Increasing Community Economic Development and 

Deployment of New Market Tax Credits in Indian Country

A Report Commissioned by the Department of Treasury 

on behalf of the White House Council on Native American Affairs: 

Federal Initiative on Access to Capital in Indian Country 
Initiative on Access to Capital in Indian Country 

Since his inauguration, President Biden has identified insufficient access to capital as a barrier to economic 

development in Indian Country and has committed to fixing this problem. In response, at the 2022 White 

House Tribal Nations Summit, the White House Council on Native American Affairs (WHCNAA) 

Committee on Economic Development, Energy, and Infrastructure (Committee) launched the Federal 

Initiative on Access to Capital in Indian Country, a multi-agency strategy to improve awareness of, 

access to, and utilization of federal funding resources for Tribal governments, Tribal enterprises, Native 

entrepreneurs, and Native Community Development Financial Institutions (CDFIs). 

The U.S. Departments of Agriculture, Treasury, the Interior, Commerce, the Small Business 

Administration, the Office of Management and Budget, and the White House Council of Economic 

Advisors committed to serving as the primary agencies for this WHCNAA effort. 

The elements of the Initiative include three phases of actions: 

1) Access to Resources: identifying, summarizing, and disseminating to Tribal communities all loan 

and financing programs available to Tribes, including through the American Rescue Plan (ARP), the 

Bipartisan Infrastructure Law (BIL), the CHIPS and Science Act, and the Inflation Reduction Act (IRA); 

2) Identification of Barriers & Solutions: identifying barriers to access to capital and summarizing 

policy, regulatory, and statutory solutions to increase access to federal financing programs; and

3) Increasing Utilization: seeking to increase use of federal capital programs by establishing baselines 

of use and setting and tracking metrics.

As a component of Phase 2, the Initiative will develop an interagency report outlining policy, regulatory, 

and statutory changes that will increase access to federal financing programs and develop an interagency 

action plan in response to the findings of the report. To commence Phase 2, the Initiative is releasing 

an inaugural report commissioned by the Department of Treasury (Treasury) extensively evaluating 

community economic development strategies and deployment of New Market Tax Credits (NMTC) in 

Indian Country. 

The Department of Treasury has been active in the Initiative through its first Office of Tribal and Native 

Affairs which advises on the implementation of $30 billion in recovery support to Tribal Nations and works 

on increasing access to economic development in collaboration with Treasury offices and bureaus.

Treasury’s Native Initiative and Research

The NMTC Program, established in 2000, helps economically distressed communities attract private 

capital by providing investors with a federal tax credit. The U.S. Department of the Treasury’s Community 

Development Financial Institutions Fund (CDFI Fund) allocates tax credit authority to Community 

Development Entities (CDEs) through a competitive application process. CDEs use their authority to 

offer tax credits to investors in exchange for equity in the CDE. Using the capital from these equity 

investments, CDEs can make loans and investments to businesses operating in low-income communities 

on better rates and terms and with more flexible features than the market. 
In exchange for investing in CDEs, investors claim a tax credit worth 39% of their original CDE equity 

stake, which is claimed over a seven-year period. The program supports activities as varied as schools, 

affordable housing, arts centers, grocery stores, food production facilities, buildings for human service 

providers, grain elevators, utilities, infrastructure, manufacturing plants, sustainable forestry, and more. 

Since the NMTC Program’s inception, the CDFI Fund has recorded investments totaling over $1.8 billion 

in Indian Country. While these credits have benefitted Tribal communities, Tribal and Native leaders have 

noted challenges to increased deployment in Native areas. 

In response to this feedback, in April 2022, the CDFI Fund launched the NMTC Program Native Initiative. 

The NMTC Native Initiative supports efforts by the CDFI Fund to increase NMTC investment in Federal 

Indian Reservations, Off-Reservation Trust Lands, Hawaiian Home Lands, and Alaska Native Village 

Statistical Areas (collectively referred to as NMTC Native Areas). The primary goal of this initiative is 

to expand access to capital for Native communities via tax incentives the NMTC Program provides. The 

NMTC Native Initiative comprises several fundamental components, which include:

•	 A report titled “Community Economic Development in Indian Country: Market Research Report” 

which reports on successfully implemented community economic development strategies that 

resulted in attracting capital to Native communities and challenges that Native entities face in 

accessing capital for community economic development;

•	 A report titled “New Markets Tax Credit Investments in Native Areas: Selected Case Studies and 

Best Practices” that includes independent findings and recommendations from case studies on 

selected NMTC investments in Native Areas and an analysis of NMTC investment data describing 

the investments that have been made in Native communities;

•	 Technical workshops informing representatives of Native organizations about the purposes and 

mechanics of the NMTC Program;

•	 Individual training sessions with Native organizations seeking to learn more about specific elements 

of the NMTC Program and roles within NMTC-funded projects;

•	 A Self-Assessment Guide for Native Organizations that seek to participate in the NMTC Program 

describing the various roles and the corresponding responsibilities related to the NMTC.

As part of this initiative, technical workshops were held in September 2022 and February 2023 and 

attended by 49 participants. Technical assistance was provided to 6 Native organizations interested 

in utilizing NMTCs, totaling approximately 80 hours. These materials above and the attached reports 

underscore how new federal funding under the Biden-Harris Administration, and the growing 

sophistication of Native CDFIs and other Native actors accessing capital, have enhanced opportunities for 

community economic development in Indian Country. 

Community Economic Development in Indian Country // Market Research Report | pg. 1

Community Economic Development in Indian Country:

Market Research Report

Prepared for:

New Markets Tax Credit Program Native Initiative 

Community Development Financial Institutions Fund (CDFI Fund)

U.S. Department of the Treasury

Washington, D.C. 

Prepared by: 

Kevin Klingbeil, Chloe Adler, Harry Maher, and Devoni Whitehead 

Big Water Consulting 

Nancy Pindus and Amanda Hermans 

Urban Institute 

August 2023
Community Economic Development in Indian Country // Market Research Report | pg. 2

Acknowledgements

The authors wish to thank their colleagues who reviewed this report, providing valuable insights 

and suggestions: Brett Theodos of Urban Institute, Karen Williams and Roman Bitsuie of 

Indigenous Development Partners, and Sean Zielenbach of SZ Consulting. Kaytlin Eldred of

Big Water Consulting contributed to the literature review and earlier drafts of the report. 

We appreciate the contributions of individuals from the organizations listed in Appendix B that 

spoke with members of the research team, sharing their knowledge as well as additional sources 

for this report. 

We thank Christopher Allison, Rosa Martinez, and David Fleites of the U.S. Department of the 

Treasury, CDFI Fund for their guidance throughout and, along with their colleagues at the CDFI 

Fund, for the thorough and thoughtful review they provided.
Community Economic Development in Indian Country // Market Research Report | pg. 3

Table of Contents

Community Economic Development in Indian Country: Market Research Report 1

Acknowledgements 2

Table of Contents 3

List of Figures 6

Executive Summary 7

Foundations of Community Economic Development in Indian Country 7

Essential Components of Community Economic Development 8

Sectors of Community Economic Development 8

Native Actors Promoting Community Economic Development in Indian Country 8

Sources of Funding and Capital for Community Economic Development 9

Community Economic Development Topics Specific to Indian Country 9

Section 1: Introduction and Purpose 12

Section 2: Methods 15

Section 3: Foundations of Community Economic Development in Indian Country 17

Self-Determination and Governance 17

The Rule of Law and Reliable Tribal Bureaucracy 19

Land Management and Jurisdiction 21

Political Stability and Independence 23

Section 4: Essential Components of Community Economic Development 26

Land 26

Location 26

Infrastructure 27

Natural Resources 29

Tribal Workforce 30

Tribal Colleges and Universities 32

Business Development, Credit Access, and Capital Formation 34

Digital Business Capacity 35

Section 5: Sectors of Community Economic Development in Indian Country 37

Natural Resources Processing 37

Natural Gas Extraction 37

Natural Resource Protection and Conservation 38

Manufacturing, Construction, and Utilities 39

Manufacturing 39

Construction 40

Telecommunications Utilities 41

Consumer and Business Services 42

Gaming 42

Hospitality and Tourism 42
Community Economic Development in Indian Country // Market Research Report | pg. 4

Business Services 43

Public Sector, Government, and Community Services 43

Health Care 44

Child Care and Education 45

Section 6: Native Actors Promoting Community Economic Development in Indian Country 46

Community Development Financial Institutions (CDFIs) 46

Community Development Corporations (CDCs) 48

Native Credit Unions and Banks 49

Tribal Economic Development Departments and Chartered Entities 51

Alaska Native Corporations 53

Homestead Associations of Hawaii 54

Tribal Organizations 55

Partnerships and Regional Development Efforts 56

Sovereign Wealth Funds 57

Section 7: Sources of Funding and Capital for Community Economic Development 59

Grants 60

U.S. Department of Housing and Urban Development (HUD) 60

U.S. Department of Agriculture (USDA) 60

U.S. Economic Development Administration (EDA) 61

American Rescue Plan Act (ARPA): Opportunity and Inequitable Funding 62

Loans and Leveraging Sources 62

Federal Loan Guarantee Sources 62

Using Existing Revenue Streams as Loan Collateralization 64

Tax Incentives 64

Programs Incentivizing or Promoting Tribal Community Economic Development 68

Private Capital and Investment 75

Role and Potential of Philanthropy 76

Capital Stacking 79

Section 8: Community Economic Development in Indian Country: Addressing Challenges and 

Moving Forward 81

Opportunities for Community Economic Development in Indian Country 81

The Need for Better Economic Data Regarding Indian Country 83

The Role of Data Sovereignty 85

Impacts of Data Limitations for Native Communities 86

Recommendations for Future Data Collection 88

Cultural Values and Economic Development 89

Conclusion 90

Glossary 92

Appendix A: Special Circumstances Pertaining to Alaska Native Villages, Oklahoma Tribes, 
Community Economic Development in Indian Country // Market Research Report | pg. 5

Pueblos, and Hawaiian Home Lands 96

Alaska 96

Oklahoma 96

Pueblos and Spanish Land Grants 98

Hawaii 99

Appendix B: Organizations Participating in Information Gathering Discussions 101

Bibliography 103

Annotated Bibliography 127
Community Economic Development in Indian Country // Market Research Report | pg. 6

List of Figures

Table 1 | Summary List of Funding Sources.............................................................67
Community Economic Development in Indian Country // Market Research Report | pg. 7

Executive Summary

This Market Research Report is part of a larger project supporting the Community Development 

Financial Institution (CDFI) Fund’s New Markets Tax Credit (NMTC) Program Native Initiative 

(NMTC Native Initiative). The project is being conducted for the CDFI Fund by Big Water 

Consulting and its partners. The NMTC Native Initiative supports efforts by the CDFI Fund to 

explore opportunities to increase Native NMTC investment in Federal Indian Reservations, OffReservation Trust Lands, Hawaiian Home Lands, and Alaska Native Village Statistical Areas 

(NMTC Native Areas) and expand Native communities’ access to capital via the tax incentives 

allocated through the NMTC Program.1

The purpose of this report is to identify and review existing research and data on the unique 

history, challenges, industries, actors, and available funding and capital sources that shape how 

tribes and Native actors successfully participate in community economic development. This 

Market Research Report reviewed existing literature summarizing the history and current state of 

community economic development in Native lands in the United States, focusing on the last 10-

20 years. Materials reviewed include articles or documents prepared by tribal entities; 

universities; philanthropic foundations; academic journals; federal, state, and local government 

or government-sponsored entities; Native membership associations; and Native news 

organizations. 

Below are the highlights of each section of the report, including the foundations, essential 

components, sectors, actors, and funding sources that are relevant to community economic 

development in Indian Country, as well as a forward-looking overview of opportunities and 

challenges.

Foundations of Community Economic Development in Indian Country

Since the 1970s, an era of reemerging self-determination has allowed for the renewed economic 

independence of tribes and Native communities through the steadily expanding assumption of 

traditional government functions, including oversight over health care, housing, roads, 

transportation, courts, and education. The strengthening of tribal capacity and governance 

practices has allowed for progress in tribal community economic development, including the 

growth of tribal gaming and other enterprises. Many tribes have established economic goals and 

are working to achieve parity with neighboring non-Indian communities on a variety of socioeconomic indicators, a goal that has already been reached or surpassed by some tribes. 

1 New Markets Tax Credit Native Areas (NMTC Native Areas) are defined to include Federal Indian Reservations, 

Off-Reservation Trust Lands, Hawaiian Home Lands, and Alaska Native Village Statistical Areas. In addition, this 

report includes community economic development in Oklahoma Tribal Statistical Areas (OTSA), as well as tribal 

projects in urban areas and state-recognized American Indian Reservations. The broader term, Native lands, as used 

in this report, refers to these areas and NMTC Native Areas. The term Indian Country is generally used in the 

common colloquial sense to mean tribal areas, including Alaska Native villages, and is not used as a legal term in 

this report. This report moves between these terms, reflecting the sources used. 
Community Economic Development in Indian Country // Market Research Report | pg. 8

A foundation of governance must be in place for community economic development efforts in 

Native lands to be successful. This includes comprehensive and strategic planning, establishing 

or maintaining a strong rule of law, effective management of tribal lands, and effective balancing 

of cultural values and community economic development goals.

Tribes and Native communities vary tremendously in terms of their governance history and 

structure, state or federal recognition, land ownership scale and status, and capacity to take on 

certain roles and authority. Specific distinctions related to the tribes and Native communities in 

Oklahoma, Alaska, Pueblos and Spanish land grants, and Hawaii are discussed in Appendix A of 

the full report. 

Essential Components of Community Economic Development

If you are a local or a tribal government pursuing a community economic development strategy, 

this requires several common elements:

• Suitable and available land;

• Skilled and ready workforce;

• Business development and digital capacity; and

• Capital formation.

However, economic development is complicated by the rural location, limited population 

density, lower income levels, and inadequate infrastructure of many communities on or near 

tribal lands.

Sectors of Community Economic Development

Community economic development in Indian Country covers the spectrum of industry sectors, 

including:

• Natural resources processing;

• Manufacturing;

• Construction;

• Utilities; 

• Casinos, hospitality, tourism, and recreation;

• Business services; and

• Public sector, government, and community services.
Community Economic Development in Indian Country // Market Research Report | pg. 9

Gaming operations and natural resources extraction and processing have allowed many tribes 

and Native communities to develop the financial resources, business acumen, and relationships 

with external business partners necessary to expand and diversify their community economic 

development. This has been particularly true for Alaska Native Corporations and tribes closer to 

urban areas or major transportation corridors. 

In recent years, the range of community economic development activities has dramatically 

expanded in some Native communities, including development of large-scale retail and health 

care facilities and regional utility and broadband service providers. This is especially true for 

tribes that can leverage revenue streams from large-scale gaming or natural resources extraction 

enterprises. Other tribes and Native communities that have been unable to leverage their location 

or natural resources have faced a much more challenging path to community economic 

development. 

Native Actors Promoting Community Economic Development in Indian Country

The growth in the scale and range of community economic development activities is largely a 

product of the varied Native entities deftly capitalizing on favorable federal contracting 

provisions, opportunities for partnering with Native and non-Native entities to serve regional 

markets, newly available capital, and an array of sector-specific grants and tax incentives 

targeting underserved and disadvantaged areas. These actors include:

• Tribal enterprises;

• Native-owned businesses;

• Tribal departments and chartered tribal entities;

• State licensed Community Development Corporations (CDCs);

• CDFI Fund-certified Native Community Development Financial Institutions (CDFIs);

and

• Community Development Entities (CDEs) that are Native owned or controlled. 

Deep and broad community economic development within individual Native communities often 

depends on the parallel, orchestrated efforts of numerous entities working in concert with one 

another to maximize opportunities available to small, medium, and large-scale projects across 

various sectors.

Growth in regional and national Native economic development-focused organizations, such as 

the Native American Finance Officers Association (NAFOA), National Center for American 

Indian Enterprise Development (NCAIED), and Native CDFI Network, that promote sharing of 

information and collective advocacy, has helped elevate tribal businesses and economic 

development entities throughout the country. Additionally, enhanced coordination with other 

tribes, nearby non-Native communities, and state and regional entities has allowed tribal 
Community Economic Development in Indian Country // Market Research Report | pg. 10

communities of all sizes to develop economies of scale and a critical mass of technical and

financial resources to develop a broader spectrum of mutually beneficial facilities.

Sources of Funding and Capital for Community Economic Development

Native organizations are accessing an expanding array of funding sources, including state and 

federal loans and grants, available private and tribal capital, and tax incentives in order to

increase community economic development on Native lands. The ability to use and combine 

different funding and financing sources largely depends on the scale and purpose of the project 

in question as well as the tribe or Native community’s ability to leverage its own available tribal

capital or general funds and revenue streams.

Tribal community economic development is increasingly layered in terms of the range of 

different Native-owned businesses, tribal enterprises, and financial institutions working in 

coordination to attract new sources of capital to support an array of ventures. These 

organizations are becoming more adept at leveraging or stacking multiple sources to fund 

projects at various cost levels to support small businesses, community facilities, large retail 

centers, and regional service providers.

Community Economic Development Topics Specific to Indian Country 

This report aims to increase knowledge and understanding of community economic development 

strategies in Indian Country. To continue moving forward, economic actors within and outside of 

Indian Country need to hold a shared understanding of the increased opportunities that exist in 

Indian Country, the limitations posed by the need for more data, and the importance of 

respecting cultural values.

Opportunities exist for enhanced community economic development in Indian Country. 

Although challenges remain, the community economic development capacities of tribal and other 

Native communities have improved over time, and tribal governments and enterprises are wellpositioned to pursue new opportunities for growth. There are projects waiting to be done in 

Native communities in various stages of planning, approvals, and obtaining funding. 

Opportunities lie in the growth of tribal enterprises and jobs in the sectors of natural resources 

extraction, manufacturing, construction, hospitality, and public sector projects such as health 

facilities and community centers. Native American CDFIs (Native CDFIs) and other financial 

entities serving Indian Country continue to search for ways to meet a growing demand for credit 

and capital, which will only continue to increase as Native economies and tribal capacities grow. 

Many regional and national Native organizations argue that the issue of community economic 

development in Native lands is now less dependent on capacity-building than on adequate and 

equitable access to financing and capital. These organizations posit that the focus should be on 

developing grant and financing criteria that more fairly incorporate the unique circumstances of 

Native communities 
Community Economic Development in Indian Country // Market Research Report | pg. 11

into application selection criteria, as well as the creation of a set of tribal and Native set-asides to 

ensure tribal participation in certain programs.2

The need for improved data underlies many limitations to community economic development in 

Indian Country.

There are glaring gaps in the available data necessary to support community economic 

development in Native lands, resulting from both a lack of relevant or accurate data being 

collected, and restricted access to the data that do exist. Accurate federal, tribal, and other data 

describing Native lands is not only necessary for supporting internal community economic 

development planning efforts, but it is also essential for allowing lenders and investors to assess 

the opportunities and risks associated with bringing their capital to Native lands. This lack of 

critical data continues to hinder the attraction of capital to Indian Country, though several tribes, 

Native organizations, and local, state, and federal agencies are actively working to improve 

existing data sources and to create new ones. 

Data sovereignty, a component of the overarching sovereignty possessed by Indian tribes, refers 

to the right of indigenous people and nations to govern the collection, ownership, and application 

of their own data.3 As tribes continue to more fully express and implement data sovereignty, 

tribes and Native communities are more actively participating in the design and monitoring 

stages of data collection projects within their lands. They are also developing strong partnerships 

with other tribal and non-tribal organizations at state, regional, and national levels to produce 

much-needed accurate tribal data sets, while retaining tribal ownership and control over the use 

of the data collected. To improve and fill in the gaps in relevant data, a comprehensive 

evaluation of available data sources should be conducted. This evaluation should address the 

issues of data relevance, accuracy, and precision.

Understanding of and respect for cultural values is essential for future community economic 

development in Indian Country.

While tribal governments work towards economic growth, they are also focused on preserving 

tribal culture, identity, sovereignty, population, and land, creating a unique balance of priorities 

that is distinct from other rural communities. All components of community economic 

development in Indian Country are also considered through a cultural lens by tribal actors, 

helping to explain some of the economic decisions made by tribal governments. For example, 

many tribes might make an active choice to avoid developing or exploiting their natural 

resources, such as minerals, water, or forests, for economic gain. While natural resources are a 

common economic resource for most rural areas, land itself, in its unspoiled state, often holds 

2 “Lawmakers Call for Expanded NMTC Access for Native Communities,” Tax Notes, September 28, 2020, 

https://www.taxnotes.com/research/federal/legislative-documents/congressional-tax-correspondence/lawmakerscall-for-expanded-nmtc-access-for-native-communities/2d088. 3 Alex Tammaro, “Native Data Sovereignty Can Address Data Gaps and Improve Equity,” Urban Wire, Urban 

Institute, June 13, 2022, https://www.urban.org/urban-wire/native-data-sovereignty-can-address-data-gaps-andimprove-equity.
Community Economic Development in Indian Country // Market Research Report | pg. 12

significant historical, cultural, and spiritual meaning for tribes. Therefore, the appropriate choice 

for a tribe might be to preserve the land rather than develop its resources for economic growth. 

Tribes might also decide to invest resources into acquiring more land, especially land of historic 

significance, rather than investing in other economic ventures. 

Those interested in partnering on projects in Indian Country can benefit from enhanced cultural 

understanding. When surveyed, Native American nonprofit leaders stressed the desire for 

funders and foundations to have already conducted background research before establishing 

relationships, so that connections are cultivated based on deepened understanding of the specific 

community.4 Outreach to Native tribes needs to be consistent and thorough while acknowledging 

the wide range of perspectives, unique experiences, and complexities of each tribe and 

community. 

4 Ellie Buteau, Hannah Martin, and Katarina Malmgren, “Overlooked (Part Two): Foundation Support for Native 

American Leaders and Communities,” Center for Effective Philanthropy, 2021, http://cep.org/wpcontent/uploads/2021/07/CEP_Overlooked_Native_American.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 13

Section 1: Introduction and Purpose

This Market Research Report is part of a larger project supporting the CDFI Fund’s New 

Markets Tax Credit (NMTC) Program Native Initiative. The New Markets Tax Credit Native 

Initiative project is being conducted for the CDFI Fund by Big Water Consulting and its partners. 

The NMTC Native Initiative supports efforts by the CDFI Fund to explore opportunities to 

increase NMTC investment in Federal Indian Reservations, Off-Reservation Trust Lands, 

Hawaiian Home Lands, and Alaska Native Village Statistical Areas (NMTC Native Areas) and 

expand Native communities’ access to capital via the tax incentives allocated through the NMTC 

Program.5 The NMTC Native Initiative incorporates several core components, including:

• This Market Research Report, which reports on successfully implemented community

economic development strategies that resulted in attracting capital to Native communities 

and challenges that Native entities face in accessing capital for community economic 

development;

• Technical assistance workshops informing representatives of Native organizations about

the purposes and mechanics of the NMTC program;

• Analysis of NMTC investment data describing the investments and activities of tribes and

Native organizations in the NMTC program;

• Case studies exploring past NMTC projects that may provide replicable models for future

projects; and

• A self-assessment guide for tribal entities that seek to participate in the NMTC Program

describing the various roles and the corresponding responsibilities related to the NMTC.

The purpose of this report is to identify and review existing research and data on tribes that have 

successfully implemented community economic development strategies, focusing on NMTC 

Native Areas and other Native lands over the last 10-20 years. The intended audience for this 

report includes: 

• The U.S. Department of the Treasury;

• Congress;

• Tribal and other Native leaders;

• Economic development entities operating within Native lands;

5 New Market Tax Credit Native Areas (NMTC Native Areas) include Federal Indian Reservations, Off-Reservation 

Trust Lands, Hawaiian Home Lands, and Alaskan Native Village Statistical Areas. In addition, this report includes 

community economic development in Oklahoma tribal statistical areas (OTSA), as well as tribal projects in urban 

areas and state-recognized American Indian Reservations. The broader term, Native lands, as used in this report, 

refers to these areas and NMTC Native Areas. The term Indian Country is generally used in the common colloquial 

sense to mean tribal areas, including Alaska Native villages, and is not used as a legal term in this report. This report 

moves between these terms, reflecting the source used. More complete definitions of these terms and others can be 

found in the Glossary.
Community Economic Development in Indian Country // Market Research Report | pg. 14

• Local, state and federal agency staff involved in community economic development 

promotion or regulation; 

• Non-Native entities involved in or interested in economic development activities in 

Native lands; and 

• Others who are simply seeking to better understand the challenges of and opportunities 

for community economic development in Native lands in the United States.

To serve these varied audiences, this report provides a broad view of community economic 

development in Native lands. Community economic development refers to a combination or 

integration of community development and economic development processes. Community 

development aims to make a community a better place to live and work by building community 

assets and institutions. Economic development focuses on the creation of wealth and economic 

opportunities. Community economic development recognizes that the two processes are 

interrelated–economic development is not possible without a solid community foundation, and 

communities need economic opportunities to thrive.6

The report synthesizes information that will help you understand the unique context for 

community economic development in Native lands, including the types of projects that are 

underway, as well as challenges, opportunities, and successful strategies. This may be 

particularly interesting if you are interested in pursuing community economic development in 

Native lands as new enterprises, participants, partners, or investors.

No summary of community economic development in Native lands would be thorough or 

accurate if it did not address the actors, programs, and sources of funding and capital involved in 

catalyzing community economic development. But this report also considers the unique 

historical, cultural, geographic, and land-related contexts that shape community economic 

development activities in Native lands. As a result, each of the community economic 

development projects, initiatives, and programs described in this report are evaluated with the 

understanding that, in addition to traditional market forces and principles that drive decisionmaking, community economic development decisions within Native lands have an 

accompanying cultural overlay that may reshape, constrain, or even defeat projects or initiatives 

that may otherwise be viewed as economically sound. 

The next section of this report, Section 2, describes the methodology we used to compile this 

information. Section 3, Foundations of Community Economic Development in Indian Country, 

includes a discussion of self-determination and governance, the rule of law and reliable tribal 

bureaucracy, land management and jurisdiction, and political stability and independence. All 

tribes and Native communities are unique in their land and governance structures pertinent to 

community economic development, but some groups face special circumstances not covered in 

Section 3. Appendix A is included to describe special circumstances pertaining to Alaska Native 

6 Rhonda Phillips and Robert H. Pittmane, eds, An Introduction to Community Development, (New York: Routledge 

2009), Chapter 1.
Community Economic Development in Indian Country // Market Research Report | pg. 15

Villages, Oklahoma tribes, pueblos and Spanish land grants, and Hawaiian Home Lands. Section 

4, Essential Components of Community Economic Development, describes the elements that any 

local or tribal government pursuing a community economic development strategy needs: suitable 

land available for the intended purpose of economic development; a skilled and ready workforce; 

and business development and capital formation capacity. Section 5, Sectors of Economic 

Development, provides examples of the economic activities underway in Indian Country, 

including natural resource processing; manufacturing, construction and utilities; consumer and 

business services; and public sector, government, and community services. Section 6 describes 

the Native actors promoting economic development in Indian Country. Section 7 describes 

sources of funding and capital for community economic development. Section 8, Community 

Economic Development in Indian Country: Addressing Challenges and Moving Forward, 

concludes with a forward-looking summary of both the challenges and opportunities facing 

community economic development in Indian Country. It especially describes data limitations in 

Native communities, as well as the importance of respecting cultural values for future success.
Community Economic Development in Indian Country // Market Research Report | pg. 16

Section 2: Methods

This section covers the methods used to conduct research and review of the current state of 

community economic development in Native lands in the United States.

The foundation of this Market Research Report is a review of existing literature summarizing the 

history and current state of community economic development in Native lands in the United 

States. Materials reviewed for this report include:

• Peer reviewed and sponsored studies, such as articles or documents prepared by tribal 

entities;

• Universities;

• Philanthropic foundations;

• Academic journals;

• Federal, state, and local government or government-sponsored entities;

• Native membership associations; and

• Native news organizations.

7

While we focused on identifying and incorporating materials that addressed community 

economic development in Native lands within the past 10-20 years, many of the challenges, 

opportunities, and models described in recently published materials were and are affected by 

laws, policies, programs, and funding mechanisms that long preceded them. To account for this, 

we occasionally drew from materials or reference events that fell outside of this period. This 

approach accounts for the slow evolution and relatively recent emergence of community 

economic development activities driven by sovereign tribal governments and Native 

communities on Native lands.

To guide the research that would inform this report, we first prepared an annotated bibliography 

of known resources from prior research that concerned community economic development in 

Indian Country, as well as relevant materials that were recently published or shared online by a 

variety of tribal and federal government, nonprofit, industry, and academic actors. We shared 

this bibliography with staff of the CDFI Fund to ensure that the materials were relevant, 

comprehensive, and appropriate. This step also provided the CDFI Fund staff with the 

opportunity to share any relevant materials compiled during the course of their work. We further 

targeted specific sectors, programs, funding sources, and model projects and activities to provide 

greater context for and specific examples of the themes found throughout the initial list of 

materials.

7 A government-sponsored entity, also known as a government-sponsored enterprise (GSE) is a quasi-governmental, 

privately held agency established by Congress to improve credit flow in some regions of the United States' 

economy. GSEs provide financial services to the public for various things, particularly mortgages, through capital 

market liquidity. GSEs help to facilitate borrowing for a variety of individuals, including students, farmers, and 

homeowners.
Community Economic Development in Indian Country // Market Research Report | pg. 17

Many initiatives unfolding within Native lands are not summarized in traditional published 

academic journals or newspapers. Additional resources included materials that may have only 

been distributed internally, shared at conferences, or prepared for specific uses such as advocacy, 

congressional testimony, or inter-organizational collaboration. 

To provide a more complete view and identify additional resources, we conducted conversations 

with individuals knowledgeable about the complexity of community economic development in 

Native lands. In preparation for these conversations, we developed an initial list of potential 

participants based on a list of organizations and contact persons provided to the team by the 

CDFI Fund. The lists included points of contact from:

• Native CDEs and Native CDFIs serving NMTC Native Areas;

• Non-Native CDEs that have made NMTC investments in NMTC Native Areas; and

• Staff members of federal agencies and national Native organizations that focus on 

community economic development in Native lands, including:

o Native American Finance Officers Association (NAFOA) 

o Native CDFI Network

o National Congress of American Indians (NCAI) 

o Federal Reserve Bank of Minneapolis’ Center for Indian Country Development

We shared this list with staff of the CDFI Fund to ensure that the individuals and organizations 

included were relevant, representative, and appropriate. We developed a short list of standard 

questions concerning relevant materials and topics to provide structure and consistency for each 

conversation. The conversations were relatively limited in scope and length (30-60 minutes). Not 

all of the individuals who received a request responded or agreed to participate in a conversation 

with the research team. We conducted a total of 18 interviews over a 7-week period. Appendix B 

lists the organizations that participated in interviews.

These conversations unearthed new examples and model activities, while also allowing subject 

matter experts to address and contextualize the layering of challenges and opportunities for 

community economic development that are summarized in published materials. The 

conversations triggered further research and shaped our interpretation of topics that received only 

cursory treatment by other sources. 

A list of all referenced materials accompanies this report and contains the full citations for the 

materials summarized in the report. An annotated bibliography with more extensive summaries 

of selected referenced materials is included as an addendum. This will allow you to further 

explore the focus and findings of these source materials.
Community Economic Development in Indian Country // Market Research Report | pg. 18

Section 3: Foundations of Community Economic Development in 

Indian Country

This section provides brief context for the events that led to the economic marginalization of 

Native communities and how these communities have been prioritizing economic development in 

recent decades. 

Community economic development aims to create conditions that allow for both short- and longterm sustainability of an area and considers both physical and social infrastructure. In Native 

communities, community economic development activities, such as accessing resources and 

setting economic priorities, come with unique cultural and historical context. Considerations of 

self-determination, governance, the rule of law, land management and jurisdiction, the political 

landscape, population retention, and cultural values are all important.

Self-Determination and Governance

The arc of Native community economic development in the United States resembles a swinging 

pendulum. European colonization of the Americas and the subsequent wars and United States 

policies resulted in the loss of tribal land and population, the disruption of tribal economies, and 

an increased tribal dependency on the federal government. Native economies that had been 

successful and sustainable before colonization became “reservation economies that were cut off 

from significant aboriginal lands and resources,” and were oftentimes dependent on failed 

federal programs.8 As a result, Native tribes and communities have long suffered from economic 

marginalization and a lack of opportunity. Unemployment and family poverty rates for American 

Indians remain higher than for the general U.S. population, while per capita income and labor 

force participation are lower, according to 5-year estimates (2011-2015) of American 

Community Survey data.9

In recent decades, strengthened tribal capacity and governance has allowed tribes to make 

progress in community economic development. The continued implementation of the federal 

policy of self-determination has given tribes more opportunities to administer their own 

programming and has allowed for the growth of tribal gaming and other enterprises. Many tribes 

have established economic priorities and are working to achieve parity with neighboring nonNative communities on a variety of socio-economic indicators. This goal of parity has already 

been reached or exceeded by some tribes, while many others are making significant strides.10

8 Dick G. Winchell, “Indigenous Rural Renewal in the Inland Pacific Northwest: The Emergence of American 

Indian Tribes in Regional Economic Development,” Journal of Rural and Community Development 8, no. 3 (2013): 

175, https://journals.brandonu.ca/jrcd/article/view/1036/253.

9 Randall Akee, “Sovereignty and Improved Economic Outcomes for American Indians: Building on the Gains 

Made Since 1990,” Washington Center for Equitable Growth, January 14, 2021, 

https://equitablegrowth.org/sovereignty-and-improved-economic-outcomes-for-american-indians-building-on-thegains-made-since-1990.

10 Winchell, “Indigenous Rural Renewal.”
Community Economic Development in Indian Country // Market Research Report | pg. 19

Tribal sovereignty is one of the critical elements that has made it possible for tribes and Native 

communities to engage more extensively in community economic development. The law of tribal 

sovereignty has developed in the federal courts and by federal statutes, executive orders and 

treaties over the last two centuries, and now rests on several fairly well-settled tenets: 

1. Tribes have virtually unlimited authority over internal tribal affairs; 

2. Tribes are subject to the plenary, or absolute, power that Congress has over them; 

3. Tribes are presumptively immune from state law; 

4. Tribes cannot be sued absent their express consent or a waiver of their immunity; and

5. Tribal sovereign immunity does not extend to individual tribal members except to the 

extent that tribal officials act within the scope of their official capacities.

11

 

While the unique, and in many cases, treaty-affirmed, status of tribes as sovereign nations within 

the United States has always implied some level of legal self-determination tribes in the U.S. 

have only recently been able to practically take advantage of their status as sovereign entities. 

Despite the sovereign status of tribes, some land allotment and settlement strategies were 

designed to weaken or nullify traditional tribal governments by giving land ownership to 

individuals through fee simple titles instead of preserving more traditional communal land 

management practices. American Indians living on reservations were not granted citizenship 

until the Snyder Act in 1924, and other federal policies throughout the mid-twentieth century 

sought to weaken tribal power by drawing American Indian populations into urban areas and, in 

some cases, ending their federal recognition in exchange for cash settlements.12 

With the passage of the Indian Self-Determination and Education Assistance Act in 1975, federal 

policy toward American Indian tribes shifted toward self-determination, giving tribes more 

power over the programs and resources available to them. Tribes and Native communities 

primarily used two common approaches to community economic development in this era: the 

standard approach and the nation-building approach.13 The standard approach, which is 

characterized by external control, a short timeline, and a lack of big-picture strategy, has 

dominated tribal economic development for years. But the nation-building approach, which 

centers sovereignty, has been a more successful and sustainable strategy. The nation-building 

approach puts practical decision-making power in the hands of Indian nations and prioritizes 

effective governing institutions and strategic thinking. This approach to development starts not 

11 Sue Woodrow, “Tribal sovereign immunity: An obstacle for non-Indians doing business in Indian Country?” 

Federal Reserve Bank of Minneapolis, July 1, 1998, https://www.minneapolisfed.org/article/1998/tribal-sovereignimmunity-an-obstacle-for-nonindians-doing-business-in-indian-country. 

12 Akee, “Sovereignty and Improved Economic Outcomes.”

13 Stephen Cornell and Joseph P. Kalt, “Two Approaches to Economic Development on American Indian 

Reservations: One Works, the Other Doesn’t,” (2006): 2, 

https://www.honigman.com/media/site_files/111_imgimgjopna_2005-02_Approaches.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 20

with “what can be funded?” but with “what kind of society are we trying to build?” and pursues 

funding or economic opportunities from there.14

Strategic and comprehensive planning enables sustainable economic development in Indian 

Country. Comprehensive planning focuses on what can be done with the resources already on 

hand—such as land or natural resources—while strategic planning takes a larger view that 

includes attracting new capital investment. Careful development and adoption of both types of 

plans through strong grassroots participatory processes can pave the way for long-term, 

consistent decision-making. Ted Jojola, an indigenous planning expert, notes that initial 

successes with enterprises like gaming can make it easier for tribes to begin strategically 

planning because profits from existing enterprises can be reinvested in an “economic 

development strategy with the intent of diversifying outside of their own limited resource 

base.”15

This shift to self-determination and nation-building strategies has proven essential in promoting 

economic development for many tribes. Many tribes have taken three specific steps to create an 

environment where community economic development and entrepreneurialism can flourish:

1. Emphasizing the rule of law;

2. Separating politics from day-to-day administration and business; and

3. Creating efficient and reliable tribal bureaucracy.

16

Despite the progress that has been made in these areas, there is still more work to be done in 

many tribal and Native communities to build a capacity capable of handling large economic 

development investments. We discuss some challenges and recommendations regarding these 

three capacity-building elements below.

The Rule of Law and Reliable Tribal Bureaucracy 

By taking steps such as establishing and enforcing property rights and methods for resolving 

disputes, tribal governments can establish a strong rule of law laying out clear rules of 

community economic development for all actors. This predictability and stability clarifies 

expectations and encourages confidence for private business investment.

Tribes seeking to promote economic development should have a bureaucracy that enables 

economic activity. Clear and timely permitting processes and dispute resolution mechanisms are 

just some of the ways that efficient and well-framed bureaucracy can encourage business 

14 Cornell and Kalt, “Two Approaches,” 17.

15 Ted Jojola, “Indigenous Planning—An Emerging Context,” Canadian Journal of Urban Research 17, no. 1 (2008): 

44, https://www.uwinnipeg.ca/ius/docs/cjur/37-47_Jojola.pdf.

16 Pettit et al., “Continuity and Change: Demographic, Socioeconomic, and Housing Conditions of American 

Indians and Alaska Natives,” U.S. Department of Housing and Urban Development Office of Policy Development 

and Research. 2014. 37, https://www.huduser.gov/portal/publications/commdevl/housing_conditions.html.
Community Economic Development in Indian Country // Market Research Report | pg. 21

development.17 Native community members, Native entrepreneurs, tribal enterprises, and tribes 

themselves will have greater success as borrowers if tribal legal infrastructure signals that 

contracts will be honored, loans will be repaid, transactions will progress smoothly, and 

decision-making is transparent.18 The adoption of Uniform Commercial Codes is one example of 

how tribes have sought to encourage investment and lending. These codes establish clear rules 

governing secured transactions between creditors and debtors that facilitate the flow of credit.19 

Streamlining tribal bureaucracy can be complicated by the fact that tribal members and their 

lands are often at least partially subject to multiple legal jurisdictions. While many tribes in the 

United States are considered sovereign nations, their lands still sit within a state and county. 

Because most tribal land is held in trust by the federal government for the benefit of tribes and 

individual tribal members (discussed in detail below), often both federal and tribal officials 

have—sometimes conflicting—authority over these lands. In addition, in some limited cases 

states also have legal or tax authority over tribes or their enterprises.20 This can make for a 

confusing mix of authority when it comes to community economic development. 

To help enterprises and investors navigate this unique system, tribes should take care to make 

their own rules and regulations clear and clarify any state and local authority, or lack thereof, to 

regulate or tax specific activities through negotiation or litigation. When concurrent jurisdiction 

issues occur, tribes might use their community economic development plans to outline which 

lands are subject to concurrent, tribal, or non-tribal jurisdiction. If possible, tribal governments 

should create collaboration agreements with other jurisdictions that have authority within tribal 

areas, setting standards so that the timing of decisions is more predictable for developers. Some 

tribes have established specific agreements with states or counties regarding the collaborative 

exercise of jurisdiction. For example, the Tulalip Tribes have a tax sharing compact with the 

State of Washington.21

Sudden changes to the legal landscape or unclear legal or jurisdictional authority can put 

community economic development at risk. Many Native communities grappled with this issue 

following the passage of Public Law 280 (PL 280) in 1953. In response to what was considered 

“weak law enforcement apparatus” on reservations, PL 280 transferred jurisdictional authority 

over criminal and civil matters in Indian Country to the states.22 This created concurrent 

jurisdiction of state and tribal authorities in tribal areas, which in many cases was confusing and 

ambiguous. It reduced tribal budgets while not providing any additional resources to states for 

17 Stephen Cornell, “What Makes First Nations Enterprises Successful?” 12-13 

18 “Access to Capital and Credit in Native Communities,” Native Nations Institute, 2016, 73, 

http://nni.arizona.edu/application/files/8214/6378/9056/Access_to_Capital_and_Credit_in_Native_Communities.pdf 

19 Susan Woodrow, "Uniform Commercial Codes: Bringing Business to Indian Country. Tribal Secured 

Transactions Laws: A Working Forum," Presentation, 2013, retrieved on September 8, 2022 from 

https://www.bia.gov/sites/default/files/dup/assets/as-ia/ieed/pdf/idc1-024558_508.pdf. 20 Lofthouse, “Institutions and Economic Development,” 237.

21 “Tax Sharing Compact Between The Tulalip Tribe and the State of Washington,” 2020, 

https://www.hca.wa.gov/assets/program/tax-sharing-compact-tulalip-tribes-of-wa-and-wa-state.pdf.

22 Valentina Dimitrova-Grajzl, Peter Grajzl, A. Joseph Guse, “Jurisdiction, Crime, and Development: The Impact of 

Public Law 280 in Indian Country,” Law & Society Review 49, no. 1 (2014).
Community Economic Development in Indian Country // Market Research Report | pg. 22

enforcement. As Dimitrova-Grajzl, et al. put it, “PL 280, on the one hand, eroded the powers of 

the local community to deal with crime and social problems and, on the other hand, provided 

enough ambiguity for authorities not to deal effectively with enforcement on reservations.”23 

In the last decades of the twentieth century, the push for self-determination brought with it the 

rise of tribally controlled law enforcement agencies. There are currently over 250 tribal law 

enforcement agencies, most of which are administered fully by tribes under contract with the 

Bureau of Indian Affairs (BIA)’s Division of Law Enforcement Services.24 Officers and other 

law enforcement employees are most often tribal employees. Complementing the authority of 

tribal police agencies is the tribal court system. In 2014, about 234 tribal courts served federally 

recognized tribes in the lower 48 states, 77% of which exercised both civil and criminal 

jurisdiction. Approximately 80% of these tribal courts served 9,999 or fewer residents.25

Tribal authority over tribal issues plays a vital role in establishing stability and safety in tribal 

areas. According to Wakeling, et al., only those tribes that have acquired meaningful control over 

their governing institutions have experienced improvements in local economic and social 

conditions, and research has not found “a single case of sustained economic development where 

the tribe is not in the driver’s seat.”26 Laws that protect people and property, effective law 

enforcement, and stable and reliable courts support community economic development by 

reducing risk or the perception of risk to investors. Few people would want to invest their money 

in places that cannot or will not protect their resources and interests, or where that protection is 

uncertain.

