeyemo once again warned Turkey against facilitating Russian sanctions evasion, both in an August 19 meeting with his counterpart in Ankara and in an August 22 letter to two Turkish business associations. The letter warns that “any individuals or entities providing material support to U.S.-designated persons are themselves at risk of U.S. sanctions,” and that ongoing “relationships with sanctioned Russian actors may expose Turkish financial institutions and businesses to sanctions risk.” The Turkish government has not formally responded to Adeyemo’s letter, which follows a similar U.S. warning to Ankara in June.

Meanwhile, on August 16, Russia’s state-run TASS ran a misleading article indicating Moscow and Ankara had signed an agreement to deliver a second regiment of the Russian-made S-400 surface-to-air missile system to Turkey. Ankara already received one regiment in 2019, leading Washington to evict Turkey from the F-35 Joint Strike Fighter program. A Turkish defense official quickly threw cold water on the TASS report, clarifying that the original contract allowed for the delivery of a second regiment, but that “no new agreements” have been signed and Russian-Turkish negotiations are “ongoing.”

Still, the official’s admission that Ankara is still considering purchasing a second S-400 regiment caused concern among members of Congress. If Turkey does press forward with the acquisition, it could elicit further U.S. sanctions under the Countering America’s Adversaries Through Sanctions Act, and Ankara’s chances of acquiring F-16 jets from the United States would be virtually nil.

The analyses above do not necessarily represent the institutional views of FDD.