with whom Justice Brennan, Justice Marshall, and Justice Powell join, dissenting.
All parties concede that the 1982 restrictions on travel-related expenditures in Cuba, 47 Fed. Reg. 17030 (1982), were not promulgated in conformity with the procedural requirements of the International Emergency Economic Powers Act of 1977, Pub. L. 95-223, Title II, 91 Stat. 1626, 50 U. S. C. §§ 1701-1706 (IEEPA). Thus, those restrictions are invalid unless they were authorized by § 101(b) of Pub. L. 95-223, 91 Stat. 1625, the grandfather clause of the IEEPA. Because I do not agree that the grandfather clause encompasses the exercise of Presidential power at issue here, I would affirm the judgment of the United States Court of Appeals for the First Circuit.
rH
Congress promulgated Public Law 95-223 to address problems unforeseen by the drafters of the Trading With the Enemy Act of 1917, 40 Stat. 411, as amended, 50 U. S. C. App. § 1 et seq. (TWEA). The TWEA was one of several statutes that reflected Congress’ conclusion that the President should have increased authority in times of war or national emergency in order to respond to such crisis situations with the coordinated alacrity they require. Accord*245ingly, the TWEA provided the President with a broad range of powers over international trade in time of war or “national emergency.”
Although TWEA provided clear procedures for enhancing the authority of a President when an emergency arose, the Act contained no similar provision to reduce the President’s authority to its normal scope when the emergency subsided. Once the President had declared a state of national emergency, the emergency officially continued to exist until the President declared that it had ended. Until such a declaration of termination was made, the President enjoyed the broad authority that the TWEA conferred upon him to address the original emergency. The historical record shows that once a President had declared the existence of a national emergency, he was slow to terminate it even after the circumstances or tensions that had led to the declaration could no longer be said to pose a threat of emergency proportion to the Nation. See generally Emergency Controls on International Economic Transactions: Hearings before the Subcommittee on International Economic Policy and Trade of the House Committee on International Relations, 95th Cong., 1st Sess., 16-19 (1977) (Subcommittee Hearings) (statement of Prof. Andreas F. Lowenfeld); id., at 27-31 (statement of Prof. Harold G. Maier).
Because of this pattern of behavior, TWEA emergency authority operated as a one-way ratchet to enhance greatly the President’s discretionary authority over foreign policy. At the time that Congress began to consider amendments to the TWEA, the United States technically faced four declared states of “emergency.” Among the four were President Franklin D. Roosevelt’s 1933 Bank Holiday Declaration, Presidential Proclamation No. 2040, 48 Stat. 1691; President Nixon’s 1970 declaration concerning a Post Office strike, Presidential Proclamation No. 3972, 3 CFR 473 (1966-1970 Comp.); and President Nixon’s 1971 declaration concerning the country’s balance-of-payments problems, Presidential Proclamation No. 4074, 3 CFR 60 (1971-1975 Comp.). The *246national emergency most often invoked in connection with exercises of TWEA powers was the emergency that had been declared on December 16, 1950, by President Truman in response to the developing Korean conflict. Presidential Proclamation No. 2914, 64 Stat. A454. That Proclamation warned of the threat of Communist aggression. Because of this declaration of emergency, the President retained broad authority of indefinite duration to respond to anything that logically could be related to the general threat of the spread of Communism.
There was widespread feeling that this broad grant of emergency powers conflicted with the intent of the TWEA, which sought to empower a President to respond to situations that presented an imminent threat requiring immediate response.1 The expert witnesses who testified before the House Subcommittee expressed a general consensus that § 5(b) of the TWEA inappropriately had been used as a flexible instrument of foreign policy in nonemergency situations. See, e. g., Subcommittee Hearings, at 13-14, 16 (statement of Prof. Andreas F. Lowenfeld) (“no practical constraint limiting actions taken under emergency authority to measures related to the emergency”); id., at 22-23 (statement of Prof. Harold G. Maier) (“combination of legislative permissiveness and executive assertiveness over the past 40 years has created a significant shift in the functional allocations of constitutional power to regulate foreign commerce”); id., at 39 (statement of Prof. Stanley D. Metzger) (suggesting *247necessary checks and limitations on executive use of § 5(b) powers); id., at 83 (statement of Peter Weiss, Center for Constitutional Rights) (TWEA “a prime example of the unchecked proliferation of Presidential power for purposes totally unforeseen by the creators of that power”).
The Members of Congress who heard the testimony found it convincing. See, e. g., H. R. Rep. No. 95-459, p. 7 (1977) (§ 5(b) “has become essentially an unlimited grant of authority”); Revision of Trading with the Enemy Act, Markup before the House Committee on International Relations, 95th Cong., 1st Sess., 8 (1977) (House Markup) (statement of Rep. Bingham) (“Section 5(b) has become a grab-bag of authorities which Presidents have been able to use to do virtually anything for which they could find no specific authority”). House Subcommittee Members also believed that some of the actions taken by the Executive Branch under the TWEA had, at most, a shaky foundation in actual emergency situations. In an exchange with Assistant Secretary of State Julius L. Katz, Subcommittee Chairman Bingham voiced his incredulity concerning the bases for certain then-effective regulations promulgated under § 5(b):
“MR. BINGHAM. Mr. Katz, what is the national emergency currently facing us that warrants the use of powers under the [TWEA]? . . .
“MR. KATZ. It continues to be the emergency involving the threat of Communist aggression which was declared in 1950 at the time of the aggression in Korea.
“MR. BINGHAM. Are you serious?
“MR. KATZ. That is the national emergency, Mr. Chairman, and it continues.
“MR. BINGHAM. The emergency is the emergency that existed in 1950?
“MR. KATZ. It has not been terminated.” Subcommittee Hearings, at 110.2
*248Dissatisfied generally with the responses of spokesmen from the Executive Branch, Representative Bingham criticized the administration’s lack of cooperation in the effort to amend the TWEA. He further observed:
“Now I think that you have to face the facts, which are that the executive branch wants to be free to continue to act with an enormous degree of discretion on the basis that an emergency exists, although by no commonsense application of the term could the situation be called an emergency.
“The threat of Communist aggression, if you will, or the threat of Communist competition which we face in the world, Mr. Katz, is a permanent situation. It is not an emergency unless you are going to define the situation that exists in the world today as a permanent emergency. I don’t see how you justify use of the term.
“Up until now the reaction of the subcommittee,, and the reaction of the witnesses that we have had, has been that the situation that we are in is quite an incredible one, and it has to be substantially altered to try to conform with reality and with principle.” Id., at 113-114.
It is clear that Congress intended to curtail the discretionary authority over foreign affairs that the President had accumulated because of past “emergencies” that no longer fit Congress’ conception of that term. To accomplish this goal, Congress amended the TWEA and enacted the IEEPA. Congress left intact the powers that the TWEA had conferred upon the President during time of war, but removed from the TWEA the authority for Presidential action in a national emergency. As a substitute for those powers, Congress promulgated the IEEPA to confer power upon the President in national-emergency situations. The substantive reach of the President’s power under the IEEPA is *249slightly narrower than it had been under the TWEA,3 and Congress placed several procedural restrictions on the President’s exercise of the national-emergency powers, including congressional consultation, review, and termination.
The prospective nature of the IEEPA left Congress with the dilemma of how to deal with existing regulations that had been promulgated under § 5(b) and obviously had not been issued in accordance with the new procedures set forth in the IEEPA. There were those on the House Subcommittee considering the amendments to the TWEA who thought that there should be no grandfathering and that the existing regulations should be allowed to expire. See, e. g., Subcommittee Hearings, at 167, 168-169, 198 (remarks of Rep. Cavanaugh); id., at 210 (remarks of Rep. Findley); id., at 119 (colloquy between Rep. Bingham and Assistant Treasury Secretary Bergsten). Such an approach would have required the President to evaluate each situation in which regulations were in effect and to determine whether the need for reinstitution of the regulations justified a new declaration of national emergency. Others believed that Congress should conduct such a review and determine which restrictions were still justified by current exigencies. See H. R. Rep. No. 96-459, at 9-10. In response to two related concerns, however, the view that there was a need for some sort of grandfathering finally carried the day.
The first argument supporting a grandfather clause was the desire to preserve the administration’s bargaining position in dealing with countries that were the subject of existing embargoes and asset freezes. Testimony before the *250House Subcommittee expressed the view that the President should not be forced by Congress to make unilateral concessions to countries that had been the targets of exercises of § 5(b) authorities. In other words, many believed that the President should not be forced to give up “bargaining chips” without receiving something in return from the countries on the other side of the negotiations. Subcommittee Hearings, at 19 (statement of Prof. Lowenfeld) (“perhaps [the Cuba embargo] should not be terminated . . . without a quid pro quo”); id., at 103, 113, 119 (statements of Assistant Treasury Secretary Bergsten) (unilateral termination of embargoes “would severely undermine the U. S. negotiating position ■with those countries, and our worldwide posture”); 123 Cong. Rec. 22477 (1977) (remarks of Rep. Whalen).
The second argument in favor of some form of a grandfather clause was related to the first. Several of the witnesses who testified at the hearings on the bill felt that the President should not be faced with the need to declare a new national emergency in order to continue existing restrictions. Such a declaration would have foreign policy reverberations of its own, and might inject new tension into a sensitive situation in which tensions were on the decline. See, e. g., Subcommittee Hearings, at 19 (statement of Prof. Lowenfeld); id., at 191-192 (remarks of Mr. Santos, Treasury Department attorney adviser). It would have been incongruous, in other words, for Congress to force the President to declare new emergencies in nonemergency situations simply to avoid having to end restrictions that, for negotiating reasons, the President had concluded should not be ended unilaterally.
The proponents of grandfathering voiced their desire that the grandfather clause be tailored narrowly to fit these concerns. In its early form before the Subcommittee, the clause contained two subparts, §§ 101(b)(1) and (2), which read:
“(1) any authority conferred upon the President by section 5(b) of the Trading with the Enemy Act, which is being exercised with respect to a set of circumstances on the date of enactment of this Act as a result of a national *251emergency declared by the President before such date of enactment, may continue to be exercised with respect to such set of circumstances; and
“(2) any other authority conferred upon the President by that section may be exercised to deal with the same set of circumstances.” Subcommittee Working Draft of June 8,1977, 95th Cong., 1st Sess., § 101(b) (emphasis added).
In response to a question about the meaning of § 101(b)(2), Subcommittee Staff Director R. Roger Majak explained the purposes of the provision:
“[W]ith respect to any uses of 5(b) authorities for any presently existing situation, not only could the President use those particular authorities that he is now using, but any others which are conferred by section 5(b).
“So if the President is presently using asset controls toward a particular country, but is not using, let us say, currency controls, he nonetheless could use, at some later date if he so desired, currency controls with respect to the situation.
“I think it boils down to a question of whether we are grandfathering a particular situation, and all the powers that may be necessary to deal with the situation, or whether we are grandfathering the particular authorities themselves and their usage.” Subcommittee Hearings, at 167.
Representative Bingham voiced his opposition to such a broad grandfather clause.
“I have a serious question about that. It seems to me that if the President has not up to now used some authority that he has under section 5(b) in connection with those cases where 5(b) has been applied, I don’t know why it should be necessary to give him authority to expand what has already been done. It is really going beyond grandfathering.
*252“It seems to me that grandfathering applies to what has been done to date, and that should be ample authority.” Ibid.
Section 101(b)(2) was removed from the draft bill presented to the Committee.4 I can think of few sorts of information *253routinely found in legislative histories that would give a clearer indication that Congress intended to grandfather only the regulations and restrictions that already had been exercised.5
When the full House Committee viewed § 101(b) after § 101(b)(2) had been deleted, Representative Cavanaugh sought to ascertain that the clause was drawn as narrowly as possible to include only those regulations currently in effect:
“MR. CAVANAUGH. . . . First of all, Mr. Berg-sten, would it be your understanding that section 101 would strictly limit and restrict the grandfathering of powers currently being exercised under 5(b) to those specific uses of the authorities granted in 5(b) being employed as of June 1, 1977.
“MR. BERGSTEN. Yes, sir.
“MR. CAVANAUGH. And it would preclude the expansion by the President of the authorities that might be included in 5(b) but are not being employed as of June 1, 1977.
“MR. BERGSTEN. That is right.” House Markup, at 21.
In explaining the effect of the grandfather clause to the full House Committee, Representative Bingham stressed that *254the grandfather clause would leave intact “specific current uses of 5(b) authorities” and emphasized that the bill “neither condones nor condemns existing policies.” Id., at 7.
It is important to emphasize that the decision to grandfather the specific uses of authorities being exercised at a certain date did not reflect congressional acknowledgment that those uses of authorities were in fact addressed to true emergency situations. To the contrary, Congress openly expressed its view that many of the grandfathered restrictions had no real basis in an emergency situation. H. R. Rep. No. 95-459, at 11 (few current uses could be justified as responding to existing emergency situations). Responding to this sentiment, Congress expressly provided annual procedures governing the continuation of grandfathered authorities that are different from the procedures that govern the continued exercise of any new restrictions entered pursuant to a new state of emergency. With respect to future exercises of emergency power, the President’s decision to continue in effect the proclamation of national emergency, and the regulations promulgated thereunder, are subject to semiannual review by Congress. See 50 U. S. C. §§ 1622(b), 1641(c). With respect to grandfathered authorities, the grandfather clause requires only that the President find continued exercise of the authority to be in the national interest. § 101(b), 50 U. S. C. App. §5; Subcommittee Hearings, at 208. In this way, the Subcommittee avoided perpetuating the “phony character” of the national emergencies under which current exercises of § 5(b) power were promulgated. Id., at 210. See also, id., at 193 (statement by Mr. Santos, Treasury Department attorney adviser) (administration would have difficulty making good-faith declaration of current national emergency with respect to Cuba); House Markup, at 3 (remarks of Rep. Bingham).
In sum, the grandfather provision of the IEEPA was designed narrowly to respond to a particularized set of *255concerns. It sought to avoid placing the President in the awkward situation either of making unilateral concessions to countries subject to restrictions or declaring a new state of emergency with respect to a country where none, in fact, existed. Congress concluded that these objectives were served fully with a grandfather clause that preserved existing restrictions, but gave the President no authority to impose new restrictions except through the new IEEPA procedures that govern the President’s authority to respond to new emergencies.
II
The Court rejects this narrow interpretation in favor of one that loses all sight of the general legislative purpose of the IEEPA and the clear legislative intent behind the grandfather clause. To achieve its labored result, the Court invokes a series of platitudes on statutory interpretation, but ignores their application to this case. Ironically, the very pieces of legislative history that the Court cites to justify its result clearly support the contrary view.
Recognizing the clear import of the legislative history, the Court begins by discovering absolute clarity in the “plain language” of the statute. The Court focuses on the fact that Congress used the term “authorities” in the grandfather clause instead of either the word “restrictions” or “prohibitions.” Finding what, in its view, is a vast difference between the meaning of the first term and that of the latter two, the Court concludes that if Congress had meant “restrictions” it would have said so explicitly. Ante, at 236.
But the Court’s confident claim that the statutory language is without ambiguity is pure ipse dixit. The Court concedes that throughout the legislative history Congress referred to what it wanted to grandfather as “restrictions,” “controls,” “specific uses,” “prohibitions,” “existing uses,” and “authorities.” It is true that Congress used the word “authorities” when it drafted the statute, but there is nothing to indicate *256that it used the term “authorities” to express any intent other than that which is made plain in the legislative history. The likely reason that the term “authorities” was used instead of a term such as “prohibitions” is simply that § 5(b) authorized a President to do much more than issue prohibitions, and Congress intended to grandfather the uses of those powers as well. For example, §5(b) authorizes the President to conduct investigations of various activities and to “freeze” the assets of foreign countries and foreign nationals. At the time Congress enacted the IEEPA, the President had exercised these authorities over several countries, including Cuba, and Congress clearly intended to grandfather those exercises. Because the exercise of these powers does not fit naturally within a word such as “prohibitions,” it is hardly surprising that Congress did not use that term. Thus, the short answer to the Court's question as to why Congress did not use the term “prohibitions” is simply that Congress intended to include more than mere prohibitions.
There is nothing in the language of the statute to suggest, however, that Congress intended the grandfather clause to provide a President with the authority to increase the restrictions applicable to a particular country without following the IEEPA procedures. As the legislative history makes clear, when Congress grandfathered all “authorities . . . being exercised,” it sought to preserve the uses of § 5(b) authorities that the President had employed in the past to address a particular situation — but no more. As Representative Bingham, a principal drafter of the bill, stated: “if the President has not up to now used some authority that he has under section 5(b) in connection with those cases where 5(b) has been applied, I don’t know why it should be necessary to give him authority to expand what has already been done.” Subcommittee Hearings, at 167.
In its effort to downplay the clear legislative history of the grandfather clause, the Court relies on platitudes about the hazards of relying on such legislative history. The Court correctly states:
*257“Oral testimony of witnesses and individual Congressmen, unless very precisely directed to the intended meaning of particular words in a statute, can seldom be expected to be as precise as the enacted language itself. To permit what we regard as clear statutory language to be materially altered by such colloquies, which often take place before the bill has achieved its final form, would open the door to the inadvertent, or perhaps even planned, undermining of the language actually voted on by Congress and signed into law by the President.” Ante, at 237.
I have no disagreement with these generalities; they simply have no relevance to this case. The “colloquies” referred to involve the drafters of the Act, are directed at the precise language of the grandfather clause, and either were addressed to the bill in its final form, or aimed at getting changes in the bill to deal with precisely the problem at issue in this case.
Failing to heed its own advice, the Court then would rely on the legislative history of the Act to discern a congressional purpose consistent with its interpretation of the statute. The Court concludes that the purpose of the grandfather clause was to prevent the proposed bill from becoming controversial. Once again, I have no disagreement with this general interpretation. But the Court misapprehends the aspects of the statute that Congress feared would be divisive. Congress concluded that it would be controversial for it to examine existing controls to determine whether they were justified by the exigencies of particular situations. H. R. Rep. No. 95-459, at 9-10. And Congress also felt it undesirable to force the President either to declare new national emergencies where none existed or to end restrictions without obtaining a quid pro quo. Accordingly, Congress decided that it would grandfather what the President already had done with respect to particular situations. The “controversy” that Congress hoped the grandfather clause would *258avert had nothing to do with the President’s authority to respond to future situations.
The Court displays its utter confusion about this matter through its reliance on a quotation from the House Report that the Court believes supports its broad interpretation of the grandfather clause. In fact, the passage provides strong support for exactly the interpretation that the Court rejects. The passage reads:
“Certain current uses of the authorities affected by H. R. 7738 are controversial — particularly the total U. S. trade embargoes of Cuba and Vietnam. The committee considered carefully whether to revise, or encourage the President to revise, such existing uses of international economic transaction controls, and thereby the policies they reflect, in this legislation. The committee decided that to revise current uses, and to improve policies and procedures that will govern future uses, in a single bill would be difficult and divisive. Committee members concluded that improved procedures for future use of emergency international economic powers should take precedence over changing existing uses. By ‘grandfathering’ existing uses of these powers, without either endorsing or disclaiming them, H. R. 7738 adheres to the committee’s decision to try to assure improved future uses rather than remedy possible past abuses.” H. R. Rep. No. 95-459, at 9-10 (emphases added).
The Court’s decision to quote this language, ante, at 239-240, is remarkable. By its terms, the quotation makes clear that the controversy Congress sought to avoid was that which would arise if Congress passed judgment on “existing uses of international economic transaction controls, and thereby the policies they reflect.” Accordingly, Congress grandfathered them. It is also clear that the “existing uses” and “economic controls” and “policies” that Congress decided *259not to review included only “what has been done to date.” Subcommittee Hearings, at 167 (remarks of Rep. Bingham). Congress had no hesitation about restricting the President’s authority to exercise the emergency powers that he possessed but had not yet exercised. To the contrary, as the quotation on which the Court mistakenly relies makes absolutely clear, the primary purpose of the Act was to curtail “future uses” of precisely that residual authority.
Thus, it is equally remarkable for the Court to suggest that the purpose of the grandfather clause is to protect the President’s authority to “respon[d] to heightened tensions with Cuba.” Ante, at 240. If one thing is apparent from the legislative history of the Act, it is that Congress was not persuaded that the realities of the situation in Cuba constituted an emergency. See supra, at 247-249, 254-255. It is therefore somewhat incongruous to conclude that Congress intended to give the President greater flexibility to respond to developments in relations with Cuba than to events in other trouble spots around the world, such as Afghanistan, the Middle East, and Poland. With respect to future developments in such places, the IEEPA makes clear that the President cannot use his emergency powers to respond to “heightened tensions” unless the President has decided that a state of emergency exists, and has so declared. Nothing in the Court’s opinion explains why Congress intended such unevenness in the President’s authority to respond to future events; and it certainly is not self-evident why a less anomalous approach would have been “controversial.”6
*260The full incongruity of the Court’s unsupported conclusion that Congress inserted the grandfather clause to preserve the President’s “flexibility to adjust existing embargoes,” ante, at 236, is perhaps even more apparent with respect to trade relations with China. In 1950, trade with China was halted by a general prohibition on unlicensed property transactions similar to the general prohibition on trade with Cuba. Compare 31 CFR § 500.201(b) (1977) (China) with 31 CFR § 515.201(b) (1977) (Cuba). In 1971, however, the President nullified this general prohibition by enacting an equally broad general license. 36 Fed. Reg. 8584. In detailing the exercises of authority under §5(b) in effect at the time of the IEEPA, the House Report chronicled the history of trade restrictions with China as follows:
“On May 8, 1971, the Department licensed most subsequent transactions with China, while continuing the blocking of Chinese assets in U. S. hands before that date. This had the effect of lifting the U. S. trade embargo of China. However, the embargoes of North Korea, Vietnam, Cambodia, and Cuba continue.” H. R. Rep. No. 95-459, at 6 (emphasis added).
*261No other reference to extant trade embargoes refers to a trade embargo against China. See, e. g., Subcommittee Hearings, at 108 (statement of Assistant Treasury Secretary Bergsten); House Markup, at 8 (statement of Rep. Bingham). Thus, in the eyes of Congress, the President was no longer exercising § 5(b) authorities with respect to trade with China even though a nullified general prohibition was still in effect. Congress presumably envisioned that the grandfather clause would preserve the freeze on Chinese assets, but that all subsequent controls on trade would be subject to the new IEEPA procedures.
The incongruity in the Court’s analysis arises because the President’s position in 1977 with respect to all trade with China was exactly like his position with respect to travel-related expenditures in Cuba. If the logic of the Court’s opinion in this case is correct, Congress intended the grandfather clause in the IEEPA to preserve the President’s authority to reinstitute a complete trade embargo with China simply by eliminating the general license that was in effect at the time that the IEEPA was passed.7 There is no question that the Congress that enacted the IEEPA did not imagine that the grandfather clause preserved the President’s authority to transform trade relations with another country from a situation of virtually free trade to a situation of complete embargo without following the IEEPA procedures. To use the Court’s words, ante, at 235, it “does undue violence to the words chosen by Congress,” to say nothing of congressional *262intent, to suggest that Congress considered the reimposition of a complete prohibition on trade with China as an “existing exercise” of § 5(b) authorities preserved by the grandfather clause. Surely, the reimposition of a complete embargo fits squarely within the “future uses” of emergency authorities to which Congress contemplated the new IEEPA procedures would apply. The situation presented in this case with respect to Cuba is no different, and it is equally clear that an increase in the embargo of Cuba is what Congress considered to be a “future use” of emergency authority not protected by the grandfather clause.
Ill
Because the restrictions on travel-related expenditures in Cuba were not promulgated in conformity with the IEEPA and because there is no coherent reason to believe that Congress intended to preserve the President’s authority to institute such restrictions without complying with the IEEPA, I respectfully dissent.
Congressional scrutiny of the TWEA powers was part of a larger effort to review the bases of all the President’s emergency powers. In 1976, Congress enacted the National Emergencies Act, Pub. L. 94-412, 90 Stat. 1255, 50 U. S. C. § 1601 et seq., which, by its § 101(a), provided that powers exercised pursuant to existing states of national emergency would be terminated within two years after its date of enactment. The National Emergencies Act, however, exempted § 5(b) of the TWEA and several other provisions from that 2-year termination requirement in order to afford Congress the opportunity for more thorough consideration of the powers and procedures conferred upon the President by those provisions. §§ 502(a)(1) and (b), 90 Stat. 1258, 1259; Subcommittee Hearings, at 1-2.
See also id., at 117, 119 (remarks of Rep. Bingham) (referring specifically to lack of emergency with Cuba).
Four powers conferred upon the President by the TWEA were not included in the powers conferred upon the President for use in time of national emergency under the IEEPA. Those four powers are: (1) the power to take title to foreign property; (2) the power to regulate purely domestic transactions; (3) the power to regulate gold or bullion; and (4) the power to seize records.
I am not persuaded by the Court’s attempt to minimize the significance of the deletion of § 101(b)(2). See ante, at 237, n. 20. First of all, when the colloquy between Mr. Santos (Treasury Department attorney adviser) and Representative Bingham is read in context, it is clear that the major area of concern for both Mr. Santos and Representative Bingham was the question of what conditions should be placed on the President’s ability to continue to exercise those authorities that were currently being exercised under § 5(b), i. e., whether the President should be required to declare a continuing national emergency or merely be required to declare that continued exercise is in the national interest. A careful reading of the entire testimony of Mr. Santos, see Subcommittee Hearings, at 187-197, suggests that, at various points, Representative Bingham and Mr. Santos were not understanding one another’s questions and comments. There was never any “meeting of the minds” on the import of Mr. Santos’ comment that all “the powers conferred [were being] exercised and that there [were] no additional powers that could be exercised that [were] not already [being] exercised.” Id., at 188.
Further, it is nonsensical to assume that Mr. Santos meant, or that Representative Bingham could have understood him to mean, that all § 5(b) powers were being exercised with respect to the countries that were currently the subject of regulations promulgated under § 5(b). For example, both participants in the conversation were well aware that in addition to the embargoes of North Korea, Vietnam, Cambodia, and Cuba, there were in effect Transaction Control Regulations, 31 CFR §505.10 et seq. (1977), which prohibited any “person within the United States” from purchasing from any foreign country strategic commodities destined for a Communist country, and Foreign Funds Control Regulations, 31 CFR §520.01 et seq. (1977), which blocked certain assets of East Germany, Czechoslovakia, Latvia, Lithuania, and Estonia that had been blocked during World War II. No party to this litigation and nothing in the legislative history suggest that there is any support for the view that all powers under § 5(b) were being exercised with respect to all these countries. Mr. Santos’ statement is ambiguous and confusing, and I do not think it wise to allow this single, isolated exchange to cast a shadow of doubt over the clear import of the deletion of § 101(b)(2).
That the Subcommittee wanted the grandfather clause to be read narrowly is also evinced by suggestions that the Subcommittee find ways to convey its intention that the grandfather provision be tightly construed. Subcommittee Hearings, at 212 (remarks of Rep. Findley). In response, Representative Bingham suggested that the changes in the bill discussed during the hearings be incorporated and that the bill be reported to the full Committee before further amendments were made. Obviously sympathetic to any means of clearly delimiting the scope of the grandfather clause, Representative Bingham, who had suggested deleting § 101(b)(2), encouraged Representative Findley to present his suggestions to narrow the scope of the clause to the full Committee if Representative Findley felt that such narrowing were still necessary after the bill had been amended according to the Subcommittee’s specifications. Subcommittee Hearings, at 212.
Even the manner in which Congress discussed the need for avoiding controversy on substantive issues suggests that Congress had no idea that the grandfather clause would be read in the manner in which the Court has interpreted it. Representative Bingham explained the reason for the grandfather clause:
“We have also in title I grandfathered in essentially those actions taken under the [TWEA] which it would be extremely difficult, if not impossible, *260to persuade the Congress to reverse at this time. I refer to the embargo against Cuba, the embargo against Vietnam and so on.
“I think for us to attempt to deal with those controversial substantive issues would be a mistake even though I personally favor lifting the embargo against Cuba and Vietnam.” House Markup, at 2.
Obviously, Representative Bingham viewed grandfathering as an alternative to reviewring the regulations then currently in effect under § 5(b) and deciding which restrictions to lift. See also H. R. Rep. No. 95-459, at 11; Subcommittee Hearings, at 210 (remarks of Rep. Findley) (arguing that Congress should not grandfather and thereby give administration “easy way” to avoid resuming normal trade relations with other countries); id,., at 193 (statement of Rep. Bingham) (question of whether or not to grandfather is question of whether or not to “disturb” existing embargoes); id., at 7-8 (statement of Rep. Bingham); see also House Markup, at 10 (remarks of Rep. Whalen) (grandfather clause gives President discretion to continue any controls currently in effect).
The petitioners attempt to discount this incongruity by arguing that the issue of whether the President could have reinstituted the Chinese embargo under the grandfather clause is “moot,” since the President ended the use of § 5(b) authorities against China in 1980. See Reply Brief for Petitioners 15, n. 18. While it may be true that the President cannot now resurrect embargo powers under the grandfather clause with respect to China because he has allowed all § 5(b) authorities used against China to lapse, under the Court’s analysis, the President would have been free to place a full embargo on China without complying with the IEEPA until such time as he allowed those powers to expire.