Land Management and Jurisdiction

The management of tribal lands is a key function of tribal governments. Historical, political, and 

cultural forces have resulted in unique legal and regulatory circumstances governing tribal lands 

in the United States.27 Through the federal trust system, the federal government is the legal 

owner and guardian of about 95% of the land in Indian Country—it holds about 56.2 million 

acres in trust for American Indian tribes or individuals.28 Tribal lands placed into trust have been 

acquired by the secretary of the U.S. Department of the Interior (DOI), who then holds the titles 

23 Ibid. 

24 “Tribal Law Enforcement,” Bureau of Justice Statistics, accessed September 6, 2022, 

https://bjs.ojp.gov/topics/tribal-crime-and-justice/tribal-law-enforcement. 

25 Steven W. Perry, Michael B. Field, and Amy D. Lauger, “Tribal Courts in the United States, 2014 – Statistical 

Tables,” Bureau of Justice Statistics, July 2021, 

https://bjs.ojp.gov/sites/g/files/xyckuh236/files/media/document/tcus14st_0.pdf. 

26 Stewart Wakeling, Miriam Jorgensen, Susan Michaelson, Manley Begay, “Policing on American Indian 

Reservations,” U.S. Department of Justice, July 2001, https://www.ojp.gov/pdffiles1/nij/188095.pdf.

27 This section pertains specifically to tribal lands in the lower 48 United States. Certain areas in those states, as well 

as Alaska Native villages, and Hawaiian Home Lands operate under different legal and regulatory circumstances, 

described later in this section.

28 Lofthouse, “Institutions and Economic Development,” 232-235. 
Community Economic Development in Indian Country // Market Research Report | pg. 23

for the benefit of a Native American tribe or individual tribal members.29 There are two types of 

trust land: 

• Tribal trust lands, which are held by the federal government on behalf of tribal 

governments, and 

• Allotted trust lands, which are held by the federal government on behalf of individual 

tribal members.

Because allotted trust lands are held in trust for individual allottees and their descendants, trust 

parcels are often passed down to multiple descendants and are then owned by more than one 

owner as undivided interests.30 This often results in fractionated land ownership, which can limit 

owners’ ability to develop the land, because development decisions need the agreement of the 

owner(s) of a majority interest. There is some precedent for consolidating these fractionalized

interests: As a part of the settlement of Cobell v. Salazar in 2009, the Land Buy-Back Program 

for Tribal Nations offered limited opportunities for willing sellers to sell their fractionalized 

interests in trust or restricted land at a fair market value to the established $1.9 billion Trust Land 

Consolidation Fund. The newly consolidated interests were then restored to tribal trust 

ownership for uses that would benefit the reservation community and tribal members. The Land 

Buy-Back Program allowed for the consolidation of more than 800,000 interests, equivalent to 

2.3 million acres across 50 locations in 15 states. But the program ended in 2022, curtailing its 

potential for future impact.31

While trust lands make up most tribal lands, reservations also frequently contain fee simple 

lands, or lands that are owned outright by individual tribal members, the tribe, or another owner,

rather than being held in trust. Fee simple lands are subject to county and state jurisdiction unless 

they are purchased by the tribe and placed into trust with the federal government.32 Different 

reservations have different mixes of land under these various systems of land tenure. 

Although the trust system was designed to prevent further loss of Native lands, it complicates 

private property rights—an important tenet of U.S. market participation—for tribes and tribal 

members. Tribes and some tribal members lack the ability to use their homes or land as 

29 “Benefits of Trust Land Acquisition (Fee to Trust),” Department of the Interior, accessed April 27, 2023, 

https://www.bia.gov/service/trust-land-acquisition/benefits-trust-land-acquisition.

30 David Listokin, Kenneth Temkin, Nancy Pindus, David Stanek, “Mortgage lending on tribal land: A Report from 

the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing needs,” U.S. Department of 

Housing and Urban Development, 2017, https://www.huduser.gov/portal/publications/NAHSC-Lending.html. 

31 “Land Buy-Back Program for Tribal Nations: About,” U.S. Department of the Interior, accessed January 10, 2023, 

https://www.doi.gov/buybackprogram/about. 

32 Rachel Kramer et al., “Assessment of the Housing Needs of American Indians, Alaska Natives and Native 

Hawaiians in Washington State,” Big Water Consulting for Washington State Dept. of Commerce, 2021, 

https://www.commerce.wa.gov/about-us/reports-publications. 
Community Economic Development in Indian Country // Market Research Report | pg. 24

collateral, since they are not the legal owners of that land.33 This can constrain or even prevent 

the development or purchase of new homes, since potential homeowners may be unable to get 

loans. Homes on trust land also tend to be severely undervalued, as the market itself is stifled. 

These two factors constrain homeownership in Native communities, which is a significant tool 

for building intergenerational wealth. Economist Jordan K. Lofthouse concludes that the “land 

trust impedes market participation and skews economic calculation,” presenting a continued 

challenge for Native community economic development.34 

Some tribes have found creative ways to circumvent the limitations of trust land using the 

Helping Expedite and Advance Responsible Tribal Home Ownership Act (HEARTH Act) of 

2012. For example, according to Lofthouse, “some tribal governments have begun using 

leasehold mortgages and long-term lease income as collateral on loans.”35 The HEARTH Act is 

a voluntary program administered by the Department of the Interior that offers tribes a more 

efficient land leasing process with less Bureau of Indian Affairs oversight. Tribes that have 

approved leasing regulations under the Act can significantly reduce the time it takes to execute 

and approve leases, which can encourage potential lessees to invest and develop in tribal 

communities. HEARTH Act leasing regulations can apply to residential, business, and 

agricultural leases, as well as leasing for public, religious, educational, or recreational purposes. 

The BIA maintains a list of all tribes with HEARTH Act authorization by year and type: As of 

2022, 77 unique tribes have had tribal leasing regulations approved by the Secretary of the 

Interior.36 Among these, 72 leasing regulations apply to the leasing of land for business 

purposes. 

While many tribes have not developed their own land leasing regulations under the HEARTH

Act, the Ho-Chunk Nation provides an example of a successful use of the law to speed up land 

leasing and unlock capital. Prior to the approval of the Ho-Chunk Nation’s land leasing 

regulations by the BIA, it took up to 18 months for the lease processing; but after 2016, when the 

Ho-Chunk Nation’s Ho-Chunk Realty Division was established, the time to acquire a lease was 

reduced to four to six weeks.37 This more streamlined process can encourage business 

investment by reducing wait times, removing uncertainty in leasing processes, and allowing the 

tribe to provide longer leases to business entities. It can also help to attract larger job-generators, 

such as manufacturing plants, which must obtain site control and frequently borrow 

33 Carla F. Fredericks and Kate R Finn, “Harnessing Private Equity for Indigenous Peoples. Boulder, CO: First 

Peoples Worldwide,” University of Colorado, Boulder, 2020, 

https://www.colorado.edu/program/fpw/sites/default/files/attachedfiles/harnessing_private_equity_for_indigenous_peoples_-_final.pdf. 

34 Lofthouse, “Institutions and Economic Development,” 243. 

35 Lofthouse, “Institutions and Economic Development,” 234.

36 “Approved Hearth Act Regulations,” Bureau of Indian Affairs, accessed September 2, 2022, 

https://www.bia.gov/service/HEARTH-Act/approved-regulations. 

37 Patrice H. Kunesh, “Case Study: HEARTH Act Implementation,” Essay, in Tribal Leaders Handbook on 

Homeownership, 88–92, Minneapolis, MN: Federal Reserve Bank of Minneapolis – Center for Indian Country 

Development, 2018. 
Community Economic Development in Indian Country // Market Research Report | pg. 25

predevelopment capital to perform preliminary construction design and bidding, site 

investigations such as environmental and geotechnical investigations, and to pursue construction 

financing. If lease approvals take a year or more, the holding costs for predevelopment capital 

and the risk of non-approval become severe impediments. The delays and leasing complexities of 

typical trust lands can make them noncompetitive for businesses that can otherwise locate 

outside of Native lands without encountering these problems. But by leveraging HEARTH Act 

authority, tribes can streamline access to capital through leasehold mortgages in an important 

step for bringing non-tribal capital to their area.

Political Stability and Independence

After the Indian Reorganization Act (IRA) of 1934 allowed tribes to adopt their own 

constitutions, various forms of political and governance structures emerged across Indian 

Country. Many tribes have modeled their constitutions after the federal system with three distinct 

branches of government, but others have developed theocracies, parliamentary systems, and 

other government structures.38 These various systems have different implications for tribal 

economic activity. 

The differences in governance among tribes and other Native communities create challenges for 

non-Native capital providers and businesses because the knowledge and experience obtained by 

working with one tribe is not necessarily applicable to another tribe. Working with Alaska 

Native Corporations and Villages and Native Hawaiian communities also involves different sets 

of policies and procedures. Some tribal governments have institutionalized lease terms (see 

discussion of the HEARTH Act above). Others have developed processes for preparing and 

approving limited waivers of sovereign immunity and the related approvals and contract 

provisions and implemented environmental regulations, historical and archaeological reviews, 

systems development or impact charges, tribal taxes, and other regulatory mechanisms. It is vital 

for tribes to provide clear and reliable explanations of the issues relevant to their operations for 

non-Native partners, because they can help quantify timelines and establish standards for 

approvals. While the substance of the decision-making criteria may reflect tribal values and 

needs—and therefore be different from a nearby non-tribal government’s substantive 

regulations—clarity and consistency will allow non-Native tribal partners to predict and price 

their risk.

As with any jurisdiction, the political and economic realms of tribal affairs are likely to be 

closely tied. Constituents elect leaders who promise to respond to their desire for good jobs and 

other economic opportunities, and those leaders in turn pursue initiatives to spur economic 

growth. But having these two realms too closely tied together can impede economic 

development. Especially in systems where elections are involved, it is important to maintain a 

separation between politics and economic activity.

38 Lofthouse, “Institutions and Economic Development.” 
Community Economic Development in Indian Country // Market Research Report | pg. 26

Cornell notes that empowering business managers to make decisions free from political 

considerations can make for stronger business practices.39 While tribal governments may have a 

role to play in creating the big picture goals for a tribe’s economic development, the day-to-day 

management should be free from the sway of politics. A long-term strategic plan that has 

received community approval may help to promote stability and protect implementation from 

political influence.40 

Cornell also suggests having a board of directors that oversees a Native-owned enterprise or 

collection of enterprises to help manage the politics-business connection. Such boards can 

introduce diverse expertise into upper-level decision-making and help protect the enterprise from 

political interference. Cornell further suggests board member terms that are longer than council 

terms, requiring two-thirds council approval to remove a board member, and allowing boards to 

appoint members themselves, with council approval, to maintain the balance between 

independence and accountability.41

However, a clean separation of economic development and politics is not in keeping with the 

governance models of some tribes. Many tribes are participatory democracies that actively 

encourage or require consensus through deliberation at the local level. These systems are built on 

historical tradition and continue to be practiced today.42 And while separating politics and 

economic development is one strategy for creating economic stability, political stability in itself 

can also help encourage community economic development activity. A political system that is 

predictable and reliable makes investment less risky, as the economic landscape will not be 

subject to upheaval with each election season. Alternatively, long-serving politicians who are not 

subject to short term limits might provide consistency and can focus on long-term economic 

development goals and projects, rather than just the projects that will help advance their electoral 

platforms in the next cycle.

In summary, regulatory consistency and transparency on the part of tribal governments, federal 

policies that recognize sovereignty and facilitate efficiencies in development processes, and a 

recognition of Indian Country’s diverse historical, cultural, and political context are all necessary 

components to fostering community economic development in Native lands.

39 Stephen Cornell, “What Makes First Nations Enterprises Successful? Lessons from the Harvard Project,” Joint 

Occasional Papers on Native Affairs, 2006.

40 Denny Hurtado, “From the Rebuilding Native Nations Course Series: ‘The Importance of Strategic Planning,’” 

Native Nations Institute for Leadership, Management, and Policy, University of Arizona, Tucson, Arizona, March 

26, 2009, Interview.

41 Stephen Cornell, “What Makes First Nations Enterprises Successful?” 12-13.

42 Kahente Horn-Miller, "What Does Indigenous Participatory Democracy Look Like? KahnawÃ :Ke's Community 

Decision Making Process," Review of Constitutional Studies 18, no. 1 (2013). 
Community Economic Development in Indian Country // Market Research Report | pg. 27

Section 4: Essential Components of Community Economic 

Development

This section provides insights on key elements that are required for tribal governments to pursue 

community economic development.

Any local or tribal government pursuing a community economic development strategy requires 

several common elements: 

• Suitable land available for the intended purpose of community economic development;

• A skilled and ready workforce; and

• Business development and capital formation. 

This section describes each of these elements. The discussion of land includes the particulars of 

location, infrastructure, and natural resources relevant to community economic development. 

The workforce section addresses the challenge of attracting workers as well as skills training and 

the role of tribal colleges and universities. Finally, the section on business development describes 

the importance of a market that includes suppliers, consumers, and adequate 

telecommunications.

Land

Location

Proximity to markets is important for economic growth. For example, it would be difficult to 

maintain a successful resort and casino on a reservation that is too remote to draw visitors and 

tourists from the surrounding area. To attract or maintain successful business enterprises and 

outside investors in the manufacturing, hospitality, or retail sectors, tribes need consistent access 

to suppliers, consumers, and employees. In seeking new or additional locations, often businesses 

screen locations based on population density and income demographics to forecast sales per 

square foot, revenue, and capacity for stand-alone profitability–metrics that place remote 

communities at a significant disadvantage. For tribes that are near other rural or urban 

communities, it may be advantageous to establish economic relationships with those 

communities. Research has found that “tribes that are more integrated with off-reservation 

economies have higher individual income, employment, and quality of life.” 43

It is important to point out that the remote locations of many reservations were the product of 

intentional choices made in the past by the federal government, choices that have “isolated the 

reservation from urban markets” and created a “legacy of federal neglect [that] has left an 

infrastructural base insufficient for development.”44 While the federal outlook has shifted since 

43Lofthouse, “Institutions and Economic Development,” 239.

44 Janet E. Kodras, “The Changing Map of American Poverty in an Era of Economic Restructuring and Political 

Realignment,” Economic Geography, 73:1 (1997): 87, DOI: 10.1111/j.1944-8287.1997.tb00085.x.
Community Economic Development in Indian Country // Market Research Report | pg. 28

the time that these decisions were made, generations later tribes are still dealing with the 

consequences of these harmful policies,45 and routine appropriations are inadequate to both catch 

up with and deal with the resulting current needs.46 The remote locations of many reservations 

create impediments to siting grocery stores, pharmacies, chain restaurants, and other retail 

establishments, which have significant impacts on tribal members’ quality of life and cost of 

living. 

Infrastructure

Adequate basic infrastructure–in the form of roads, energy, water, waste management, and 

telecommunications–is a prerequisite for community economic development. Access to these 

critical components can be a challenge for Native communities due to the remote location of 

many reservations, challenging terrain within their lands, and a lack of adequate funding for 

improvements. A 2017 survey related to housing development in tribal areas found that 

infrastructure development was the most frequently cited barrier driving rising development 

costs.47 Several tribes cited a lack of available funding, in addition to physical construction 

challenges, when explaining why it was difficult to service new housing development with 

adequate infrastructure.48 

Several funding sources are available to support the development or maintenance of 

infrastructure on tribal lands. These include funds from: 

• The Indian Health Service (IHS) (especially Sanitation Facilities Construction); 

• U.S. Department of Agriculture (USDA) Rural Development; 

• Environmental Protection Agency (EPA), especially the Environmental General 

Assistance Program; and 

• U.S. Department of Housing and Urban Development’s (HUD) Indian Community 

Development Block Grant (ICDBG) and Indian Housing Block Grant (IHBG), which can 

be used specifically for infrastructure.49 The Infrastructure Investment and Jobs Act of 

45 For example, Opportunity Zones, included in the Tax Cuts and Jobs Act of 2016 and designed to promote 

economic development in underserved areas, initially excluded tribal governments from participating in Opportunity 

Funds, a vehicle that investors can use to pool funds for development in Opportunity Zones. This oversight has since 

been addressed in regulations that were updated in 2019. See https://www.cherokeephoenix.org/news/tribes-shutout-of-opportunity-zone-deals/article_1cfb3941-2635-50e9-a718-163e4d66d8b1.html. March 2019 and 

https://www.cherokeephoenix.org/news/tribes-shut-out-of-opportunity-zone-deals/article_1cfb3941-2635-50e9-

a718-163e4d66d8b1.html. September 2019.

46 Nancy Pindus et al., “Housing Needs of American Indians and Alaska Natives in Tribal Areas: A Report from the 

Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs,” U.S. Department of Housing 

and Urban Development Office of Policy Development and Research, 2017, 127, 

https://www.huduser.gov/portal/sites/default/files/pdf/HNAIHousingNeeds.pdf. 

47 Pindus et al., “Housing Needs of American Indians,” 127.

48 Since 1998, the first year that IHBG became operational, Congress has provided a consistent level of funding 

annually in nominal terms—an average of about $667 million per year from 1998 through 2014. Over 17 years, 

however, inflation has seriously eroded that level. See Pindus et al., 2017.

49 Ibid. 
Community Economic Development in Indian Country // Market Research Report | pg. 29

2021 (PL 117-58) also provided additional opportunities for infrastructure funding for 

tribes, with $13 billion set aside for Indian Country.50 

In light of the physical and funding challenges faced when improving infrastructure, some tribes 

have gotten creative in how they provide services to their members. For example, rather than 

providing development-wide infrastructure, Citizen Potawatomi Nation offers individual water 

wells and septic systems built by the tribal Office of Environmental Health for tribal members 

purchasing or building a home in the service area. Other tribes have developed beneficial 

partnerships with local utility providers. At Gila River Indian Community, for example, the tribe 

has developed a partnership with Verizon to provide internet and phone service for members.51

Some tribes have also leveraged partnerships with nearby communities to develop better 

infrastructure. The Quileute Tribe in Washington state recently worked with the town of Forks 

on a broadband expansion initiative, and the Jamestown S’Klallam Tribe partnered with the city 

of Sequim to tap into the wastewater system of the city and lower infrastructure costs.52 

The need for adequate basic infrastructure to support community economic development extends 

beyond the needs of housing developments. For instance, manufacturing facilities may require 

access to heavy rail, interstate freeways, an airport, or a port. These factors make major cities on 

rail lines and interstate freeways more competitive for manufacturing employers. Adequate 

water, wastewater treatment, energy, and telecommunications capacity are also site selection 

criteria for manufacturing facilities. Topography may be important for larger facilities—most 

manufacturing plants require level land. The geotechnical condition of the land, such as its load 

bearing capacity, is also a consideration. 

These resource requirements can make siting manufacturing and other projects on tribal land 

difficult. State and local governments offer a range of incentives to attract employers to locations 

that require infrastructure upgrades, including waiving connection fees or systems development 

charges and offering land or tax abatements.53,54 Tribes often compete for grants and capital 

against other communities that have shovel-ready sites where utilities are already in place or 

where developers have access to state and local incentives. Many tribes’ primary assets are land 

and natural resources, and smaller tribes may lack the capital to bring adequate utilities to an 

50 “Fact Sheet: Biden-

Harris Administration Releases Tribal Playbook, Announces Massive New Tribal Funding 

from Bipartisan Infrastructure Law,” The White House, May 31, 2022, https://www.whitehouse.gov/briefingroom/statements-releases/2022/05/31/fact-sheet-biden-harris-administration-releases-tribal-playbook-announcesmassive-new-tribal-funding-from-bipartisan-infrastructure-law.

51 Pindus, et al., “Housing Needs of American Indians,” 129.

52 Kramer et al., “Assessment of the Housing Needs,” 75.

53 “Economic Development Incentives,” Chicago Metropolitan Agency for Planning, June 2009, accessed 

September 8, 2022, 

https://www.cmap.illinois.gov/documents/10180/50455/Economic+Development+Incentives+Strategy_June.pdf/07

22371d-51d3-4f3e-aa15-171347ad7455. 

54 John E. Anderson, and Robert W. Wassmer, Bidding for Business: The Efficacy of Local Economic Development 

Incentives in a Metropolitan Area (Kalamazoo, MI: W.E. Upjohn Institute for Employment Research, 2000) 24, 

https://doi.org/10.17848/9780585313610. 
Community Economic Development in Indian Country // Market Research Report | pg. 30

undeveloped industrial site without charging the business owner or project developer. Yet, the 

employment benefits to the surrounding non-tribal community may be equal to or greater than 

the employment gains for tribal residents. Winchell’s study of the Inland Pacific Northwest 

found that successful tribal government operations and tribal economic and business 

developments in this region represent some of the most significant and positive economic change 

in rural areas anywhere in the nation.55

Community facilities providing services such as education, health care, and child care also rely 

on infrastructure and face challenges similar to housing and manufacturing projects. 

Transportation infrastructure is critical for accessing health care, child care, and schools. Tribal 

member access to IHS facilities, many of which are the only primary care access points in 

remote areas, can be limited by a lack of transportation options and harsh weather conditions. 

Many IHS facilities are outdated and their infrastructure cannot support the most up-to–date 

medical equipment and treatments.56 

Broadband is critical for reliable and high-speed internet access and can enable distance learning 

and telemedicine, service needs that were highlighted during the COVID pandemic.57 But while 

broadband access in tribal areas has grown steadily between 2013 and 2019, it does continue to 

lag behind other areas of the country. In 2019, all tribal areas were 20 percentage points behind 

urban areas, and about four percentage points behind other non-tribal rural areas in terms of 

individual access to broadband service.58 Overall, approximately 65% of the population on rural 

tribal lands had access to fixed terrestrial 25/3 Mbps services in 2019, the minimum service 

speed necessary to be considered broadband. But the utility of that minimum speed has recently 

come under debate, with the Chairwoman of the Federal Communications Commission recently 

announcing a goal of raising it to 1 Gbps/500 Mbps in the near future.59 The current rate of 

access for tribal members at that higher standard is much lower.

Many of these challenges related to infrastructure access can exacerbate potential employers’ and 

developers’ discomfort with community economic development in Native lands. Some funding 

programs assist low-income communities by reducing the cost of occupancy and offsetting 

infrastructure costs, but these programs are not a silver bullet for dealing with infrastructure 

issues, and come with their own challenges, such as jurisdictional issues, compliance 

55 Winchell, “Indigenous Rural Renewal.”

56 “Tribal Infrastructure: Investing in Indian Country for a Stronger America,” National Congress of American 

Indians, 2017, https://www.ncai.org/NCAI-InfrastructureReport-FINAL.pdf. 

57 “Breaking Down Barriers to Broadband Access,” U.S. Government Accountability Office, GAO Watch Blog, 

August 11, 2022, https://www.gao.gov/blog/breaking-down-barriers-broadband-access.

58 Stephanie Henning and Anthony “Morgan” Rodman, “National Tribal Broadband Strategy,” U.S. Department of 

the Interior, Indian Affairs, January 15, 2021, 3, https://www.bia.gov/sites/default/files/dup/assets/asia/doc/2020.%20December.%20National%20Tribal%20Broadband%20Strategy%20FINAL-cover%20change.pdf. 

59 “Chairwoman Rosenworcel Proposes to Increase Minimum Broadband Speeds and Set Gigabit Future Goal,” 

Federal Communications Commission, July 15, 2022, https://www.fcc.gov/document/chairwoman-rosenworcelproposes-increase-minimum-broadband-speeds.
Community Economic Development in Indian Country // Market Research Report | pg. 31

requirements, attracting investors, and inconsistencies in application of U.S. tax policy on Native 

lands.60

Natural Resources

In addition to often being forced into remote locations, tribes have historically been separated 

from prime natural resources, including land with the best agricultural potential.61 In many cases, 

this has left tribes with limited community economic development opportunities. And even in 

cases where tribes are situated on resource-rich land, they had a limited ability to manage and 

benefit from those resources until the late twentieth century. 

Many tribes have either discovered or recently regained access to their natural resources, and 

today, American Indians are stewards of a variety of land, water, mineral, oil and gas, and other 

resources. The passages of the Indian Mineral Development Act (IMDA) in 1982 and then the 

Tribal Energy Development and Self-Determination Act (TERA) of 2005 gave tribes 

substantially more control of the mineral resources on their lands. Now, once a tribe has gained 

approval from the Secretary of the Interior for a Tribal Energy Resource Agreement, the tribe has 

blanket authority to manage mineral development on its lands, without separate approval of each 

venture.62

Native lands encompass an estimated 30% of the nation’s coal reserves west of the Mississippi, 

as much as 50% of potential uranium reserves, and up to 20% of known natural gas and oil 

reserves.63 As of 2011, 42 federally recognized tribes produced oil and gas, three had significant 

coal operations, and others had deposits of copper, uranium, and other rare earth minerals on 

their lands.64 Having access to these potentially valuable natural resources can lead to 

complicated decisions for many tribes. While some tribes choose to develop these resources for 

economic gain, others do not—they may opt instead to protect the land that the resources are on, 

which may hold spiritual or cultural significance for the tribes. For example, the Northern 

Cheyenne Tribe ultimately elected not to mine their coal reserves, despite conflicting views 

within the tribe, and the San Carlos Apache Tribe and others fought the opening of a copper 

mine that was not on their reservation lands but was on land that was sacred to their people.65

60 Chex Oxendine, “Barriers to Tribal Economic Development Hinge on Sovereignty-related Issues,” Tribal 

Business News, April 11, 2022, https://www.tribalbusinessnews.com/sections/economic-development/13861-

barriers-to-tribal-economic-development-hinge-on-sovereignty-related-issues.

61 Bryan Leonard, Dominic Parker, and Terry Anderson, “Land Quality, Land Rights, and Indigenous Poverty,” 

Journal of Development Economics 143, (2020): 4, https://doi.org/10.1016/j.jdeveco.2019.102435.

62 Maura Grogan, Rebecca Morse, April Youpee-Roll, “Native American Lands and Natural Resource 

Development,” Revenue Watch Institute, 2011, 15, 

https://resourcegovernance.org/sites/default/files/RWI_Native_American_Lands_2011.pdf.

63 Grogan, et al., “Native American Lands,” 3.

64 Grogan, et al., “Native American Lands,” 8-9.

65 Grogan, et al., “Native American Lands,” 7.
Community Economic Development in Indian Country // Market Research Report | pg. 32

Tribal Workforce

A sufficient pool of workers with the appropriate skills is necessary for sustained economic 

development. American Indians and Alaska Natives (AIAN) fare worse than individuals in the 

United States overall on each of the three most commonly used labor market metrics. Between 

2019 and 2022: 

• The labor force participation rate (the labor force divided by the population) for all of the 

country was 62.4% compared to 60.8% for AIAN people;

• The employment rate (the number of employed workers divided by the population) was 

60.2% for the country and 57.4% for AIAN people; and

• The unemployment rate (the number of non-employed people who are available and 

looking for work—or who expect recall to a previous job—divided by the number of 

people in the labor force) was higher for AIAN people at 5.6% as compared to 3.6% for 

the U.S. overall.66 

 

Research from 2018 finds that, for many reservations, the number of jobs per inhabitant is on par 

with nearby county areas.67 However, the employment rate on tribal lands is heavily driven by 

just a few sectors, such as art, entertainment and recreation, and public administration, which are 

closely tied to gaming and tribal government. This suggests that there are potential opportunities 

to expand job creation and economic development in the sectors where Indian Country still falls 

far behind neighboring counties, such as retail, manufacturing, and health and social services.68 

This opportunity for growth is further supported by evidence that, unlike the population of most 

of rural America, the American Indian population on tribal lands is growing, providing a 

potential workforce to fill new jobs.69 Kunesh notes that Indian Country can be a positive part of 

the solution (or at least mitigation) of population loss in rural America.70 Reservations are 

homelands for American Indians, creating intergenerational ties to the land and thus a rooted 

66 Center for Indian Community Development, “Native American Labor Market Dashboard,” Federal Reserve Bank 

of Minneapolis, accessed December 11, 2022, https://www.minneapolisfed.org/indiancountry/resources/nativeamerican-labor-market-dashboard. The numbers cited are for individuals 16 and older based on Current Population 

Survey (CPS) 3-month rolling averages in September 2022. 

67 Richard M. Todd, “Industry Concentration of Jobs Highlights Economic Diversification Opportunity in Indian 

Country,” Center for Indian Country Development, Federal Reserve Bank of Minneapolis, 2018, 

https://www.minneapolisfed.org/article/2018/industry-concentration-of-jobs-highlights-economic-diversificationopportunity-in-indian-country. 

68 Richard M. Todd, “Industry Concentration of Jobs Highlights Economic Diversification Opportunity in Indian 

Country,” Center for Indian Country Development, Federal Reserve Bank of Minneapolis, 2018, 

https://www.minneapolisfed.org/article/2018/industry-concentration-of-jobs-highlights-economic-diversificationopportunity-in-indian-country. 

69 “Rural America At A Glance,” U.S. Department of Agriculture, 2018, https://www.ers.usda.gov/publications/pubdetails/?pubid=90555 

70 Patrice H. Kunesh, “Getting Real about Indian Country Surprising Progress in the Heartland,” Indian Country 

Today, 2019, https://newsmaven.io/indiancountrytoday/opinion/getting-real-about-indian-country-surprisingprogress-in-the-heartland-P9OJ5PA0aECquc42NM5dYg. 
Community Economic Development in Indian Country // Market Research Report | pg. 33

population that can help temper the general depopulation trend. Reservations have important 

economic strengths to offer rural America, including the ability to attract tourist dollars (from 

casinos, but also amenities and culture), agriculture and natural resources (minerals, forests, 

water), and unique access to federal funding sources.

Furthermore, education outcomes are promising for AIAN individuals. A 2010 report of the 

National Congress of American Indians (NCAI) noted that, based on 2005-2009 American 

Community Survey 5-Year estimates, when compared with the total United States population: 

• More American Indians and Alaska Natives completed high school or an equivalent 

program, without additional higher education, than the total U.S. population (32% as 

compared to 29.3%);

71 

• More American Indians and Alaska Natives completed some college or an associate

degree than the total population (31.2%, compared to 27.7%); however, 

• Fewer completed a bachelor’s degree or higher (12.8% compared to 27.5% for the total 

U.S. population).72 Nevertheless, this trend may be changing: 

o Native college enrollment more than doubled between 1976 and 2006; 

o The number of master’s and doctoral degrees awarded to American Indians and 

Alaska Natives between 2000 and 2010 outpaced the total increase in master’s 

and doctoral degrees awarded in total over that same time period (a 54% increase 

in the number of master’s degrees awarded to Native students as compared to a 

50.4% increase for the United States overall; and

o An increase of 34.7% of doctorates awarded to Native students as compared to 

31.9% for the United States overall. 

While many tribal members with higher education degrees may leave reservations in search of 

economic opportunity, increased community economic development in tribal areas may 

encourage these individuals to remain or return to tribal lands.

Beyond having available jobs, improved education outcomes, and a growing population, tribes 

need to be able to equip potential workers for success with workforce development opportunities 

to build needed skills, as well as adequate pay and accessible and affordable housing. 

Developing housing near employment that is suitable for the income levels and family sizes of 

workers and near community amenities and services such as parks and schools is important for 

71 General educational development tests are a group of four subject tests which, when passed, provide certification 

that the test taker has achieved American or Canadian high school-level academic skills.

72 NCAI Policy Research Center, “Tribal Insights Brief: Higher Education & Workforce Development: Leveraging 

Tribal Investments to Advance Community Goals,” National Congress of American Indians, June 18, 2012, 

https://www.ncai.org/resources/ncai_publications/tribal-insights-brief-higher-education-workforce-developmentleveraging-tribal-investments-to-advance-community-goals. 
Community Economic Development in Indian Country // Market Research Report | pg. 34

attracting and retaining workers. These factors should be considered part of a comprehensive 

community economic development strategy. 

Unfortunately, in remote areas, these workforce development and affordable housing resources 

are in particularly short supply. The availability of labor was noted as a barrier to housing 

development by tribal housing providers that participated in a 2017 survey of Native American 

and Alaska Native housing needs.73 Tribal housing departments and Tribally Designated 

Housing Entities (TDHEs) do not have enough construction activity to support the hiring and 

retention of construction workers (either in-house employees or contractors) on a consistent 

basis. The combination of irregular employment for construction workers on tribal land, limited 

training opportunities in some remote locations, and higher paying employment outside of tribal 

areas leads to worker shortages and higher costs, further limiting the volume of new construction 

that can be initiated.

Tribal Colleges and Universities

Tribal colleges and universities play an important role in meeting the postsecondary educational 

needs of American Indians, particularly those living in geographically isolated areas.74 In 

addition to offering critical vocational training and academic opportunities, tribal colleges and 

universities are an important employer in many tribal communities. They also provide 

opportunities for tribal communities to build knowledge for generating wealth and economic 

development opportunities through the preservation of tribal culture, history, and traditions.75 

The academic resources available through tribal colleges can be most effectively deployed in 

conjunction with a strategic community economic development plan that targets a few industries 

or sectors. This way, educational programs can focus on the jobs likely to be available. With 

clear priorities, companion small business lending can focus on vendor, supplier, and services 

businesses to support the target industries. Target industries should be chosen in the context of 

the character of available land and infrastructure—for example, manufacturing plants have to 

have level land with good transportation, water, and power, while health care facilities need to be 

located near roads that are accessible to workers, residents and emergency vehicles.

In recent years many tribal colleges have implemented training programs in construction, health 

care, and science, technology, engineering and mathematics (STEM) careers.76 For example, in 

2015, Oglala Lakota College partnered with the University of Colorado at Boulder to train youth 

on the Pine Ridge Reservation in green construction methods while they worked on completing 

73 Pindus et al., “Housing Needs of American Indians.”

74 Alisa F. Cunningham, “Tribal College Contributions to Local Economic Development,” Institute for Higher 

Education Policy, Washington, DC.; American Indian Higher Education Consortium, Alexandria, CA, 2000, 

http://www.aihec.org/our-stories/docs/reports/TC_contributionsLocalEconDevmt.pdf. 

75 Cunningham, “Tribal College Contributions to Local Economic Development.”

76 Paul Boyer, “Ready for Work,” Native Science Report, accessed September 1, 2022,

https://nativesciencereport.org/2020/02/ready-for-work. 
Community Economic Development in Indian Country // Market Research Report | pg. 35

the general education development (GED) test. The goal was to move these youth into 

employee-owned construction firms.77

The Health Professions Opportunity Grants (HPOG) program, funded by the U.S. Department of 

Health and Human Services (HHS) Administration for Children and Families, provides 

education and training to Temporary Assistance for Needy Families (TANF) recipients and other 

low-income individuals for occupations in the health care field that pay well and are expected to 

either experience labor shortages or be in high demand. Five tribal colleges and other tribal 

organizations are HPOG grantees: Blackfeet Community College in Browning, MT; Cankdeska 

Cikana Community College in Fort Totten, ND; College of Menominee Nation in Keshena, WI; 

Cook Inlet Tribal Council, Inc. in Anchorage, AK; and Turtle Mountain Community College in 

Belcourt, ND.

In the first four years of the HPOG program (2010-2014) nearly 2,000 participants enrolled in 

the program across the five tribal colleges. Nearly half trained as nurse assistants, aides, or 

orderlies, and 18% trained as licensed practical nurses or vocational nurses. Other students 

trained as registered nurses, emergency medical technicians, medical records technicians, and 

other health-related occupations. As of year four of these five-year grants 1,138 students had 

completed the program, and 40% of those who were previously unemployed had found jobs in 

health care. Of those employed in other jobs at the time of enrollment, 35% were employed in 

health care by the time they completed the program.78

In addition to federal initiatives, tribal organizations have been active in promoting workforce

development. For example, the National Congress of American Indians’ (NCAI) Partnership for 

Tribal Governance works collaboratively with tribal nations to document their innovative 

approaches and share them with actors across Indian Country. Examples of innovative 

approaches include the Empowerment Department of Ysleta del sur Pueblo, which provides a 

wrap-around system striving to eliminate programmatic redundancies, increase fiscal efficiency, 

and streamline its services; and the Coeur d’Alene Tribe’s Education Pipeline that features 15 

chronologically sequenced, educational groupings from Early Child through high school and 

GED programs, various post-secondary tracks, graduate degrees, and professional degrees. The 

NCAI also seeks to identify common challenges, emerging trends, and effective strategies in 

tribal workforce development. The project has developed in-depth case studies of four tribal 

nations, including videos and recorded interviews, and has published a workforce development 

toolkit for tribal decision-makers. In 2020, NCAI prepared a policy brief on workforce 

development with recommendations to federal policymakers.79

77 Pindus et al., “Housing Needs of American Indians.”

78 Michael Meit, et al., “Higher Education & Workforce Development in Tribal Communities & the Role of Tribal 

HPOG,” Administration for Children and Families, U.S. Department of Health and Human Services, July 2015, 

www.acf.hhs.gov/sites/default/files/documents/opre/hpog_practice_brief_higher_education_and_workforce_develop

ment_in_0.pdf.

79 “Workforce Development: Building the Human Capacity to Rebuild Tribal Nations,” National Congress of 

American Indians, accessed September 1, 2022, https://www.ncai.org/ptg/workforce-development.
Community Economic Development in Indian Country // Market Research Report | pg. 36

Business Development, Credit Access, and Capital Formation

When it comes to business development in tribal areas, Cornell suggests that tribes look for 

opportunities to establish three distinct business types: 

1. Non-Native-owned enterprises; 

2. Tribally owned enterprises; and 

3. Citizen-owned enterprises.80 

This allows tribes to take advantage of the strengths of all three approaches while not being fully 

tied down by the disadvantages of any. Non-Native owners or partners can help bring in new 

expertise or capital, tribally owned businesses can control revenue distribution, and citizen 

entrepreneurship might be best suited for meeting daily community needs.81

Since the beginning of the self-determination era, tribal communities have been making progress 

when it comes to business development and economic growth. The number of tribal enterprises 

has grown significantly over the last 25 years, and especially the number of non-gaming tribal 

enterprises.82 According to a 2021 analysis by the Federal Reserve Bank of Minneapolis, this 

growth has even ticked up in recent years: 99 new non-gaming tribal businesses were recorded in 

the U.S. Small Business Administration (SBA) database in 2020, the most of any year on 

record.83 Tribes are diversifying their business portfolios and opening businesses in industries 

such as professional services, construction, general administrative support, and manufacturing.

Credit access and financial literacy, which can promote individual economic opportunity and 

drive economic development in communities, are still underdeveloped in Native American 

communities.84 The challenges stem, in large part, from the rural locations of tribal lands, since 

access to credit in rural areas can be limited by geographic distance and the lack of auxiliary 

services such as widespread broadband coverage. In addition, many Native individuals are 

unable to build credit with loans made through payday lenders, tribal credit operations, or banks 

in tribal areas that don't report to credit bureaus. Native American financial institutions, 

discussed in Section 6, are entities that primarily serve Native communities or have majorityNative ownership or leadership. These organizations have begun to step in to fill this creditbuilding gap.

80 Cornell, “What Makes First Nations Enterprises Successful?”

81 Ibid. 

82 Matthew Gregg and Elijah Moreno, “Examining tribal enterprises to understand Native economic development,” 

Federal Reserve Bank of Minneapolis, July 14, 2021, https://www.minneapolisfed.org/article/2021/examiningtribal-enterprises-to-understand-native-economic-development. 

83 Ibid. 

84 Andrew P. Scott, “An Overview of Rural Credit Markets,” Washington, DC: Congressional Research Service, 

September 21, 2021, https://crsreports.congress.gov/product/pdf/R/R46914. 
Community Economic Development in Indian Country // Market Research Report | pg. 37

The introduction of new facilities, organizations, and enterprises within and around tribal 

reservations provide an opportunity to increase earnings and employment for the local Native 

community, especially if they are tribally owned and operated. As Akee notes, tribally owned 

and operated businesses may have different priorities, and make business decisions that support 

tribal resilience and sovereignty, as compared to private business owners.85 New development in 

Indian Country also has the potential to expand into new, innovative industries that can 

strengthen and diversify the economies in the area.86 A coordinated effort to restore and expand 

existing land resources would give tribal governments the tools they need to improve job and 

income prospects, especially given the history of indigenous land theft.87 This could include 

initiatives to lessen the disparity between tribe and private American Indian property 

ownership.88 Additionally, it might give tribal inhabitants the option to support themselves 

through traditional subsistence activities in the nonmarket economy, which is something for 

which many tribal members commonly express a desire.89 

Digital Business Capacity

The COVID-19 pandemic has been devastating to tribal areas in many respects, but it has also 

compelled many tribes to improve their capacity to conduct business digitally. According to a 

report on the housing needs of Native communities in Washington State, many tribes were 

forced to update virtual communication and payment systems during the pandemic, and in many 

cases were able to leverage Coronavirus Aid, Relief, and Economic Security (CARES) Act 

funding to do so.90 This has made things like remote work, online rent payment and service 

requests, and virtual regional and national meetings more accessible to tribal members. However, 

according to the DOI National Tribal Broadband Strategy, the broadband capacity necessary to 

attract industry is still limited. Insufficient service impedes tribes’ efforts to achieve selfgovernance and self-determination, as well as individuals’ access to education, health care, and 

economic resources.91

85 Akee, “Sovereignty and Improved Economic Outcomes.”

86 Ibid. 

87 Ibid. 

88 Ibid. 

89 Ibid. 

90 Kramer, et al., “Assessment of the Housing Needs,” 70.

91 Henning and Rodman, “National Tribal Broadband Strategy,” 2.
Community Economic Development in Indian Country // Market Research Report | pg. 38

Section 5: Sectors of Community Economic Development in Indian 

Country

This section covers the economic development activities within specific economic sectors that 

have historically been the primary contributors to the wealth and capital for Indian Country.

Local economies are an essential driver of economic well-being and the ability to improve living 

conditions in a given area.92 For Indian Country, there are a set of industries and economic 

sectors that have historically been the primary contributors to the generation of local wealth and 

capital. This section describes economic development activities within four broad economic 

sectors: 

• Natural resources processing; 

• Manufacturing, construction, and utilities; 

• Consumer and business services; and 

• Public sector, government, and community services.

By the end of the 1980s, significant disparities had emerged between tribes with respect to the 

scale and diversity of their economic enterprises. Some tribes had been successful in developing 

diverse types of private businesses and capitalizing on rich resources, but others had generated 

very few private sector jobs.93 In more recent years, the desire to diversify into new and different 

economic sectors has been a main focus for many tribal governments and supporting 

organizations, and many have taken steps to develop and implement structures that prioritize 

non-gaming revenue and job creation.94 The COVID-19 pandemic, which shuttered many 

casinos and hospitality businesses during 2020, added further motivation to diversify.95

Natural Resources Processing

Natural Gas Extraction

As discussed in the previous section, in a 2011 estimate, Native lands were believed to contain 

nearly one third of the western United States’ coal reserves, 50% of the country’s potential 

uranium reserves, and 20% of its natural gas and oil reserves.96 However, non-Native actors have 

92 Pettit, et al., “Continuity and Change.” 

93 Stephen Cornell and Joseph Kalt, “American Indian Self-Determination: The Political Economy of a Policy that 

Works. HKS Faculty Research Working Paper Series” John J. Kennedy School of Government, Harvard University, 

2010, https://dash.harvard.edu/bitstream/handle/1/4553307/RWP10-043_Cornell_Kalt.pdf.

94 “True Economic Diversification Financial Roundtable: Economic Diversification in Indian Country,” Tribal 

Government Gaming, Tribal Government Gaming, 2020, https://tribalgovernmentgaming.com/article/trueeconomic-diversification.

95 Mario Koran, “We’ve got to get gaming out of our blood,” Indian Country Today, April 5, 2022, 

https://indiancountrytoday.com/news/weve-got-to-get-gaming-out-of-our-blood.

96 Grogan, et al., “Native American Lands.”
Community Economic Development in Indian Country // Market Research Report | pg. 39

historically done much of the extraction of natural resources from Native lands, and in some 

cases (especially where Tribal Energy Resource Agreements [TERA] have not been established) 

the federal government retains significant authority to approve or deny these projects.97

Despite these historical and administrative challenges, several tribes have created companies to 

control the extraction of natural resources on their lands. One such example is the Southern Ute 

Indian Tribe, located in Southwest Colorado. The tribe established the Red Cedar Gathering 

Company to control the extraction and treatment of natural gas within the bounds of its 

reservation in the San Juan Basin.98 The Red Cedar Gathering Company is one division of the 

Southern Ute Indian Tribe Growth Fund; another is the Red Willow Production Company, which 

produces oil and natural gas both on the reservation and more broadly in the western United 

States and Gulf of Mexico.99 The tribe also operates the Aka Energy Group with the goal of 

providing “infrastructure and innovation for the energy transition to carbon neutrality.”100

Thanks largely to its resource extraction and alternative energy development activities, the tribe 

is the largest employer in La Plata County, Colorado, where the tribal headquarters and many 

tribal facilities are located.101

Natural Resource Protection and Conservation

There has been movement by many tribes with natural resource-dependent economies toward 

conservation and away from extraction industries. Many tribes have experienced extraction as 

exploitive and economic development efforts are pivoting towards environmental cleanup, 

including land reclamation and remediation.102 Reclamation refers to the process of “converting 

disturbed or damaged land to its former or other productive uses,” and remediation specifically 

means the removal and mitigation of contaminants from soil and water.103 For example, the 

Confederated Tribes of Grand Ronde Community of Oregon are in the process of restoring land 

at Willamette Falls that had formerly been used as a paper mill since the arrival of European 

settlers in the 1800s. The tribes purchased the land in 2019 and are now undergoing the process 

of testing the site for environmental hazards and contaminants, decommissioning underground 

storage tanks on the site, and repurposing or demolishing portions of the mill. They eventually 

97 Grogan, et al., “Native American Lands.” The Tribal Energy Development and Self-Determination Act of 2005 

allows tribes to gain approval from the Secretary of the Interior for a Tribal Energy Resource Agreement, giving 

them blanket authority to manage mineral development on its lands, without separate approval of each venture.

98 “Business Areas,” Southern Ute Growth Fund, accessed September 6, 2022, https://www.sugf.com/business.

99 “Red Willow Production Company,” Southern Ute Indian Tribe, accessed September 6, 2022, 

https://www.rwpc.us.

100 “Business Areas.”

101Ibid.

102 Carina Dominguez, “Indigenous Women Say ‘No’ to Extraction for Sustainable Future,” Indian Country Today, 

April 29, 2022, accessed September 6, 2022, https://indiancountrytoday.com/news/indigenous-women-say-no-toextraction-for-sustainable-future.

103 M. Anne Naeth, P. Michael Rutherford, and Allen M. Jobson, “Soil Reclamation and Remediation of Disturbed 

Lands,” University of Saskatchewan, August 12, 2021, accessed September 6, 2022, 

https://openpress.usask.ca/soilscience/chapter/soil-reclamation-and-remediation-of-disturbed-lands.
Community Economic Development in Indian Country // Market Research Report | pg. 40

plan to use the land for mixed-use development and intend to find “opportunities to share the 

tribes’ cultural and historical stories” in and around the development.104

Renewable energy presents another opportunity for community economic development in the 

natural resources sector outside the realm of extraction. The Fond du Lac Band of Lake Superior 

Chippewa Indians completed a solar project on its reservation in 2016 in line with its strategic 

energy plan, which has a goal of cutting energy use and emissions by 20% over the course of 

four years through renewable energy development, energy efficiency measures, and reduced 

fossil fuel purchasing.105 The tribe received technical assistance on the solar project from the 

U.S. Department of Energy’s (DOE) National Renewable Energy Laboratory to implement the 

project cost-effectively using cutting-edge technology. Bruno Zagar, the Band’s environmental 

specialist and energy projects manager, describes the technical assistance as helping “bring in 

expertise for Indian Country, but it also helped the local utility to adopt the smartest technology 

available.”106 Not only did the Band reduce its fossil fuel use by 50% and its carbon emissions 

by 80% by 2020,107 it set a new technological and sustainability precedent for the state of 

Minnesota.108

Manufacturing, Construction, and Utilities

Manufacturing and construction make up a significant proportion of Native-owned enterprises 

relative to the proportion of enterprises in the United States at large: along with professional 

services and general administrative support, these industries make up three-fourths of Native 

establishments, compared to 30% of all U.S. business establishments.109

Manufacturing

Manufacturing enterprises are important sources of both job and capital creation for many tribes. 

For example, electronics manufacturer S & K Electronics, owned by the Confederated Salish and 

Kootenai Tribes in northwestern Montana, employs nearly 1,200 people and returns a portion of 

its revenue–nearly $1 million in 2020–to the tribe as a dividend each year to help fund 

government services.110 Many tribes also look to manufacturing as an important area for growth 

and diversification away from the historically dominant industries in Indian Country, such as 

104 Dean Rhodes, “Tribe Receives $800,000 EPA Grant to Clean up Blue Heron Site,” Smoke Signals, May 13, 

2021, accessed September 6, 2022, https://www.smokesignals.org/articles/2021/05/13/tribe-receives-800-000-epagrant-to-clean-up-blue-heron-site.

105 “Fond Du Lac Band Poised to Double 2020 Clean Energy Goal,” U.S. Department of Energy, September 27, 

2016, https://www.energy.gov/indianenergy/articles/fond-du-lac-band-poised-double-2020-clean-energy-goal. 

106 “Fond Du Lac Band Poised to Double 2020 Clean Energy Goal,” U.S. Department of Energy, September 27, 

2016, https://www.energy.gov/indianenergy/articles/fond-du-lac-band-poised-double-2020-clean-energy-goal. 

107 “Strategic Energy Plan,” FDL Resource Management, 2022, accessed September 7, 2022, 

https://www.fdlrez.com/RM/energyplan.htm. 

108 “Fond Du Lac Band Poised to Double 2020 Clean Energy Goal.”

109 Gregg and Moreno, “Examining tribal enterprises.”

110 James Robert Colombe and Rory Taylor, “Tribal Enterprises Drive Economic Activity in Indian Country and 

Beyond,” Federal Reserve Bank of Minneapolis, July 6, 2021, https://www.minneapolisfed.org/article/2021/tribalenterprises-drive-economic-activity-in-indian-country-and-beyond.
Community Economic Development in Indian Country // Market Research Report | pg. 41

natural resource extraction and gaming. Tribal colleges and universities, such as Navajo 

Technical University, are developing and expanding their engineering programs to expand 

available pathways to careers in manufacturing and other STEM industries.111 A variety of 

federal programs are available for financing manufacturing projects in Native lands, including 

Economic Development Administration (EDA) grants and New Markets Tax Credits (NMTC). 

Construction 

Construction, like manufacturing, provides a variety of opportunities for Native communities. 

Construction growth can provide needed jobs, but also additional facilities and infrastructure that 

are needed in tribal areas. Much of the work Native-owned construction firms do is in nonNative lands, but the percentage of projects controlled by Native firms in Indian Country is 

growing.112 One construction firm making strides in Indian Country is Rosebud Construction, 

Inc., which is owned and operated by the Rosebud Sioux (or Sicangu Oyate) Tribe. As a tribally 

owned enterprise housed under the umbrella of the tribe’s economic development corporation, 

Siċaŋġu Co, their proceeds are reinvested in development projects that create jobs on the 

Rosebud Reservation in southern South Dakota.113

Housing construction, for example, is necessary for both community economic development and 

increasing homeownership rates in Indian Country. Not only does the construction of housing in 

Native communities create employment opportunities for community members, but it also 

addresses the housing shortages frequently seen on reservations where rates of homelessness and 

overcrowding are often high.114 

Although HUD programs in tribal areas have always had the twin goals of supporting both 

housing and community economic development, current funding levels are insufficient for tribes 

and tribal housing entities to address the shortage of housing units, complete necessary repairs

and renovations for existing housing units, and promote higher levels of homeownership.115

Tribes are taking new approaches and leveraging additional funds. For example, on the 

Cheyenne River Indian Reservation, located in South Dakota, the Badger Park housing 

subdivision was developed in response to a housing needs assessment on the reservation 

demonstrating high demand for and low supply of units available for homeownership.116 The 

111 Marcella Bombardieri, “At Navajo Technical University, a World-Class Laboratory Is Building Native American 

Manufacturing Capacity,” Center for American Progress, January 24, 2023, 

https://www.americanprogress.org/article/at-navajo-technical-university-a-world-class-laboratory-is-buildingnative-american-manufacturing-capacity.

112 Michele Van Haecke, “Native American Construction on the Rise,” ENRSouthwest, May 1, 2010, 

https://www.enr.com/articles/23503-native-american-construction-on-the-rise.

113 “Rosebud Construction,” Siċaŋġu Co., accessed September 6, 2022, https://www.sicangu.co/construction.

114Jennifer Biess, “Homelessness in Indian Country Is a Hidden, but Critical, Problem,” Urban Wire, Urban 

Institute, April 11, 2017, https://www.urban.org/urban-wire/homelessness-indian-country-hidden-critical-problem. 

115 Pindus et al., “Housing Needs of American Indians.”

116 Anne Celovsky, Amber Hunter, Katelin Jones, Kevin Klingbeil, Mary Lindeblad-Fry, and Nancy Pindus, 

“Cheyenne River Housing Authority Housing Needs Study Report,” South Dakota Native Homeownership 

Coalition, accessed September 6, 2022, 
Community Economic Development in Indian Country // Market Research Report | pg. 42

Cheyenne River Housing Authority has been building modular single-family units (which are 

then placed on the subdivision) since 2016 to meet this demand.117 

Telecommunications Utilities

As described in Section 4, robust infrastructure and utilities are an essential element for 

community economic development. The construction and installation of these utilities also 

provide an opportunity for job creation and economic diversification in Native lands. Improving 

telecommunications utilities and internet access in Indian Country has been a major focus of 

tribal leadership in the last decade. 

The need for expanded broadband access was acutely demonstrated during the shift to remote 

school and office work in the COVID-19 pandemic. With limited home internet access, students 

were especially challenged by the closure of schools, libraries, and other institutions that offer 

access to public Wi-Fi.118 Established in 2021, the National Telecommunications and 

Information Administration's Tribal Broadband Connectivity Program has funded nearly 150 

broadband projects to date across Indian Country to help close this gap.119 Two reservations, 

Pine Ridge and Rosebud, received grants from the $3 billion program in August 2022. The 

grants will allow the reservations to develop and operate their own broadband services and will 

fund broadband connections to an estimated 3,300 homes spanning 2.5 million acres. In response 

to the grant award, Kevin Killer, president of the Oglala Sioux Tribe noted that “how strong your 

internet is — is related to how strong your economy is going to be, essentially."120

Alaska’s ambitious broadband connectivity push serves as an example of effective use of New 

Market Tax Credits (NMTCs). The AU-Aleutians Fiber Project is working to connect Alaska 

Native villages throughout the state, including some of its most remote communities.121 The 

project is a collaboration between several community development entities and GCI, Alaska’s 

largest telecommunications company. According to Lewis Schnaper, vice president of GCI 

Business, using NMTCs to fund the project helped to unlock over $200 million in private 

https://static1.squarespace.com/static/5be730232487fdec648106ac/t/5c7078a1e4966b8d06adb454/1550874816156/

Final+CRHA+Housing+Study+HQ+PDF+-+no+Bleed.pdf.

117 Brendan Pedersen, “Ignored by banks, Indigenous communities build their own financial system,” University of 

Arizona, July 14, 2021, accessed September 6, 2022, 

https://nnigovernance.arizona.edu/sites/default/files/resources/2021%20American%20Banker_0.pdf. 

118 Brian Howard and Mikhail Sundust, “COVID-19: The Impact of Limited Internet Access and Issues with Social 

Distancing for Native Students,” American Indian Policy Institute, Arizona State University, accessed September 6, 

2022, https://aipi.asu.edu/sites/default/files/indigenous_digital_divide_policy_brief.pdf. 

119 “TBCP Awards,” National Telecommunications and Information Administration, accessed April 28, 2023, 

https://broadbandusa.maps.arcgis.com/apps/dashboards/07f987529ae24273aec3320e5033d503. 

120 Shalom Baer Gee, “Pine Ridge, Rosebud Reservations Receive $70M Broadband Grant,” Rapid City Journal, 

August 23, 2022, accessed September 6, 2022, https://rapidcityjournal.com/news/pine-ridge-rosebud-reservationsreceive-70m-broadband-grant/article_04f7788c-ef2e-5115-9e7f-a7731c22aeca.amp.html. 

121 “GCI, Wells Fargo Partner to Make AU-Aleutians Fiber Project a Reality,” GCI Newsroom, April 27, 2021, 

accessed September 6, 2022, https://news.gci.com/news-releases/new-market-tax-credits.
Community Economic Development in Indian Country // Market Research Report | pg. 43

investment for a “broadband network now serving over 44,000 mostly Alaska Native people in 

84 remote western Alaska communities.”122

Consumer and Business Services

Gaming 

The success of gaming enterprises run by tribes has sparked and enabled much of the economic 

development activity happening in Indian Country. Winchell notes that after the Indian Gaming 

Regulatory Act (IGRA) was passed in 1988, many tribes were able to develop “extremely 

successful tribal gaming operations that produced a rapidly expanding capacity for tribal 

business operations and investment, and a re-emergence of successful and effective tribal 

economies.”123 In many cases, the proceeds from the gaming industry have allowed tribes to 

“become self-determined, to purchase back the lands that were taken from them, and to reestablish sustainable tribal traditions, cultures, and successful economies.”124 Economic growth 

resulting from these profits has also allowed tribes to demonstrate to outside actors their capacity 

for managing significant economic investment.

Despite the benefits of gaming for some tribes, these benefits have not been enjoyed equally. As 

Pettit, et al. point out, a large share of casino revenues goes to a small number of tribes: for 

instance, in 2011, 5% of tribal gaming enterprises (23 enterprises) generated about 38% of total 

Indian gaming revenues, and 18% (78 enterprises) accounted for close to 75%.125 In addition, 

these revenues are geographically uneven, tending to be concentrated near major population 

centers. While tribal gaming enterprises in rural areas may still be important employers for local 

tribal members, they might not be particularly profitable community economic development 

solutions if they have limited nearby customer bases. 

Of those tribes that have been able to benefit from gaming, many have used those revenues to 

pivot into other industries and diversify their tribes’ economic activity. In some cases, tribes are 

making investments with gaming capital that “put them in the ranks of America’s largest 

companies.”126 For example, recent large-scale development deals in Las Vegas include the 

Mohegan Tribe’s Mohegan Sun Casino at Virgin Hotels Las Vegas, the San Manuel Band’s 

Palm Casino Resort, and a new property by the Hard Rock Hotel, owned by the Seminole Tribe 

of Florida.127

122 “Alaska – New Markets Tax Credit Coalition,” accessed September 7, 2022, 

https://nmtccoalition.org/state/alaska.

123 Winchell, “Indigenous Rural Renewal,” 177.

124 Winchell, “Indigenous Rural Renewal,” 175.

125 Pettit, et al., “Continuity and Change,” xiii.

126 Mark Trahant, “At The Crossroads: State of the Economy in Indian Country.,” Indian Country Today, 2022. 

https://indiancountrytoday.com/news/at-the-crossroads-state-of-the-economy-in-indian-country.

127 Ibid.
Community Economic Development in Indian Country // Market Research Report | pg. 44

Hospitality and Tourism

The hospitality industry is becoming a growing focus for tribes looking to diversify their 

economic landscape beyond gaming.128 Tourism and hospitality enterprises, such as attractions 

and lodging, can also generate opportunities for other local businesses by drawing people to a 

Native community. Grants like the BIA Tribal Tourism Grant and the Native Hawaiian Tourism 

Grants administered by the Hawaii Tourism Authority can support businesses in planning 

development to grow tribal economies.129 One example of a successful and multi-faceted 

hospitality and tourism enterprise in this space is the Grand Canyon Resort Corporation, which is 

owned by the Hualapai Tribe and operates multiple tourism businesses, such as the Grand 

Canyon Skywalk. This tribal enterprise has been in business for over 30 years, and in 2015 the 

resort reached a milestone of one million total visitors. According to Sherry Counts, Hualapai 

Tribal Council chairwoman, the success of this enterprise has been used to improve the electrical 

and water systems at Grand Canyon West, provide housing for employees, construct new 

facilities for health care, and invest in Hualapai youth, including the tribe’s Head Start program, 

Boys and Girls Club, and academic scholarships.130

Business Services

Business services include any service that supports business but does not produce physical 

goods; for example, communications, insurance, the provision of business supplies, and 

technology support. AMERIND is one such business service provider, the only fully tribally 

owned insurance provider in the country. Based in New Mexico and originally created as a risksharing pool between 400 tribes, AMERIND provides property and liability insurance, workers' 

compensation, and employee benefits to tribal governments as well as businesses and individuals 

in Indian Country.131 AMERIND’s Chief Operating Officer Robert Dahl sees this as an 

embodiment of tribal sovereignty and self-determination: “[W]hen tribes purchase conventional, 

statutory workers’ compensation policies, they are not only signing up for a standard, one-sizefits-all model, they’re waiving their sovereign immunity and subjecting themselves to state 

jurisdiction and courts.”132 Business services companies created by and for tribes and tribal 

members allow for customized approaches. In the case of AMERIND, the tribe purchasing 

insurance can operate under its own jurisdiction and sovereignty in its business dealings. 

128 Ibid. 

129 Tribal Business News Staff, “Office of Indian Economic Development Opens Applications for Tribal Tourism 

Grants Program,” Tribal Business News, August 23, 2021, accessed September 6, 2022, 

https://tribalbusinessnews.com/sections/tourism/14001-office-of-indian-economic-development-opens-applicationsfor-tribal-tourism-grants-program. 

130 “Grand Canyon West reaches 1 million visitors, gearing up for 2016 tourism,” Navajo-Hopi Observer,

January 12, 2016, accessed December 12, 2022, https://www.nhonews.com/news/2016/jan/12/grand-canyon-westreaches-1-million-visitors-gear.

131 “Tribal Government & Business,” AMERIND, accessed September 6, 2022, https://amerind.com/services/tribalgovernment-business. 

132 Robert Dahl, “AMERIND Empowers Tribes to Take Control of Their Insurance Programs,” Tribal Business 

News, July 25, 2022, accessed September 6, 2022, https://tribalbusinessnews.com/sponsored-contentcategory/13976-amerind-empowers-tribes-to-take-control-of-their-insurance-programs. 
Community Economic Development in Indian Country // Market Research Report | pg. 45

Public Sector, Government, and Community Services

The public sector is an important space for community economic development in Indian 

Country. Tribal governments and organizations themselves are often the largest or one of the 

largest employers on reservations and in Native communities.133 Tribes provide a range of 

services, and tribal health centers and community facilities are often accessible in remote Native 

communities where other service providers are not. 

Health Care

As a necessary service, health care is an important sector driving employment in many Native 

communities. The federal government is obligated by law to provide health care to American

Indians and Alaska Natives, and it does so through the IHS, which runs health centers in many 

tribal areas. In addition to health care, these health centers provide much needed jobs for tribal 

members. Furthermore, there is room to grow: Many tribes lack access to the necessary health 

care facilities, and IHS has been criticized for being chronically underfunded by congressional 

appropriations.134 Many tribes are stepping in to leverage other federal funding sources to 

increase development in the health care sector. 

In August 2022, the EDA awarded the Chippewa Cree Tribe a $1 million grant to construct a 

tribal health center on the Rocky Boy’s Reservation in Montana.135 Funded by the American 

Rescue Plan, the grant will fund the infrastructure supporting the health center. About $66,000 in 

local funds is matching the EDA grant. The project is expected to create 14 jobs and generate 

$58,845 in private investment on the reservation, in addition to providing critical health services 

to the community where access to health care facilities was previously limited.136

Another Native community health center project, and one which demonstrates the use of NMTCs 

to support public sector development, is the West Hawaii Community Health Center in the 

Kealakehe Hawaiian Home Land. Construction began in 2013 and the Health Center began 

serving patients in 2015.137 A 10,000-square-foot facility, the center has four exam rooms, a 

procedure room, and five dental procedure rooms (two serving adults and three pediatric).138 The 

center also provides behavioral health, family planning, and health education services, and an 

affiliated mobile dental clinic serves community members experiencing homelessness. The 

133 Trahant, “At The Crossroads.”

134 Misha Friedman, “For Native Americans, Health Care Is A Long, Hard Road Away,” NPR, April 13, 2016, 

https://www.npr.org/sections/health-shots/2016/04/13/473848341/health-care-s-hard-realities-on-the-reservation-aphoto-essay.

135 “U.S. Department of Commerce Invests $1 Million in American Rescue Plan Funds to Support Construction of 

Tribal Health Center on Rocky Boy Reservation,” U.S. Economic Development Administration, August 16, 2022, 

accessed September 6, 2022, https://eda.gov/news/press-releases/2022/08/16/rocky-boy-reservation.htm.

136 Ibid.

137 “West Hawaii Community Health Center Opens,” Big Island Video News, July 15, 2015, accessed September 7, 

2022, https://www.bigislandvideonews.com/2015/07/15/west-hawaii-community-health-center-opens.

138 “Laʻi ʻŌpua Celebrates New Health Center,” Department of Hawaiian Home Lands, December 13, 2013, 

accessed September 7, 2022, https://dhhl.hawaii.gov/2013/12/12/la%ca%bbi-%ca%bbopua-celebrates-new-healthcenter.
Community Economic Development in Indian Country // Market Research Report | pg. 46

center employs health care practitioners and social workers, as well as administrative and 

managerial staff, and provides on-the-job training in clinical entry-level roles.139 The health 

center was the first step in the creation of the Laʻi ʻŌpua Community Center, which opened in 

2020 and will provide community members with a preschool, social service center, 

intergenerational day care facility, abuse shelter, and community recreation facilities.140,141

Child Care and Education

The development of child care and educational facilities provides another important opportunity 

for tribes to generate community economic development while also providing critical services to 

their communities. There are a variety of federal sources that fund the development of 

educational programs and facilities in Indian Country. For example, the USDA’s Community 

Facilities program provides grants and loans for education services and other community 

facilities projects in rural areas, while the U.S. Department of Education’s State Tribal Education 

Partnership (STEP) provides funds for capacity building around the administration of 

educational programs in Native communities. New Markets Tax Credits can also be leveraged to 

develop new educational facilities.

In 2013, the confederated Tribes of Warms Springs Reservation of Oregon leveraged a lowinterest loan from the USDA’s Community Facilities Program for the construction of a new K-8 

school complex. Additional funding was provided by the tribal government and Jefferson County 

School District 509-J. The new, 8,000-square-foot complex replaced an 83-year-old elementary 

school, benefitting approximately 720 schoolchildren.142 The Winnebago Tribe used NMTC 

funding to open its Educare center in 2013, the first of its kind in a tribal community.143 Located 

on the Winnebago Reservation in Nebraska, the center provides early childhood education and 

child care to infants, toddlers, and preschoolers, focusing specifically on families earning low 

incomes on the reservation. Serving nearly 200 students and families, the tribe’s long-term 

community development goal with the Educare center is to close the education gap that can 

disproportionately affect children in remote areas and those whose parents earn low incomes. 

The project has also created 59 permanent jobs paying about double the area’s average salary 

and supported 73 short-term construction jobs while the center was being built.144

139 “Employment – Hawaiʻi Island Community Health Center,” accessed September 7, 2022, 

https://www.hicommunityhealthcenter.org/employment. 

140 “Laʻi ʻŌpua Breaks Ground on Community Center,” Department of Hawaiian Home Lands, March 15, 2017, 

accessed September 7, 2022, https://dhhl.hawaii.gov/2017/03/15/la%ca%bbi-%ca%bbopua-breaks-ground-oncommunity-center.

141 “Laʻi ʻŌpua Celebrates New Health Center.” 

142 Jill Rees, “USDA Announces Funding for New School Complex for the Confederated Tribes of the Warm 

Springs Reservation,” U.S. Department of Agriculture, June 19, 2013, https://www.rd.usda.gov/newsroom/newsrelease/usda-announces-funding-new-school-complex-confederated-tribes-warm-springs. 

143 “Winnebago Educare,” New Markets Tax Credit Coalition, July 29, 2021, accessed September 7, 2022, 

https://nmtccoalition.org/project/winnebago-educare.

144 “Winnebago Educare,” New Markets Tax Credit Coalition, July 29, 2021, 

https://nmtccoalition.org/project/winnebago-educare.
Community Economic Development in Indian Country // Market Research Report | pg. 47

Section 6: Native Actors Promoting Community Economic 

Development in Indian Country

This section describes the actors, programs, and sources of funding and capital involved in 

catalyzing economic development in Indian Country. 

While tribal governments work towards economic growth, they also prioritize preserving tribal 

culture, identity, sovereignty, and land. This combination creates a unique set of interests that is 

distinct from other rural communities. Many organizations have been established to assist tribes 

in balancing these priorities while fostering economic development. 

Increasingly, Native financial institutions have stepped up in response to limited access to capital 

and a sparse distribution of financial institutions on Native lands. Tribal economic development 

corporations, as well as regional and national Native organizations, help to promote economic 

development, share best practices, provide technical assistance, and advocate for policies that 

support economic development in Native communities.

But access to these specialized economic entities is not evenly distributed across Indian Country. 

The Federal Reserve Bank of Minneapolis’ Center for Indian Country Development maps the 

headquarters locations and asset sizes of banks and credit unions owned by, and CDFIs primarily 

serving, American Indian, Alaska Native, and Native Hawaiian individuals and communities. 

Their map shows the unevenness of availability and access, with potential gaps in the Southeast 

and Mountain States, while Hawaii, Oklahoma, and South Dakota each contain more certified 

Native CDFIs than any other states.145 

The section below describes the current distribution and capacity of Native actors promoting 

economic development in Indian Country.

Community Development Financial Institutions (CDFIs)

Native Community Development Financial Institutions (Native CDFIs) are an important 

connector between Native communities and community economic development opportunities. 

Native CDFIs are community development financial institutions that direct at least 50% of their 

activities to serve Native Americans, Alaska Natives, or Native Hawaiian communities.

Native CDFIs have the potential to bridge the gap between the goals of tribes and non-Native 

investors. A recently announced grant award demonstrates federal policymakers’ awareness of 

this gap and of the key role that Native CDFIs can play in tribal economic development. The 

Mountain Plains Regional Native CDFI Coalition, a group of Native-led and mission-driven 

community development loan funds, received a $45 million grant through the competitive Build 

Back Better Regional Challenge, funded by the American Rescue Plan and administered by the 

145 “Mapping Native American Financial Institutions,” Center for Indian Community Development, Federal Reserve

Bank of Minneapolis, accessed September 6, 2022, 

https://www.minneapolisfed.org/indiancountry/resources/mapping-native-banks. 
Community Economic Development in Indian Country // Market Research Report | pg. 48

EDA. The Coalition will use the grant to invest in indigenous businesses and entrepreneurs to 

drive business development and job creation in Montana, South Dakota, Wyoming, and North 

Dakota. It will also create a locally led financing infrastructure, including a Regional Revolving 

Loan Fund, which “aims to reverse decades of historical disinvestment and institutionalized 

inequities for Native communities.”146 The EDA funding will also support a training program, 

improve data infrastructure, and make other investments that will expand the capacity of the 

indigenous financial sector.147

Jorgensen and Akee, reviewing the history and development of Native CDFIs, find that the 

demand for credit and capital remains high and will continue to increase as Native community 

economies grow.148 They find that the greatest challenge facing the Native CDFI industry is 

greater capitalization, and that substantial capital additions to CDFI Fund awards, along with 

tribal government support, are needed to fuel a new level of growth. Native CDFIs currently rely 

primarily on equity capital, but one solution for greater capitalization is shifting towards a 

greater use of debt capital, which can be accessed from a variety of sources ranging from the 

federal government to private foundations, other tribes, and mainstream CDFIs. 

A 2017 survey of 39 certified Native CDFIs across the United States confirms the finding that 

the Native CDFI industry is growing, but that there are still unmet lending opportunities in the 

industry.149 The leading products and services provided by Native CDFIs are small consumer 

loans and consumer financial education. About 70% of the survey respondents indicated that 

their loan or investment portfolios contained less than $5 million in assets, and about 43% 

reported total assets in their loan or investment portfolios of less than $1 million. Meanwhile, 

22% of the respondents reported portfolios of over $10 million. Respondents also expected their 

portfolios to grow significantly by 2020.150 The Department of the Treasury reports a total of 65 

Native CDFIs located in 23 states as of March 2023.151

These portfolios demonstrate significant growth in the Native CDFI industry since 2001, when 

financials for seven Native CDFIs showed an average portfolio of $1.1 million in assets and only 

146 “U.S. Department of Commerce Invests Approximately $45 Million to Grow the Indigenous Finance Sector in 

Montana, North Dakota, South Dakota, Wyoming Through American Rescue Plan Regional Challenge,” U.S. 

Department of Commerce, September 2, 2022, accessed September 14, 2022, https://www.eda.gov/news/pressrelease/2022/09/02/us-department-commerce-invests-approximately-45-million-grow. 

147 Ibid. 

148 Miriam Jorgensen and Randall K.Q. Akee, “Access to Capital and Credit in Native Communities: A Data 

Review,” Tucson, AZ: Native Nations Institute and the Arizona Board of Regents, 2017, 

https://nnigovernance.arizona.edu/sites/nnigovernance.arizona.edu/files/2022-

09/Accessing_Capital_and_Credit_in_Native_Communities__A_Data_Review.pdf. 

149 Michael Kododoko, “Findings from the 2017 Native CDFI Survey: Industry Opportunities and Limitations.” 

Center for Indian Country Development, Federal Reserve Bank of Minneapolis, November 2017. 

https://www.minneapolisfed.org/~/media/files/community/indiancountry/resources-education/working-papers/cicdwp-2017-04.pdf. 

150 Ibid. 

151 “CDFI Certification,” CDFI Fund, U.S. Department of the Treasury, accessed April 24, 2023, 

https://www.cdfifund.gov/programs-training/certification/cdfi.
Community Economic Development in Indian Country // Market Research Report | pg. 49

$351,000 in loans and investments outstanding. Native CDFIs have been persistent in their 

growth in the intervening years: Four of the 2017 respondents obtained their CDFI certification 

in the years between 2007-2009, when the economic crisis was impacting the operations of many 

nonprofits. This is an indication of Native CDFIs’ commitment to delivering financial services to 

Native American communities.152 

Native CDFIs are also essential players bridging the Native homeownership gap that stems in 

large part from the challenges of mortgage lending and homeownership on tribal lands. Although 

programs exist to support mortgage lending to tribal members, including HUD’s Section 184 

Indian Home Loan Guarantee Program (which provides lenders with assurance should a Native 

borrower foreclose), these investments have largely not taken place on reservations, especially 

on trust land. Native CDFIs have stepped in to fill this gap, working with tribally designated 

housing entities to support Native borrowers with programs tailored to work for their specific 

communities. Four Bands Community Fund, founded in 2000 as part of a community and 

economic development push on the Cheyenne River Reservation,153 partnered with the Cheyenne 

River Housing Authority to provide financial services supporting home ownership in Badger 

Park. This CDFI offers mortgages and credit builder loans to reservation residents in addition to 

providing homebuyer education programs.154 

Native CDFI: Lakota Funds. Established in 1986 as the first Native CDFI, Lakota Funds was 

created with the goal of improving access to capital, technical assistance, business networks, and 

infrastructure on the Pine Ridge Indian Reservation in South Dakota. Since its inception, Lakota 

Funds has deployed over 1,250 loans totaling over $17.5 million, has helped establish or expand 

nearly 850 businesses, and has created nearly 2,050 permanent jobs. The organization’s loan 

portfolio now exceeds $4 million, and its maximum loan size is $300,000. It is also an active 

member of the South Dakota Native Homeownership Coalition.155

Community Development Corporations (CDCs)

Community development corporations (CDCs) are community-centered nonprofit organizations 

whose primary purpose is to provide resources and revitalize low-income, historically 

underserved areas and neighborhoods that have experienced high levels of disinvestment.156

CDCs often specialize in a variety of different initiatives, such as providing services related to 

affordable housing, sanitation, neighborhood planning, community health, and educational 

services.157 CDCs operate by bringing in capital via property development (both residential and 

commercial). They are primarily composed of community members and often work to enhance 

152 Kokodoko, “Findings from the 2017 Native CDFI Survey.” 153 Lakota Vogel, “Developing a Healthy Economy | Cheyenne River,” The Architectural League of New York, 

September 11, 2020, accessed September 6, 2022, https://archleague.org/article/cheyenne-river-reservation-healthyeconomy/.

154 Celovsky et al., “Cheyenne River Housing Authority Housing Needs Study Report,” 23.

155 “Our Story,” Lakota Funds, accessed January 11, 2023, https://lakotafunds.org/about/. 

156 “Community Development Corporations (CDCs),” Community-Wealth.Org, February 18, 2014, 

https://community-wealth.org/strategies/panel/cdcs/index.html. 

157 “Community Development Corporations (CDCs).”
Community Economic Development in Indian Country // Market Research Report | pg. 50

community conditions through community organizing, which is critical for citizen empowerment 

and building political power.158

Homestead Community Development Corporation. The Homestead Community 

Development Corporation (HCDC) is a Native Hawaiian-serving organization with the mission 

of developing affordable housing and economic opportunities on or near Native Hawaiian trust 

land, known as “homesteads” or Hawaiian Home Lands.159 HCDC is one of the few developers 

that directly assists Native Hawaiians in increasing access to housing opportunities and 

homeownership through programs like modified self-help homes, modular tiny homes, and rental 

units.160 In addition to housing, HCDC provides employment assistance and job opportunities 

through a variety of economic development projects, such as a community campground, an 

open-air marketplace, a youth center, a 55-acre commercial solar facility, and an enterprise 

center which provides educational services, low-cost retail spaces, community gathering space, 

and employment opportunities.161 HCDC also provides lending for enterprises through its 

Homestead Loan Fund.162

Native American Community Development Corporation. An affiliate of the Native American 

Bank, the Native American Community Development Corporation (NACDC) works alongside 

Native communities to address factors which inhibit economic development in Indian Country, 

and to address critical needs related to the growth of family and community assets through 

sustainable economic development.163 Located on the Blackfeet Indian Reservation, NACDC 

provides a range of services to Native community members, such as adult and youth 

entrepreneurship and financial literacy classes, alternative financing opportunities for start-ups 

and existing businesses, and credit repairing assistance.164

Native Credit Unions and Banks

In the U.S., Native financial institutions such as banks and credit unions are one of the smallest 

categories of minority depository institutions, or MDI–in 2022, only 20 of the 145 MDI banks 

registered with the FDIC were Native MDIs.165 Of the 65 Native CDFIs in the United States (as 

of March 2023), two are Depository Institution/Holding Companies (DIHCs), three are banks or 

thrifts, seven are credit unions, and 53 are loan funds.166

158 Ibid.

159 “Creating Jobs and Affordable Housing on Hawaiian Homelands,” Homestead Community Development 

Corporation, accessed September 6, 2022, https://hawaiianhomesteads.org.

160 Ibid.

161 Ibid.

162 Ibid.

163 “Native American Community Development Corporation,” NACDC, 2008, https://nacdc.org/about.html. 

164 “Native American Community Development Corporation.”

165 “Minority Depository Institutions List,” Federal Deposit Insurance Corporation, November 30, 2022, 

https://www.fdic.gov/regulations/resources/minority/mdi.html.

166 “CDFI Certification.”
Community Economic Development in Indian Country // Market Research Report | pg. 51

Unfortunately, many Native Americans live in “credit deserts,” or areas with limited access to 

credit, particularly those who live near or on Indian reservations.167 The average distance 

between the center of a tribal reservation and the nearest bank is 12.2 miles, and the average 

distance between the center of a tribal reservation and the nearest ATM is 6.9 miles.168 Residents 

of tribal reservations may have to travel more than 60 miles to the nearest bank or ATM. In 

contrast, the average distance that individuals not living on a tribal reservation need to travel to 

find an ATM is approximately 0.01 miles.169 Jorgensen and Akee acknowledge that there have 

been some improvements in geographic access to financial services for Native communities 

between 2001 and 2013. As of 2013, a greater number of residents in Native communities appear 

to live “close enough to bank branches and ATMs to make banking a viable option.”170

Credit default is typically higher among Native Americans who live in majority-Native 

communities.171 Poor credit scores, combined with the car dependency of rural areas and limited 

access to credit unions, makes high-risk lending, such as payday lending, a commonly used 

option. Native credit unions and banks that provide financial literacy education, reasonably 

priced access to loans for cars, small business lending, and credit builder loans are a significant 

help in moving Native communities away from high-risk lending options.172 Credit unions often 

provide the same financial services that traditional banks provide, at a lower cost due to lower 

capital requirements and operational costs.173

Bank: The Bank of Cherokee County. Founded in 1907, the Bank of Cherokee County is a 

tribally owned bank in Cherokee County, Oklahoma which invests around 95% of deposits back 

into the county, unlike other traditional banks.174 In addition, the Bank of Cherokee County 

strives to uplift the workplace and community through community services and volunteering. It 

167 “Native-owned Banks and Credit Unions: Serving the Underserved,” Native American Financial Services 

Association, https://nativefinance.org/news/native-owned-banks-and-credit-unions-serving-the-underserved.

168 “Native-owned Banks and Credit Unions: Serving the Underserved,” Native American Financial Services 

Association, https://nativefinance.org/news/native-owned-banks-and-credit-unions-serving-the-underserved.

169 Ibid.

170 Jorgensen and Akee, “Access to Capital and Credit.”.

171 Kassandra Martinchek and Alexander Carther, “Native Communities Face Sustained Challenges to Building

Financial Resilience,” Urban Wire, Urban Institute, February 25, 2021, https://www.urban.org/urban-wire/nativecommunities-face-sustained-challenges-building-financial-resilience.

172 Nikki Pieratos, “Native Credit Unions: A Middle Path for Building Financial Access and Capability in Native 

Communities,” Federal Reserve Bank of Minneapolis, February 15, 2019, 

https://www.minneapolisfed.org/article/2019/native-credit-unions-a-middle-path-for-building-financial-access-andcapability-in-native-communities.

173 “Native Credit Unions Provide Needed Services for Tribal Communities,” Native Knot, April 18, 2019, 

https://www.nativeknot.com/news/Native-American-News/Native-Credit-Unions-Provide-Needed-Services-forTribal-Communit.html.

174 “Our Story,” Bank of Cherokee County, https://www.bankofcherokeecounty.net/about/our-story.
Community Economic Development in Indian Country // Market Research Report | pg. 52

is the only bank in the town of Hulbert, Oklahoma and has branches in Tahlequah and Park 

Hill.175

Bank: Bay Bank. The Oneida Nations’ Bay Bank in Green Bay, Wisconsin is a tribally owned 

bank founded by the Oneida Nation in 1995 in partnership with a group of local business 

professionals.176 From the start, it had the mission of providing the Greater Green Bay area with 

a locally controlled financial institution. The institution has been exclusively owned by the 

Oneida Nation since 2000, and while it serves all customers, its mission has expanded to include 

providing more federally funded programs to directly assist tribal members. For example, it is 

the only bank in the area to offer the HUD Section 184 Indian Home Loan Guarantee Program 

for Native home buyers. Bay Bank also developed specialized mortgage and business programs 

to assist tribal members in obtaining housing and entering entrepreneurial work.177

Credit Union: The Lac Courte Oreilles Federal Credit Union. Since 2000, the Lac Courte 

Oreilles (LCO) Band of Lake Superior Chippewa Indians located near Hayward, Wisconsin, has 

been served by the Lac Courte Oreilles Federal Credit Union, which is open to any LCO tribal 

member or employee of an LCO tribal entity such as the casino, tribal office, or schools.178 The 

LCO Federal Credit Union strives to be responsive to the community's distinct financial needs, 

and to promote economic strength and development, as well as leadership, by assisting LCO 

tribal members in obtaining and accumulating savings, increasing purchasing power, and 

providing educational opportunities to promote financial literacy.179 The credit union offers 

financial literacy classes once a season on topics such as operating a checking and savings 

account, budgeting, understanding credit, and local economy sustainability. Classes are held in 

various communities and locations on the LCO reservation to ensure accessibility.180

Credit Union: The Seneca Nation of Indians Federal Credit Union. Open to any enrolled 

members, immediate family members, or employees of the New York Seneca Nation of Indians 

and Seneca Gaming Corporations and subsidies, the Seneca Nation of Indians Federal Credit 

Union (SNIFCU) provides low-cost financial services and opportunities that provide local 

development and circulate wealth within the community.181 In addition, SNIFCU members can

participate in voting for the Board of Directors for the institution.182

175 “Our Story.”

176 “About Us,” Bay Bank, https://www.baybankgb.com/About-Us.

177 Ibid.

178 “Welcome to LCO Federal Credit Union - Home,” LCO Federal Credit Union, 

https://www.lcofcu.com/index.php. 

179 Ibid.

180 Ibid.

181 “Membership Eligibility - Seneca Nation of Indians Federal Credit Union,” SNIFCU, 

https://www.snifcu.org/membership.php/#HTJ.

182 Ibid.
Community Economic Development in Indian Country // Market Research Report | pg. 53

Tribal Economic Development Departments and Chartered Entities

Economic Development Corporations (EDCs) are organizations, often 501(c)(3) nonprofits, that 

provide economic development in a specific geographical location.183 EDCs provide a variety of 

services to assist businesses and communities to generate and expand successful economic 

development. Some of their services include: 

● Offering information, assistance, and resources to those launching new firms within 

corporate boundaries; 

● Giving grants, loans, and tax-exempt bonds to businesses as financial aid within a 

specific location; and

● Business recruitment of new personnel and assistance with on-the-job training.184

These services are invaluable resources for business owners, many of whom would not have 

been able to launch their corporations without such assistance. Many of the services can act as a 

safety net for business owners, ensuring that their operations lead to additional profits and 

allowing for increased productivity and employment opportunities for the community.185 

Tribal economic development corporations can be established to serve the economic 

development needs of Indian Country by increasing access to business resources. They promote 

the expansion of tribal resources and community development opportunities to increase wealth 

and business ventures. Corporations such as Ho-Chunk, Inc., the San Pasqual Economic 

Development Corporation, and the Siċaƞġu Co. are all examples of Native-led EDCs established 

with the intent to serve a specific Native-community within a location while prioritizing 

community sustainability and economic resilience. 

Siċaƞġu Co. Siċaƞġu Co. (formerly the Rosebud Economic Development Corporation, or 

REDCO) is a Native-focused, place-based EDC which focuses on addressing the systemic issues 

faced by the Sicangu Lakota Oyate Nation within the Rosebud Sioux Tribe.186 Siċaƞġu Co. is 

guided in improving the Sicangu Oyate by a “7Gen vision,” or the promotion of a “healthy, just, 

and abundant world Seven Generations from now” guided by ancestral, holistic, and cultural 

Lakota wisdom.187 Siċaƞġu Co. is the result of a merger between Rosebud Economic 

Development Corporation (REDCO) and Tatanka Funds, a Native CDFI, and is focused on 

business and policy development. Profits that are generated from Siċaƞġu Co. are redistributed 

back into community development, tribal programing, and growth and development of the 

organization.188 Siċaƞġu Co. administers the 7Gen internship, an opportunity for individuals to 

183 “Functions of an Economic Development Corporation,” Hardee County Economic Development Council, 

Hardeebusiness.com, https://hardeebusiness.com/resources/functions-of-an-economic-development-corporation. 

184 Ibid. 

185 Ibid. 

186“About Us,” SIĊAŊĠU CO, https://www.sicangucorp.com/about-us-1.

187 “Rosebud-Based Ecosystem Re-Brands as Siċaƞġu Co,” Sicangu Co, 28AD, 

https://www.sicangucorp.com/post/rosebud-based-ecosystem-re-brands-as-sic-a%C6%9Eg-u-co. 

188 “About Us,” SIĊAŊĠU CO.
Community Economic Development in Indian Country // Market Research Report | pg. 54

learn more about economic and community development and advocate for change by leading a 

community-based project.

189

Ho-Chunk, Inc. The Winnebago Tribe–located in Thurston and Dixon counties, Nebraska, and 

Woodbury County, Iowa–started Ho-Chunk, Inc. in 1994 to help its people by creating jobs and 

diversifying the tribe’s revenue. Its goal was to establish an entrepreneurial company that was 

able to recognize and develop various economic opportunities. As Ho-Chunk, Inc. has grown, so 

has its economic impact–locally and across the tri-state region of Nebraska, Iowa, and South 

Dakota. Ho-Chunk, Inc. is now a leading regional employer and prominent developer of real 

estate and other capital projects. Recognizing the critical importance of qualifying tribal 

members for jobs with the company, Ho-Chunk, Inc. has established several education and 

training initiatives. These include internships that provide work experience within a business 

environment to college students ranging from the first year through the master’s level; college or 

technical college scholarships for selected candidates; and academic development opportunities 

to Winnebago tribal member students in 7th to 12th grade.190

San Pasqual Economic Development Corporation (SPEDC). SPEDC is authorized by the San 

Pasqual Band of Mission Indians, located in Southern California, to pursue economic 

development activities on behalf of the tribal government and members. The organization is 

charged with developing and implementing the tribe’s long-term strategy of sustainable 

economic self-sufficiency. The mission of the San Pasqual Economic Development Corporation 

is to preserve and safeguard the tribe’s culture and traditions through the creation of a long-term 

economic development structure, ensuring prosperity for the next seven generations of the tribe. 

SPEDC has developed and overseen several projects, including Horizon Gas Station and The Pit 

Stop Market in Valley Center, CA, a $7 million project spanning 8,100 square feet that brings 

convenient retail to the surrounding area while holding true to the community’s roots. The 

Native Oaks Golf Course and restaurant is another SPEDC project that attracts visitors, employs 

tribal members, and follows the natural contours of the countryside.191

Alaska Native Corporations192

Alaska Native Corporations, established in 1971 through the Alaska Native Claims Settlement 

Act (ANCSA), are the largest private landowners in the state of Alaska, and provide a significant 

contribution to Alaska’s state economy and a source of jobs and wages that benefit Alaska 

Natives.193 In 2019, the combined revenue of all Alaska Native corporations totaled $9.1 

189 “Growing Lakota Knowledge, Building Lifelong Skills, Making Memories,” SIĊAŊĠU CO, 

https://www.sicangu.co/news/growing-lakota-knowledge. 

190 “Ho-Chunk Incorporated,” Ho-Chunk, Inc., accessed April 30, 2023, https://www.hochunkinc.com. 191 “Who We Are,” San Pasqual Economic Development Corporation, accessed April 30, 2023, 

https://sanpasqualedc.com.

192 See Appendix A for additional information about the Alaska Native Claims Settlement Act (ANCSA). 

193 “Native Corporations Overview,” Resource Development Council, https://www.akrdc.org/alaska-nativecorporations. 
Community Economic Development in Indian Country // Market Research Report | pg. 55

billion.194 The often sizable dividends from the Alaska Native corporations constitute a 

substantial portion of household incomes for Alaska Natives. ANCSA divided the land of Alaska 

into 12 regions, each with a Regional Corporation delegated by Alaska Natives and dedicated to 

addressing the real social and economic needs of Natives within their corporation.195 Alaska 

Native corporations frequently collaborate with resource industries on development projects and 

take advantage of economic opportunities that are available to them.196

The 12 Alaska Native Regional Corporations are as follows: 

1. Ahtna, Inc., 

2. The Aleut Corporation, 

3. Arctic Slope Regional Corporation, 

4. Bering Straits Native Corporation, 

5. Bristol Bay Native Corporation, 

6. Calista Corporation, 

7. Chugach Alaska Corporation, 

8. Cook Inlet Region, Inc., 

9. Doyon Limited, 

10. Koniag Incorporated, 

11. Nana Regional Corporation, and 

12. Sealaska Corporation.

Homestead Associations of Hawaii197

Homestead Associations in Hawaii, comparable to tribes on the U.S. mainland,198 are 

beneficiary-controlled organizations that serve and represent the interests of Hawaii’s homestead 

community.199 Homestead Associations work with Homesteads and Beneficiary Associations 

(HBA) to assist the DOI in administering federal laws that apply to trust lands and trust funds.200

The Sovereign Council of Hawaiian Homestead Associations (SCHHA) is the longest running, 

largest self-governing federation of homestead associations, and is devoted to preserving and 

194 Ibid.

195 “Native Corporations Overview.”

196 Ibid.

197 See Appendix A for additional information pertaining to Hawaiian Home Lands.

198 “About the SCHHA,” Homestead Community Development Corporation, https://hawaiianhomesteads.org/schha.

199 Ibid.

200 “Homestead & Beneficiary Associations: Frequently Asked Questions,” U.S. Department of the Interior, 

https://www.doi.gov/hawaiian/homestead-beneficiary-associations-faq.
Community Economic Development in Indian Country // Market Research Report | pg. 56

expanding self-determination and sovereignty of Native Hawaiians who are eligible under the 

1920 Hawaiian Homes Commission Act.201

The Department of Hawaiian Home Lands (DHHL), governed by the Hawaiian Homes 

Commission Act of 1920, was created to improve and protect the lives of Native Hawaiians of 

Hawaiian heritage.202 DHHL acts to serve Native Hawaiian beneficiaries and manage Hawaiian 

Home Lands within its land trust, which contains over 200,000 acres spread across the islands of 

Maui, Moloka’i, O’ahu, Kaua’i, Hawai’i, and Lāna‘i.203 DHHL serves Native Hawaiians in a 

variety of ways: beneficiaries may be granted 99-year homestead leases at a cost of $1 per year 

for residential, agricultural, or pastoral purposes.204 These leases may be extended for a total 

term of no more than 199 years.205 Beneficiaries may receive financial assistance for home 

purchase, construction, replacement, or repair through direct loans, insured loans, or loan 

guarantees.206 However, as a state agency, DHHL has received criticism for its failure to provide 

homesteads in a quick and efficient manner.207 Program applicants have reported decades-long 

waiting lists, unclear financial expectations for qualification, and unsuitable homestead lands,208

which create complications for Native Hawaiians looking to obtain homestead housing.209

Tribal Organizations 

Tribal organizations play an important role in providing information, convenings, training, and 

advocacy for tribes on the topic of community economic development. Each of the organizations 

described in this section has a unique focus, but all support tribal governance and community 

economic development.

National Congress of American Indians. The National Congress of American Indians (NCAI), 

founded in 1944, is the oldest and largest American Indian and Alaska Native rights organization 

meant to represent Native tribes in advocating for tribal sovereignty and against assimilation and 

the termination of tribal rights by the federal government.210 NCAI’s constitution includes the 

goal of improving “economic development, health, and welfare in Indian and Alaska Native 

communities.”211 The organization actively promotes tribal economic investments in Indian 

201 “About the SCHHA.”

202 “About The Department of Hawaiian Home Lands,” Department of Hawaiian Home Lands, 

https://dhhl.hawaii.gov/dhhl.

203 Ibid.

204 “About The Department of Hawaiian Home Lands.”

205 Ibid.

206 Ibid.

207 Rob Perez and Agnel Philip, “To Reclaim Ancestral Land, All Native Hawaiians Need Is a $300,000 Mortgage 

and to Wait in Line for Decades,” ProPublica, October 24, 2020, https://www.propublica.org/article/hawaii-nativeland-homesteads-department-of-hawaiian-home-lands.

208 Blaze Lovell, “The Problem With Hawaiian Homestead Land? Much Of It Can’t Be Developed,” Honolulu Civil 

Beat, https://www.civilbeat.org/2019/06/the-problem-with-hawaiian-homestead-land-much-of-it-cant-be-developed. 

209 Ibid.

210 “About NCAI,” National Congress of American Indians, https://www.ncai.org/about-ncai. 

211 “About NCAI,” National Congress of American Indians, https://www.ncai.org/about-ncai. 
Community Economic Development in Indian Country // Market Research Report | pg. 57

Country with the goal of spurring innovative economic policy and growth while honoring tribal 

sovereignty.212 NCAI conducts research and prepares policy reports which outline opportunities 

for economic development, how tribes are exercising and advocating for sovereignty and 

securing economic success through sustainable practices. 

Native American Finance Officers Association. The Native American Finance Officers 

Association (NAFOA) was established in 1982 to financially assist tribal economies and 

strengthen tribal finance.213 NAFOA promotes responsible fiscal and economic policy, promotes 

financial and economic literacy, and brings together tribal leadership, seasoned professionals, 

and business partners.214 NAFOA provides memberships to 140 member tribes over more than 

25 states and connects them to services such as training on financial management, grant 

management and improved administrative processes; advocacy opportunities; exclusive 

membership events and networking; and discounts on conference registrations and 

publications.215 NAFOA also administers the NAFOA Institute, which provides educational and 

professional opportunities for tribal members, from early career and young professional 

development to executive leadership and grants management.216

National American Indian Housing Council. Founded in 1974, the National American Indian 

Housing Council provides training and technical assistance to all tribes and tribal housing 

entities, supporting them in providing safe, affordable, and culturally appropriate housing for 

Native people and communities.217 NAIHC also conducts research and provides informational 

services within the realm of Native housing issues and programs.218 NAIHC hosts the annual 

Legislative Conference in Washington D.C., an event which provides tribal advocates, leaders, 

attorneys, and other housing professionals the opportunity to hear directly from congressional 

members and federal representatives regarding the decisions that directly affect tribal programs, 

communities, and funding.219 NAIHC also hosts an annual convention and trade show in 

partnership with AMERIND, and an annual legal symposium where over 500 tribal specialized 

housing professionals, tribal leaders, federal agencies, and law firms gather to address emerging 

tribal housing issues.220

National Center for American Indian Enterprise Development. The National Center for 

American Indian Enterprise Development (NCAIED) is the largest Native-centered national 

212 “Economic Development & Commerce,” National Congress of American Indians, https://ncai.org/policyissues/economic-development-commerce. 

213 “About NAFOA,” Native American Finance Officers Association, https://nafoa.org/about.

214 “About NAFOA.”

215 Ibid.

216 “NAFOA Institute,” Native American Finance Officers Association, https://nafoa.org/institute. 

217 Erla Sagg, “About NAIHC,” Native American Indian Housing Council, https://naihc.memberclicks.net/aboutnaihc.

218 “About the National American Indian Housing Council,” Native American Indian Housing Council, 

https://naihc.net/about-2.

219 “NAIHC 2022 Legislative Conference,” Native American Indian Housing Council, 

https://web.cvent.com/event/5312605d-98d4-413e-bc91-f9e245470cee/summary.

220 “NAIHC 2022 Legal Symposium,” Native American Indian Housing Council, https://naihc.net/legal-symposium.
Community Economic Development in Indian Country // Market Research Report | pg. 58

business organization. It is a 501(c)(3) nonprofit that strives to improve the lives of current and 

future generations of Native Americans.221 NCAIED hosts the annual Reservation Economic 

Summit (RES), the country's largest tribal economic development conference, which offers 

business development sessions and networking and collaboration opportunities aimed at 

facilitating access to capital and enterprise development.222

Partnerships and Regional Development Efforts 

Many tribal governments have addressed tribal economic development in collaboration with 

each other at a regional level, in addition to their individual efforts. For example, the Affiliated 

Tribes of Northwest Indians (ATNI), the South Puget Intertribal Planning Agency (SPIPA), the 

Great Lakes Inter-Tribal Council (GLITC), the Upper Columbia United Tribes (UCUT), and the 

United South and Eastern Tribes (USET) all pull together multiple tribes within specific regions 

of the United States for knowledge sharing, collaboration, and collective advocacy.

For example, the Affiliated Tribes of Northwest Indians (ATNI), which operates as a regional 

congress of tribal elected leaders and staff with over 50 member tribes in seven states, has 

actively worked to keep economic development issues on the forefront of tribal discussion 

through its Economic Development Committee (EDC).223 ATNI’s economic development 

subsidiary (ATNI-EDC) provides financial and technical assistance for community and 

economic development efforts to the ATNI member tribes and their tribal members.224 The 

Upper Columbia United Tribes (UCUT), made up of the Coeur d’Alene Tribe of Idaho, the 

Kootenai Tribe of Idaho, the Confederated Tribes of the Colville Reservation, the Spokane Tribe 

of Indians, and the Kalispel Tribe of Indians, collaborate on several inter-tribal initiatives for 

natural resources and fisheries management on their lands in the Upper Columbia watershed.225 

Beyond partnerships, many tribal entities have become powerful economic players and service 

providers in their surrounding regions. Winchell explores several examples of this in the Pacific 

Northwest. The Coeur d’ Alene Tribe’s wellness center, for example, is a public facility that is 

open to all residents of the region. It offers multiple swimming pools, gyms, weight and training 

rooms, as well as meeting rooms and an office for health care providers. The Confederated 

Tribes of the Colville Reservation operates four grocery stores that service rural areas. Overall, 

Winchell finds that “tribes have become important players within the rural regional economy and 

are now often in the lead in new innovations and investment in rural facilities and business 

operations.”226

221 “About NCAIED: The National Center for American Indian Enterprise Development,” The National Center for 

American Indian Enterprise Development, https://www.ncaied.org/about.

222 “About the Summit | The National Center for American Indian Enterprise Development | RES 2022,” RES 2022 

- Reservation Economic Summit, accessed September 13, 2022, https://res.ncaied.org/Summit-Info/About. 

223 Winchell, “Indigenous Rural Renewal,” 176.

224 “Affiliated Tribes of Northwest Indians Economic Development Corporation,” Affiliated Tribes of Northwest 

Indians Economic Development Corporation, accessed September 15, 2022, https://atniedc.com.

225 Winchell, “Indigenous Rural Renewal,” 191-192 

226 Winchell, “Indigenous Rural Renewal,” 191-192 
Community Economic Development in Indian Country // Market Research Report | pg. 59

Sovereign Wealth Funds

A sovereign wealth fund (SWF), also known as a social wealth fund or a sovereign investment 

fund, is a state-owned investment which generates wealth for the benefit of its citizens and 

economy.227 SWFs are created to help diversify an entity's source of revenues to strengthen its 

types of income streams, and have been successfully managed by authorities such as the Abu 

Dhabi Investment Authority (ADIA) and the China Investment Corporation (CIC). The 

introduction of SWFs in Indian County can help with the diversification of wealth beyond the 

sectors or industries that tribes currently engage in or have access to, such as casinos and 

agriculture.

Seminole Tribes’ Sovereign Wealth Fund. The Seminole Tribe of Florida developed a 

sovereign wealth fund to improve financial benefits and generational wealth to the Seminole 

Tribe.228 The Seminole SWF recently acquired its first real estate investment asset. Located in 

uptown Dallas, Texas, the McKinney Uptown Apartments are a midrise, upscale, residential 144-

unit complex with luxury amenities and located close to dining, entertainment, and office 

space.229 Due to the increase in demand for multifamily apartment rentals, the real estate market 

has seen a steep increase in demand for apartment units and is an investment opportunity that has 

provided wealth for the Seminole Tribe.230 The tribe has historically received SWF revenue from 

casinos and other gaming properties, and the addition of commercial real estate allows for the 

tribe to further diversify contributions to the sovereign wealth fund.231

227 “Sovereign Wealth Fund (SWF).” Investopedia. 

https://www.investopedia.com/terms/s/sovereign_wealth_fund.asp. 

228 Ari Rioseco, “Tribe Creates Sovereign Wealth Fund,” The Seminole Tribune, https://seminoletribune.org/tribecreates-sovereign-wealth-fund. 

229 Ibid. 

230 Ibid. 

231 Ibid. 
Community Economic Development in Indian Country // Market Research Report | pg. 60

Section 7: Sources of Funding and Capital for Community 

Economic Development

This section highlights the various potential sources of funding and capital available for 

community economic development in Indian Country. 

There are a wide number of federal tools that have been leveraged for community economic 

development in Indian Country, with varying degrees of success. Tribes have historically had to 

rely primarily on public funds and grants to support their development projects. But in recent 

decades, increased income from tribal enterprises, the need for more capital for larger 

development projects, and federal incentives to leverage private funding to develop tribal 

housing have led to a more diversified mix of funding and capital in Indian Country. 

However, tribes still face challenges when it comes to accessing non-Native capital for projects, 

and private investors also note risks or perceived risks associated with investing in Native 

projects.232 Recent trends such as social impact investing and the response to the COVID-19 

pandemic are changing the way both tribes and investors evaluate and structure projects. The 

successful examples of community economic development projects listed in the previous 

sections show the range of expertise and capacity among tribal governments, Native CDFIs, 

Native banks, Native CDEs, and other tribal entities, as well as the expansion potential of Native 

economies. 

To fully understand the scope of economic development activities within Indian Country, it is 

important to note the common primary funding sources, such as government and private grants 

and loans, tribal capital, private investment, and tax incentives, as well as the possible ways to 

combine them. Several federal agencies, such as HUD and the EDA, have created special 

programs, set-asides, or initiatives focused on addressing the unique needs of tribal entities. 

Existing tribal revenue streams from tribal enterprises and reimbursements can be used to 

leverage additional capital and enable capital stacking. 

A recently completed study from the U.S. Government Accountability Office (GAO) examined 

economic development programs available to tribal entities and found that federal efforts to 

support economic development show fragmentation and some overlap. GAO reports that 

programs are fragmented across seven agencies: the USDA, U.S. Department of Commerce, 

DOE, HHS, HUD, DOI, and the SBA. The tribal organizations that GAO spoke with said many 

tribes have limited capacity to identify and access programs and may not be aware of the federal 

assistance available.233

Table 1 towards the end of this section provides a high-level summary of select significant 

federal programs that offer funding for economic development in Indian Country, including the 

232 “Access to Capital.”

233 “Tribal Economic Development: Action is Needed to Better Understand the Extent of Federal Support,” U.S. 

Government Accountability Office (GAO), August 2022, https://www.gao.gov/assets/gao-22-105215.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 61

funding type, eligibility criteria, authorized purposes, and typical award amounts. In the 

following paragraphs, we offer a more in-depth look at these various funding categories. 

Additional funding that may be supportive of community economic activities may come from 

other sources, such as FEMA, EPA, DOE, and state and local programs.

Grants

U.S. Department of Housing and Urban Development (HUD)

HUD offers two primary block grant programs that are specifically designed for Native projects: 

the Indian Housing Block Grant (IHBG) and the Indian Community Development Block Grant 

(ICDBG). Per its name, IHBG is focused on the operation, maintenance, and development of 

affordable housing in Indian Country, while the ICDBG can be used for community facilities and 

other economic development activities, in addition to housing.

IHBG was authorized by the Native American Housing Assistance and Self-Determination Act 

of 1996, PL 104-330, as amended (NAHASDA). This legislation changed the system for funding 

and developing tribal housing, with a focus on tribal self-determination and flexibility to 

accommodate the diversity of needs and cultural preferences across Indian Country. It was also 

designed to enable and encourage tribes to secure more private investment for housing projects. 

IHBG funds are awarded by formula to federally recognized tribes or their Tribally Designated 

Housing Entities (TDHEs), as well as a limited number of state-recognized tribes.234

While the program was designed to encourage private investment, an analysis of Annual 

Performance Report data submitted by NAHASDA grantees (through 2013) showed that 

grantees received less than $2 per $100 of IHBG grants in private sector investment. However, 

the flexibility and complexity of leveraging private investment, which is often combined with 

other government or tribal funds, makes reporting this information especially difficult.235

The ICDBG grant funds are split up into two categories: single purpose and imminent threat.236

Federally recognized tribes or villages and a limited number of state-recognized tribes and tribal 

organizations can apply for single-purpose grants on a competitive basis, while imminent threat 

grants are offered on a first-come, first-served basis to address threats to the public health or 

safety of tribal residents. Funds can be used for housing, community facilities, and economic 

development.

U.S. Department of Agriculture (USDA)

The United States Department of Agriculture has several grant programs that help contribute to 

rural development in both tribal and non-tribal areas. These various programs provide funding 

234 “Indian Housing Block Grant Program,” U.S. Department of Housing and Urban Development, accessed August 

24, 2022, https://www.hud.gov/program_offices/public_indian_housing/ih/grants/ihbg.

235 Pindus, et al., “Housing Needs of American Indians.”

236 “Indian Community Development Block Grant Program,” U.S. Department of Housing and Urban Development, 

accessed August 24, 2022, https://www.hud.gov/program_offices/public_indian_housing/ih/grants/icdbg.
Community Economic Development in Indian Country // Market Research Report | pg. 62

for activities such as the construction of water infrastructure, community facilities, utilities, 

telecommunications systems, as well as the preservation and construction of affordable housing, 

small business development, and initiatives at tribal colleges and universities.237 TheCommunity 

Facilities Direct Loan and Grant Program provides grants, low interest direct loans or a 

combination of the two, and offers a loan guarantee program. The funds can be used to purchase, 

construct, or improve essential community facilities, purchase equipment and pay related project 

expenses. The ReConnect Program offers loans, grants, and loan-grant combinations to facilitate 

broadband deployment in areas of rural America that currently do not have sufficient access to 

broadband. The Rural Business Development Grants and the Rural Innovation Stronger 

Economy (RISE) Grants provide businesses of various sizes with grants, loans, and technical 

assistance to secure employment opportunities in rural communities.

U.S. Economic Development Administration (EDA)

The EDA offers a variety of grant programs aimed at promoting community economic 

development for communities across the country, including Native communities. They include 

the Build to Scale program, which funds tech-based projects, the Economic Adjustment 

Assistance program, which provides support for public works and infrastructure projects in 

regions experiencing adverse economic changes, and the Local Technical Assistance and 

Planning programs, which support capacity-building activities such as economic feasibility 

studies, impact analyses, disaster resiliency plans, and project planning.238

Many tribes and Native organizations have leveraged EDA grants to develop businesses, public 

works, and infrastructure to support community and economic development. However, a 2004 

GAO report found that the success of projects funded by these grant programs has been mixed, 

in terms of generating jobs, higher incomes, and private sector investment.239 Additionally, the 

report found that these shortcomings were not a result of issues with tribal governance, but 

instead stemmed from the challenges associated with a complex federal grant process of 

application, review, approval and monitoring. This highlights one of the key challenges 

associated with using federal grant funding for economic development.

As a part of the American Rescue Plan Act of 2021 (ARPA), the EDA received an additional 

infusion of $100 million to allocate to indigenous communities, with awards ranging from 

$100,000 to $5,000,000 towards projects designed to create the conditions for economic growth 

in indigenous communities. Recipients of these funds can include tribes, a consortium of tribes, 

or nonprofits that serve Native Hawaiians or Pacific Islanders. This money can be used to help 

237 “All Programs,” U.S. Department of Agriculture, accessed on September 13, 2022, 

https://www.rd.usda.gov/programs-services/all-programs. 

238 “Federal Resources for Tribal Economic Development,” Bureau of Indian Affairs, July 12, 2022, 

https://www.bia.gov/sites/default/files/dup/inline-files/oied_shared_ed_resource_directory_v1_7.12.22.pdf. 

239 “Indian Economic Development: Relationship to EDA Grants and Self-determination Contracting Is Mixed,” 

U.S. Government Accountability Office, September 08, 2004, https://www.gao.gov/assets/gao-04-847.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 63

fund vital infrastructure and other projects that could help lead to economic development.240 We 

discuss more about the specific opportunities and challenges of ARPA funding below.

American Rescue Plan Act (ARPA): Opportunity and Inequitable Funding

ARPA provides a case study in grant distribution for tribal programs. Under ARPA, $20 billion 

dollars was allocated to all federally recognized American Indian and Alaska Native tribal 

governments. Under the act, Treasury developed a formula to quickly allocate funding to tribal 

governments because Native communities were disproportionately impacted by COVID-19. The 

resulting formula distributed an initial $1 billion evenly divided among all tribes. Sixty-five 

percent of the remaining funding was allocated based on the number of tribal citizens that tribes 

served, and 35% was based on the number of employees on reservations prior to the COVID-19 

pandemic.241 While this plan allowed for speed in the allocation of $20 billion, the funding was 

disproportionately distributed, and as much as $880,000 per tribal citizen went to already 

wealthy tribes, while tribes with higher poverty rates received less than $10,000 per tribal 

citizen.242 Future efforts to efficiently distribute grant money will need to improve upon this 

system to better track inequities and prioritize tribes with higher levels of need.

Loans and Leveraging Sources

Loan sources on reservation lands include government-backed loan guarantee programs, existing 

tribal capital from various revenue sources, and private capital loans. Government loan guarantee 

programs help extend low-interest credit to traditionally underserved communities or businesses 

and promote homeownership and wealth-building. 

Federal Loan Guarantee Sources

Federal loan guarantee programs can help promote lending in Indian Country by providing 

lenders with security to approve loans or lines of credit. Federal loan guarantee programs have 

reportedly been underutilized by eligible parties due to stringent credit requirements, specific 

location requirements, high closing costs associated with mortgage loans, and loan limits that 

may discourage use for larger projects.243 

Many agencies that offer grants for economic development activities also offer loan guarantee 

programs for similar activities. For example, the USDA offers both grants and loan guarantees 

240 “EDA ARPA Plan Programs: Indigenous Communities,” Bureau of Indian Affairs, accessed September 9, 2022, 

https://www.bia.gov/service/whcnaa/eda-arpa-indigenous-communities.

241 Eric C. Henson, Miriam R. Jorgensen, Joseph P. Kalt, & Isabelle G. Leonaitis, “Assessing the U.S. Treasury 

Department’s Allocations of Funding for Tribal Governments under the American Rescue Plan Act of 2021,” Native 

Nations Institute, November 3, 2021, 

https://ash.harvard.edu/files/ash/files/assessing_the_u.s._treasury_departments_allocations_of_funding_for_tribal_g

overnments.pdf. 

242 Ibid. 

243 Kramer et al., “Assessment of the Housing Needs.”
Community Economic Development in Indian Country // Market Research Report | pg. 64

for community facilities projects.244 The USDA Community Facilities Guaranteed Loan Program 

provides 80% loan guarantees of up to $100 million for loans going towards community facilities 

including health care services, fire and public safety, community or cultural facilities, 

transportation facilities, utilities, and more.245 The USDA Business and Industry (B&I) Loan 

Guarantee Program guarantees 80% of loans under $5 million, and 60% for loans over $10 

million.246

The Small Business Administration (SBA) provides two primary loan guarantee programs: The 

SBA 7(a) loan guarantee program helps small businesses obtain credit on reasonable terms and 

provides a guarantee of up to 85% for loans under $150,000 and a 75% guarantee for loans up to 

$5 million, while the SBA 504 Loan program provides additional low-interest loans of up to $5 

million through the SBA.247,248 The BIA Loan Guarantee and Insurance Program provides loan 

guarantees for Native individuals and organizations funding projects that will benefit the

economy of a reservation or tribal service area.249

HUD and the USDA also have loan guarantee programs targeted towards individual 

homeownership (USDA 502 and HUD Section 184) that help build intergenerational wealth 

through homeownership opportunities.250 HUD’s program is specifically for American Indian 

and Alaska Native borrowers, and can be used for the new construction, rehabilitation, purchase, 

or refinancing of a one to four unit home on or off Native lands.251 Homeownership programs 

can promote community economic development by supporting private development enterprises, 

growing intergenerational wealth through asset ownership, and increasing housing options for 

workers.

The CDFI Fund provides a Bond Guarantee Program that can help CDFIs access capital. 

Through this program, CDFIs (including Native CDFIs) can issue federally guaranteed bonds 

and use their proceeds to extend credit for community development purposes. Through fiscal 

244 “All Programs.”

245 “Community Facilities Guaranteed Loan Program,” U.S. Department of Agriculture, accessed September 13, 

2022, https://www.rd.usda.gov/programs-services/community-facilities/community-facilities-guaranteed-loanprogram.

246 “Business & Industry Loan Guarantees,” U.S. Department of Agriculture, accessed September 13, 2022, 

https://www.rd.usda.gov/programs-services/business-programs/business-industry-loan-guarantees.

247 “7(a) Loans,” U.S. Small Business Administration, accessed September 9, 2022, https://www.sba.gov/fundingprograms/loans/7a-loans.

248 “504 Loans,” U.S. Small Business Administration, accessed September 9, 2022, https://www.sba.gov/fundingprograms/loans/504-loans.

249 “Indian Loan Guarantee and Insurance Program (ILGP),” U.S. Department of the Interior Bureau of Indian 

Affairs, accessed September 13, 2022, https://www.bia.gov/service/loans/ilgp.

250 Kramer, et al., “Assessment of the Housing Needs.”

251 “Section 184 Indian Home Loan Guarantee Program,” U.S. Department of Housing and Urban Development, 

accessed January 11, 2023, https://www.hud.gov/section184.
Community Economic Development in Indian Country // Market Research Report | pg. 65

year (FY) 2022, more than $ 2.1 billion had been guaranteed in bonds through the CDFI Bond 

Guarantee Program.252

Citizens Potawatomi Community Development Corporation, headquartered in Shawnee, 

Oklahoma, was the first Native CDFI to participate in the CDFI Bond Guarantee Program, 

receiving a $16 million bond in 2015, with plans to use the bond loan to provide financing for 

large scale commercial real estate projects in the Citizens Potawatomi Nation. 253

Using Existing Revenue Streams as Loan Collateralization

Since tribes often cannot use trust land as collateral for loans, a reliable revenue stream becomes 

very important in securing capital and better loan terms. Examples of potential revenue streams 

that may be used as collateral include reimbursement from health care facilities, successful 

hospitality operations, and Indian Housing Block Grant (IHBG) allocations that serve as 

collateral for HUD Title VI loans. Blackfeet Housing Authority’s Glacier Heights Expansion 

project successfully leveraged a Title VI loan that used existing IHBG revenue streams as 

collateral to help cost-effectively develop 40 single-family homes.254 In this project, 19 units 

housed Native Veterans, which helped leverage additional future revenue streams, including 

Tribal HUD-VASH rental assistance and administrative fees. Other similar projects have been

able to collateralize IHBG funding and other consistent revenue sources. 

Tax Incentives 

Tax credits and other tax incentives can encourage economic development by offering tax 

benefits to investors in return for their investment in specific types of economic development 

projects. Tax credits allow taxable entities to subtract the amount of the credit from their owed 

taxes.255 Other types of tax incentives include tax abatement and tax exemptions.

The Low-Income Housing Tax Credit (LIHTC) is a major tax incentive program for affordable 

housing and community development projects, and is often used in Native projects. During site 

visits conducted as part of a HUD tribal housing study, LIHTC was the program most often 

mentioned by tribes in connection with leveraging funds and was used at nine of the 22 sites 

visited. Many tribes welcomed the opportunity to leverage funds for developing new housing — 

the White Earth Nation, for example, was working on its fifth LIHTC project at the time of the 

survey and noted that more investors and developers are interested in building with LIHTC tax 

252 “Agency Financial Report Fiscal Year 2022,” CDFI Fund, U.S. Department of the Treasury, accessed April 12, 

2023, https://www.cdfifund.gov/sites/cdfi/files/2023-01/CDFI_Fund_FY22_AFR_FINAL508.pdf. 

253 “Treasury Guarantees $327 Million in Bond Funding for Projects in Low-Income Communities,” September 29, 

2015, https://www.cdfifund.gov/news/178. 254 “ONAP National Best Practice Webinar: Featuring Blackfeet Housing,” Office of Native American Programs, 

March 4, 2020, 

https://www.hud.gov/sites/dfiles/PIH/documents/National%20Webinar%20Blackfeet%20Housing%20HUDVASH

%20FINAL.pdf. 

255 Troy Segal, “Tax Credit,” Investopedia, January 27, 2022, https://www.investopedia.com/terms/t/taxcredit.asp.
Community Economic Development in Indian Country // Market Research Report | pg. 66

credit incentives. But others noted that many LIHTC projects require the availability of 

leveraged funds and involve complicated paperwork and application requirements, which can be 

difficult to meet. The Bad River Tribe appointed a project manager specifically for tax credits 

and American Reinvestment and Recovery Act (ARRA) projects because the application and 

compliance process required too much work for regular staff.256

The overwhelming need for affordable housing in Native communities makes it easier to 

demonstrate demand and attract investors. In contrast, for NMTC investments, it may be more 

difficult to demonstrate demand for various commercial and community facility projects. 

However, LIHTC does require tribes to accept limited partnerships with outside entities, limited 

waivers of sovereign immunity, extended compliance periods, and other perceived "intrusions" 

into their sovereignty and this experience can serve as a gateway to larger, more complex 

transactions using NMTCs.

 

The New Markets Tax Credit (NMTC) Program, established in 2000, helps economically 

distressed communities attract private capital by providing investors with a federal tax credit. 

The CDFI Fund allocates tax credit authority to Community Development Entities (CDEs) 

through a competitive application process. CDEs use their authority to offer tax credits to 

investors in exchange for equity in the CDE. Using the capital from these equity investments, 

CDEs can make loans and investments to businesses operating in low-income communities on 

better rates and terms and with more flexible features than the market. In exchange for investing 

in CDEs, investors claim a tax credit worth 39% of their original CDE equity stake, which is 

claimed over a seven-year period.257 The program supports activities as varied as schools, 

apartment buildings, arts centers, restaurants, food production facilities, buildings for human 

service providers, grain elevators, manufacturing plants, sustainable forestry, and more. 

By design, the NMTC is a flexible tool that allows CDEs discretion over which projects they 

fund.258 A recent analysis of NMTC investments from 2001- 2019 conducted by researchers at 

the Center for Indian Country Development, identified a total of 54 NMTC investments that 

involved a tribal entity. Those projects were directed to 36 of the 347 federally recognized tribes 

in the contiguous United States, one Alaska Native Village Corporation, and two consortia of 

Alaska Native Villages.259 The report finds that “while the share of NMTC investments 

involving tribal entities is increasing, the total number of tribes involved remains small, and the 

256 Pindus, et al., “Housing Needs of American Indians,” 143-145. 

257 “New Markets Tax Credit Program Fact Sheet,” CDFI Fund, U.S. Department of the Treasury, accessed 

December 12, 2022, https://www.cdfifund.gov/sites/cdfi/files/documents/nmtc-fact-sheet-english-16sept2020-

final.pdf. 

258 Brett Theodos, Christina Plerhoples Stacy, Daniel Teles, Christopher Davis, and Ananya Hariharan,(Washington, 

DC: Urban Institute, April 2021. https://www.urban.org/sites/default/files/publication/103956/which-types-ofprojects-receive-new-markets-tax-credit-funding_0.pdf Accessed December 20, 2021.

259 Matthew Gregg, Michou Kokodoko, and Elijah Moreno, “Take-up of New Markets Tax Credit Increases in 

Indian Country, With Potential for Far More, Federal Reserve Bank of Minneapolis, May 10, 2022, 

https://www.minneapolisfed.org/article/2022/take-up-of-new-markets-tax-credit-program-increases-in-indiancountry-with-potential-for-far-more.
Community Economic Development in Indian Country // Market Research Report | pg. 67

number of financial intermediaries directing NMTC investments to tribal entities is even 

smaller.” 260

There are other tax incentives aimed at attracting investment capital such as Opportunity Zones 

and renewable energy credits. The Tax Cuts and Jobs Act of 2017 included a federal incentive—

Opportunity Zones—to spur investment in undercapitalized communities. Local areas (defined 

by census tracts) were eligible for selection as Opportunity Zones if they are Low Income 

Communities (LICs) under the high poverty or low median income definitions established for the 

New Markets Tax Credit program. Also eligible for selection were census tracts contiguous to 

LICs if median family income did not exceed 125% of the qualifying tract. About 56% of tracts 

in the United States were eligible for selection as Opportunity Zones and of these, governors 

selected over 8,700 zones, roughly 12% of tracts. Corporations and individuals that invest capital 

in Opportunity Zones defer or reduce taxes on capital gains.261 

Governors in 26 states named census tracts that include tribal areas. Of the 1,341 census tracts 

eligible for selection in tribal areas, 30% were selected. This, of course, is a first step as these 

areas need to attract investors and a tract being designated a zone does not ensure it will access 

Opportunity zone capital.262 But for the 360 designated opportunity zones on rural lands in 

Indian Country, with 90 in Oklahoma and 70 in Alaska, the picture is bleak. Because of an 

oversight in the federal law, tribal governments cannot form or participate in Opportunity Funds 

and thus cannot pool investments from external sources.263 The law allows territories like Guam 

and American Samoa to set up opportunity funds, but tribal governments were not given the 

same status. The Opportunity Zones Program is still relatively new and reporting is limited, so its 

potential, especially in Indian Country, remains to be seen. 

The Inflation Reduction Act of 2022 allows state, local, and tribal governments, as well as 

nonprofit organizations and other tax-exempt entities, such as rural electric cooperatives, to 

receive certain tax credits as direct payments from the Internal Revenue Service as an incentive 

to continue making investments to build a clean energy economy.264 

260 Gregg, Kokodoko, and Moreno, “Take-up of New Markets Tax Credit,” 1.

261 Brett Theodos, Brady Meixeil, and Carl Hedman, “Did States Maximize Their Opportunity Zone Selections?” 

May 18, 2018, revised July 18, 2018, 

https://www.urban.org/sites/default/files/publication/98445/did_states_maximize_their_opportunity_zone_selections

_7.pdf. 

262 Nancy Pindus and Brady Meixeil, “Why Opportunity Zones are Important for Indian Country,” June 7, 2018, 

https://www.urban.org/urban-wire/why-opportunity-zones-are-important-indian-country. Note: This analysis 

included all Opportunity Zone tracts that had been approved by Treasury as well as proposed tracts awaiting 

approval as of publication date.

263 Paul Monies. “Tribes Shut Out of Opportunity Zone Deals.” March 26, 2019, 

https://nondoc.com/2019/03/26/tribes-shut-out-of-opportunity-zone-deals/

264 “Fact Sheet: Four Ways the Inflation Reduction Act’s Tax Incentives Will Support Building an Equitable Clean 

Energy Economy,” U.S. Department of the Treasury, 2022, https://home.treasury.gov/system/files/136/Fact-SheetIRA-Equitable-Clean-Energy-Economy.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 68

Another tax incentive financing tool is tax-exempt bonds. Tribal Economic Development Bonds 

(TED Bonds), created by the ARRA, have been one of the broadest and most flexible forms of 

tribal tax-exempt bonds. They are not fully subject to the limits that typically affect tribal 

government’s use of tax-exempt funds for the financing of “essential government functions.”265

However, the tool has limitations: gambling establishments are excluded and projects must be 

located on tribal land, to name a few. TED Bonds were funded at $2 billion in 2009.266 Issuance 

of tribal economic development bonds is subject to a national volume cap for all such bonds and 

a Published Volume Cap Limit for the aggregate amount of national volume cap that may be 

allocated per Indian tribal government. As of May 2, 2023, the amount of remaining available 

national volume cap was $0. The Published Volume Cap Limit per Indian tribal government is 

$100,000,000 and does not change. While no new Tribal Bond funding is available, there may be 

national volume cap available in the future if previously allocated volume cap is forfeited.267

While the issuance of bonds is a promising source of capital—since the bonds can attract 

investors and enable tribes to borrow funds at a reduced interest rate—they also come with 

administrative and compliance issues. If you are a tribal applicant, you must apply for an 

allocation of bonds that specifies what the capital will be used for, the cost of the project or 

projects, a financing plan, and outside documentation that the bonds will be marketable. Not all 

tribes that received allocations were able to use them due to delays in projects, difficulties 

obtaining loans, or selecting other financing options. Allocations that are not deployed within 

180 days are returned to the Treasury.

268

Initial demand for TED Bonds in their early years was slow, though activity has picked up in 

subsequent years. The first tranche of allocations to 58 applicants totaled just under $1 billion 

with allocations ranging from $1.5 million to $22.4 million. The second tranche of allocations 

totaled just over $1 billion with allocations to 76 applicants ranging from $2.7 million to $30 

million.269 As of August 1, 2022 the remaining available national volume cap was about $63 

million.270 Gregg et al. comment that “the allocation pool has been effectively exhausted,” 

pointing out that there is no shortage of potential investments and there is a need to continue this 

program or provide other ways to provide greater tax parity between states and tribes.271

265 “Treasury Department Fact Sheet: Tribal Economic Development Bonds,” U.S. Department of the Treasury, 

2014, https://www.irs.gov/pub/irstege/Tribal%20Economic%20Development%20Bonds%20Fact%20sheet%202014.pdf. 

266 “Treasury Department Fact Sheet: Tribal Economic Development Bonds.”

267 “Published Volume Cap Limit for Tribal Economic Development Bonds,” Internal Revenue Service, U.S. 

Department of the Treasury, last updated May 4, 2023, https://www.irs.gov/tax-exempt-bonds/published-volumecap-limit-for-tribal-economic-development-bonds.

268 Ibid. 

269 “IRS Announces Tribal Economic Development Bonds Allocations,” Internal Revenue Service, last updated 

February 2, 2022, 

https://www.irs.gov/tax-exempt-bonds/irs-announces-tribal-economic-development-bonds-allocations. 

270 “Published Volume Cap Limit for Tribal Economic Development Bonds.”

271 Matthew Gregg, Ryan Nunn, and Casey Lozar, “An Urgent Priority: Accurate and Timely Indian Country Data,” 

Federal Reserve Bank of Minneapolis, May 10, 2022, https://www.minneapolisfed.org/article/2022/an-urgentpriority-accurate-and-timely-indian-country-data.
Community Economic Development in Indian Country // Market Research Report | pg. 69

Programs Incentivizing or Promoting Tribal Community Economic Development

The Small Business Association (SBA)’s 8(a) Business Development Program is a nine-year 

program that provides management, technical, financial, and procurement assistance to firms 

owned or controlled by socially and economically disadvantaged individuals.272 There are also 

special exceptions in the law that govern enterprises owned by Alaska Native corporations, 

tribes, Native Hawaiian organizations, and CDCs. These entities may have multiple 8(a) firms, 

but for most firms and individuals, participation is one time only. 

Once certified, participating businesses can compete for certain federal sole-source and 

competitive set-aside contracts. Up to $7.5 million in sole-source contracts is authorized for 

assigned manufacturing North American Industry Classification System codes, and $4.5 million 

for all other acquisitions.273Alaska Native corporations have been particularly successful at 

leveraging 8(a) status into productive contracts. A 2007 GAO report found that obligations for 

8(a) contracts to ANC firms increased from $265 million in FY 2000 to $1.1 billion in 2004.274

Table 1 | Summary List of Federal Funding Sources

1.1 Bureau of Indian Affairs

Agency/

Program 

Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Indian Business 

Incubators 

Program 

Grants Indian entities; tribal 

organizations; tribal colleges 

or universities; institute of 

higher education in any state 

admitting students as per 20 

U.S.C. 1091(d); joint 

applicants who are 

independently eligible 

Establish and run business 

incubators that serve 

entrepreneurs who will 

provide products or services in 

American Indian and Alaska 

Native communities.

$100,000-

$300,000275

272 “8(a) Business Development program,” U.S. Small Business Administration, accessed September 13, 2022, 

https://www.sba.gov/federal-contracting/contracting-assistance-programs/8a-business-development-program. 

273 “8(a) Business Development program.”

274 Katherine V. Schinasi, “Alaska Native Corporations: Increased Use of Special 8(a) Provisions Calls for Tailored 

Oversight,” U.S. Government Accountability Office, September 19, 2007, https://www.gao.gov/assets/gao-07-

1251t.pdf. 

275 “Indian Business Incubators Program,” Bureau of Indian Affairs, accessed September 6, 2022, 

https://www.bia.gov/service/grants/ibip. 
Community Economic Development in Indian Country // Market Research Report | pg. 70

Agency/

Program 

Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Indian Loan 

Guarantee and 

Insurance 

Program 

Loan 

Guarantee 

and 

Insurance 

Most lending institutions, 

including CDFIs, may obtain 

a guarantee or insurance; 

non-bank lenders may be 

eligible to access guarantees. 

Borrowers must be an 

enrolled member of a 

federally recognized tribe or 

group; or a business entity 

owned by federally 

recognized AIAN individuals

Loans may be used for a 

variety of purposes including 

operating capital, equipment 

purchases, acquisition and 

refinancing, building 

construction, and lines of 

credit. The project must 

benefit the economy of a 

reservation or tribal service 

area. 

In 2000, the 

average loan 

guarantee 

was $7 

million.276 In 

addition, 

lenders issued 

insured loans 

at an average 

amount of 

just over 

$57,000

Living 

Languages Grant 

Program 

Grant Federally recognized tribal 

governments 

Funding to document and 

revitalize languages that are at 

risk of disappearing because of 

a declining native-speaker 

population.

$150,000 to 

$200,000277

National Tribal 

Broadband Grant

Grant Federally recognized tribal 

governments 

Developing or extending 

broadband services in 

communities to spur economic 

development and commercial 

activity, create opportunities 

for self-employment, enhance 

educational resources and 

remote learning opportunities, 

and meet emergency and law 

enforcement needs.278

$100,000 -

$175,000279

276 “Indian Loan Guarantee and Insurance Program,” Bureau of Indian Affairs, accessed December 28, 2022, 

https://www.bia.gov/service/loans/ilgp/what-indian-loan-guarantee-and-insurance-program-ilgp.

277 “Past Funded LLGP Grant Projects,” Bureau of Indian Affairs, accessed August 24, 2022, 

https://www.bia.gov/service/grants/llgp/past-funded-llgp-grant-projects. 

278 “National Tribal Broadband Grant (NTBG),” Bureau of Indian Affairs, accessed August 24, 2022, 

https://www.bia.gov/service/grants/ntbg. 

279 “Past Funded NTBG Grant Projects,” Bureau of Indian Affairs, accessed August 24, 2022, 

https://www.bia.gov/service/grants/ntbg/past-funded-ntbg-grant-projects. 
Community Economic Development in Indian Country // Market Research Report | pg. 71

Agency/

Program 

Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Native American 

Business 

Development 

Institute Grant

Grant Tribes and tribal 

organizations 

Funds go to hiring consultants 

to perform feasibility studies 

or business plans to help tribes 

and tribal organizations weigh 

their risks to determine 

whether a project is worth 

pursuing and empowers them 

to make informed decisions 

about their economic futures. 

All projects must be completed 

within one year. 

$25,000-

$40,000280

Tribal Tourism 

Grant Program

Grant Tribes or organizations Hiring consultants, preparing 

project feasibility studies, and 

expanding or developing 

tourism business plans, 

awarded tribes and 

organizations can leverage 

grant funding to explore 

COVID-19 recovery options.

$25,000 -

$150,000

1.2 U.S. Department of Agriculture

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Business and 

Industry Loan 

Guarantees

Loan 

guarantee 

For-profit or nonprofit 

businesses, 

cooperatives, federally 

recognized tribes, 

public bodies, 

individuals engaged or 

proposing to engage in 

a business

Business development 

activities, business acquisition, 

land acquisition for commercial 

or industrial properties, the 

purchase and installation of 

machinery and equipment, 

supplies or inventory, debt 

refinancing.

$25 million loan 

maximum, 80% 

loan guarantee 

in 2022.281

Community 

Facilities Grants

Grant Organizations and 

tribes in cities, towns, 

unincorporated areas 

with less than 20,000 

individuals

Nonprofit public improvement 

projects, including real estate 

and equipment projects.

$15,000 -

$50,000282

280 “Past Funded NABDI Grant Projects,” Bureau of Indian Affairs, accessed September 6, 2022, 

https://www.bia.gov/service/grants/nabdi/past-funded-nabdi-grant-projects.

281 “OneRD Guarantee Loan Initiative Lender Guide,” U.S. Department of Agriculture, November 4, 2020, 

https://www.rd.usda.gov/sites/default/files/OneRDLenderGuide.pdf. 

282 Ibid. 
Community Economic Development in Indian Country // Market Research Report | pg. 72

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Community 

Facilities 

Guaranteed and 

Direct Loans

Loans and 

loan 

guarantees

Organizations and 

tribes in cities, towns, 

unincorporated areas 

with less than 20,000 

individuals

Nonprofit public improvement 

projects, including real estate 

and equipment projects.

$100,000 - $5 

million283

Intermediary 

Relending Program

Loan Nonprofits, federally 

recognized tribes, 

public agencies, 

cooperatives

Provides 1% low-interest loans 

to local lenders that re-lend to 

businesses to improve 

economic conditions and create 

jobs in rural communities.

Up to $1 million 

for local 

lenders; up to 

$400,000 to 

ultimate 

recipient284

ReConnect Loan or 

grant

Tribes or organizations Construction, improvement, or 

acquisition of facilities and 

equipment to provide 

broadband service in eligible 

rural areas.285

$25 million -

$50 million286

Rural Business 

Development Grants

Grant Public bodies, 

government entities, 

nonprofit entities, and 

federally recognized 

tribes

Technical assistance and 

training for small rural 

businesses.

$10,000 -

$500,000287

Rural Innovation 

Stronger Economy 

(RISE) Grant

Grant Nonprofit entities, state 

entities, tribal entities, 

institutions of higher 

education, public 

bodies

Building or supporting a 

business incubator, providing 

worker training for new or 

higher-paying jobs.

$500,000 -

$2,000,000288

283 “Housing Support Programs Across the Federal Government.”

284 “Intermediary Relending Program,” U.S. Department of Agriculture, accessed April 11, 2023, 

https://www.rd.usda.gov/programs-services/business-programs/intermediary-relending-program.

285 “ReConnect Loan and Grant Program,” U.S. Department of Agriculture, accessed August 24, 2022, 

https://www.usda.gov/reconnect.

286 Ibid.

287 “Rural Business Development Grants (RBDG),” U.S. Department of Agriculture, December 2019, 

https://www.rd.usda.gov/sites/default/files/fact-sheet/508_RD_FS_RBS_RBDG.pdf.

288 “Rural Innovation Stronger Economy (RISE) Grants,” U.S. Department of Agriculture, accessed April 11, 2023, 

https://www.rd.usda.gov/programs-services/business-programs/rural-innovation-stronger-economy-rise-grants.
Community Economic Development in Indian Country // Market Research Report | pg. 73

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Rural 

Microentrepreneur 

Assistance Program

Loan or 

grant

Nonprofits, federally 

recognized tribes, 

institutions of higher 

education

Provides loans and grants to 

Microenterprise Development 

Organizations (MDOs), which 

can then provide loans and 

technical assistance to small 

rural businesses.

Up to $500,000 

for MDOs, up to 

$50,000 for 

ultimate 

recipients.289

Section 502 Direct 

Loan Program

Loan Low-income 

homebuyers in rural 

areas

Purchase homes in rural areas; 

build, repair, renovate or 

relocate a home; or purchase 

and prepare sites.

Loan limits vary 

by county, 

typically below 

$500,000 for a 

1-unit 

property.290

1.3 U.S. Department of Health and Human Services

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Social and 

Economic 

Development 

Strategies (SEDS) 

Grants

Grant Federally recognized 

tribal governments, 

tribal organizations, 

nonprofits

Community-driven projects 

designed to grow local 

economies, strengthen Native 

American families, preserve 

Native American cultures, and 

strengthen community-based 

businesses and social and 

economic infrastructure in 

Native American communities.

$100,000 -

$400,000291

289 “Rural Microentrepreneur Assistance Program,” U.S. Department of Agriculture, accessed April 11, 2023, 

https://www.rd.usda.gov/programs-services/business-programs/rural-microentrepreneur-assistance-program.

290 “Single Family Housing Direct Home Loans,” U.S. Department of Agriculture, accessed April 11, 2023, 

https://www.rd.usda.gov/programs-services/single-family-housing-programs/single-family-housing-direct-homeloans.

291 “Social and Economic Development Strategies -SEDS,” U.S. Department of Health and Human Services, April 

6, 2021, https://www.grants.gov/web/grants/view-opportunity.html?oppId=329546.
Community Economic Development in Indian Country // Market Research Report | pg. 74

1.4 U.S. Department of Housing and Urban Development

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Indian Community 

Development Block 

Grant

Grant Federally recognized 

tribes/villages, limited 

state-recognized tribes 

and tribal organizations

Housing, community facilities, 

and other economic 

development activities.292

$500,000 - $1.2 

million293

Indian Housing 

Block Grant

Grant Federally recognized 

tribes/villages, limited 

state-recognized tribes

Affordable housing 

development, assistance, 

services, and problem solving; 

safety and crime prevention.294

$86,000 - $650 

million 

(dependent on 

tribe size and 

need)295

Section 184 Indian 

Home Loan 

Guarantee Program

Loan 

guarantee

American Indians or 

Alaska Natives who are 

members of a federally 

recognized tribe, 

federally recognized 

Indian tribes, tribally 

designated housing 

entities, Indian Housing 

Authorities

New home construction or 

rehabilitation, the purchase of 

an existing home, or 

refinancing, both on and off 

Native lands. Can be used for 

homes with between one and 

four units.

Loan limits vary 

by county, 

typically below 

$500,000 for a 

1-unit 

property296

1.5 U.S. Department of the Treasury

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

CDFI Bond 

Guarantee Program 

(CDFI Fund)

Bond 

Guarantee

CDFIs, including 

Native CDFIs

Enables CDFIs to issue 

federally guaranteed bonds and 

use their proceeds to extend 

credit for community 

development.

Through FY 

2019, nearly 

$1.6 billion had 

been guaranteed 

in bonds 

through the 

CDFI Bond 

Guarantee 

Program297

292 “Indian Community Development Block Grant Program.”

293 “FY 2021 Indian Community Development Block Grant,” U.S. Department of Housing and Urban Development, 

accessed August 24, 2022, https://www.hud.gov/sites/dfiles/PA/documents/ICDBG-Competitive-Awards-2022.pdf.

294 “Indian Housing Block Grant Program.”

295 “Housing Support Programs Across the Federal Government,” U.S. Department of Agriculture, September, 2016, 

https://www.usda.gov/sites/default/files/documents/housing-support-programs-federal-government.pdf.

296 “Section 184 Indian Home Loan Guarantee Program.”

297 “Fact Sheet: CDFI Bond Guarantee Program.”
Community Economic Development in Indian Country // Market Research Report | pg. 75

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Native American 

CDFI Assistance 

Program (NACA, 

CDFI Fund) 

Grant Competitive process; 

Native CDFIs

Facilitates the creation and 

advancement of Native CDFIs. 

Serves organizations in the 

early planning stages of CDFI 

formation; tribal entities 

working to certify an existing 

lending program; and 

established Native CDFIs in 

need of further capacitybuilding assistance.

FY 2022: 

Technical 

Assistance 

$125,000 - 

$150,000 

Financial 

Assistance 

$197,000- 

$1,000,000298

New Markets Tax 

Credit Program 

(CDFI Fund)

Tax credit Competitive process;

CDFI-certified 

Community 

Development Entities 

(CDEs) receive 

authority to issue tax 

credits

CDEs offer loans, equity 

investments, and other services 

to Qualified Low Income 

Community Businesses in a 

wide variety of industries 

including manufacturing, food, 

retail, housing, health, 

technology, energy, education, 

and child care.

299

Leveraged 

funding varies 

by type of 

project, but 

typically range 

from $1-20 

million300

Low Income 

Housing Tax Credit 

(IRS)

Tax credit Developers producing 

affordable housing 

throughout the U.S.

Affordable rental housing 

development. 

$1 million - $2 

million301

Tribal Economic 

Development Bonds 

(TED Bonds) (IRS)

Tax 

exempt 

bonds that 

can be 

issued by 

tribal 

governments

Federally recognized 

tribal governments

To finance any project or 

activity for which state or local 

governments could issue taxexempt bonds. For example, 

TED Bonds could be used to 

finance water treatment 

facilities, sewage facilities, 

solid waste disposal facilities, 

and qualified residential 

facilities.

Volume cap 

limit per tribal 

government for 

the two-month 

period starting 

August 1, 2022, 

was 

$100,000,000.

302

298 “NACA Program Award Book,” CDFI Fund, U.S. Department of the Treasury, 2022, 

https://www.cdfifund.gov/sites/cdfi/files/2023-02/2022_NACA_Award_Book.pdf. 

299 “New Markets Tax Credit,” CDFI Fund, U.S. Department of the Treasury, accessed December 28, 2022, 

https://www.cdfifund.gov/programs-training/programs/new-markets-tax-credit.

300 CDFI Fund, FY 2022 NMTC Public Data Release: 2003-2020 Data File, (October 6, 2022), distributed by CDFI 

Fund, https://www.cdfifund.gov/documents/data-releases.

301 “2022 QAPs and Applications,” Novogradac, accessed August 24, 2022, https://www.novoco.com/resourcecenters/affordable-housing-tax-credits/2022-qaps-and-applications. 

302 “Published Volume Cap Limit for Tribal Economic Development Bonds.”
Community Economic Development in Indian Country // Market Research Report | pg. 76

1.6 U.S. Economic Development Administration

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

CARES Act 

Economic Recovery 

Corps and Equity 

Impact Investments 

Programs

Grant Local and state 

governments, Native 

tribal governments, 

501(c)(3) nonprofits

Two programs designed to 

support underserved 

communities across the country 

in developing successful 

economic plans and projects.

$3 million - $30 

million303

Build to Scale Grant States, local 

governments, tribes, 

nonprofit organizations, 

higher education 

institutions, publicprivate partnerships, 

research organizations, 

venture development 

organizations, 

economic development 

organizations

Projects aimed at furthering 

tech-based economic 

development initiatives. 

Between 

$300,000 and $2 

million304

Public Works and 

Economic 

Adjustment 

Assistance

Grant District Organizations 

of Economic 

Development Districts, 

federally recognized 

tribes and any Alaska 

Native Village or 

Regional Corporations, 

state and local 

governments, 

institutions of higher 

education, public or 

private nonprofit 

organizations

A wide range of technical, 

planning, and public works and 

infrastructure assistance in 

regions experiencing adverse 

economic changes.

$100,000 -

$30,000,000305

303 “CARES Act Economic Recovery Corps and Equity Impact Investments,” U.S. Economic Development 

Administration, accessed August 24, 2022, https://www.grants.gov/web/grants/viewopportunity.html?oppId=341163.

304 “2022 Build to Scale Program Notice of Funding Opportunity,” U.S. Economic Development Administration, 

May 2022, https://www.eda.gov/sites/default/files/2022-05/FY22-Build-to-Scale-NOFO.pdf.

305 “FY 2023 EDA Public Works and Economic Adjustment Assistance Programs,” U.S. Department of Commerce, 

March 14, 2023, https://www.grants.gov/web/grants/view-opportunity.html?oppId=346815.
Community Economic Development in Indian Country // Market Research Report | pg. 77

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

Indigenous 

Communities 

Program

Grant Tribes or nonprofits 

serving Native 

Hawaiians or Pacific 

Islanders

Develop projects to recover 

from the pandemic and build 

economies.

$100,000 -

$5,000,000306

Planning and Local 

Technical 

Assistance Program

Grant Individual and 

consortia of: local and 

state governments, 

Native tribal 

governments, 501(c)(3) 

nonprofits, and higher 

education entities

Economic feasibility studies, 

impact analyses, disaster 

resiliency plans, and project 

planning.

$100,000307

1.7 Small Business Administration

Agency/Program Funding 

Type

Eligibility Authorized Purposes Typical 

Amounts

The SBA 7(a) Loan 

Guarantee Program 

Loan 

guarantee

Small businesses Helps small businesses obtain 

credit.

Guarantee of up 

to 85% for loans 

under $150,000 

and a 75% 

guarantee for 

loans up to $5 

million308

SBA 504 Loan 

Program

Loan For-profit company Long-term, fixed rate financing 

for major fixed assets that 

promote business growth and 

job creation.

Up to $5.5 

million309

Private Capital and Investment

Despite progress being made in tribal economic development, for many tribes there are inherent 

tensions in working with non-Native investors. While the influx of private capital holds the 

306 “Funding Opportunities.”

307 “Funding Opportunities,” Economic Development Agency, accessed August 24, 2022, https://eda.gov/fundingopportunities. 308 “7(a) Loans.”

309 “504 Loans.”
Community Economic Development in Indian Country // Market Research Report | pg. 78

potential to expand tribal economies and allow tribal governments to improve services to 

residents, the interests of investors may not align with tribes’ self-determined goals.310 

In addition, as discussed in Section 3, many investors still hold biases and misperceptions 

concerning the riskiness of lending to Native borrowers. Jorgensen recommends that non-tribal 

providers of capital and credit educate themselves about the business-related infrastructure of 

tribes with whom they work, and that tribes and other advocates take the lead in such education. 

In some cases, Jorgensen points out that the reduced flow of funding can be understood as a 

symptom of some Native nations’ limited preparedness to engage with lenders and lending 

institutions.311 The use of Native CDFIs or other Native financial institutions as intermediaries 

can also help make connections and ease uncertainties between parties. Access to credit lags in 

tribal areas that have a dearth of financial institutions, a lack of diversity of funding sources, and 

less access to collateral and equity resources. Successful examples of projects financed with 

private capital are discussed in Section 4 and others are included below in the subsection on 

capital stacking.

A 2013 survey of home mortgage lenders, Native CDFIs and credit unions, and other 

organizations serving Indian Country provides some insights into the motivations behind private 

lending in Indian Country. Tribally owned mortgage lenders were primarily motivated by their 

ability to serve their own people. Other lenders were motivated to provide mortgages to a 

traditionally underserved population, but mortgage lending on Native lands itself was not 

expected to be especially profitable because of the lengthy time to close loans and their relatively 

modest dollar amount. 312

Some lenders hoped their presence and service to Native homeowners would achieve greater 

economic returns from future long-term business opportunities, such as business loans to tribes, 

especially to tribes that operated casinos or other business activities requiring capital for 

investment. Lender respondents noted the importance of being visible within the Native 

community, for example by sending representatives to community events and meeting with 

groups to make sure tribal members are aware of what the lender has to offer.313

Role and Potential of Philanthropy

Philanthropies and foundations offer a wide variety of opportunities for community 

organizations and other entities to access funding. But Native American nonprofit leaders report 

having less positive experiences with foundation funders than do nonprofit leaders of other races 

and ethnicities. Native nonprofit leaders cite similar challenges to those that arise when 

partnering with private investors, including difficulties building relationships and a lack of 

understanding on the part of foundations. In a 2021 survey, almost two thirds of foundation 

310 Fredericks and Finn, “Harnessing Private Equity.”

311 “Access to Capital.”

312 Listokin et al., “Mortgage Lending on Tribal Land.” 

313 Ibid. 
Community Economic Development in Indian Country // Market Research Report | pg. 79

leaders said that they provide little or no grant dollars to organizations primarily serving Native 

American communities.314 

Native-serving nonprofits, such as the First Nations Development Institute, Native Americans in 

Philanthropy, NDN Collective, and Native Ways Foundation, have urged foundations to take 

actions to better support their communities, including participating in their organization’s 

meetings and events, conducting site visits, being more communicative, and hiring Native 

American staff. Several of these nonprofits have developed resource materials that are available 

to foundations to learn more about working effectively with Native American leaders and 

communities.315

Generally, Native American communities and causes are underfunded relative to their share of 

the population: A 2019 report found that large U.S. foundations provided just 0.4% of their 

funding towards Native American communities and causes even though 2% of the total 

population of the United States is American Indian and Alaska Native.316 Between 2006 to 2022, 

a total of 53,513 grants from over 6,000 large funders were designed to benefit American Indian, 

Alaska Native and Native Hawaiian populations in the United States. These grants totaled $3.8 

billion, and were granted to 5,748 organizations. 

Top funders that provided more than $100 million in grants each to Native communities over this 

period include the Ford Foundation, W.K. Kellogg Foundation, The Robert Wood Johnson 

Foundation, Northwest Area Foundation, Novo Foundation, and Bush Foundation. The top 

project categories funded by foundation grants in Native communities include education, human 

rights, arts and culture, and community and economic development. 

The outlook for philanthropic investments in Native communities appears to be improving. The 

Johnson Center for Philanthropy reports that “philanthropy is entering a new era of engagement 

with Native communities.”317 Events in recent years such as the stand-off at Standing Rock and 

the racial reckonings of 2020 have brought an increased awareness in the philanthropic 

community of the unique experiences, strengths, and challenges faced by Native American 

communities.318 MacKenzie Scott’s philanthropic efforts, both in their scale and hands-off 

approach, are influencing the philanthropic landscape.319

314 Ellie Buteau, Hannah Martin, and Katarina Malmgren, “Overlooked (Part Two): Foundation Support for Native 

American Leaders and Communities,” Center for Effective Philanthropy, 2021, http://cep.org/wpcontent/uploads/2021/07/CEP_Overlooked_Native_American.pdf. 

315 Buteau, Martin, and Malmgren, “Overlooked (Part Two).”

316 Avi Bond, et al., “Investing in Native Communities: Philanthropic Funding for Native American Communities 

and Causes,” Candid, 2019, https://www.issuelab.org/resources/35493/35493.pdf.

317 Trish Abalo, Adam Engwis, and Tory Martin, “Philanthropy is Entering a New Era of Engagement with Native 

Communities,” Dorothy A. Johnson Center for Philanthropy, January 18, 2022, 1, 

https://johnsoncenter.org/blog/philanthropy-is-entering-a-new-era-of-engagement-with-native-communities/. 318 Abalo, Engwis, and Martin, “Philanthropy is Entering a New Era.”

319 MacKenzie Scott, “Seeding by Ceding,” Medium, June 15, 2021, https://mackenzie-scott.medium.com/seedingby-ceding-ea6de642bf. 
Community Economic Development in Indian Country // Market Research Report | pg. 80

In describing the selection process for her donations, MacKenzie Scott noted a focus on 

community-centered service. She and her advisors conducted research to identify and evaluate 

equity-oriented nonprofit teams working in areas that have been neglected. Furthermore, she 

chose to make relatively large gifts with no restrictions, trusting in the experience and judgment 

of organizations on the front line.320 

Eight Native American and Alaska Native organizations focused on supporting indigenous 

higher education, philanthropy, and arts and culture received a portion of the $2.74 billion in 

donations announced in June 2021 by MacKenzie Scott. These organizations are:

● American Indian College Fund, which gives scholarships to Native American students; 

● American Indian Higher Education Consortium (AIHEC), a group representing tribal 

colleges; 

● First Peoples Fund, a national nonprofit that supports Native artists and youth through 

entrepreneurship and cultural practice; 

● Native Americans in Philanthropy, an organization that invests funding throughout 

Native communities; 

● Native Arts & Cultures Foundation, which grants funding and mentorship to Native 

artists; 

● NDN Collective, an indigenous-led organization supporting self-determination and 

movement building; 

● Alaska Native Heritage Center, which works to preserve and strengthen Alaska Native 

languages, cultures and traditions; and

● Santa Fe, N.M.-based IAIA Museum of Contemporary Native Arts, the country’s only art 

museum focusing on modern Native art.321

Tribal colleges and cultural institutions are an important component of community economic 

development, for building the future workforce and for providing jobs to residents of Native 

communities. A 2013 report sponsored by the First Peoples fund found that an estimated 30% of 

Native peoples are practicing or potential artists, but many are living below the poverty level and 

lack the arts-specific business skills and training needed to operate successful art ventures. With 

320 Scott, “Seeding by Ceding.”

321 Jenna Kunze, “Indigenous Nonprofits Included in Philanthropist MacKenzie Scott’s Latest $2.74B Round of 

Donations,” Tribal Business News, June 15, 2021, https://tribalbusinessnews.com/sections/economicdevelopment/13526-indigenous-nonprofits-included-in-philanthropist-mackenzie-scott-s-latest-2-74b-round-ofdonations. 
Community Economic Development in Indian Country // Market Research Report | pg. 81

additional support, the Native arts economy “has the potential to expand dramatically, affecting 

not only the artists themselves, but their communities, as well.”322

At the same time, global efforts to address climate change are increasing recognition of the value 

of the cultural and historical knowledge of indigenous people.323 In September 2021, nine 

grantmakers signed on to the Protecting Our Planet Challenge. Their collective $5 billion 

commitment to conservation efforts included a pledge to work closely and differently with 

indigenous communities going forward.324 At the United Nations Climate Change Conference 

(COP26) in November 2021, the United States and four other countries, in partnership with 17

funders, pledged to invest $1.7 billion to help indigenous and local communities protect the 

biodiversity of tropical forests that are vital to protecting the planet from climate change, 

biodiversity loss, and pandemic risk.325 While much of this effort is directed at tropical 

rainforests, the overarching approach represents a change in the relationship of philanthropy to 

indigenous communities, including Native entities in the United States.

Capital Stacking

Jorgensen has documented examples of tribes successfully gaining access to capital and credit, 

including in the sectors of health care facilities, infrastructure projects (water and sewer, cellular 

towers and telecommunication equipment, broadband), grocery stores, and land purchases.326

Successful projects in each of these categories have used unique combinations of multiple 

sources of financing, such as tribal revenue; a tribal bond issue secured by a pledge of third-party 

billing revenues (for the health care facility); federal awards and grants from IHS, EPA, and 

USDA; loans from tribal banks and the USDA; and loans from several CDEs that raised 

investment capital through the NMTC program. While capital stacking is a common approach to 

funding community economic development within and outside of Native communities, these 

examples demonstrate how creative tribes must be to acquire the funding they need to build the 

communities they desire. These projects also demonstrate the importance of a reliable revenue 

stream to secure and repay loans, and that tribes and Native financial institutions and banks can 

realize benefits by building relationships and working together.

Capital stacking does not always bring in new private investment. During site visits for a HUD 

report on Native American and Alaska Native housing, tribes mentioned combining other federal 

322 “Establishing a Creative Economy,” First Peoples Fund, July 2013, 7, 

https://static1.squarespace.com/static/57be24e9d1758e95b6146331/t/57c9d010c534a5aa98846fce/1472843798529/d

ocument-market-study.pdf. 

323 Abalo, Engwis, and Martin, “Philanthropy is Entering a New Era of Engagement.”

324 Jim Rendon, “$5B Conservation Plan Offers New Approach, But Faces Hurdles,” AP News, September 28, 

2021, https://apnews.com/article/climate-change-science-business-philanthropy-oceans6ca70181c532be88358cbedda72dce1e. 

325 “Governments and Private Funders Announce Historic US$1.7 Billion Pledge at COP26 in Support of 

Indigenous Peoples and Local Communities,” Ford Foundation, November 1, 2021, 

https://www.fordfoundation.org/news-and-stories/news-and-press/news/governments-and-private-fundersannounce-historic-us-17-billion-pledge-at-cop26-in-support-of-indigenous-peoples-and-local-communities.

326 “Access to Capital.” 
Community Economic Development in Indian Country // Market Research Report | pg. 82

funds, such as ICDBG funds, or tribal funds or land to support a project, in addition to their main 

funding source.327 Several tribes mentioned using the HUD Title VI Loan Guarantee program,

which allows recipients of Indian Housing Block Grant Funds to use current and future fund 

allocations as a means of leverage to obtain HUD guaranteed financing. While combining 

funding sources can allow some projects to move forward, it can also impose an administrative 

burden: several site visit respondents mentioned the need to work with experts, hire additional 

staff, or obtain more training to improve their ability to leverage funding and combine multiple 

funding sources. In addition, many smaller tribes view leveraging as unfeasible because their 

recurring funding streams are small, limiting their ability to develop the project scale necessary 

to make other sources, such as LIHTC, work for them.

In 2021, Nesika Illahee, an affordable housing development in northeast Portland’s Cully 

neighborhood, was completed using a unique partnership of federal, tribal, state, and local 

resources.328 Community Development Partners (CDP), the Native American Youth and Family 

Center (NAYA), and the Native American Rehabilitation Association (NARA) partnered with 

the Confederated Tribes of Siletz Indians (Siletz) to develop the project. The Siletz Tribe 

sponsored a portion of the project with its HUD IHBG funding. Twenty of the development’s 59 

units give first residential priority to Siletz tribal members and second priority to members of a 

federally or state-recognized tribe and Alaskan Natives. One goal of the project is to combat 

homelessness, which is experienced disproportionately by Native Americans relative to other 

county residents. It also aimed to foster a sense of belonging for tribal members in an urban 

setting through culturally specific design, services, and amenities. This project provides an 

interesting example of capital stacking that involves a tribe, but it is located in an urban area, 

which may bring other unique opportunities or challenges.

The Nesika Illahee development reflects the combination of funding sources and their 

requirements. Oregon Housing and Community Services (OHCS) granted 4% low-income 

housing tax credits, which required that the development accommodate households making no 

more than 60% of area median income. The tribe’s IHBG funds supported 20 units that give first 

residential priority to Siletz tribal members and second priority to members of a federally or 

state-recognized tribe and Alaskan Natives. Since IHBG funds do not guarantee that renters will 

provide tribes and TDHEs with rental income, the development received additional support for 

these units, including $1.5 million that will provide $75,000 per year in rental subsidies over 20 

years. The OHCS Mental Health Housing and General Housing Account programs funded 15 

units that are set aside as recovery housing for tenants with substance use disorders. These 

residents receive additional support from NARA through drug and alcohol counseling. Located 

about a half-mile from the complex, NAYA serves families with children through wraparound 

services that provide food, clothes, and domestic violence interventions along with other forms 

of emergency assistance.

327 Pindus, et al., “Housing Needs of American Indians,” 143. 328 “Innovative Funding Provides Culturally Specific Affordable Housing to Native Americans,” PD&R Edge; U.S. 

Department of Housing and Urban Development, 2021, https://www.huduser.gov/portal/pdredge/pdr-edgeinpractice-072621.html. 
Community Economic Development in Indian Country // Market Research Report | pg. 83

All units contain ENERGY STAR® appliances and LED lighting. The OHCS Multifamily 

Energy Program (MEP) covered the costs of these energy-efficiency measures, which have 

reduced Nesika Illahee’s electricity use by nearly 50% and earned the development Platinum 

certification from Earth Advantage. OHCS also provided a loan through its Local Innovation and 

Fast Track rental housing program, bringing its total contribution to Nesika Illahee to more than 

$10 million.

With Native American households making up 90% of its residents, Nesika Illahee is a culturally 

specific community whose design and amenities give residents a place to partake in tribal 

traditions at different scales, including virtual and oral storytelling using art pieces created by 

local and national Native American artists. Signage and murals provide a familiar cultural 

element for residents. 
Community Economic Development in Indian Country // Market Research Report | pg. 84

Section 8: Community Economic Development in Indian Country: 

Addressing Challenges and Moving Forward

This concluding section highlights opportunities and promising practices that can further 

economic resilience in Native lands and address the need for more and better data, including 

recommendations for future data collection.

To best support the community economic development aims of American Indians, Alaska 

Natives, and Native Hawaiians, it is essential to be aware of the challenges that have historically 

prevented Native communities from accessing opportunities, as well as the challenges that 

remain today. The objective of the CDFI Fund’s NMTC Native Initiative is to support efforts to 

increase NMTC investment in NMTC Native Areas. This Market Research Report aims to 

increase knowledge and understanding of community and economic development strategies in 

Indian Country as one step toward increasing investments in NMTC Native Areas and other 

Native lands. A shared understanding of the following points is critical for moving forward:

● Opportunities exist for enhanced community economic development in Indian Country 

because of new federal funding, increased tribal capacity to plan projects, and the 

growing sophistication of Native CDFIs and other Native actors accessing capital. 

● The need for more and better data underlies many limitations to community economic 

development in Indian Country.

● Understanding of and respect for cultural values is essential for future community 

economic development in Indian Country.

Opportunities for Community Economic Development in Indian Country

Although challenges remain, the community economic development capacities of tribal and other 

Native entities have improved over time and tribal governments and enterprises are wellpositioned to pursue new opportunities for growth.

Increased federal funding, including ARRA (2009) and the CARES Act (2020), which included 

set-asides for Native communities, provided significant amounts of new, time-sensitive funding. 

When these funds needed to be deployed quickly, tribes gained experience prioritizing and 

structuring projects. The COVID-19 pandemic raised awareness of disparities in infrastructure, 

broadband, housing, and health care in tribal areas. Implementing projects to address these 

disparities has provided tribes with experience in addressing complex financing and land issues 

and working with non-Native outside investors. 

Federal funding sources continue to provide opportunities for tribes and Native communities. 

GAO identified eight federal programs that are specifically for tribal entities and provided over 

$930 million in grants and loan guarantees in FY 2017–2021. An additional 14 programs were 

identified that provide significant amounts to tribal entities but also to a wider range of eligible 

recipients, such as small businesses or local governments. However, the total amount of 
Community Economic Development in Indian Country // Market Research Report | pg. 85

assistance provided by these 14 programs to tribal entities is unknown because two of these 

agencies, SBA’s Office of Capital Access and USDA’s Farm Service Agency, do not analyze 

data to estimate obligations provided to tribal entities. GAO states that “estimating and reporting 

the amount of program obligations provided to tribal communities would allow federal agencies 

and decision makers, such as Congress, to better understand the reach of these programs and 

identify areas where tribal entities may need additional support.”329

Historically, the Community Reinvestment Act (CRA) has not been a strong incentive for banks 

to invest in Indian Country. Banks have some flexibility in setting their CRA assessment areas, 

but they have to include areas where they have branches and ATMs, as well as surrounding 

communities. Since reservations tend to be under-banked—in part because of population density 

issues—many banks do not include these areas as part of their CRA assessment areas, choosing 

instead to invest in other low- and moderate-income communities to obtain CRA credit. But 

recently proposed (2020) updates to Community Reinvestment Act (CRA) rules include some 

incentives for increased lending in Indian Country including: 

● Specific measures aimed at spurring investments in tribal public safety, housing, 

education, health care, and communications infrastructure, as well as other community 

and economic development projects on tribal lands;

● Providing banks with CRA credit for serving tribal communities even when Indian 

Country falls outside their CRA assessment areas; and

● Creating CRA scoring incentives for banks that choose to do business in Indian 

Country.330

Since these rules are proposed and not final, they may face additional changes before potential 

adoption. It is too early to know whether a final version of these rules will have a significant 

impact on the number of entities involved in Native communities.

The growth of Native financial entities also presents opportunities for increased access to capital 

and credit in Indian Country. Native CDFIs, credit unions, and other tribal entities are beginning 

to develop and offer lending options specifically crafted for potential Native homeowners' 

incomes, employment status, expense loads, credit histories, and relative borrowing comfort 

levels. Native financial institutions have the opportunity to strengthen their impact and 

community support through the inclusion of services that will serve the unique needs of their 

clients. However, this is contingent on the ability of Native CDFIs to continually collaborate and 

work closely with both tribal governments and outside investors to be successful. According to a 

survey of mortgage lenders, a physical presence near Indian land and developing consistent, 

329 “Tribal Economic Development: Action is Needed.”

330 “Community Reinvestment Act Proposed Rulemaking,” Board of Governors of the Federal Reserve System, 

August 24, 2022, https://www.federalreserve.gov/consumerscommunities/community-reinvestment-act-proposedrulemaking.htm. 
Community Economic Development in Indian Country // Market Research Report | pg. 86

working relationships between tribes and financial actors is effective for improving tribal 

collaboration with non-tribal entities.331 

The details discussed in this report confirm that the pieces and players are in place to continue to 

build a pipeline of community economic development projects in Native communities. As 

described in Section 3, tribes have increased their land management and planning capacity, and 

as described in Section 6, Native actors are expanding the diversity and volume of their 

partnerships and access to capital. There are projects waiting to be done in Native communities 

in various stages of planning, review and approval, and funding. Opportunities lie in the growth 

of tribal enterprises and jobs in the sectors of natural resources extraction, manufacturing, 

construction, hospitality, and public sector projects such as health facilities and community 

centers. Native CDFIs and other financial entities serving Indian Country continue to search for 

ways to meet a growing demand for credit and capital, which will only continue to increase as 

Native economies and tribal capacities grow. 

The Need for Better Economic Data Regarding Indian Country

There are glaring gaps in the available data necessary to support community economic 

development in Native lands, resulting from both a lack of relevant or accurate data being 

collected and restricted access to the data that do exist. This lack of critical data continues to 

hinder the attraction of capital to Indian Country, though several tribes, Native organizations, and 

local, state, and federal agencies are actively working to improve existing data sources and to 

create new ones.

Quality data on economic and community characteristics can be thought of as the “lingua franca 

of investors and policymakers”—necessary for attracting investment and facilitating policy 

change.332 Despite this, the historical misuse of tribal data in non-economic contexts, “like the 

study of tribal health issues [without the consent of the tribal members participating in the study], 

has generated mistrust about sharing tribal data more broadly.”333 One concrete example of the 

consequences this mistrust has for tribes and tribal enterprises: In 2020, the federal government 

was unable to determine the total debt of tribally-owned enterprises, which left the government 

unable to determine sufficient levels of economic support for these entities during the COVID-19 

pandemic.334

That sufficient data for community economic development is lacking in Indian Country is no 

secret. A 2012 report from the Board of Governors of the Federal Reserve System found that 

insufficient research and data and a lack of coordination of research efforts across federal 

331 Listokin et al., “Mortgage Lending on Tribal Land.”

332 “The Role of Data in Building Vibrant Tribal Economies,” Financial Security Program, The Aspen Institute,

November 30, 2022, https://www.aspeninstitute.org/blog-posts/the-role-of-data-in-building-vibrant-tribaleconomies.

333 Ibid. 

334 Ibid. 
Community Economic Development in Indian Country // Market Research Report | pg. 87

agencies were major impediments to the development of Native American economies.335 There 

are three primary data challenges facing Indian Country: “inadequate sample sizes, mismatched 

geographies, and unique data characteristics.”336 Inadequate sample size, resulting from the 

relatively small Native populations in many areas of the U.S., is the reason often cited for the 

exclusion of Native populations from national statistics reporting. Longitudinal datasets “often 

do not have a sufficient number of American Indians to conduct the standard analyses employed 

for other races,” due to the small relative size of the population.337 The data that is available from 

the U.S. Census Bureau’s Decennial Census, American Community Survey (ACS), and other 

surveys does not provide information about how individuals are doing over time, making it 

difficult to evaluate the impact of policies and programs aimed at improving economic and 

quality of life outcomes.338 Additionally, although the ACS does oversample in Native and tribal 

areas, the ACS has a smaller sample size than the 2000 decennial census long-form that it 

replaced and thus wider confidence intervals, particularly for smaller or more rural geographies 

seen in many tribal areas.

Some surveys and reports fail to incorporate American Indian, Alaska Native, or Other Pacific 

Islander as an available answer choice altogether. For example, the monthly Bureau of Labor 

Statistics Jobs Report did not publish monthly labor force estimates for Native Americans 

because of “issues around sample size,” before changing its policy in early 2022.339,340 Data 

collected on Native communities might also require unique attributes that are typically not 

collected in existing surveys, such as tribal affiliation and enrollment.341

Geography becomes a challenge for accurate data collection in Native lands and service areas 

because “the geographic units used in many surveys do not line up precisely with Indian Country 

maps,” and conditions can vary dramatically just inside and just outside tribal-area borders.342

Tribal lands and Native communities often cross other political boundaries, including county and 

state boundaries, and adjacent non-Native communities may exhibit very different characteristics 

that may obscure real needs and opportunities or even prevent tribes and Native entities from 

being eligible for certain grants, tax credit programs, and other community economic 

development incentive programs. Furthermore, while data may be available at a county or 

335 “Growing Economies in Indian Country: Taking Stock of Progress and Partnerships,” Board of Governors of the 

Federal Reserve System, April 2012, https://www.federalreserve.gov/newsevents/conferences/GEIC-white-paper20120501.pdf.

336 Gregg, Nunn, and Lozar, “An Urgent Priority,” 1.

337 Gabriel R. Sanchez, Robert Maxim, and Raymond Foxworth, “The monthly jobs report ignores Native 

Americans. How are they faring economically?” The Avenue, Brookings, November 10, 2021, 

https://www.brookings.edu/blog/the-avenue/2021/11/10/the-monthly-jobs-report-ignores-native-americans-how-arethey-faring-economically.

338 Ibid.

339 Ibid.

340 Alicia Wallace, “The US will now break out jobs data for Native Americans,” CNN Business, March 5, 2022, 

https://www.cnn.com/2022/03/05/economy/native-american-monthly-employment-data/index.html.

341 Akee, “Sovereignty and Improved Economic Outcomes.”

342 Gregg, Nunn, and Lozar, “An Urgent Priority.”
Community Economic Development in Indian Country // Market Research Report | pg. 88

reservation level, it may not be available at other vital levels, such as service areas, funding 

formula areas, or tribally established reservation districts.

The Census Bureau’s application of “differential privacy,”–the deliberate introduction of noise 

into a dataset to prevent users from identifying individual respondents–to its decennial census 

data set has created significant concern about the accuracy of that essential source of 

demographic data for Native communities, other racial groups, and other areas with smaller 

populations. Differential privacy methods are especially implemented in areas with lower 

population counts, “such as rural or remote areas where commercial data could more easily be 

used to identify individuals.”343 This could significantly change population counts in areas 

“where a disproportionate number of individuals from certain racial and ethnic groups reside, 

especially when they are in small numbers in that area or geographic region,” and for small 

populations such as the American Indian, Alaska Native, and Native Hawaiian populations.344

This practice has the potential to exacerbate the aforementioned issues with the availability and 

reliability of data on Native populations.

The Role of Data Sovereignty

Data sovereignty, a component of the overarching sovereignty possessed by Indian tribes and a 

critical manifestation of tribal self-determination, refers to the right of indigenous people and 

nations to govern the collection, ownership, and application of their own data.345 Historically, 

Native communities were essentially treated as laboratories by universities and research 

institutions, with resource-limited tribes unable to exercise substantial control over potentially 

harmful research activities within their lands.346 

To prevent the exploitative and extractive practices of some researchers operating within 

reservations and Native communities, and to ensure that tribes and Native communities retain 

access to and ownership of information collected from their people as well as the authority to 

determine how that information can be used, many tribes have established Institutional Review 

Boards (IRBs).347

343 “Differential Privacy and the 2020 U.S. Decennial Census: Impact on American Indian and Alaska Native Data,” 

NCAI Policy Research Center, National Congress of American Indians September, 2019, 

https://www.ncai.org/prc/2020_Census_and_AIAN_data_FINAL_9_11_2019.pdf. 

344 Ibid. 

345 Alex Tammaro, “Native Data Sovereignty Can Address Data Gaps and Improve Equity,” Urban Wire, Urban 

Institute, June 13, 2022, https://www.urban.org/urban-wire/native-data-sovereignty-can-address-data-gaps-andimprove-equity.

346 Danielle Hiraldo, et al., “Native Nation Rebuilding for Tribal Research and Data Governance,” Tucson: Native 

Nations Institute, University of Arizona, January 1, 2020, 

https://nnigovernance.arizona.edu/sites/nnigovernance.arizona.edu/files/resources/Policy%2520Brief-

%2520Native%2520Nation%2520Rebuilding%2520for%2520Tribal%2520Research%2520and%2520Data%2520G

overnance.pdf. 

347 “Institutional Review Boards,” Indian Health Service, accessed April 28, 2023, 

https://www.ihs.gov/dper/research/hsrp/instreviewboards. 
Community Economic Development in Indian Country // Market Research Report | pg. 89

These boards are generally composed of experienced researchers from tribal colleges and nearby 

universities, local leaders, and community members who are tasked with reviewing the purpose, 

methodology, and efficacy of proposed research; evaluating potential or anticipated harms or 

negative impacts on community members who will be asked to participate in the research; and 

retaining the authority to approve or reject proposed uses or publication of the information 

gathered. In addition to protecting community members from harm or exploitation, IRBs often 

also seek to coordinate, and in some cases limit, externally developed research activities within 

reservations and Native communities, which are already frequently surveyed internally by tribes 

and tribal programs themselves to assess needs, refine programs and services, and plan for the 

future.348

 

As tribes continue to more fully express and implement data sovereignty, and other non-tribal 

entities embrace and incorporate the guiding principles of data sovereignty into their processes, 

tribes and Native communities are more actively participating in the design and monitoring 

stages of data collection projects within their lands. They are also developing strong partnerships 

with other tribal and non-tribal organizations at state, regional and national levels.349 By 

capitalizing on the resources and expertise of each of the partners, they can produce muchneeded accurate tribal data sets, while retaining tribal ownership and control over the use of the 

data collected. For many tribes, the next step along the path toward true data sovereignty and 

self-determination is the development of the requisite data management infrastructure and human 

resources necessary to securely store, organize, analyze, and efficiently use and share the data 

that they possess.350

Impacts of Data Limitations for Native Communities

The lack of accurate, relevant, and precise subject-specific data undercuts the efforts of tribes 

and Native organizations to promote and sustain community economic development activities. 

This data is not only necessary for supporting internal community economic development 

planning efforts, but it is also essential for allowing lenders and investors to assess the 

opportunities and risks associated with bringing their capital to Native lands. The unique land 

ownership issues and stunted housing markets in many Native communities, for example, limits 

or prevents many mainstream data-related services, such as Zillow, from covering Native 

communities. Many appraisers located outside of Native lands may be discouraged from 

conducting land and structure valuation activities in these areas due to the lack of available 

databases of comparable property values.351 As a result, land sales are hindered due to 

348 Deana Around Him, et al., “Tribal IRBs: A Framework for Understanding Research Oversight in American 

Indian and Alaska Native Communities,” American Indian and Alaska Native Mental Health Research 2, no. 2 

(2019): 71–95. 

349 Heather Erb, “Tribal Data Sovereignty and the Critical Role of Data in Public Health Governance,” American 

Indian Health Commission for Washington State, accessed April 28, 2023, https://bja.ojp.gov/doc/tribal-datasovereignty-presentation.pdf. 

350 Hiraldo, et al., “Native Nation Rebuilding for Tribal Research and Data Governance.”

351 Kevin Klingbeil and Harry Maher, “Appraisal Market Study,” South Dakota Native Homeownership Coalition, 

February 2, 2021, https://www.sdnativehomeownershipcoalition.org/2019/wp-content/uploads/2019/10/SDNHCAppraisal-Market-Study-Final-Report.pdf. 
Community Economic Development in Indian Country // Market Research Report | pg. 90

uncertainty regarding property values for both the seller and the buyer. Many tribes have created 

their own realty and title offices to reduce the amount of time necessary to obtain title status 

reports to facilitate land and home sales and purchases, and to develop their own databases 

recording real property sales to support their land and housing markets.

Similarly, because many businesses operating on reservations are owned by the tribe and are not 

subject to federal taxation, critical business data, such as average return on investment, 

anticipated growth in terms of hiring and revenue, numbers and timing of new business or 

facility development, or telecommunications connectivity of households and local enterprises, 

which demonstrate the viability of economic development in Native lands, may not be 

disclosed.352 In cases where it is disclosed, such as in the National Indian Gaming Commission 

(NIGC) annual reports on the Native gaming industry, it may only be available in the form of 

aggregated data sets or comprehensive tribal economic reports.353

The limited presence and scope of measurement and reporting of community economic 

development activities in tribal lands, via tribal planning departments, data/vital records centers, 

and chambers of commerce, also likely contributes to the challenge of attracting capital to Native 

lands. Without consistent and available measurement or reporting, potential investors and 

grantmaking entities have a more difficult time identifying the broader framework in which a 

project or investment will fit, and may not believe that the necessary infrastructure will be 

created or maintained to support their investment. There is no standardized system for measuring 

the contributions that some tribal governments provide to their regional and local economies. 

Recent tribal efforts to measure economic impacts include a 2014 summary of the economic 

impacts of the five tribes of Idaho on Idaho’s economy, a 2019 study of economic impacts of 

Oklahoma tribes,354 a 2019 Michigan study of the benefits of non-gaming tribal enterprises, and 

a 2022 report on the impact of investments made by 29 Washington tribes to the state’s quality 

of life.355

The absence of reliable demographic and community economic development data also has a 

direct impact on the levels of federal grant funding allocated to tribes and Native communities as 

well as their eligibility to participate in specific programs designed to target areas with 

demonstrated need.356 For example, the Indian Housing Block Grant (IHBG) formula allocates 

Native American Housing and Self-Determination Act (NAHASDA) funding based on the 

number of self-identified American Indian Alaska Native and Native Hawaiian (AIANNH) 

individuals and households in an area, since these services can only be provided to tribal 

352 “Indian Country’s Once-in-a-Seven-Generation Opportunity,” Wells Fargo, 2022, 

https://www08.wellsfargomedia.com/assets/pdf/commercial/focus/2022-tribal-economic-resiliency-report-0929.pdf.

353 “The Role of Data in Building Vibrant Tribal Economies.”

354 “Oklahoma Native Impact,” Oklahoma Native Impact Study, 2019, https://www.oknativeimpact.com.

355 Meister Economic Consulting, “The Economic Impact of Tribal Gaming: A State-by-State Analysis,” American 

Gaming Association, November, 2018, https://www.americangaming.org/wp-content/uploads/2018/11/EconomicImpact-of-Tribal-Gaming-Two-Pager-11.5.18.pdf.

356 “Data and Funding Gaps in Tribal Early Care and Education,” Bipartisan Policy Center, April, 2021, 

https://bipartisanpolicy.org/explainer/gaps-in-tribal-care.
Community Economic Development in Indian Country // Market Research Report | pg. 91

members.357 Funding for the tribal transportation program is partially based on the AIANNH 

population data incorporated into the IHBG formula, so any inaccuracy within the data set used 

for IHBG funding is then magnified when used as the basis for another critical federal funding 

formula. Other tax incentive programs, such as the LIHTC and NMTC programs, require that 

projects be located in Qualified Census Tracts or areas designated as low-income communities, 

which are based on the income levels of households in the relevant area. But tract boundaries do 

not always correspond to the geography of Native lands, and many “landless” tribes have service 

areas rather than official reservation lands. Geographical mismatches between tribal lands or 

services areas and official Census boundaries can prevent tribes from qualifying for federal 

programs, especially if tribal lands fall into tracts that overlap with wealthier non-Native 

communities.

Recommendations for Future Data Collection

To improve and fill in the gaps in federal, tribal, and other data describing Native communities, a 

comprehensive evaluation of available data sources should be conducted. This evaluation would 

address the issues of data relevance, accuracy, and precision described above. One example of a 

similar but narrower exercise was an evaluation of an array of potential data sources for the 

IHBG formula, completed by the Data Study Group to support the Indian Housing Block Grant 

Formula Negotiated Rulemaking Committee. The Data Study Group highlighted the specific 

reasons why federal, tribal, and other data sources would or would not work for the specific 

purpose of supporting the IHBG formula and allocation of funds pursuant to NAHASDA. The 

researchers also recommended changes to certain surveys and data collection processes to better 

serve Native communities, such as oversampling in Native lands or revisiting the use of proxies 

(such as neighbors or knowledgeable non-members of the household) to collect information 

about large or multi-family households.358

Changing large scale data collection processes to better cover specific populations is not always 

feasible or practical without significant legislative advocacy. But efforts to further analyze or 

visualize existing data or analyze datasets in relation to one another can help increase their value 

in promoting community economic development in Native lands. The Center for Indian Country 

Development (CICD) launched an effort to expand the evaluation, analysis, and visualization of 

data regarding tribal and Native communities, which includes analysis of Current Population 

Survey (CPS) data to more appropriately capture the employment and labor force participation 

rates of individuals who self-identify as either AIAN alone or AIAN in combination with other 

races.359 CICD has also mapped financial resources in American Indian, Alaska Native and 

Native Hawaiian (AIANNH) areas and layered geospatial data to enable users to identify 

357 “Data Use and Regulatory Status of the Indian Housing Block Grant Program,” U.S. Government Accountability 

Office, GAO-15-353R, Washington, DC: U.S., March 10, 2015, https://www.gao.gov/products/gao-15-353r.

358 “IHBG Negotiated Rulemaking Data Study Group Final Report,” Indian Housing Block Grant Formula 

Negotiated Rulemaking Committee, no. 1, July 31, 2015, 

https://ihbgrulemaking.org/images/Library/IHBG_Negotiated_Rulemaking_Data_Study_Group_Report_080315_Vo

lume_I.pdf.

359 “Native American Labor Market Dashboard.”
Community Economic Development in Indian Country // Market Research Report | pg. 92

economic development activities in AIANNH areas as well as areas eligible for Community 

Reinvestment Act activities.360,361

Any evaluation of existing data sources must include an inventory of local and tribal data. Tribal 

governments gather a wide array of informative data through their own departments and 

chartered entities because of their ongoing relationships with local and state governments, utility 

providers, and other local, state, and national organizations. For example, application and 

certification processes enable programs to collect vital information about household incomes, 

telecommunications and utility costs, the condition of housing and community infrastructure, 

health and wellness, and employment status.

Many tribes and Native organizations have recognized that new data collection is necessary to 

ensure that Native communities are equipped with databases that are appropriate for their 

intended purposes and that accurately reflect the conditions, needs, and opportunities in their 

communities. The resulting surveys, market studies, and needs assessments enable tribes and 

Native communities to gather more accurate data regarding:

• Informal economies (including self-employment in the form of craft-making and fishing); 

• Available skills sets and experience within their communities; 

• Individual interest in new employment, small business development and further 

education; 

• Community interest in specific new tribal enterprises and services; and

• The potential interest and availability of members living off-reservation to support new 

enterprises, tribal departments, and homeownership programs. 

As tribes and Native communities become collectors and providers of new, more accurate local 

datasets, their ability to serve as partners in regional planning and economic development efforts 

will increase.

Critical requirements for tribal data collection include the internal tribal, organizational, or 

departmental capacity to complete data collection efforts with the statistical rigor required for the 

proposed data use. It might be necessary to locate new sources of funding to conduct data 

collection activities. Programs such as the HUD Section 4 Capacity Building program, 

implemented in Native communities by Enterprise Community Partners, provides funding 

specifically for tribes and community development organizations to build data collection 

capacity. Additionally, specific federal grant programs managed by Federal Emergency 

360 Center for Indian Community Development, “Native American Funding and Finance Atlas,” Federal Reserve 

Bank of Minneapolis, accessed January 13, 2023, https://www.minneapolisfed.org/indiancountry/resources/nativeamerican-funding-and-finance-atlas.

361 “Mapping Native American Financial Institutions.”
Community Economic Development in Indian Country // Market Research Report | pg. 93

Management Agency (FEMA),362 the Substance Abuse and Mental Health Services 

Administration (SAMHSA),363 and EDA364 provide funding for needs assessment and planning 

activities, which includes a community-based data collection component. Tribal grants and 

planning departments, vital records offices, data and business resource centers, and other 

organizations engaged in using existing and newly collected data are vital for maximizing the 

utility and value of collected data and for highlighting areas for improvement for tribal, federal, 

and other surveys.

Cultural Values and Economic Development

While tribal governments work towards economic growth, they are also focused on preserving 

tribal culture, identity, sovereignty, population, and land, creating a unique balance of priorities 

that is distinct from other rural communities. All components of community economic 

development in Indian Country are also considered through a cultural lens by tribal actors, which 

can help explain some of the economic decisions made by tribal governments. 

Tribal self-governance adds a layer of complexity to economic growth, which is distinct from the 

layers of governance non-tribal rural areas experience. For example, many tribes might make an 

active choice to avoid exploiting or developing their natural resources, such as minerals, water, 

or forests, for economic gain. While natural resources are a common economic resource for most 

rural areas, land itself, in its unspoiled state, often holds a significant historical, cultural, and 

spiritual meaning. Therefore, the appropriate choice for a tribe might be to preserve the land 

rather than develop resources for economic growth. Tribes might also decide to invest resources 

into acquiring more land, especially land of historic significance, rather than investing in other 

economic ventures. Tribal land ownership through the trust system is critical to maintaining 

tribal sovereignty and preserving the reservation land base. This system is unique to Indian 

Country and does not occur in other rural areas.

Tribes often weave their cultural values into their decisions for how to run their businesses. For 

example, many tribes have designated their casinos as alcohol-free, which is not a common 

choice among non-tribal casinos. Many tribal casinos offer day care centers on site for

employees. Tribes may also incorporate their Native languages into their economic development 

strategies by adding them to road, interstate, town, and business signage.

Many tribes have strong community, family, and cultural ties that help communities stay 

together even if poverty rates are high, in an effort to protect cultural identity. This is different 

from many other rural areas, where large-scale migration is a common response to poverty. This 

362 “Hazard Mitigation Grant Program,” Federal Emergency Management Agency, accessed January 13, 2023, 

https://www.fema.gov/grants/mitigation/hazard-mitigation. 363 “Circles of Care,” Substance Abuse and Mental Health Services Administration, U.S. Department of Health & 

Human Services, accessed January 13, 2023, https://www.samhsa.gov/tribal-ttac/circles-care. 

364 “Fiscal Year 2021-2023 EDA Planning and Local Technical Assistance Program,” U.S. Economic Development 

Administration, accessed January 13, 2023, https://www.eda.gov/funding/funding-opportunities/fiscal-year-2021-

2023-eda-planning-and-local-technical-assistance. 
Community Economic Development in Indian Country // Market Research Report | pg. 94

community dynamic might inform tribal decisions to use general tribal funds and gaming or 

enterprise revenue to preserve and create affordable housing, when possible, to allow members 

to remain near their tribal lands and communities. 

Those interested in partnering on projects in Indian Country can benefit from enhanced cultural 

understanding. When surveyed, Native American nonprofit leaders stressed the desire for 

funders and foundations to have already conducted background research before establishing 

relationships to cultivate connections based on deepened understanding of the specific 

community.365 Outreach to Native tribes needs to be consistent and thorough while 

acknowledging the wide perspectives and unique experiences and complexities of each tribe and 

community.

Conclusion

After emerging from several generations of near-complete federal (and, in some cases, state) 

government control of economic development within most Native lands and communities, tribes 

and Native communities have been steadily building their community economic development 

capacity and diversified their local economies since the onset of the self-determination era in the 

1970s. This has resulted in an expansion of tribal enterprises and community economic 

development activities, including in the gaming, health care, clean energy, and environmental 

sectors.

Tribes and Native communities have successfully used federal programs, grants, and tax credit 

allocations, as well as land leasing authority granted under the HEARTH Act, to leverage 

investment in housing and develop mechanisms that support and promote expanded investment 

within trust lands. This review of community economic development in Indian Country describes 

the diverse range of approaches and successful efforts to funding and planning community 

economic development in Indian Country, as well as challenges still facing the space. 

Many regional and national Native organizations argue that the issue of community economic 

development in Native lands is now less dependent on capacity-building than on adequate and 

equitable access to financing and capital. These organizations posit that the focus should be on 

developing grant and financing guidelines that more fairly incorporate the unique circumstances 

of Native communities into selection criteria, as well as the creation of a set of tribal and Native 

set-asides to ensure tribal participation in certain programs.366 Such set-asides would outweigh or 

defray the cost and uncertainty related to applying for competitive grants, tax credits, and other 

financing mechanisms.

Despite the progress that has been made, federal policymakers, funders, and private investors 

still often lack necessary understanding about the community economic development goals and 

365 Buteau, Martin, and Malmgren, “Overlooked (Part Two).”

366 “Lawmakers Call for Expanded NMTC Access for Native Communities,” Tax Notes, September 28, 2020, 

https://www.taxnotes.com/research/federal/legislative-documents/congressional-tax-correspondence/lawmakerscall-for-expanded-nmtc-access-for-native-communities/2d088.
Community Economic Development in Indian Country // Market Research Report | pg. 95

outlooks of Native American leaders, planners, and communities. Relationship-building and 

consultation should continue to ensure that all parties can participate in the array of opportunities 

that exist for investment and economic development in Native lands. Furthermore, there are 

structural factors in current federal and state programs and policies that limit the abilities of even 

well-intended programs to adequately support and encourage participation of Native 

communities and meet their needs in ways that are consistent with their cultural values. This 

Market Research Report is a first step towards bridging that divide.
Community Economic Development in Indian Country // Market Research Report | pg. 96

Glossary

AIANNH: American Indian, Alaska Native, and 

Native Hawaiian. The Indian Housing Block 

Grant formula allocates NAHASDA funding 

based on the number of self-identified AIANNH 

individuals and households in an area. 

ANCSA: Alaska Native Claims Settlement Act: 

Authorized Alaska Natives to 44 million acres of 

public land in Alaska and $962.5 million in cash 

as settlement of their aboriginal claim to land in 

the state. It established Alaska Native villages 

and regional Alaska Native corporations to 

oversee the lands and payments, changing the 

land ownership model from one of shared coownership to one of corporate shareholding.

ANVSA: Alaskan Native Village Statistical 

Areas. Census-defined areas representing the 

permanent or seasonal residences for Alaska 

Natives who are members of, or receiving 

governmental services from, a defined Alaska 

Native village.

ATNI: Affiliated Tribes of Northwest Indians. 

Formed in 1953, today ATNI is a nonprofit 

organization representing 57 Northwest tribal 

governments from Oregon, Idaho, Washington, 

southeast Alaska, Northern California and 

Western Montana, dedicated to tribal 

sovereignty and self-determination.

CDC: Community Development Corporation. 

Community-centered nonprofit organizations 

whose primary purpose is to provide resources 

to and revitalize low-income, historically 

underserved areas that experience high levels of 

divestment.

CDFI Fund: Community Development 

Financial Institutions Fund. Created for the 

purpose of promoting economic revitalization 

and community development through

investment in and assistance to community 

development financial institutions. The CDFI 

Fund was established by the Riegle Community 

Development and Regulatory Improvement Act 

of 1994. Native American CDFIs and a special 

CDFI Native Initiative Fund stimulate and aid 

these CDFIs.

CDFI: Certified Community Development 

Financial Institution. Banks, credit unions, loan 

funds, microloan funds, or venture capital 

providers that provide access to financial 

products and services for residents and 

businesses in low-income communities.

CRA: Community Reinvestment Act. Enacted 

in 1977, the Community Reinvestment Act 

requires the Federal Reserve and other federal 

banking regulators to encourage financial 

institutions to help meet the credit needs of the 

communities in which they do business, 

including low- and moderate-income

neighborhoods.

fractionated ownership: The term used to note 

ownership of a property in the name of more 

than one individual. It is typically used in 

conjunction with allotted or individual trust 

lands to describe situations in which, over time 

and through division of inheritance, multiple 

parties have claim to a single property.

Federal Indian Reservations: Land reserved 

for a tribe or tribes under treaty or other 

agreement with the United States, executive 

order, or federal statute or administrative action 

as permanent tribal homelands, and where the 

federal government holds title to the land in trust 

on behalf of the tribe.

GLITC: Great Lakes Inter-Tribal Council, Inc. 

is a consortium of federally recognized Indian 

tribes in Wisconsin and the Upper Peninsula of 

Michigan. The organization was chartered in 

1965 as a nonprofit corporation. Today, GLITC 

is recognized as a tribal organization under the 

Indian Self-Determination and Education Act. 

Its mission has evolved to support member tribes 

in expanding self-determination efforts by 

providing services and assistance.
Community Economic Development in Indian Country // Market Research Report | pg. 97

GSE: Government-sponsored entity. A 

government-sponsored entity, also known as 

a government-sponsored enterprise, is a 

quasi-governmental, privately held agency 

established by Congress to improve credit 

flow in some regions of the United States' 

economy. GSEs provide financial services to 

the public for various things, particularly 

mortgages, through capital market liquidity. 

GSEs help to facilitate borrowing for a 

variety of individuals, including students, 

farmers, and homeowners.

Hawaiian Home Land Trust: More than 

200,000 acres set aside by Congress in 1921 via 

the Hawaiian Homes Commission Act (HHCA), 

managed today by the State of Hawaii 

Department of Hawaiian Home Lands (DHHL). 

Eligible Native Hawaiians—those who are 50% 

or more Native Hawaiian by blood quantum—

can apply to live on designated trust land. 

HEARTH Act: Helping Expedite and Advance 

Responsible Tribal Homeownership. The 

HEARTH Act of 2012 creates an alternative 

land leasing process. Tribes are authorized to 

execute agricultural and business leases of tribal 

trust lands for a primary term of 25 years and up 

to two renewal terms of 25 years each without 

approval by the Secretary of the U.S. 

Department of the Interior, provided governing 

tribal leasing regulations have already been 

submitted to the Secretary.

Homestead Associations: Comparable to tribes 

on the main continent, these are Native 

Hawaiian entities that are beneficiary-controlled 

and serve and represent the interests of a 

homestead community.

Indian Country: The definition of “Indian 

Country” has changed throughout history, but 

the term is used here in the common colloquial 

sense to mean tribal areas, including Alaska 

Native villages. The term “Indian Country” is 

not used as a legal term in this report.

ICDBG: Indian Community Development 

Block Grant. A grant program administered by 

HUD to promote community development in 

Native communities.

IHBG: Indian Housing Block Grant, a formula 

grant that allocates funding for a range of 

affordable housing activities on Indian 

reservations and Indian areas. The block grant 

approach to housing for Native Americans was 

enabled by the Native American Housing 

Assistance and Self Determination Act of 1996 

(NAHASDA.) 

IMDA: Indian Mineral Development Act of 

1982. Allowed tribes to enter into agreements 

for the development of their mineral resources.

Indian Self-Determination and Education 

Assistance Act of 1975: This piece of 

legislation redistributed power from the federal 

government to tribes in education and program 

administration. Later amendments in the 1980s 

and 1990s established block grants from the 

Indian Health Service and Bureau of Indian 

Affairs to cover other programs.

LIHTC: Low-Income Housing Tax Credit. 

Created by the Tax Reform Act of 1986, the 

LIHTC program gives state and local LIHTC 

allocating agencies the equivalent of nearly $8 

billion in annual budget authority to issue tax 

credits for the acquisition, rehabilitation, or new 

construction of rental housing targeted to lowerincome households.

Native American Credit Unions: A credit 

union is a financial cooperative, owned entirely 

by its members. Typically, more than half of a 

Native American credit union’s current and 

eligible potential members and more than half of 

its current board of directors are Native 

American.

NAFOA: The Native American Finance 

Officers Association. Established in 1982 to 
Community Economic Development in Indian Country // Market Research Report | pg. 98

financially assist tribal economies and 

strengthen tribal finance.

NAHASDA: Native American Housing 

Assistance and Self Determination Act. Signed 

on October 26, 1996, NAHASDA replaced the 

myriad programs that had previously provided 

housing assistance to Native American tribes 

under the U.S. Housing Act of 1937 with a block 

grant that allowed tribes or their Tribally 

Designated Housing Entities (also called 

TDHEs) more flexibility to decide whom to 

serve, what services to offer, and how to deliver 

programs and services. As with the 1937 Act, 

under NAHASDA, tribes are still required to 

primarily serve low-income families.

NAIHC: The National American Indian 

Housing Council. Founded in 1974, NAIHC 

provides training and technical assistance to 

tribes and tribal housing entities to support the 

development of safe, affordable, and culturally 

appropriate housing for Native people and 

communities.

NCAI: The National Congress of American 

Indians. Founded in 1944, NCAI is the oldest, 

and largest American Indian and Alaska Native 

rights organization meant to represent Native 

tribes and advocate for tribal sovereignty.

NCAIED: The National Center for American 

Indian Enterprise Development. The largest 

Native-centered national business organization.

Native CDFI: Native Community Development 

Financial Institution. CDFIs that direct at least 

50% of their activities to serve Native 

Americans, Alaska Natives, or Native Hawaiian 

communities.

New Markets Native Areas (NMTC Native 

Areas): Defined by the CDFI Fund as Federal 

Indian Reservations, Off-Reservation Trust 

Lands, Hawaiian Home Lands, and Alaskan 

Native Village Statistical Areas.

NMTC: New Markets Tax Credits. The New 

Markets Tax Credit Program, established in 

2000, incentivizes community development and 

economic growth through the use of tax credits 

that attract private investment to distressed 

communities.

off-reservation trust lands: Areas off of 

reservations but for which the United States 

holds title in trust for the benefit of a tribe (tribal 

trust land) or for an individual American Indian 

(individual trust land). Census-recognized offreservation trust lands are associated with a 

specific federally recognized reservation or 

tribal government, and American Indian tribes 

have primary governmental authority over these 

lands.

OTSA: Oklahoma Tribal Statistical Area. 

Census-designated areas representing former 

American Indian reservations that existed in 

Indian and Oklahoma territories prior to 

Oklahoma statehood.

Pueblo: Communities and homelands of the 

Pueblo peoples, mostly in the Southwestern 

United States.

State-recognized American Indian 

Reservations: Tribal lands that are recognized 

by a state but not necessarily recognized by the 

federal government.

SWF: Sovereign wealth fund. Also known as a 

social wealth fund or a sovereign investment 

fund, these are state-owned investments which 

generate wealth for the benefit of its citizens and 

economy.

TDHE: Tribally Designated Housing Entity. 

The entity designated by each tribe that is 

responsible for administering its housing 

assistance program that is funded by the federal 

government.

TERA: Tribal Energy Development and SelfDetermination Act of 2005 allows tribes to gain 

approval from the Secretary of the Interior for a 
Community Economic Development in Indian Country // Market Research Report | pg. 99

Tribal Energy Resource Agreement, giving them 

blanket authority to manage mineral 

development on its lands, without separate 

approval of each venture.

USET: United South and Eastern Tribes, Inc., 

established in 1969, is a nonprofit, inter-tribal 

organization serving thirty-three (33) federally 

recognized tribal nations from the Northeastern 

Woodlands to the Everglades and across the 

Gulf of Mexico. USET is dedicated to enhancing 

the development of tribal nations, improving the 

capabilities of tribal governments, and 

improving the quality of life for Indian people 

through a variety of technical and supportive 

programmatic services.
Community Economic Development in Indian Country // Market Research Report | pg. 100

Appendix A: Special Circumstances Pertaining to Alaska Native 

Villages, Oklahoma Tribes, Pueblos, and Hawaiian Home Lands

While all economic development throughout Native communities is shaped by unique legal, 

historical, and cultural contexts, there are some important distinctions between Alaska Native 

villages and Alaska Native corporations, Oklahoma tribal lands, Pueblos and Spanish land 

grants, and Hawaiian Home Lands. 

Alaska

Passage of the Alaska Native Claims Settlement Act (ANCSA) in 1971 radically changed the 

way the United States deals with Indian tribes and Native villages in Alaska and dramatically 

affected the path of economic development for Alaska Natives. What is now Alaska is the 

aboriginal home of several Indian tribes and many Alaska Native groups, including Athabascan 

Indians, Aleuts, and Inuit (the Inuit include the Inupiat and Yupik peoples). Before 1971, the 

United States dealt with Indians and Native groups in Alaska in a fashion similar to that used 

with Indian tribes in the lower 48 states: through treaties, legislation, and executive orders.

 

ANCSA extinguished Native land claims to almost all of Alaska in exchange for about one-ninth 

of the state’s land plus $962.5 million in compensation. By conveying Native land title to 12 

regional and 200 local Village Corporations chartered under Alaska state law, ANCSA changed 

the relationship between Natives and the land from one of co-ownership of shared lands to one of 

corporate shareholding (that is, land ownership was based on a corporate model). After ANCSA, 

Native villages served members and Native village corporations, and Native regional 

corporations served shareholders. A thirteenth regional Native corporation was created for 

Alaska Natives who had left the state and were not shareholders in one of the 12 regional 

corporations. 

The Native regional corporations and Native village corporations operate very differently from 

most Native villages and Indian tribes. They have stockholders, substantial liquid assets, and are 

governed by a board of directors. Through a combination of corporate structure where individual 

members of tribes or Native villages own shares in the corporation, the relatively large amount of 

liquid assets they received when they were created (pursuant

to the enactment of ANCSA), and their mission of protecting and expanding their assets, Alaska 

Native corporations are generally more open to investment outside their Native communities and 

have invested broadly in the economy of the United States.367

Oklahoma 

The history of Oklahoma Indians is unlike that of any other state, and differences remain in land 

ownership and legal jurisdiction that continue to affect the economic development activities of 

Oklahoma tribes. Most of the tribes in Oklahoma are there as a result of relocation policies, 

367 Walter Hillabrant, Judy Earp, Mack Rhoades, and Nancy Pindus, “Overcoming Challenges to Business and 

Economic Development in Indian Country,” Princeton, NJ: Mathematica Policy Research, Inc. 2004.
Community Economic Development in Indian Country // Market Research Report | pg. 101

which forced the movement of some tribes to the state from as far away as New England and the 

Pacific Northwest. The Five Civilized Tribes of the Southeast United States (Seminole, Choctaw, 

Chickasaw, Cherokee, and Creek) were among those forcibly removed to lands in Oklahoma in 

exchange for their homelands in the east.368

By 1837, all of Oklahoma’s Indian Territory had been assigned to the Five Civilized Tribes, 

although some plains tribes such as the Kiowa, Comanche, Wichita, and Apache were granted 

hunting rights in the area. Between 1837 and the outbreak of the Civil War, the tribes largely 

functioned with limited interference from the U.S. government. The Civil War, however, had a 

devastating effect on the tribes. Some Indians remained loyal to the Union; others joined the 

Confederacy. The United States used the latter to abrogate all treaties made with the Five 

Civilized Tribes. Over the next few years, a new series of treaties resulted in extensive land 

cessions.369

Shortly after the Civil War, hostilities with the Southern Plains tribes led to the segregation of 

the Native population into Indian Territory. Many tribes were moved into the lands ceded by the 

Five Civilized Tribes. This move accounts for the current day boundaries of the reservations in 

Western Oklahoma. Life in Indian Territory again went through a period of relative calm, until 

the enactment of the Dawes Act, also known as the General Allotment Act, in 1887, which 

finally destroyed the notion of Indian Territory. The law authorized the President to break up 

reservation land, which was held in common by the members of a tribe, into small allotments to 

be parceled out to individuals. This, in effect, terminated the centralized reservations of the Five 

Civilized Tribes. The tribes of the western side of Oklahoma, such as the Comanche, the Kiowa, 

the Apache, the Tonkawa, and the Shawnee, remained largely independent of the white way of 

life; they maintained their nomadic hunting way of life.370

This complicated history has led to variation in state policies affecting Oklahoma Native 

populations, and ongoing legal disputes regarding land and mineral rights, court jurisdiction, 

taxation, and tribal sovereignty. While the situation has improved since 1976, legal issues 

continue. Oklahoma Tribal Statistical Areas (OTSAs) used by the Census denote areas that were 

formerly reservations, and still contain significant Native populations. The Census also 

recognizes OTSA joint-use areas, which are OTSAs that are administered jointly or claimed by 

two or more American Indian tribes that have a delineated OTSA.371 Despite these Censusrecognized areas, Oklahoma tribes have a limited amount of reservation land held in trust by the 

368Hank Adams, John Echohawk, Dough Nash, Kevin Gover, and Roman Bitsuie, “Report on Trust Responsibilities 

and the Federal-Indian Relationship; Including Treaty Review. Final Report to the American Indian Policy Review 

Commission., Section VI Oklahoma,” HathiTrust, American Indian Policy Review Commission, 1976, 

https://babel.hathitrust.org/cgi/pt?id=uc1.31210015689068&view=1up&seq=1&skin=2o21. 

369 Adams, et al., “Report on Trust Responsibilities.”

370 Ibid. 

371 Nancy Pindus, et al., “Technical Appendixes: Housing Needs of American Indians and Alaska Natives in Tribal 

Areas: A Report From the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs,” 

U.S. Department of Housing and Urban Development, January, 2017.
Community Economic Development in Indian Country // Market Research Report | pg. 102

federal government. Unlike many tribal communities in the lower 48, most land ownership in 

Oklahoma tribal areas is in fee-simple ownership which can be readily mortgaged.

Pueblos and Spanish Land Grants

From the end of the seventeenth century to the mid-nineteenth century, Spain (and later Mexico) 

made land grants to individuals, towns, and groups to promote development in the frontier lands 

that now constitute the American Southwest. There were two kinds of grants—private grants 

given to individuals, and community grants to settlers for new towns.372

 

Spain also issued land grants to several indigenous pueblo communities, which had occupied the 

areas granted long before Spanish settlers arrived in the Southwest. For example, in the 

Albuquerque area the Spanish governor awarded grants to the Pueblo de Sandia and the Pueblo 

de Isleta peoples. Under Spanish and Mexican law, common land was set aside as part of the 

original grant for the use of the entire community. The Spanish system required that the land 

surrounding an Indian pueblo be allotted to that pueblo for one league in each direction from the 

pueblo. This set up political and cultural boundaries for the Pueblo Indians and helped sustain 

Pueblo cultures.373 

 

In 1848, the Treaty of Guadalupe Hidalgo formally ended the Mexican-American War, and the 

United States assumed control over vast new territories, including much of what is now the state 

of New Mexico. Under the treaty, the United States agreed to recognize all types of property 

ownership within the ceded areas. Over the next half century, the United States developed 

procedures to validate land grants in the territory of New Mexico to implement the treaty 

provisions. 

But land tenure and ownership patterns were very different in Mexico and the United States. The 

Mexican and Spanish systems were based on a rural, community-based system of land holding 

prevalent in medieval Europe, and not on fee-simple ownership. Land was viewed more in its 

relationship to the community and was used primarily to provide sustenance to the local 

population, rather than as a commodity that could be exchanged or sold in a competitive market. 

The Surveyor General at the time found that many boundaries could no longer be found. Some 

grants overlapped. Owners had lost their original papers.374 Whether the United States accurately 

carried out the provisions of the treaty, especially regarding community land grants, has been a 

controversial issue for generations. Many persons, including grantee heirs, scholars, and legal 

experts, still claim that the United States did not protect the property of Mexican-Americans and 

their descendants, particularly the common lands of community land grants.375 They remain 

372 “Treaty of Guadalupe Hidalgo: Definition and List of Community Land Grants in New Mexico,” U.S. 

Government Accountability Office (GAO), GAO-01-951, September 2001, https://www.gao.gov/assets/gao-01-

330.pdf. 

373 “History: Land Grants,” Albuquerque Historical Society Tricentennial, accessed September 6, 2022, 

https://albuqhistsoc.org/SecondSite/pkfiles/pk208landgrants.htm. 

374 Ibid. 

375 “Treaty of Guadalupe Hidalgo.”
Community Economic Development in Indian Country // Market Research Report | pg. 103

critical of the federal courts’ treatment of the common lands and the failure to approve more of 

the acreage claimed. These disputes still arise and can delay or prevent economic development.

Hawaii

Although Congress has repeatedly acknowledged its special political and trust relationship with 

the Native Hawaiian community since the overthrow of the Kingdom of Hawaii more than a 

century ago, the federal government does not maintain a formal government-to-government 

relationship with the Native Hawaiian community as an organized, sovereign entity.

As part of this relationship and to support the self-sufficiency and well-being of the Native 

Hawaiian people, Congress established the Hawaiian Home Land Trust in 1921, a set-aside of 

more than 200,000 acres of land via the Hawaiian Homes Commission Act (HHCA). The State 

of Hawaii Department of Hawaiian Home Lands (DHHL), a state agency, manages the Hawaiian 

Home Land Trust, with oversight provided by the U.S. Department of the Interior (DOI). HHCA 

provides eligible Native Hawaiians—those who are 50% or more Native Hawaiian by blood 

quantum—with the ability to live on designated trust land. These trust lands are leased to HHCA 

trust beneficiaries for residential, agricultural, and pastoral purposes in homestead communities. 

From a legal perspective, the Hawaiian Home Lands are public lands held in trust by the State of 

Hawaii for the benefit of Native Hawaiians, as defined in HHCA. Thus, HHCA beneficiaries 

who become residents on one of the Hawaiian Home Lands are not landowners, but rather 

“lessees.” 

The Native Hawaiian population receives federal housing funds through the Native Hawaiian 

Housing Block Grant (NHHBG), which is authorized by an amendment to the Native American 

Housing Assistance and Self-Determination Act (NAHASDA). DHHL manages NHHBG funds 

in addition to their day-to-day management of the Hawaiian Home Lands program. In 2014, 

Hawaii had 56 occupied homestead communities with 9,838 leases and, in 2010, according to the 

2010 Census, there were 30,858 residents on the Home Lands.376Apart from the Home Lands, 

Native Hawaiians are not eligible for any other federal set-asides available to recognized tribal or 

Native entities. Demand for homestead leases has consistently outstripped supply.377

Economic development within Hawaiian Home Lands is both supported and complicated by the 

fact that the DHHL manages the land held in trust for Hawaiian Home Lands trust beneficiaries. 

Most of the housing, infrastructure and economic development activities within these lands is 

conducted or coordinated by DHHL and are subject to applicable legal, regulatory, staffing, and 

376 Kristen Corey, Jennifer Biess, Nancy Pindus, Doray Sitko, “Housing Needs of Native Hawaiians: A Report From 

the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs,” U.S. Department of 

Housing and Urban Development, 2017.

377 Nancy Pindus, et al., “Housing Needs of American Indians and Alaska Natives in Tribal Areas: A Report From 

the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs,” U.S. Department of 

Housing and Urban Development, January, 2017.
Community Economic Development in Indian Country // Market Research Report | pg. 104

financial constraints.378 But homestead associations and organizations such as the Hawaiian 

Community Development Corporation allow Native Hawaiians to engage in economic 

development and engage in programs such as the Native CDFI program. Homestead associations 

are beneficiary-controlled organizations that serve and represent the interests of their homestead 

communities. They assist the DOI to communicate and work with Homestead and Beneficiary 

Associations (HBA) to administer federal laws that apply to Trust Lands and Trust Funds.379

Nonprofit organizations and homestead associations representing Native Hawaiian beneficiaries 

throughout the islands are developing greater capacity, expanding critical partnerships and 

program eligibility, and attracting greater and more diverse sources of funding and capital to 

serve Native Hawaiians and carry out community economic development activities within 

Hawaiian Home Lands and in communities throughout the Hawaiian Islands.380

378 “Maui Beneficiary Ho’ohui Project,” Big Water Consulting, October 12, 2021, 

https://static1.squarespace.com/static/5be730232487fdec648106ac/t/622250eba04b4565ed2e8982/1646416112418/

Maui+Beneficiary+Ho%27ohui+Project+Final+Report.pdf.

379 “Homestead & Beneficiary Associations: Frequently Asked Questions.”

380 “Maui Beneficiary Ho’ohui Project.”
Community Economic Development in Indian Country // Market Research Report | pg. 105

Appendix B: Organizations Participating in Information Gathering 

Discussions

Many initiatives unfolding within Native lands are not summarized in traditional academic 

journals or newspapers. To provide a more complete view of current models, challenges and 

opportunities for community economic development in Native lands and identify additional 

sources of information describing them, the research team conducted conversations with 

knowledgeable individuals from the organizations listed below. 

Organizations Participating in Discussions with Big Water Consulting

Citizen Potawatomi Community Development Corporation, 13 July 2022. https://cpcdc.org.

Cook Inlet Housing Authority, 12 July 2022. https://www.cookinlethousing.org.

MoFI, 27 July 2022. https://www.mofi.org.

Small Business Administration (SBA), 5 August 2022. https://www.sba.gov/about-sba/sbalocations/headquarters-offices/office-native-american-affairs.

Clearinghouse CDFI, 27 July 2022. https://www.clearinghousecdfi.com.

Native American Bank, 19 July 2022. https://nativeamericanbank.com.

Four Bands Community Fund, 14 July 2022. https://fourbands.org.

Alaska Growth Capital BIDCO, Inc., 27 July 2022. https://www.alaskagrowth.com.

Craft3, 14 July 2022. https://www.craft3.org.

Federal Reserve Bank of Minneapolis’ Center for Indian Country Development, CICD), 20 July 

2022. https://www.minneapolisfed.org/indiancountry.

Native Nations Institute, University of Arizona, 3 August 2022. https://nni.arizona.edu.

Native CDFI Network, 18 July 2022. https://nativecdfi.net.

Travois. 13 July 2022. https://travois.com.

Native American Finance Officers Association (NAFOA), 18 July 2022. https://nafoa.org.
Community Economic Development in Indian Country // Market Research Report | pg. 106

Sovereign Council of Hawaiian Homestead Associations (SCHHA) and Native CDFI Network, 

27 July 2022. https://hawaiianhomesteads.org/schha

Northwest Native Development Fund, 14 July 2022. https://thenndf.org.

Native Community Capital, 29 July 2022. https://nativecap.org.

Chickasaw Nation Community Development Endeavor, LLC, 19 August 2022. http://cncde.net.
Community Economic Development in Indian Country // Market Research Report | pg. 107

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Annotated Bibliography381

Adams, Hank, John Echohawk, Dough Nash, Kevin Gover, and Roman Bitsuie. “Report on 

Trust Responsibilities and the Federal-Indian Relationship; Including Treaty Review. 

Final Report to the American Indian Policy Review Commission., Section VI Oklahoma” 

HathiTrust. American Indian Policy Review Commission, 1976.

https://babel.hathitrust.org/cgi/pt?id=uc1.31210015689068&view=1up&seq=1&skin=2o

21. 

This is the final report prepared by the American Indian Policy Review Commission in 

1976. Congress charged the Commission with conducting a comprehensive review of 

Indian Affairs in the U.S., including “a study and analysis of the Constitution, treaties, 

judicial interpretations and Executive Orders to determine the attributes of the unique 

relationships between the federal government and Indian tribes and the land and other 

resources they possess.” The report covers federal Indian law, trust law, and treaty law, as 

well as Oklahoma, water use and development, and forestry. It is based on a review of 

historical documents, field studies, hearings, site visits, conferences, and Indian 

reservation community interviews. The report finds that the history of legal concepts and 

policy applications in the field of Indian Affairs discloses a constant stream of 

abandonment and abuses of law within the executive, legislative, and judicial processes 

of America. It recommends a path towards a positive and promising future for the Native 

American people within the United States. It explores the concepts of sovereignty, 

treaties, and trust relations and trust responsibilities and illustrates the differences among 

tribes and some of the factors related to outside finance. The report also recognizes the 

importance of economic development and access to sufficient capital to allow for 

development programs compatible with the environment of the tribal area.

 

Akee, Randall K.Q., Eric C. Henson, Miriam R. Jorgensen, Joseph P. Kalt. “Policy Brief: 

Dissecting the U.S. Treasury Department’s Round 1 Allocations of CARES Act COVID19 Relief Funding for Tribal Governments.” Cambridge and Tucson: Harvard Project for 

American Indian Economic Development and Native Nations Institute, 2020. 

https://nnigovernance.arizona.edu/sites/default/files/resources/Dissecting%20the%20US

%20Treasury%20Department%E2%80%99s%20Round1%20Allocations%20of%20CAR

ES%20Act%20COVID%E2%80%9019%20Relief%20Funding%20for%20Tribal%20Go

vernments.pdf 

This policy brief was conducted by the Harvard Project for American Indian Economic 

Development and Native Nations Institute. This resource looks at Treasury’s allocation of 

CARES funding to tribal governments, and seeks to understand the extent to which 

381 Note that some of the sources listed here are not directly referenced in the final report but are included as 

important context for understanding community economic development in Indian Country.
Community Economic Development in Indian Country // Market Research Report | pg. 131

reusing the IHBG formula impacts CARES funding outcomes. This brief analyzes the 

HUD IHBG formula, Census data, and tribal data to compare populations using different 

datasets and concludes that different datasets result in different funding allocations. It 

highlights the complications of using existing data for assessing tribal needs. The authors 

conclude that an appropriate allocation rule would employ the current tribal enrollment 

figures submitted by tribes to Treasury.

Akee, Randall. “Sovereignty and Improved Economic Outcomes for American Indians: Building 

on the Gains Made Since 1990.” Washington Center for Equitable Growth, 2021. 

https://equitablegrowth.org/sovereignty-and-improved-economic-outcomes-for-americanindians-building-on-the-gains-made-since-1990. 

This essay provides an overview of the economic status within Indian Country, including 

recommendations for improving the economic well-being of American Indians. This 

resource supports the exercise of tribal sovereignty and the expansion of innovative 

industries on reservations to increase revenue. In addition, the report recommends that 

steps should be taken to reduce obstacles to economic development on tribal lands, 

including by providing funding for educational institutions on tribal reservations to 

develop skills and reduce the barrier to entry for economic development. The source also 

recommends increasing data collection efforts to include the American Indian population 

in nationally representative datasets. 

American Indian Policy Review Commission. “Report of Special Joint Task Force on Alaska 

Native Issues.” American Indian Policy Review Commission, 1976. 

https://babel.hathitrust.org/cgi/pt?id=pur1.32754070365295&view=1up&seq=3

&skin=2021 

This report is an extension of the 1976 Report on Reservation and Resource Development 

and Protection administered by the Indian Policy Review commission. It provides 

historical background of economic development specifically for Alaska Natives. The 

report looks at the relationship between Alaska Native tribes and the federal government. 

Bowman, Michelle. W. “Engagement, Research and Policy: Integrating Indigenous Voices into 

Economic Inclusion at the Federal Reserve.” Federal Reserve Board, November 29, 

2021. https://www.federalreserve.gov/newsevents/speech/bowman20211129a.htm.

This speech by Governor Michelle W. Bowman at the Virtual Symposium on Indigenous 

Economies details the current state of Native banking, the importance of including Native 

voices in banking, and the federal government’s relationship to Native banking. Her talk 

considers the unique challenges of financial institutions in Native communities. Bowman 

states that "bank branches are harder to find in Indian Country. Credit is often more 

expensive for reasons not fully explained by available borrower characteristics alone." 
Community Economic Development in Indian Country // Market Research Report | pg. 132

She notes that in response, the number of Native-led Community Development Financial 

Institutions (CDFIs) has quadrupled over the past two decades. While Native CDFIs 

cannot singlehandedly resolve Indian Country's credit needs, “research and pilot 

programs demonstrate the power of cultural fit as they bring credit, financial services, 

and consumer education into tribal communities.” 

Brashares, Edith, and Siobhan O’Keefe. “Indian Tribal Government Access to Tax-Exempt Bond 

Financing.” U.S. Department of the Treasury, October 27, 2013. 

https://ssrn.com/abstract=2370079 or http://dx.doi.org/10.2139/ssrn.2370079 

This paper provides background information on the tax rules for the use of tax-exempt 

bonds by tribal governments. The authors use an analysis of IRS Statistics of Income 

(SOI) data to look at how tax incentives are used by tribes. According to the findings, 

tribes with resources such as gaming income or energy resource royalties, as well as

tribes with members in need, are more likely to borrow using tax-exempt bonds. 

However, tribes with populations that have the greatest need, as measured by their SNAP 

population and poverty rate, may be more likely to use tax-exempt bonds to finance tribal 

government investment. 

Buteau, Ellie, Hannah Martin, and Katarina Malmgren. “Overlooked (Part Two): Foundation 

Support for Native American Leaders and Communities.” Center for Effective 

Philanthropy, 2021. http://cep.org/wpcontent/uploads/2021/07/CEP_Overlooked_Native_American.pdf. 

This report is based on research by the Center for Effective Philanthropy (CEP) including 

survey data and interviews with Native nonprofit leaders. CEP found that Native 

nonprofit leaders report having fewer positive experiences with their foundation funders 

than nonprofit leaders of other races/ethnicities, which has been the case since prior to the 

COVID-19 pandemic. Almost two thirds of foundation leaders say that they provide little 

or no grant dollars to organizations primarily serving Native American communities. The 

report also highlights that most foundations continue to overlook nonprofits that serve 

Native American communities, including rural tribal lands, despite the significant 

challenges facing Native American communities. The report concludes with advice for 

funders working with tribal communities. 

Ciampoli, Paul. “SRP, Navajo Tribal Utility Authority Extend Solar Agreement, Sign New Solar 

Contract.” SRP, Navajo Tribal Utility Authority Extend Solar Agreement, Sign New 

Solar Contract | American Public Power Association. PublicPower.org, 2022. 

https://www.publicpower.org/periodical/article/srp-navajo-tribal-utility-authority-extendsolar-agreement-sign-new-solar-contract. 
Community Economic Development in Indian Country // Market Research Report | pg. 133

This online news article focuses on the contract expansion of Navajo Nation’s large-scale 

solar farm, also known as the “Kayenta” facilities. The agreement was signed between 

officials with the Navajo Tribal Utility Authority (NTUA), leaders of the Navajo Nation, 

and the state of Arizona’s Salt River Project (SRP). This project will assist in the 

development of the Navajo Nation through the generation of around $15 million in tax 

revenues, and help transition their economy away from coal-dependency. 

Corey, Kristen, Jennifer Biess, Nancy Pindus, and Doray Sitko. “Housing Needs of Native 

Hawaiians: A Report From the Assessment of American Indian, Alaska Native, and 

Native Hawaiian Housing Needs.” U.S. Department of Housing and Urban Development, 

2017. https://www.huduser.gov/portal/publications/housing-needs-native-hawaiians.html.

This report focuses on the housing conditions of the Native Hawaiian community in 

Hawaii. The report describes housing conditions on the Hawaiian Home Lands, presents 

comparisons with the population of Hawaii as a whole, and provides a history of federal 

policies affecting land and housing of Native Hawaiians living in Hawaii. It illustrates 

that the Native Hawaiian homeownership rate lags behind that of residents of Hawaii at 

large.

Cornell, Stephen and Joseph P. Kalt. “Two Approaches to Economic Development on American 

Indian Reservations: One Works, the Other Doesn’t.” Joint Occasional Papers on Native 

Affairs, (2006). https://www.honigman.com/media/site_files/111_imgimgjopna_2005-

02_Approaches.pdf. 

This working paper analyzes two common approaches to economic development in 

Indian Country: the “standard” approach and the “nation-building” approach. In the view 

of the authors, the standard approach is more common historically but less successful, 

and involves short-term thinking and outside actors driving decision-making. The nationbuilding approach, alternatively, is rooted in Native self-determination, strategic 

planning, and long-term goals.

Cunningham, Alisa, F. “Tribal College Contributions to Local Economic Development.” 

Institute for Higher Education Policy, Washington, DC.; American Indian Higher 

Education Consortium, Alexandria, CA, 2000. http://www.aihec.org/ourstories/docs/reports/TC_contributionsLocalEconDevmt.pdf. 

This report examines the role that tribal colleges play in entrepreneurship and small 

business development in Native communities. The report’s objective is to understand 

how tribal colleges impact local economic development in Indian Country using the 

analysis of case studies and literature reviews. While published in 2000, the resource 

remains valuable because it highlights instances where the introduction of Native values 

and local traditions into entrepreneurial training led to greater success and economic 
Community Economic Development in Indian Country // Market Research Report | pg. 134

development than those that did not, and includes a list of procedures for policymakers to 

advance community development efforts in tribal colleges. 

Fogarty, Mark. “New Markets Tax Credit Program only now getting off the ground in Indian 

Country.” Tribal Business News Home, 2022. 

https://tribalbusinessnews.com/sections/economic-development/13921-new-markets-taxcredit-program-only-now-getting-off-the-ground-in-indian-country. 

This article seeks to understand why growth in NMTC Native Areas is so slow in regards 

to the development and distribution of NMTCs through the collection of interviews and 

Native NMTC data. The author finds that for every $100 allocated for NMTC 

investments, only $1 is being directed towards Native tribal entities, despite the fact that 

there is a disproportionately high amount of tracts in NMTC Native Areas that are 

eligible for NMTC investment. This resource illustrates the need for NMTC investment 

in NMTC Native Areas, and the direction of attention to increase Native NMTC 

recipients.

Fogarty, Mark. “Wheels of economic development grind slowly for Natives in Federal New 

Markets Tax Credit Program.” Tribal Business News Home, 2021. 

https://tribalbusinessnews.com/sections/finance/13630-wheels-of-economicdevelopment-grind-slowly-for-natives-in-federal-new-markets-tax-credit-program. 

This article on the NMTC program and its relationship with Native communities provides 

a good overview of the obstacles Native organizations face in applying for and being 

awarded NMTC allocations. The article seeks to understand why rural and tribal 

communities are at a disadvantage in the LIHTC and NMTC allocation process and 

provides suggestions for addressing disparities. This resource looks at comments from the 

Native CDFI network and LIHTC and NMTC allocation histories, and suggests potential 

improvements to programs to make the process more equitable in Native communities. 

Fredericks, Carla F. and Kate R. Finn. “Harnessing Private Equity for Indigenous Peoples.” 

Boulder, CO: First Peoples Worldwide University of Colorado, Boulder, 2020. 

https://www.colorado.edu/program/fpw/sites/default/files/attachedfiles/harnessing_private_equity_for_indigenous_peoples_-_final.pdf. 

This report, conducted at the University of Colorado Boulder through First Peoples 

Worldwide, seeks to understand how to better facilitate larger scale financing in Native 

Country, with a specific emphasis on tribal sovereignty and social prosperity through 

advancing private equity. This report contains three major components: the overall

interest and need for large-scale economic development in Native Country, the necessary 

“core values” that center indigenous perspectives and prosperity, and how private equity 

plans, according to the authors, must align with said core values. This resource provides 
Community Economic Development in Indian Country // Market Research Report | pg. 135

historical and contemporary context to economic development in Indian Country, 

methods to harness private equity for Native people, and recurring themes and initiatives 

to ensure a sustainable and non-extractive deployment of services and facilities.

Graham, Lorie M. “An Interdisciplinary Approach to American Indian Economic Development.” 

North Dakota Law Review: Vol. 80: No. 4, Article 2, 2004. 

https://commons.und.edu/ndlr/vol80/iss4/2. 

This journal article looks at the reasons for variation in levels and rates of economic 

growth for Native American tribes. It explores various dimensions affecting tribal 

economic growth, such as politics, socioeconomics, and cultural norms, as well as the

legal dimensions that influence tribal developments. Published in 2004, this journal 

article remains valuable because it provides a legal background of how development has 

occurred in tribal areas through various lenses, such as sovereign immunity, land 

ownership and control of property, and taxation and regulation. 

Gregg, Matthew, Michou Kokodoko, & Elijah Moreno. “Take-up of New Markets Tax Credit 

Increases in Indian Country, With Potential for Far More.” Federal Reserve Bank of 

Minneapolis, 2022. https://www.minneapolisfed.org/article/2022/take-up-of-newmarkets-tax-credit-program-increases-in-indian-country-with-potential-for-far-more.

This article analyzes the extent to which NMTC investments have been used to create 

new capital for tribal governments, tribal enterprises, nonprofit tribal consortia, and 

Alaska Native Corporations. This source identifies 30 NMTC investments between 2001 

and 2019 which are affiliated with a tribal business or government, an Alaska Native 

Village government, or a Native nonprofit organization, in addition to 24 other projects 

that occurred on tribal lands and involved tribal entities. This resource provides further 

evidence for the disparities in awards provided to tribal areas, but highlights that 

investments for NMTC Native Areas are slowly rising. It also outlines the current state of 

NMTC lending in Indian Country. 

Gregg, Matthew, Ryan Nunn, and Casey Lozar. “An Urgent Priority: Accurate and Timely 

Indian Country Data.” The Federal Reserve Bank of Minneapolis, 2022. 

https://www.minneapolisfed.org/article/2022/an-urgent-priority-accurate-and-timelyindian-country-data.

This article outlines current challenges in data collection and research in Indian Country. 

It highlights gaps that exist in the way public data is or is not collected in Indian Country, 

and reaffirms that government, individual, and business-level data is often scarce for 

Indian Country. It also discusses how the unique characteristics of Indian Country 

provide opportunities for data collaborations. It posits that more complete data on Native 

communities will help create opportunities for better decision-making. 
Community Economic Development in Indian Country // Market Research Report | pg. 136

Hillabrant, Walter, Judy Earp, Mack Rhoades, and Nancy Pindus. “Overcoming Challenges to 

Business and Economic Development in Indian Country.” Princeton, NJ: Mathematica 

Policy Research, Inc. 2004. http://webarchive.urban.org/publications/411104.html.

This report was prepared for tribal, state, and federal officials and other stakeholders in 

welfare reform in Indian Country. It was one of four reports on the evaluation of tribal 

Welfare to Work programs as mandated by the Balanced Budget Act of 1997. The 

evaluation describes (1) examples of business and economic development activities and 

the federal programs and initiatives used by a convenience sample of eight tribes and two 

Alaska Native corporations; (2) the legal, historical, and cultural context of tribal 

business and economic development; and (3) the challenges tribes/Native corporations 

face in pursuing business and economic development, as well as the promising 

approaches they are developing to minimize or overcome them.

Horn-Miller, Kahente. "What Does Indigenous Participatory Democracy Look Like? KahnawÃ 

:Ke's Community Decision Making Process." Review of Constitutional Studies 18, no. 1 

(2013). https://papers.ssrn.com/sol3/papers2.cfm?abstract_id=2437675.

With the 1979 Community Mandate to move towards traditional government, the 

community of Kahnawà:ke, part of the Mohawk Territory in Quebec, has consistently 

requested more involvement in decision-making on issues that affect the community. The 

Kahnawà:ke Community Decision Making Process is a response to the community's call 

for a more culturally relevant and inclusive decision and law-making process. The 

process is a transitory measure to assist and facilitate the legislative function of 

Kahnawà:ke governance. This paper examines the development of the process and how it 

functions in the modern Kahnawà:ke community as an example of indigenous 

participatory democracy in action.

Jorgensen, Miriam, and Stephanie Gutierrez. “Native Nation Building: It Helps Rural America 

Thrive.” Aspeninstitute.org, 2021. https://www.aspeninstitute.org/wpcontent/uploads/2021/11/TR-FP-2-Native-Nation-Building-FINAL1.pdf. 

This report provides historical background and context with a focus on Native 

populations in rural areas, and provides characteristics of successful Native nation 

building. It highlights strategies for equitable rural development with a Native 

perspective, including emphasizing that efforts for Native nation building must stem from 

Native nations’ own self-determination efforts, and that building Native nations can 

spread wealth through other non-Native communities that live nearby.

Jorgensen, Miriam and Randall K.Q. Akee. “Access to Capital and Credit in Native 

Communities: A Data Review.” Tucson, AZ: Native Nations Institute and the Arizona 

Board of Regents, 2017. 
Community Economic Development in Indian Country // Market Research Report | pg. 137

https://nnigovernance.arizona.edu/sites/nnigovernance.arizona.edu/files/2022-

09/Accessing_Capital_and_Credit_in_Native_Communities__A_Data_Review.pdf. 

This document is the second part of a two-part series and a follow-up to the 2001 Native 

American Lending Study. It uses a range of datasets to document the evolution of Native 

communities’ capital access since 2001. Its three main sections summarize data 

describing access to capital and credit for Native consumers, Native business owners, and 

tribal communities and governments.

Kokodoko, Michou, Valentina Dimitrova-Grajzl, Peter Grajzl, and Joseph Guse. “Native CDFIs 

Improve Credit Outcomes for Indian Country Residents.” Federal Reserve Bank of 

Minneapolis, 2021. https://www.minneapolisfed.org/article/2021/native-cdfis-improvecredit-outcomes-for-indian-country-residents.

This article published by the Federal Reserve Bank of Minneapolis describes the ways in 

which Native CDFIs specifically help improve access to financing in Indian Country, and 

explores whether it is more difficult to get mortgage financing for Native Americans. The 

authors find that mortgage loans with Native Americans as the primary borrower are 

more likely to be higher-priced than loans that have other races or ethnicities as the 

primary borrower. In addition, the loans have an average interest rate nearly two 

percentage points above the average loan for non-Native Americans. This demonstrates 

that for Native borrowers, obtaining financing has historically been less accessible than 

for other Americans. 

Kokodoko, Michael. “Findings from the 2017 Native CDFI Survey: Industry Opportunities and 

Limitations.” Center for Indian Country Development, Federal Reserve Bank of 

Minneapolis, November 2017. Accessed December 16, 2022. 

https://www.minneapolisfed.org/~/media/files/community/indiancountry/resourceseducation/working-papers/cicd-wp-2017-04.pdf. 

This article provides insight into how Native CDFIs operate and provides financial 

institutions with more information regarding Native CDFI-based investment 

opportunities. By surveying 39 certified Native CDFIs across the United States about 

their funding options and programs, this research noted that Native CDFIs are ready to 

deploy more funding in an effective manner, despite the variety of challenges that prevent 

economic development in their communities from taking place. In addition, this resource 

indicates the capacity of Native CDFIs and their current limitations, as well as providing 

the recommendation to increase Native capacity for NMTC use.

Kokodoko, Michou. “Making the New Markets Tax Credit work in Native communities.” 

Federal Reserve Bank of Minneapolis, 2017. 

https://www.minneapolisfed.org/article/2011/making-the-new-markets-tax-credit-workin-native-communities. 
Community Economic Development in Indian Country // Market Research Report | pg. 138

This article seeks to understand the unique challenges Native communities face in 

accessing NMTCs, and how Native CDFIS and CDEs have used NMTCs successfully. 

Successful examples illustrate a strong relationship between the financial institution and 

the tribes. Some challenges are also noted in this document, including: the inability to use 

NMTCs on gambling facilities; many corporations that are owned by tribes are ineligible 

to be QALICBs; and the complicated structures regarding land ownership. The discussion 

regarding successful examples may be useful for pinpointing common themes that can 

benefit future projects.

Kramer, Rachel, Harry Maher, Kevin Klingbeil, Nancy Pindus, Megan Knox, and Lonny Macy. 

“Assessment of the Housing Needs of American Indians, Alaska Natives and Native 

Hawaiians in Washington State.” Big Water Consulting for Washington State 

Department of Commerce, 2021. https://www.commerce.wa.gov/wpcontent/uploads/2022/04/CommerceReports_2021_CSHD_NAHousing_4.26.22_Final.pdf. 

This report was conducted on behalf of the Washington State Department of Commerce, 

and looks at the current housing conditions for American Indians, Alaska Natives, and 

Native Hawaiians in the state of Washington, as well as what programs can help address 

needs for housing. This report looks at American Housing Survey (AHS) and University 

of Washington Real Estate data through literature and data reviews, in addition to 

interviews, surveys, and focus groups with tribal leaders. The study found that 

inflationary erosion hurts IHBG funding, the main source of funding for most TDHEs; 

LIHTC projects often do not pencil out for small TDHEs (which is likely also the case for 

NMTCs); housing and economic development are intertwined; many of the tribes with 

strong funding for housing beyond IHBG also have casino revenue; and high turnover 

among professional housing staff makes work difficult. 

Kurlander, Phyllis. “Creating an Environment to Attract Investors and Develop New Enterprises 

on the Fort Mojave Indian Reservation.” John F. Kennedy School of Government, 

Harvard University. Malcolm Wiener Center for Social Policy, 1994. 

https://hwpi.harvard.edu/files/hpaied/files/prs94-4.pdf?m=1639579236. 

This report, published in 1994, identifies key components for successful private 

investment and business development on the Fort Mojave Indian Reservation, which 

includes an integrated approach to economic development to enable the tribe to move 

towards economic self-determination and a sustainable economy. Interviews were 

conducted with Native American economic development professionals, Fort Mojave 

tribal members, federal government officials and more, to determine the key 

recommendations for spurring economic development in Indian reservations. This 
Community Economic Development in Indian Country // Market Research Report | pg. 139

resource's recommendations are as follows: 1) incorporate tribal assets into business 

strategy; 2) boost tribal government through self-government efforts; 3) distinguish 

between business and government goals; and 4) establish a dependable contract 

enforcement and dispute resolution system. While this resource is dated, it provides 

context for considering how these recommendations can fit into current economic 

development efforts. 

Lhamon, Catherine E., Patricia Timmons-Goodson, Debo P. Adegbile, Gail L. Heriot, Peter N. 

Kirsanow, David Kladney, Karen Narasaki, and Michael Yaki. “Broken Promises: 

Continuing Federal Funding Shortfall for Native Americans.” The United States 

Commission on Civil Rights, 2018. https://www.usccr.gov/files/pubs/2018/12-20-

Broken-Promises.pdf. 

This report highlights the difficult relationship between Native tribes and the federal 

government. It looks at the nature of relationships between tribes and the federal 

government since the year 2003 and concluded that the federal government has failed to 

assist tribes with individualized economic development necessary for tribes to exercise 

self-determination. The programs that are designed to support Native Americans remain 

chronically underfunded. In addition, data collected about Native Americans are often 

incomplete, inaccurate, old, or simply not tracked by the federal government. These 

factors and more have led many tribes to have a fraught relationship with the federal 

government, which can exacerbate the economic disparities in Indian Country. 

Listokin, David, Kenneth Temkin, Nancy Pindus, and David Stanek. “Mortgage lending on tribal 

land: A Report from the Assessment of American Indian, Alaska Native, and Native 

Hawaiian Housing needs.” U.S. Department of Housing and Urban Development, 2017. 

https://www.huduser.gov/portal/publications/NAHSC-Lending.html. 

This report provides the perspective of outside lenders working in Indian Country in the 

context of mortgage lending. It describes the contemporary mortgage program 

availability and activity in Indian Country (focusing on Section 184) and examines how 

today’s lenders view challenges to and best practices for mortgages in Indian Country; 

much of the report reflects the perspectives of the interviewed lenders. The analysis also 

examines the Section 184 Program’s effect on lending activity during the 2008 financial 

crisis.

Lofthouse, Jordan K. “Institutions and Economic Development on Native American Lands.” The 

Independent Review 24, no. 2 (Fall 2019): 227-248. 

https://www.independent.org/pdf/tir/tir_24_2_04_lofthouse.pdf. 

This paper brings market-process theory and entrepreneurship into the broader discussion 

of the institutional effects on Native American economic development. The author states 
Community Economic Development in Indian Country // Market Research Report | pg. 140

that this is important because it gives greater insight into the intimate connections 

between institutions, entrepreneurship, and economic growth. The author concludes that 

Native Americans live under fundamentally different institutions than other Americans 

and notes that the complex property rights regime of the federal land trust stifles mutually 

beneficial exchange, hampers the market processes, and allows government officials to 

intervene heavily into economic affairs. Also, the author notes that the dual bureaucracy 

of federal and tribal officials increases transaction costs because of the broad authority 

and discretion that these officials have to make public policy. Under those unique 

institutions, the federal government has created an environment of uncertainty and high 

costs that pose significant constraints for entrepreneurial action, thus limiting economic 

development at large.

MacDonald, Peter, Kenneth Smith, Philip Martin, Lorraine Ruffing, Leo Denetsone, Bill 

Douglass, Frank Ryan, Ron Trosper, Pat Porter, and A.T. Anderson. “Report on 

Reservation and Resource Development and Protection.” Final Report of the Indian 

Policy Review Commission, 1976. 

https://babel.hathitrust.org/cgi/pt?id=nyp.33433048657716&view=1up&seq=1

7&skin=2021. 

This 1976 report was conducted by the Indian Policy Review Commission provides 

foundational information regarding economic development in Indian Country. It looks at 

how the federal government has historically interacted with tribes, addresses how 

economic development looks for different Indian tribes, and considers what a successful 

relationship between tribes and the federal government would look like. Surveys and 

interviews of different tribes and tribal members are used to compare and contrast the 

meanings and interpretations of economic development. The authors conclude that total 

Indian economic development cannot be reached if the federal government does not 

provide American Indian governments’ control of their own affairs.

Miller, Robert JR. Reservation Capitalism: Economic Development in Indian Country. Lincoln 

NE: U of Nebraska Press, 2013.

This book describes economic disparities of Native Americans and their history, but 

provides a hopeful perspective that economic development will lead to improved 

conditions and sustainable economies. The author also provides background information 

on Indigenous economic systems and property rights and explains how the vast majority 

of Native lands and natural resource assets were lost. Historically, most tribal 

communities were prosperous, composed of healthy, vibrant societies sustained over 

hundreds and in some instances perhaps even thousands of years. Miller focuses on 

strategies for establishing public and private economic activities on reservations and for 
Community Economic Development in Indian Country // Market Research Report | pg. 141

creating economies in which reservation inhabitants can be employed, live, and have 

access to the necessities of life, circumstances ultimately promoting complete tribal selfsufficiency. 

Native Nations Institute. “Access to Capital and Credit in Native Communities.” 2016. 

http://nni.arizona.edu/application/files/8214/6378/9056/Access_to_Capital_and_Credit_i

n_Native_Communities.pdf. 

This report, which was commissioned by the CDFI Fund, seeks to understand the 

challenges Native communities face in accessing credit and capital. It uses public 

comments, consultations, focus groups, literature reviews, and interviews with key 

informants to pinpoint challenges that Native communities face in accessing the means 

for financial wellness and development.

Oweesta Corporation. Snapshot 2018 The Growing Native CDFI Movement, 2018. 

https://www.oweesta.org/wp-content/uploads/2018/11/Snapshot-2018-Growing-NCDFIMovement_web.pdf.

This report describes the Native CDFI industry in 2018, focusing on capital needs, 

contextualizing these needs within the history of the Native CDFI movement. The 

authors used surveys, interviews, and public sharing of data internal to Oweesta, and 

concluded that the Native CDFI wrap-around service model is successful, with growing 

financial and operational sustainability. This report also documents Native CDFIs’ 

increasing needs for lending and operational capital and discusses the current obstacles 

restricting this capital flow. Finally, this report makes recommendations for Native 

CDFIs and future partners for confronting these challenges and better supporting this 

impactful movement.

Palmer, Vanessa, Ryan Nunn, & Casey Lozar. “Native American Labor Market Dashboard Fills 

Important Data Gap for Indian Country.” Federal Reserve Bank of Minneapolis, 2021. 

https://www.minneapolisfed.org/article/2021/native-american-labor-market-dashboardfills-important-data-gap-for-indian-country 

This study introduces tools and tracks unemployment among the American Indian and 

Alaska Native (AIAN) population, a measure which is not sufficiently tracked by the 

Census or Bureau of Labor Statistics measurements. This report acknowledged that 

unemployment, which is reported by the Census Bureau, often looks different from 

unemployment in AIAN communities, and that federal statistical agencies do not report 

data specific to the AIAN population due to it being a relatively small sample size. This 

resource can be helpful to offer relevant insights on the monitoring of AIAN-specific 

data. 
Community Economic Development in Indian Country // Market Research Report | pg. 142

PD&R Edge. “Innovative Funding Provides Culturally Specific Affordable Housing to Native 

Americans.” U.S. Department of Housing and Urban Development, 2021. 

https://www.huduser.gov/portal/pdredge/pdr-edge-inpractice-072621.html. 

This case study highlights examples of using multiple funding streams to support an 

affordable housing project, including the Indian Housing Block Grant Program. While 

this case study provides an example of a project done in an urban area outside of tribal 

lands, it provides a perspective of how projects can be developed with cultural identity in 

mind, as well as a successful example of creatively leveraging multiple funding streams. 

Pettit, Kathy, G. Thomas Kingsley, Jennifer Biess, Kassie Bertumen, Nancy Pindus, Chris 

Narducci, & Amos Budde. “Continuity and Change: Demographic, Socioeconomic, and 

Housing Conditions of American Indians and Alaska Natives.” U.S. Department of 

Housing and Urban Development Office of Policy Development and Research, 2014. 

https://www.huduser.gov/portal/publications/commdevl/housing_conditions.html. 

This resource looks at the economic diversity that exists across different tribal areas and 

provides examples of economic development and Native CDFI successes. The findings 

illustrate that real per capita income in Indian Country grew 2-3x the rate of the general 

U.S. population from 1990 to 2000. Economic development has been uneven across 

Indian Country. 

Pindus, Nancy, G. Thomas Kingsley, Jennifer Biess, Diane Levy, Jasmine Simington, & 

Christopher Hayes. “Housing Needs of American Indians and Alaska Natives in Tribal 

Areas: A Report From the Assessment of American Indian, Alaska Native, and Native 

Hawaiian Housing Needs.” U.S. Department of Housing and Urban Development Office 

of Policy Development and Research, 2017. 

https://www.huduser.gov/portal/sites/default/files/pdf/HNAIHousingNeeds.pdf. 

This report provides information regarding the demographic, social, and economic 

conditions of American Indians and Alaska Natives (AIAN) in tribal and non-tribal areas 

through a housing lens. It determines housing conditions and housing shortage via 

nationally representative survey of housing conditions and needs among AIAN 

households in tribal areas, a survey of 110 Tribally Designated Housing Entities 

(TDHEs), and 22 site visits. This report illustrates a significant need for housing in AIAN 

areas.

Pindus, Nancy, and Kevin Klingbeil. “Tribes are Using Creative Place-Based Solutions to 

Increase Homeownership Options.” Housing Matters, Urban Institute, 2019. 

https://housingmatters.urban.org/articles/tribes-are-using-creative-place-based-solutionsincrease-homeownership-options. 
Community Economic Development in Indian Country // Market Research Report | pg. 143

This online blog post explains the importance of Native CDFIs and their essential role in 

providing financing in Indian Country. It explains the unique challenges of mortgage

lending and homeownership in Indian Country and provides an overview of several 

studies. It notes that Native CDFIs are essential for bridging the gap between traditional 

financial institutions and Native communities. 

Scott, Andrew P. “An Overview of Rural Credit Markets.” Washington, DC: Congressional 

Research Service, September 2021. 

https://crsreports.congress.gov/product/pdf/R/R46914. 

A significant portion of the U.S. population lives in rural areas, where access to financial 

services—specifically credit products—varies compared to access in urban areas. One 

reason for this variation is that the demographics and economic realities of rural areas 

differ from those of urban areas in several ways. For example, rural populations are more 

likely to be older and have lower incomes relative to urban populations, and local rural 

economies tend to be less diversified in terms of number and types of industries present, 

making them more susceptible to economic shocks. Credit access is broadly 

underdeveloped in Native American communities, which constrains economic 

development. The federal government supports economic development in tribal nations 

through various development, community development, and housing programs. This 

report describes Rural Consumer Financial Services, including for housing, manufactured 

housing, retail banking, and alternative credit as well as agricultural and commercial 

financial services. The report includes sections on credit in Native American 

communities and federal programs to promote Native credit access.

Trahant, Mark. “At The Crossroads: State of the Economy in Indian Country.” Indian Country 

Today, 2022. https://indiancountrytoday.com/news/at-the-crossroads-state-of-theeconomy-in-indian-country. 

This is a series of 10 articles from the Institute for Nonprofit News, Indian Country 

Today and nine other news partners. The series highlights the current state of the 

economy in Indian Country. It used a nationwide survey that was administered by Indian 

Country Today and various partners, and found a lack of data surrounding the economic 

size of Indian Country. In addition, it found that many tribes are the largest employers in 

their rural areas, and described the potential of certain sectors to boost economic growth, 

such as health care and green energy like solar and wind. 

U.S. Government Accountability Office. “Tribal Economic Development: Action is Needed to 

Better Understand the Extent of Federal Support: Report to Congressional Committees.” 
Community Economic Development in Indian Country // Market Research Report | pg. 144

GAO-22-105215. Washington, DC: U.S. 2022. https://www.gao.gov/products/gao-22-

105215. 

GAO conducted this study in accordance with a provision of the Indian Community 

Economic Development Act of 2020. This report examines economic development 

programs available to tribal entities and the extent of fragmentation, overlap, and 

duplication among these programs; analyzes available data on obligations to tribal 

entities for these programs; and describes selected tax incentives available to tribes. GAO 

reviewed program information, analyzed obligations data, and interviewed tribal entities, 

agency officials, and Native Community Development Financial Institutions. GAO 

reported that programs are fragmented across seven agencies: the U.S. Departments of 

Agriculture (USDA), Commerce, Energy, Health and Human Services, Housing and 

Urban Development, and the Interior, and the Small Business Administration (SBA). 

Tribal organizations GAO spoke with said many tribes have limited capacity to identify 

and access programs and may not be aware of the federal assistance available. Some 

programs that serve a wider range of eligible recipients do not identify the amount that 

went to tribal entities. Using location data for the New Markets Tax Credit, GAO 

estimated that from 2004 through 2019, tribal communities (defined as individuals and 

businesses on or near reservations, trust land, or Oklahoma Tribal and Alaska Native 

Village Statistical Areas) received between $734 million and $891 million of investment 

(1.3 to 1.6% of the total dollars invested via the credit). GAO recommended that 

Commerce maintain information on economic development programs available to tribal 

entities across the federal government and that SBA and USDA establish plans to 

periodically analyze and report the amount of economic development assistance provided 

to tribal entities.

Winchell, Dick G. “Indigenous Rural Renewal in the Inland Pacific Northwest: The Emergence 

of American Indian Tribes in Regional Economic Development.” Journal of Rural and 

Community Development 8, no. 3 (2013): 174-197. 

https://journals.brandonu.ca/jrcd/article/view/1036/253. 

This journal article explores policies that have historically harmed or helped economic 

growth in Indian Country using various data sources. Findings illustrate that tribal 

communities don’t score well in terms of impact per dollar invested because they are less 

condensed than non-tribal rural areas. The author also highlights that there is a historical 

lack of successful NMTC applications for Native CDFIs, which discourages many tribal 

projects from expending money and time to apply. The author highlights the need for 

Native set-asides for NMTC allocations, which already exists for LIHTC. 
New Markets Tax Credit 

Investments in Native Areas: 

Selected Case Studies and Best 

Practices
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 2

New Markets Tax Credit Investments in Native Areas: 

Selected Case Studies and Best Practices

Prepared for:

New Markets Tax Credit Program Native Initiative

Community Development Financial Institutions Fund (CDFI Fund)

U.S. Department of the Treasury

Washington, D.C.

Prepared by:

Kevin Klingbeil, Chloe Adler, and Harry Maher

Big Water Consulting

Nancy Pindus

Urban Institute

Karen Williams

IDP

Sean Zielenbach

SZ Consulting

September 2023
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 3

Acknowledgements

The authors would like to thank the representatives of the Community Development Entities and 

other entities who contributed their time and insight to this report via their survey responses and 

interviews. Their experience and knowledge were instrumental to our understanding of the cases 

discussed in this report, and to our analysis of the barriers and opportunities associated with the 

New Markets Tax Credit Program in Native Areas. We would also like to acknowledge the 

contributions of the individuals and organizations who shared information with the research team 

during the preparation of the Community Economic Development in Indian Country: Market 

Research Report, findings from which were also incorporated into this report. Additionally, we 

would like to thank research team members Marina Titova and Roman Bitsuie for their help in 

editing this report.

We are also appreciative of the guidance and support of Christopher Allison, Rosa Martinez, and 

David Fleites of the U.S. Department of the Treasury’s Community Development Financial 

Institutions Fund (CDFI Fund). Their oversight and thoughtful review made this report possible.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 4

Table of Contents

Acknowledgements 3

Table of Contents 4

List of Figures 6

Executive Summary 7

a. Overview 7

b. Methodology and Selected Cases 7

c. Summary of Past NMTC Transactions in Native Areas 7

d. Findings, Best Practices, and Recommendations 7

I. Introduction 12

a. Project Overview 12

b. About the New Markets Tax Credit (NMTC) Program 12

c. About the Community Development Financial Institutions Fund (CDFI Fund) 13

d. Report Purpose and Contents 13

e. Report Structure 15

II. Methodology for Case Study Selection and Implementation 16

a. Limitations 19

III. Summary of Past NMTC Transactions in Native Areas 21

a. Amount Invested and Investments Over Time 21

b. Map of Transaction Locations 23

c. Number of CDEs Making Investments 26

d. Qualified Active Low-Income Community Business (QALICB) Characteristics 26

IV. Description of Selected Case Study Projects 28

V. Findings, Best Practices, and Recommendations 33

1. Online Surveys 33

2. Interviews 34

A. Challenges Native or Tribally Focused CDEs Face in Obtaining NMTC Allocations

35

B. Regulatory/Programmatic Challenges to Financing Native Projects 42

C. Project Viability Challenges 45

D. Land Issues 49
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 5

E. Project Collateral 51

F. Uncertainty Surrounding Tribal Corporations 53

G. Sovereign Immunity 53

H. Understanding NMTC Regulations and CDE Requirements 54

I. Tribal Politics 56

J. Lender Familiarity with Native Areas 58

K. NMTC Native Set-Aside 61

VI. Conclusion 63

Appendix A: Case Study Survey and Interview Guide 64

a. Survey Script: CDE 64

b. Follow-Up Survey Interview Script: CDE 65

Appendix B: CDE Survey Results 67

Appendix C: Glossary 76
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 6

List of Figures

Figure 1 | Projects and NMTC Investment in AIANNH Lands by Year Closed 22

Figure 3 | Case Study Project Locations 24

Figure 4 | Map of ONAP Regions 25

Table 1 | Overview of Case Study Projects 28

Figure 5 | SQ (Survey Question) 1 Does your entity specialize in deploying NMTC capital in any 

of the following areas? 67

Figure 6 | SQ2 In addition to your role as CDE in this project, what other role(s), if any, did your 

organization play for this project? 68

Figure 7 | SQ3 Prior to this transaction, how long had your institution been lending/investing in 

Indian Country? 68

Figure 8 | SQ5 To what extent was private or conventional capital (from private lenders or 

banks) available for this project? 69

Table 3 | SQ6 Did you encounter any Tribal cultural or Tribal legal matters that had to be 

addressed during the NMTC process? 69

Figure 9 | SQ7 Had your entity invested in Native Areas as a part of an NMTC transaction prior 

to this transaction? 70

Table 4 | SQ8 Did your entity have any pre-existing relationship with the Tribe or the project 

sponsor? 70

Table 5 | SQ9 Compared with other transactions you have financed outside of Native Areas, did 

any NMTC regulations pose a concern or challenge in attracting interest from a tax credit 

investor or closing the transaction? 71

Table 6 | SQ10 Compared with other transactions you have financed outside of Native Areas, did 

your entity require any atypical or additional fees, guarantees, or special covenants for this 

project as a condition of investment due to its location within a Native Area? 72

Figure 10 | SQ11 Did the QEI closing process take longer, shorter, or the same amount of time as 

the process associated with NMTC projects outside of Native Areas? 72

Figure 11 | SQ12 Please provide the approximate proportion of capital types in the QEI that 

financed this transaction. The following are averages taken across the nine CDE responses. 73

Figure 12 | SQ13 Why did your organization decide to provide capital to this project? 74

Figure 13 | SQ14 To what extent did your organization use specialized expertise for this project?

74

Table 7 | SQ15 Given your experience with NMTCs in financing a project in a Native Area, 

would your entity request future allocations to finance other NMTC projects in Native Areas? 75
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 7

Executive Summary

a. Overview

This Case Study Report is part of the Community Development Financial Institutions (CDFI) 

Fund’s New Markets Tax Credit (NMTC) Native Initiative. The goal of the NMTC Native 

Initiative is to increase NMTC investments in Federal Indian Reservations, Off-Reservation 

Trust Lands, Hawaiian Home Lands, and Alaska Native Village Statistical Areas, collectively 

referred to as NMTC Native Areas. This Case Study Report presents findings, best practices, and 

recommendations derived from an online survey and subsequent interviews with participants in 

past NMTC investments in NMTC Native Areas.

b. Methodology and Selected Cases

The research team developed a list of NMTC projects that would potentially illustrate varied, 

successful, and replicable paradigms with specific, on-the-ground examples. The research team 

then worked closely with the CDFI Fund to curate a list of nine representative projects. 

Ultimately, the team conducted interviews with one Community Development Entity (CDE) for 

each project, and with Qualified Active Low-Income Community Businesses (QALICBs) for 

several projects.

c. Summary of Past NMTC Transactions in Native Areas

Overall, 225 Qualified Low-Income Community Investments (QLICIs) within 149 unique 

projects made by 51 CDEs took place in American Indian, Alaska Native and Native Hawaiian 

(AIANNH) lands within the United States between 2003 and 2020. NMTC investments across 

all these projects totaled $1.8 billion in 2021 dollars. NMTC investments on AIANNH lands 

make up 2.6% of all NMTC investments. Since 2017, there have been an average of 12 projects a 

year and $144 million in NMTC investment each year in AIANNH lands.

d. Findings, Best Practices, and Recommendations

The survey was developed as a precursor to the interview, wherein CDEs were given 

significantly more room to expand on their experience working on the NMTC transaction case at 

hand. Select survey findings include:

● Two-thirds (66%) of responding CDEs had over 10 years of experience lending/investing 

in Indian Country prior to the transaction.

● More than half (56%) of these CDEs stated that they encountered tribal cultural or legal 

matters that had to be addressed as part of the project process.

● About one fifth (22%) of CDEs had a pre-existing relationship with the tribe or project 

sponsor involved in the case project.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 8

● Two-thirds (66%) of responding CDEs would request future allocations to finance other 

NMTC projects in Native Areas based on their experience with the case project.

A set of more robust findings from the interviews conducted are summarized below. Findings are 

accompanied by recommendations for future policy changes to address the identified challenges, 

and by best practices used in the past to address said challenges.

● Challenges for obtaining allocations in Native Areas and with Native CDEs include:

○ Native CDEs often have limited staff capacity to develop compelling applications 

and lack the financing track record to justify their allocation requests.

■ Recommendations for the CDFI Fund: 

● Provide additional training for tribes, Native individuals, and 

Native organizations related to financing and economic 

development planning and implementation;

● Increase Native CDE participation in NMTC transactions;

● Provide programmatic support for greater NMTC investment in 

Native Areas and Native CDEs; and

● Provide funding to help Native CDEs access technical assistance in 

preparing for NMTC applications.

■ Recommendations for Native CDEs/CDFIs:

● Seek to engage as secondary CDEs with tribes; investors and 

allocatee CDEs and the CDFI Fund should support this goal to 

serve as Secondary CDEs; and

● Participate as a partner/collaborative lender to a Native QALICB.

○ NMTC reviewers often do not understand the unique challenges associated with 

attracting capital to Native Areas and consequently may not appreciate the critical 

role that NMTCs can play in these communities.

■ Recommendation: Train NMTC application reviewers about community 

economic development in Native Areas.

○ Outcomes on Native lands often center around essential human services, basic 

needs, or cultural initiatives that may not generate significant job numbers or 

easily quantifiable outcomes.

■ Recommendation: Give greater weight to qualitative project outcomes in 

NMTC allocation application.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 9

○ Unrelated party financing requirements and the complexity of the NMTC 

Program pose barriers for tribally controlled CDEs in financing projects owned or 

controlled by the same tribe, limiting their ability to obtain competitive scores in 

the application process.

■ Recommendation: Provide more flexibility for Native CDEs in the 

definition of related entities.

○ Timing challenges, such as the project closing deadlines and limited lookback 

period, have made it harder to use NMTC capital for Native projects.

■ Recommendations: 

● Promote greater collaboration among federal agencies involved in 

Native Area transactions; and 

● Tribes that have not obtained Helping Expedite and Advance 

Responsible Tribal Home Ownership (HEARTH) Act authority to 

issue commercial leases without Bureau of Indian Affairs (BIA) 

approval should consider doing so. If tribes use this authority, their 

policy guidelines for lease terms and conditions, and the 

requirements of leasehold mortgage provisions, should be made 

available to funders early in financing processes.

○ There is a limited timeframe to reimburse prior-incurred costs, which 

disadvantages Native projects, as projects in Native Areas often take longer to 

close an NMTC investment.

■ Recommendation: Extend the prior-incurred cost reimbursement period.

● Project viability challenges:

○ These often-rural projects have higher construction costs and difficulties 

attracting and keeping staff to work at facilities.

○ There are eligibility challenges with sprawling footprints that may extend beyond 

NMTC-eligible areas.

■ Best Practices: 

● Sponsors use conventional debt underwriting standards to ensure 

the project can meet basic lending and NMTC Program 

underwriting principles and criteria.

● Utilize Targeted Populations as an alternative to census tract 

qualification. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 10

● Land ownership issues complicate NMTC financing for tribal business development due 

to restrictions on land alienation and the need for leasehold mortgages.

○ Collateralizing NMTC projects in non-metropolitan areas can be challenging due 

to difficulties in defining rural land values and limited transaction data for 

accurate appraisals.

○ Land held in trust by the federal government cannot be used as collateral, leading 

to reliance on leasehold mortgages, other assets or leveraging non-real estate 

assets for loans.

■ Best Practice: Tribe facilitates access to leasehold mortgage security.

● Tribally sponsored projects may face difficulties meeting lenders’ requirements for 

collateral because of the trust status of land, or the complexity of tribal finances resulting 

in difficulty offering tribal guarantees.

○ Best Practice: Tribal sponsors identify and develop processes for enforceable and 

adequately secured promissory notes and loan agreements.

● Uncertainty remains regarding the eligibility of tribal corporations as QALICBs, resulting 

in additional steps such as creating state law entities and lease agreements to navigate the 

issue.

○ Recommendation: Participants should work with Treasury/IRS to prioritize 

creating greater clarity regarding the eligibility of tribal corporations to be 

QALICBs.

● Sovereign immunity of tribes can hinder transactions from moving forward, as investors 

and CDEs require enforceable promissory notes.

○ Best Practice: Tribes consider limited waivers of sovereign immunity.

● Understanding the complexities of the NMTC Program and compliance issues can take 

time and resources due to the potential need for legal and accounting guidance, especially 

for tribes with limited exposure to the program and staff turnover; additionally, issues 

with local politics and leadership turnover can delay NMTC transactions.

○ Best Practice: Tribal sponsors and potential CDE applicants evaluate the cost and 

benefit of engaging NMTC experts.

● Tribal politics and leadership turnover may delay the closing of NMTC transactions in 

Native Areas.

○ Best Practices: 

■ Cohesive tribal governance and economic development strategies; and
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 11

■ Determine acceptable practices regarding choice of venue and applicable 

law and establish these policies before working with third-party lenders.

● Effective outreach to partners requires a deep understanding of specific communities and 

learning about and acknowledging their unique experiences, perspectives, and 

complexities.

○ Recommendation: Lenders should take steps to facilitate better relationships with 

Native Entities.

● Interviewees shared that a Native set-aside for either Native organizations or projects 

within Native Areas could effectively increase NMTC investment in Native Areas.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 12

I. Introduction

a. Project Overview

This report, titled “New Markets Tax Credit Investments in Native Areas: Selected Case Studies 

and Best Practices” (referred to as the Case Study Report), is a component of the Community 

Development Financial Institutions Fund’s (CDFI Fund) New Markets Tax Credit Program 

Native Initiative (the NMTC Native Initiative). Big Water Consulting and its partners conducted 

the project on behalf of the CDFI Fund. The NMTC Native Initiative supports efforts by the 

CDFI Fund to explore opportunities to increase NMTC investment in Federal Indian 

Reservations, Off-Reservation Trust Lands, Hawaiian Home Lands, and Alaska Native Village 

Statistical Areas (collectively referred to as NMTC Native Areas). The primary goal of this 

initiative is to expand access to capital for Native communities via tax incentives the New 

Markets Tax Credit Program (NMTC Program) provides. The NMTC Native Initiative comprises 

several fundamental components, which include:

● This Case Study Report on the findings from case studies on selected New Market Tax 

Credit (NMTC) investments in Native Areas; 

● A report titled “Community Economic Development in Indian Country: Market Research 

Report” (referred to as the Market Research Report), which reports on successfully 

implemented community economic development strategies that resulted in attracting 

capital to Native communities and challenges that Native entities face in accessing capital 

for community economic development;

● Technical workshops informing representatives of Native organizations about the 

purposes and mechanics of the NMTC Program;

● Individual training sessions with Native organizations seeking to learn more about 

specific elements of the NMTC Program and roles within NMTC-funded projects;

● An analysis of NMTC investment data describing the investments and activities of tribes 

and Native organizations in the NMTC Program; and

● A document titled “Self-Assessment Guide for Native Organizations” (referred to as the 

Self-Assessment Guide), a guide for tribal entities that seek to participate in the NMTC 

Program describing the various roles and the corresponding responsibilities related to the 

NMTC.

b. About the New Markets Tax Credit (NMTC) Program 

The New Markets Tax Credit Program, established by Congress in December 2000, permits 

individual and corporate taxpayers to receive a non-refundable tax credit against federal 

income taxes for making equity investments in financial intermediaries known as 

Community Development Entities (CDEs). CDEs that receive the tax credit allocation 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 13

authority under the program are domestic corporations or partnerships that provide loans, 

investments, or financial counseling in low-income urban and rural communities. The tax 

credit provided to the investor totals 39% of the cost of the investment and is claimed over a 

seven-year period. The CDEs in turn use the capital raised to make investments in lowincome communities. CDEs must apply annually to the CDFI Fund to compete for New 

Markets Tax Credit Program allocation authority. Since the inception of the NMTC Program, 

the CDFI Fund has completed 18 allocation rounds and has made 1,461 awards totaling $71 

billion in tax allocation authority. This includes $3 billion in Recovery Act Awards and $1 

billion of special allocation authority used for the recovery and redevelopment of the Gulf 

Opportunity Zone.

To learn more about the New Markets Tax Credit Program, please visit 

www.cdfifund.gov/nmtc.

c. About the Community Development Financial Institutions Fund (CDFI Fund)

Since its creation in 1994, the CDFI Fund has awarded more than $5.5 billion to CDFIs, 

community development organizations, and financial institutions through: 

● The Bank Enterprise Award Program;

● The Capital Magnet Fund; 

● The CDFI Rapid Response Program; 

● The Community Development Financial Institutions Program, including the Healthy 

Food Financing Initiative;

● The Economic Mobility Corps; 

● The Financial Education and Counseling Pilot Program; 

● The Native American CDFI Assistance Program; and 

● The Small Dollar Loan Program. 

In addition, the CDFI Fund has allocated more than $71 billion in tax credit allocation 

authority to Community Development Entities through the New Markets Tax Credit 

Program, and guaranteed bonds for over $2.1 billion through the CDFI Bond Guarantee 

Program.

To learn more about the CDFI Fund and its programs, please visit the CDFI Fund’s website 

at www.cdfifund.gov. 

d. Report Purpose and Contents

This report provides a comprehensive overview of the case studies conducted as part of the CDFI 

Fund's NMTC Program Native Initiative. The report:

● Outlines the methodology used for selecting and implementing the case studies;

● Summarizes CDFI Fund data that describes past NMTC transactions in Native Areas;
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 14

● Describes the projects selected to serve as case studies for this component of the Native 

Initiative;1

● Summarizes the results and findings from the online surveys and interviews that were 

conducted in furtherance of the case studies;

● Describes best practices for increasing the availability of NMTC capital in Native Areas; 

and

● Provides recommendations for increasing Native participation in the NMTC Program and 

promoting partnerships between Native Entities, Allocatees, and NMTC Investors. 

By examining these case studies, the report seeks to identify common challenges and 

opportunities for expanding NMTC investment in Native Areas. The findings help inform 

strategies and recommendations to expand Native communities' access to capital through the 

NMTC Program.

In presenting the findings from the case studies, the report delves into a variety of factors 

affecting the deployment of NMTCs in Native Areas. It explores the challenges faced in 

obtaining and utilizing NMTC capital for projects within Native Areas, including project 

viability challenges, land-related concerns, and uncertainty surrounding the eligible roles of 

tribal corporations within NMTC transactions. The report also examines factors influencing the 

use of the NMTC Program and its complications within Native communities, such as sovereign 

immunity, tribal politics, and lender familiarity with Native Areas. 

By highlighting these insights, the report aims to facilitate a better understanding of the 

challenges and opportunities that exist in utilizing the NMTC Program to benefit Native 

communities.

Furthermore, this report offers best practices and recommendations for increasing the availability 

of NMTC capital in NMTC Native Areas. Survey and interview respondents emphasized the best 

practices that were critical to the success of their participation in the NMTC Program, such as the 

importance of cohesive tribal governance and economic development strategies, tribal policies 

that support development financing, and the value of engaging with NMTC experts. 

Additionally, the report suggests steps that Native Community Development Entities (CDEs) can 

take to increase their participation levels in NMTC transactions, as well as increase their 

competitiveness for NMTC allocation authority. The research team includes additional 

recommendations that propose policy or legislative changes, and are directed to either the CDFI 

Fund or Congress, to enhance tribal and Native enterprise understanding of, interest in, and 

competitiveness for NMTC financing. These recommendations address the specific challenges 

faced by Native communities as described by both the survey participants and the findings of the 

Market Research Report, and also draw from the prior experience of the research team.

1 The word “project” will be used for the remainder of this report to mean a real estate, equipment, or working 

capital investment unless otherwise specified.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 15

e. Report Structure

This report is divided into eight sections as described below:

● The executive summary provides a high-level overview of the purpose, findings, and 

recommendations within this report.

● “Section 1: Introduction” provides a more in-depth outline of this report and places it 

within the larger context of the CDFI Fund's NMTC Native Initiative.

● “Section 2: Methodology for Case Study Selection and Implementation” details how case 

studies were selected, and how the survey and interviews were conducted. Limitations to 

outreach and data collection are described in this section.

● “Section 3: Summary of Past NMTC Transactions in Native Areas” includes the amount 

invested over time, a map of transaction locations, information about the CDEs making 

NMTC investments, and the types of businesses involved. The section includes 

information that served as a foundation for the selection of case studies within this report.

● “Section 4: Description of Selected Case Study Projects” describes the case study 

projects in detail; it includes a table with selected high-level information surrounding the 

case study projects. 

● “Section 5: Findings, Best Practices and Recommendations” describes the findings of 

both the online case study surveys and follow-up interviews, as well as relevant best 

practices and recommendations for addressing the key challenges identified in the survey 

and interview findings. The research team briefly summarizes quantitative survey 

findings but delves into a more profound discussion surrounding the themes that emerged 

over the course of interviews that exemplify the experiences of individuals and 

organizations involved in NMTC projects within NMTC Native Areas. Following each 

finding, the research team either describes an existing best practice or provides a 

recommendation for program improvements drawn from the case study findings and 

research team’s experience with the NMTC Program. 

● “Section 6: Conclusion” provides a brief summary of the results from the case studies. It 

also details the other project components that informed the findings, best practices, and 

recommendations identified in this report and their implications for increasing the 

investment of NMTC capital in Native Areas.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 16

II. Methodology for Case Study Selection and Implementation

The case studies are intended to provide richer and more nuanced case-specific detail concerning 

NMTC investment in NMTC Native Areas that cannot be gleaned by data analysis. 

Understanding the impetus for these investments, as well as challenges and opportunities 

experienced by the participants in NMTC investments in Native Areas, can provide insights on 

making NMTC capital more accessible and better utilized in Native Areas. The research team 

reviewed transaction data concerning NMTC investments in NMTC Native Areas and Tribal 

Statistical Areas to identify a diverse set of projects that would illustrate a variety of successful 

approaches for using NMTC to address the capital needs of tribes. 

By filtering the data set provided by the CDFI Fund, the research team developed a list of NMTC 

projects that would fulfill the task-specific goal of incorporating and examining a diverse range 

of projects. Based on discussions with the CDFI Fund, the research team initially refined the 

candidate list to eighteen case studies located on Native lands or tribally owned property. 

Case study selection was based on the following characteristics: 

● Project locations in the contiguous United States, Alaska, and Hawaii;

● Metropolitan and non-metropolitan areas;

● Size of tribal enrollment;

● Total project cost;

● Project business type or asset class;

● Project year; and

● The name of the Community Development Entity (CDE) that financed the project.

The first selection criterion for potential case studies was project location. This entailed choosing

at least one project from each of the U.S. Department of Housing and Urban Development’s 

Office of Native American Programs (HUD ONAP) regions, including one project from Hawaii 

and one from Alaska.2 Additionally, the selection of projects sought to maintain a balance 

between projects located inside and outside of Metropolitan Statistical Areas (MSAs),3 with the 

majority of projects situated outside of MSAs.

Another criterion used in case selection was tribal enrollment numbers. Projects located on 

reservations that are home to small tribes (less than 1,500 members), large tribes (more than 

10,000 members), and mid-size tribes (between 1,500 and 10,000) were included in the initial 

selection. According to 2024 Indian Housing Block Grant (IHBG) data, the median size tribe had 

2 U.S. Department of Housing and Urban Development Office of Native American Programs. (2023). National 

Directory of Tribes and TDHEs by ONAP Regions. 

https://www.hud.gov/program_offices/public_indian_housing/ih/codetalk/onap/map/nationalmap.

3

Per the U.S. Census Bureau, a metropolitan statistical area (MSA) is a geographical region with a relatively high 

population density at its core and close economic ties throughout the region.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 17

626 enrolled members, and the average tribe had 4,150 enrolled members.4 Tribes of various 

sizes can have access to different levels of resources, and, in the initial analysis (described 

below), the data showed that larger tribes are more likely to receive NMTC allocations than 

smaller tribes. 

The research team selected projects at different project cost levels, including projects with a total 

cost under $10 million, projects with a total cost between $10 million and $30 million, as well as 

projects with a total cost above $30 million. For reference, the median project cost within the 

dataset was $12.8 million.

Project industry category was also used as a selection criterion. The research team used a 

typology first developed by the Urban Institute to categorize NMTC projects.5 At least one 

project was chosen from each of the most common categories identified. The selected categories 

included:

● Manufacturing and Food Processing; 

● Health Care Services; 

● Community Facilities or Tribal-Use Buildings; 

● Energy, Water, Waste, and Sewage; 

● Schools and Child Care; and

● Hotels; and Office and Professional Services. 

These categories were selected based on the fact that at least five projects within the dataset 

containing all NMTC projects in Native Areas fell within each individual selected category. 

Project completion date was included as a criterion to ensure that projects selected to serve as 

case studies reflected changes in the program as well as communities served over time. Projects 

were divided into three different time periods: 2003-2010, 2010 to 2015, and 2016 to 2020. 

These periods were selected so the research team could better understand and evaluate how the 

NMTC Program’s evolution and policy changes have influenced its impact on community 

development in Native Areas.

Finally, potential projects were sorted based on the number of Community Development Entities 

(CDEs) involved in the project. This ensured that projects with multiple CDEs were represented 

as well as projects with a single CDE. Projects were selected to incorporate a diverse set of 

CDEs, with a mix of both Native CDEs and non-Native CDEs.

After this list of 18 projects was compiled, the research team shared this list and associated 

project-specific characteristics with the CDFI Fund, which subsequently selected nine projects 

4

FY 2024 IHBG Formula Estimates. 

https://www.hud.gov/program_offices/public_indian_housing/ih/codetalk/onap/ihbgformula

5

For a list of all categories used, see: Theodos et al. (2021). Which Types of Projects Receive New Markets Tax 

Credit Funding. The Urban Institute. https://www.urban.org/sites/default/files/publication/103956/which-types-ofprojects-receive-new-markets-tax-credit-funding_0.pdf
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 18

and three alternate projects that could be drawn from in case the research team had difficulty 

obtaining initial survey responses for any of the nine projects that were initially selected. The 

CDFI Fund selected the nine projects based on representativeness of the use of NMTCs in a 

particular region or sector (and/or representativeness of the business financed), and for which the 

CDFI Fund had no prior direct knowledge (e.g., via site visits). For projects that involved more 

than one CDE, the CDFI Fund selected the CDE with organizational characteristics that were not 

represented by CDEs for other single CDE projects.

Ultimately, one case was added to the sample to replace another case that was found not to be 

located on reservation land, not involving a tribal entity, and not specifically serving a Native 

population. The same selection criteria were used to choose a replacement case: a similar mixeduse commercial and municipal building transaction located on reservation land and involving a 

tribe.

Following the CDFI Fund’s selection of the nine projects that would serve as the subjects for the 

case studies, the research team began the process of reaching out to the five key participants (the 

CDE, leverage lender, investor, Qualified Active Low-Income Community Businesses 

(QALICB), and tribe/tribal sponsor)6involved with each project to gather online survey 

responses and schedule follow-up interviews regarding the projects. 

The research team initially administered an online survey to gather foundational background 

information about the project's participants, laying the groundwork for more in-depth exploration 

through subsequent interviews. The research team used the platform LimeSurvey to host the 

online survey, which allows for survey skip logic.7 Outreach was done via phone and email, and 

attempts were made to contact the CDE, leverage lender, investor, QALICB, and tribe/tribal 

sponsor involved in each project. 

The research team started by contacting the CDEs, with the hope that these key participants 

would be able to provide the critical - and potentially difficult to source - contact information for 

the other key participants involved with each project. Respondents were initially given two 

weeks to respond to the survey, but this period was extended another two weeks. At least one 

CDE responded for each transaction.

The research team was less successful in its efforts to obtain responses from other key 

participants within transactions, as described further in the Limitations section of this report 

below. Only two QALICBs responded to the QALICB survey. One investor responded to the 

survey for investors, and no tribal leaders or leverage lenders completed the surveys. 

6 Definitions of these terms and others are available in Appendix B: Glossary. 

7

Skip logic refers to a type of survey logic in which a respondent’s answer to a question may determine the 

subsequent questions they are asked. In the case of these surveys, it was used to ensure respondents were only asked 

questions relevant to their experience, e.g., if they responded that they had not faced additional challenges related to 

NMTC regulations due to the project’s location in a Native Area, they would not then be presented with a question 

asking them to elaborate on these challenges.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 19

The surveys were formatted as below:

● CDE survey: 15 substantive questions and other questions asking CDEs to list other 

key participants within the transaction in question 

● QALICB survey: 17 questions 

● Investor survey: 16 questions 

● Tribal leader survey: 10 questions

● Leverage lender survey: 7 questions.

The research team crafted distinct online survey instruments for each of the five roles in the 

NMTC projects. Each survey was designed to collect quantitative information about the key 

participants’ level of pre-existing experience with NMTCs, challenges they faced utilizing 

NMTCs for the specific project of interest, availability of capital for the project, challenges 

related to the project’s location in a Native Area, resources utilized for the project (including 

expert consultants and capital), and community outcomes associated with the project. 

Upon completion of the brief online survey, respondents were prompted to schedule a follow-up 

interview with the research team. These interviews were designed to gather more extensive 

qualitative information regarding the responses to the survey and to understand better the 

respondents’ experience using NMTCs for a project located in a Native Area. Interviews were 

conducted virtually via Zoom and lasted between 30 and 60 minutes each. The research team 

developed standard scripts for each role, gave the interviewees opportunities to elaborate on their 

responses. and, if they chose to do so, make additional points regarding the project and their 

experience with NMTCs and the NMTC Program. Interviews were recorded and transcribed for 

later reference.

a. Limitations

Two key obstacles prevented the research team from connecting with each of the five key 

participants for each project. First, many of the projects selected were over a decade old. Many 

of the key organizations had experienced staff turnover since the projects closed, creating a 

barrier to contacting sources familiar with the details of these specific projects. This turnover 

contributed to lower-than-expected response rates. Second, the Paperwork Reduction Act8

limited the number of organizations that could be contacted to nine, meaning that, once 

meaningful contact was made with a key participant for that project, the research team could not 

replace the case with another. 

After several attempts were made to gather a response from each key participant, the research 

team adjusted the outreach strategy by shifting their focus from obtaining a response from all of 

the key participants for each project, to gathering responses from just the CDE and tribe/tribal 

8

“A Guide to the Paperwork Reduction Act: Do I Need Clearance?”

https://pra.digital.gov/do-i-need-clearance/
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 20

sponsor or QALICB. One project was added to the list after participants in another project could 

not be reached. 

To provide additional context, interviews were also conducted with sources knowledgeable about 

the deployment of NMTCs in Native Areas who had not worked on one of the specific cases 

identified, typically because they were identified as a resource by one of the selected key 

participants. These knowledgeable sources included a consultant brought in on many NMTC 

deals in Native Areas because of their specific expertise, a lawyer well-versed in the NMTC 

Program, and a NMTC underwriter for a bank with significant experience involving NMTC 

transactions. The interviews with these sources did not follow a predetermined script but were 

more free-form.

Ultimately, the team conducted interviews with individuals from the CDE for each project, and 

with QALICBs for several projects. While lack of response from project sponsor representatives 

may have resulted in fewer alternative solutions to challenges that are uniquely tribal, the 

research team’s workshop-based discussions with Native lenders including the Native CDFI 

Coalition, Native American Bank, and Citizen Potawatomi Community Development 

Corporation helped to mitigate this potential impact. Furthermore, the ultimate designs of some 

of the transactions illustrate measures to address such challenges, such as the pledge of revenue 

instead of real estate for the Navajo Tribal Utility Authority office discussed later in this report.

Coming after the completion of several key deliverables for the Native Initiative, this Case Study 

Report draws upon additional recent and relevant work to provide context and further 

documentation for this report's findings, best practices, and recommendations (discussed in 

Sections V). For example, this section incorporates relevant additional insights from the research 

team’s analysis of NMTC investment data, and from the research conducted to prepare the 

Market Research Report. These findings are included in this report as additional context for the 

discussion of several key NMTC topics. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 21

III. Summary of Past NMTC Transactions in Native Areas

This section provides an overview of the NMTC investments made in American Indian, Alaska 

Native, and Native Hawaiian (AIANNH) lands9 within the United States between 2003 and 

2020.10 It focuses on the amount invested and types of investments made over time in these 

areas, highlighting the contributions of Qualified Low-Income Community Investments 

(QLICIs) in various projects. Additionally, this section explores the extent of the involvement of 

different Community Development Entities (CDEs) and the breakdown of Qualified Active 

Low-Income Community Businesses (QALICBs) by ownership structure, race, gender, and 

establishment age based on data reported by CDEs. The information presented in this section 

served as a foundation for further analysis and the selection of the case studies summarized in 

subsequent sections of this report.

a. Amount Invested and Investments Over Time

Overall, 225 Qualified Low-Income Community Investments (QLICIs) within 149 unique 

projects made by 51 CDEs took place in AIANNH lands within the United States between 2003 

and 2020. NMTC investments across all these projects totaled $1.8 billion in 2021 dollars.11

Across this time period, the median QLICI investment amount was $6.9 million, the median 

NMTC investment per project was $10.2 million, and the median total project cost was $12.8 

million (all in 2021 dollars). NMTC investments on AIANNH lands make up 2.6% of all NMTC 

investments. Total project costs on AIANNH lands make up 2.4% of the total project costs for all 

NMTC projects during this period.

Since 2017, there have been an average of 12 projects a year and $144 million in NMTC 

investment each year in AIANNH lands. Figure 1 shows this general increase in the number of 

projects from 2003 to 2020. NMTC investment by year follows a similar pattern, peaking in 

2011 at $267.9 million. This peak was not driven by a few outsized projects, but rather reflects 

an increase in both the amount of allocation deployed and the number of projects financed using 

NMTCs.

9 American Indian/Alaska Native/Native Hawaiian (AIANNH) Areas refer to geographical regions in the United 

States that are designated for the Native indigenous populations, including American Indians, Alaska Natives, and 

Native Hawaiians. This includes the following legal entities: federally recognized American Indian reservations and 

off-reservation trust land areas, state-recognized American Indian reservations, and Hawaiian home lands (HHLs). 

The statistical entities included are Alaska Native village statistical areas (ANVSAs), Oklahoma tribal statistical 

areas (OTSAs), tribal designated statistical areas (TDSAs), and state designated tribal statistical areas (SDTSAs).

10 CDEs that receive NMTC allocations are required to provide the CDFI Fund with annual reports, one of which is 

the transaction-level report on the investments made using the NMTC proceeds. Transaction level reports are 

submitted within 180 days of the CDE's fiscal year end date. At the time of this analysis, the transaction level report 

consisted of NMTC investments made in fiscal years ending 2020.

11 All dollar amounts reported in this section were converted to 2021 dollars.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 22

Figure 1 | Projects and NMTC Investment in AIANNH Lands by Year Closed

Source: CDFI Fund New Markets Tax Credits (NMTC) Investments Made in American Indian, 

Alaska Native, and Native Hawaiian (AIANNH) Areas, 2001 through 2020
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 23

b. Map of Transaction Locations

The map in Figure 2 below shows NMTC Projects, the location of AIANNH lands, and 

AIANNH population by state (AIANNH alone or in combination with one or more other races).

Figure 2 | NMTC Projects, AIANNH Lands, and AIANNH Population by State

Data sources: CDFI Fund New Markets Tax Credits (NMTC) Investments Made in American 

Indian, Alaska Native, and Native Hawaiian (AIANNH) Areas, 2001 through 2020; Population 

data from U.S. Census 2010 Decennial Census. TIGER/Line Shapefiles® obtained from U.S. 

Census Bureau include 2022 American Indian/Alaska Native/Native Hawaiian Area and 2022 

State and Equivalent.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 24

Figure 3, below, shows the locations of the cases chosen for this case study report.

Figure 3 | Case Study Project Locations

Source: Big Water Consulting, 2023
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 25

Figure 4, below, shows the Office of Native American Programs (ONAP)’s regions of the United 

States for the purposes of demonstrating in which ONAP region each case was located.

Figure 4 | Map of ONAP Regions

Source: National Directory of Tribes and TDHEs by ONAP Regions12

12 https://www.hud.gov/program_offices/public_indian_housing/ih/codetalk/onap/map/nationalmap
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 26

c. Number of CDEs Making Investments

There were fifty-one (51) CDEs that made investments in AIANNH lands between 2003 and 

2020. Of those CDEs, 43% were only involved in one NMTC project in AIANNH lands during 

that time period. Just over half (51%) of these CDEs completed more than one but less than ten 

projects in AIANNH lands. Only three CDEs completed ten or more projects in AIANNH lands. 

Of the fifty-one (51) CDEs that have made investments in AIANNH lands, 90% were not 

Native-owned/controlled.13 The research team ascertained this based on the knowledge of 

experts familiar with the CDEs and by contacting the CDEs to inquire about their Nativeowned/controlled status.

Of the 149 projects conducted by these CDEs, 81% involved only a single CDE. Of these 

projects, 19% involved multiple CDEs.14 This is similar to the breakdown in the full CDFI Fund 

NMTC public data, where 20% of all NMTC projects are flagged as multi-CDE projects and 

80% are not. 

d. Qualified Active Low-Income Community Business (QALICB) Characteristics

The QALICBs involved in investments in NMTC Areas on AIANNH (American Indian, Alaska 

Native, and Native Hawaiian) lands varied by ownership structure, ownership race and gender, 

and the age of the organization, with newer organizations being classified as startups.

Overall, there were seventy-three (73) projects in AIANNH lands that had for-profit QALICBs, 

with an average NMTC investment of $13.2 million. Forty-three (43) projects had nonprofit 

QALICBs with an average NMTC investment of $11.4 million. Twenty-three (23) projects had 

tribal QALICBs with an average NMTC investment of $9.8 million. For ten projects, the 

QALICB type was classified as "missing."15

Among the projects in AIANNH lands, 57% had Qualified Active Low-Income Community 

Businesses (QALICBs) that were classified as startups, meaning the date that the entity was 

established was two years or fewer before the year the deal closed. These projects with startup 

QALICBs had an average NMTC investment of $12.7 million. On the other hand, 19% had 

QALICBs that were not classified as startups, with an average investment of $9.8 million. The 

remaining 24% of QALICBs fell under the "missing" category due to undefined or conflicting 

years of establishment for Qualified Low-Income Community Investments (QLICIs) within the 

same project.

13 The NMTC Program Allocation Application defines a Native American-owned or Native American-controlled 

entity as “a for-profit entity, including an MDI, that has at least 51% of its equity ownership (or the equivalent in 

limited liability companies) interest being owned by individuals who are Native American” or “a not-for-profit 

entity with at least 51% of its Board of Directors (i.e. Governing Board) comprised of individuals who are Native 

American.” https://www.cdfifund.gov/sites/cdfi/files/2022-11/CY_2022_NMTC_Program_Application.pdf

14 Transactions in the dataset involved between one and three CDEs.

15 The "missing" category includes projects where the QALICB was undefined and projects with multiple QLICIs 

that defined QALICBs differently.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 27

Eight percent of the projects had QALICBs that were identified as being more than 50% owned 

or controlled by women, with an average NMTC investment of $6.9 million. Additionally, 40% 

had QALICBs that were identified as being more than 50% owned or controlled by racial/ethnic 

minorities, with an average NMTC investment of $12.7 million.

Qualified Active Low-Income Community Businesses (QALICBs) separately reported the race 

of the owner/director of the QALICB to the CDFI Fund. Of these QALICBs, 3% had an Alaska 

Native owner/director, 32% had an American Indian owner/director, 4% had a white 

owner/director, and 38% were owned by corporations and had no specific race reported. Nearly a 

quarter (23%) of projects had “missing” data for the race or ethnicity of the QALICB owner or 

director.16

The information presented above played a crucial role in the selection of case studies for the 

project. As described in the previous section of this report, the case studies aim to delve deeper 

into specific investment projects on AIANNH (American Indian, Alaska Native, and Native 

Hawaiian) lands, providing valuable insights into their impact, success factors, and challenges. 

Case studies were selected by examining a range of projects across different regions, at different 

periods of time, involving a variety of different CDEs, business types, tribal enrollment numbers, 

and Native and non-Native project ownership. 

Through this focused approach, the research team sought to capture the lessons learned and 

highlight best practices in a diverse and representative array of AIANNH lands.

16 Many project sponsors use newly formed single-purpose QALICBs. The CDFI Fund's data doesn't distinguish 

between a newly formed special-purpose QALICB and a newly formed operating business sponsoring a project.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 28

IV. Description of Selected Case Study Projects

Based on the criteria explained in the previous section, the research team narrowed the list of 

potential case studies to a final list of nine projects. These represented a diverse range of 

business types, geographical regions, and strategies for maximizing the usefulness of the NMTC 

Program. 

Table 1, below, and the following project descriptions provide an overview of the selected case 

studies.

Table 1 | Overview of Case Study Projects

Project17 Year

Closed

Region Project Total 

QLICIs

Sector Native 

CDE?

Choctaw Early 

Childhood and 

Elementary 

Education

2020 Eastern/

Woodlands 

Region

$15,000,000 Community - Schools 

and child care

No

Crain 

Manufacturing 

2007 Southern 

Plains

$8,100,000 Other - Manufacturing 

and Food Processing

No

Makah 

Commercial 

Fishing Dock

2014 Northwest $7,620,320 Other - Forest, 

agriculture, fishing, 

mining, and quarry

No

Maniilaq Nursing 

Home

2010 Alaska $17,460,995 Health Yes

Minnewaukan

Public School 

District K-12 

School

2012 Northern 

Plains

$10,864,000 Community - Schools 

and child care

No

17 Project names were developed by the research team using project descriptions to aid in succinctly and accurately 

representing and referencing each project. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 29

Table 1 Continued | Overview of Case Study Projects

Project Year 

Closed

Region Project Total 

QLICIs

Sector Native 

CDE?

Navajo Tribal 

Utility Authority 

Administrative 

Building

2010 Southwest $9,500,000 Other - Energy, water, 

waste, broadband and 

sewage

No

St. Croix 

Chippewa Indians 

Judicial Center

2017 Eastern/

Woodlands 

Region

$13,840,000 Mixed Use -

Community Facilities 

and Retail

No

Wa She Shu 

Travel Plaza

2015 Southwest $10,500,000 Retail No

West Hawaii 

Community Health 

Center

2013 Hawaii $21,807,500 Health No

a. The Choctaw Early Childhood and Education Center project funded the construction of 

two new early childhood education centers and the expansion of an elementary school on the 

Choctaw Reservation (Pearl River and Standing Pine Early Childhood Education Centers and 

the Pearl River Elementary School). 

i. The early childhood centers each serve 50 children ages eight weeks to five 

years. 

ii. The expansion to the Pearl River Elementary School added 25 new classrooms 

serving 400 additional students, as well as a new library. 

iii. The expansion created 42 new full-time jobs.

iv. Dakotas America was the Community Development Entity (CDE) associated 

with this investment and the Qualified Low-Income Community Investment 

(QLICI) was closed in 2020.

b. Crain Manufacturing was a Durant, OK-based manufacturer of trailer jacks and hitches. It 

was located in Choctaw territory, but not on tribally owned land. 

i. At its peak, Crain employed 40 people and generated annual sales of about $5 

million. However, it was affected heavily by spiking steel prices in the late 

2000s and had to close its doors. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 30

ii. REI New Markets Investment, LLC was the CDE associated with this 

investment and the QLICI was closed in 2007.

c. The Makah Commercial Fishing Dock is crucial to the Makah Tribe’s economy. Located 

on Neah Bay in Northwest Washington, fishing accounts for 50% of the tribe’s economic 

activity. In 2013, the existing commercial dock collapsed, rendering it unusable. The tribe 

responded quickly and completed a new commercial dock within nine months, funded in part 

by New Markets Tax Credits. 

i. Ninety small businesses and Native fishing operations use the new dock and 

facilities, which employ 400 people and support the trade of $7-10 million 

worth of fish annually. Dock leasing, moorage, and fuel sales based around the 

commercial dock also support the tribe and its members. 

ii. Although the dock is not located on the Makah Reservation, it is on tribal 

property. 

iii. HEDC New Markets was the CDE associated with this investment and the 

QLICI was closed in 2014.

d. The Maniilaq Nursing Home (Utuqqanaat Inaat, or “a place for Elders”) is located 

within the Maniilaq Health Center and opened in October 2011. It fills the “critical need for 

Elder care in low-income resident villages,” and employs 20 full-time staff members. 

Operated by the Maniilaq Association, a consortium of 12 Northwest Alaskan tribes/villages, 

it is the region’s first nursing home—before its construction, Elders had to travel 550 miles 

south to Anchorage to receive long-term care. 

i. Located in Kotzebue, AK, which is considered a “hub community” for the 

region, it is situated on Alaska Native Village Statistical Area and Alaska 

Native Claims Settlement Act land. This was a targeted population project 

specifically serving Native Elders qualifying as low-income. 

ii. The nursing home houses 18 Elders at any given time, all of whom have low 

incomes, and provides long-term, 24-hour care.

iii. Alaska Growth Capital BIDCO, Inc., a Native CDE, is the CDE associated with 

this investment, and the QLICI was closed in 2010.

e. The Minnewaukan Public School District needed to replace and relocate one of its K-12 

schools, which was at risk of flooding due to rising water levels of a nearby lake and was not 

meeting the space and facility needs of its students (over 90% are members of the Spirit Lake 

Tribe or Turtle Mountain Band of Chippewa Indians). When it was unable to use flood 

insurance as collateral on a conventional loan to construct a new school building, the school 

district used NMTC financing from Travois to construct a new building with classrooms, 

cafeteria, gym, computer lab, and library.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 31

i. In its first school year after opening, the school served 296 students and 

employed 60 teachers and staff. The new school building created 18 new fulltime jobs. 

ii. The school is on property owned by the public school district and is not on 

tribal land, although it serves a largely Native student body and was built as a 

replacement for the school on tribal land. 

iii. Travois was the CDE associated with this investment, and the QLICI was 

closed in 2012.

f. The Navajo Tribal Utility Authority (NTUA) has several district offices on the Navajo 

Reservation, including an office in Chinle, Arizona. NTUA is a nonprofit enterprise of the 

Navajo Nation, providing utilities and communication services to the Navajo People of New 

Mexico and Arizona. The NMTC financed the renovation and construction of multiple 

NTUA administrative buildings, which, prior to these efforts, had been affected by mold, dim 

lighting, and other environmental concerns. The new building replaced a 40-year-old 

dilapidated building and consolidated administrative operations. NTUA serves an area that is 

the size of West Virginia but has a population of only 40,000, meaning that the average percustomer cost of delivering services is high. 

i. An estimated 14,000 households in this service area do not have access to 

infrastructure including electricity, indoor plumbing, or waste disposal, and 

more than half of NTUA’s customers pay their bills at the office in person 

because of their lack of access to banking, internet, or postal services. Restoring 

this office building greatly reduces the amount of time and travel required for 

these families to pay their bills for NTUA services. 

ii. The construction of the new building created 8 new full-time jobs.

iii. Stonehenge Community Development was the CDE associated with this 

investment, and the QLICI was closed in 2010.

g. The St. Croix Chippewa Indian Tribe of Wisconsin used NMTCs to construct a mixed-use 

judicial center, grocery store, market, RV park, and amphitheater on the St. Croix 

Reservation. The NMTC deal provided refinancing of existing gaming debt, loans for new 

economic development project construction, repurposing of the existing judicial building, 

and the development of a new judicial center. This mixed-use facility contains both 

governmental and retail space on the St. