Kudlow started the America First Policy Institute last year and has since then repeatedly turned his FBN show into an infomercial boosting his own group.
“I hope you stay in the game. I’m going to try to recruit you for the America First Policy Institute,” Fox Business Network host Larry Kudlow said last week, concluding an interview with retiring GOP congressman Kevin Brady.
It was just the latest instance of Kudlow using his perch to promote and enlist new members for his side hustle, an influential conservative policy think tank some have deemed a MAGA “White House in waiting.”
Kudlow founded the America First Policy Institute (AFPI) in 2021 with several other former Trump administration officials. Over the past year, Kudlow’s peculiarly aggressive promotion of the nonprofit organization—for which he serves as vice chair—has become a regular fixture of his late-afternoon weekday show.
In just the past six months alone, Kudlow has directly mentioned AFPI at least 51 separate times on his program. He has routinely and prominently featured other board members, including former Small Business Administration director Linda McMahon, who is now the AFPI chair.
Even within the universe of Fox News—a network that often acts as a de facto comms arm of the Republican Party and staffs directly from Trumpworld—Kudlow’s brazenness in plugging his own political organization stands out.
Media experts who spoke with The Daily Beast were split on whether Kudlow routinely turning his show into an AFPI infomercial necessarily represents a conflict of interest, as the Fox host discloses his chair status while flogging the institute and he is clearly not a journalist.
In a “mainstream newsroom,” Kudlow’s incessant promotion of AFPI “would not be permissible,” said Tim Gleason, a professor emeritus at the University of Oregon’s journalism school. “Cable news continues to blur the lines between ‘news’ and ‘opinion’ and… Fox is at the extreme, having essentially eliminated the distinction in much of its programming,” he continued. “However, applying the ethical standards of major news organization, as the host of a program that is presented as a ‘financial market analysis, roundtable discussions on the policies impacting the domestic and global economies and news-making interviews with business influencers across the world,’ Kudlow’s role at AFP is a clear conflict of interest.”
However, Kathleen Culver, director of the Center for Journalism Ethics at the University of Wisconsin-Madison, said that while “this would clearly be a conflict of interest for a business or financial reporter, I doubt Kudlow’s audience views him as that and I don’t recall his laying claim to being a journalist.” She added that Kudlow is clearly a “commentator and is being transparent with his audience about an entanglement that could be seen as a conflict.”
Of course, the ethical nuances don’t absolve the ex-Trump official of what can only be described as pure, uncut shamelessness.
Kudlow and Fox News did not respond to a request for comment.
A former Reagan administration official, Kudlow subsequently spent more than 15 years as an on-air analyst with CNBC before returning back to the White House in 2018, this time as President Donald Trump’s director of the National Economic Council. His time as Trump’s chief economic adviser was marked by his rosy predictions of a booming economy during the early days of the pandemic, which he absurdly claimed had been “contained” by the administration.
Amid Trump’s deranged efforts to overturn his decisive 2020 election loss to President Joe Biden, Kudlow began planning his own post-White House moves. While he said in December that year that he planned to return to cable news, he was also preparing to launch a nonprofit group alongside other Trump advisers. The then-unnamed organization’s main mission, outside of promoting Trump’s policies after he exited the White House, seemed to be to create “a landing spot for former Trump officials” after Biden took office.
Days after Biden’s inauguration, and less than a month after Trump incited the deadly Capitol riots, Fox News CEO Suzanne Scott announced Kudlow would join the network as a contributor and host his own show on sister channel Fox Business Network.
“Larry’s vast experience in policy making coupled with his intuitive on-air presence will add depth and insight to our business analysis programming,” Scott said in a statement at the time. “We are excited to welcome him to the FOX News Media team and look forward to creating a show that utilizes his immense expertise to help guide viewers through this unprecedented time of economic uncertainty.”
Apparently, one of the ways Kudlow would “help guide viewers” through the bumpy economic times would be to shamelessly and repeatedly publicize his own Trump-centric think tank.
Two months after debuting on Fox, the America First Policy Institute officially launched with an initial budget of $20 million and a 35-person staff. Besides Kudlow and McMahon, the AFPI also featured Brooke Rollins, the former chief of Trump’s Domestic Policy Council, as the group’s CEO and president. “In the coming months, the group plans to take a large office space near the U.S. Capitol as a symbol that it’ll fight to be a muscular, well-heeled center of the future of conservatism,” Axios’ Mike Allen wrote about the group in April 2021.
Since then, the think tank has expanded to a staff of 150 employees and a budget of at least $25 million. Since the AFPI only launched in mid-2021, its first 990 tax forms disclosing financial information like revenue and salaries has yet to be made public. The group now has 22 different policy centers, most of which are run and staffed by a who’s who of Trump alumni and allies.
The board is full of ex-Trump cabinet members and senior staffers. Former acting DHS chief Chad Wolf is the group’s executive director and chairs its homeland security and immigration division. Former Energy Secretary Rick Perry leads the AFPI’s center for energy and environment, former Interior Secretary David Bernhardt handles their initiative for “American Freedom,” and one-time acting Attorney General Matt Whitaker is the co-chair for the group’s center for law and order.
The AFPI roster also contains the likes of White House senior counselor Kellyanne Conway (now a Fox News contributor), faith leader Paula Cain-White, ex-White House deputy press secretary Hogan Gidley, and former Florida Attorney General Pam Bondi—all of whom maintain close ties to Trumpworld.
As the institute has gained influence within the GOP—it hosted a summit this summer that featured Trump returning to D.C. for the first time since leaving the White House in disgrace—some have taken to describing it as a “White House in waiting.” Even before this summer’s big D.C. event, Trump hosted a fundraiser for the group at his Mar-a-Lago residence last year and directed a $1 million donation to AFPI from his Save America PAC.
While that two-day summer gala was kicking off, Kudlow ran what amounted to an AFPI infomercial on his show.
“With all these problems and America on the wrong track under Mr. Biden, this can be changed. Now I’m down here in Washington, D.C., attending a summit conference hosted by the America First Policy Institute,” he said at the top of his July 26 broadcast. “It’s a conservative think tank that is working to develop policies that will ‘Make America Great Again’ again. Brooke Rollins is the president and CEO. Linda McMahon is chairman of the board. Yours truly is vice-chair of the board. The group is littered with senior policymakers from the Trump administration and many other conservative scholars. Our ideas may not always be perfect but they are a whole lot better than what is going on under the Bidens.”
After running down a wishlist of right-wing policies and culture-war grievances, Kudlow insisted the 501(c)(3) group is “not political” but merely presents a “vision to stop the madness of the Biden administration.” He then made his grand pitch to viewers.
“We believe there is a huge coalition out there of common sense voters, families, working folks, be they Republican, independent or Democrat who will join our crusade to ‘Make America Great Again’ again,” he declared. “The cavalry is coming. Pessimism can be turned into optimism again. Americans, they can be restored. So folks, keep your chin up. AFPI efforts to rejuvenate America right now may be the greatest story never told, but we are working on it.”
When not hawking AFPI through flowery monologues, Kudlow has repeatedly promoted the organization through other on-air means. Over the past several months, he has repeatedly brought fellow board members onto his show in an effort to hype up the institute.
Bondi, who has made at least 11 appearances on Kudlow’s program since April, promoted an upcoming AFPI Hispanic conference in Florida during one such interview late last month. Kudlow, saying he had just spoken with Rollins, added that he understood Trump himself was slated to “give a substantive policy speech” at the event.
“Is there any truth to that?” Kudlow wondered, coyly playing mock-interviewer in a mock-interview.
“Well, there is a big event in Miami. A great Hispanic conference,” responded Bondi, who chairs the group’s constitutional litigation partnership. “I will be down there, Brooke will be down there, Linda McMahon, our whole group at America First Policy Institute. It’s a positive message about Americans, America first. Everything we believe in.”
Drawing their promotional interview out further while clearly knowing the answer, Kudlow again asked, “President Trump will speak at the Hispanic event?”
Bondi said she hoped Trump could make it, prompting Kudlow to interject: “You’re allowed to say yes. I got sign-off from Brooke. She just texted me.”
Rollins, too, has appeared on Kudlow’s show to boost AFPI. In one on-air interview last month at the Reagan Presidential Library, which also featured McMahon, Kudlow gushed over the “fabulous job” Rollins was doing running the institute. Rollins directly echoed Kudlow’s “cavalry is coming” line about AFPI while McMahon celebrated the Fox host’s “guidance” as well as his “design for the tax cuts” under Trump’s administration.
“We’re returning power to the people. That’s what Reagan stood for when he flew on this plane with you right beside him and that’s what Donald Trump stood for,” Rollins concluded.
Several other key AFPI board members have appeared on Kudlow’s program in recent months. Stephen Moore, a former Trump economic adviser now serving as a senior fellow with Kudlow’s organization, has been a frequent guest on the show, appearing at least once a week. Wolf and Perry have also made multiple appearances this year.
And Conway, who leads the AFPI’s Center for the American Child, has popped up at least nine times since May. “Kellyanne Conway, I will see you at the AFPI tomorrow,” Kudlow told her at the end of a July 25 chat.
“Can’t wait, thanks,” she replied with a wink.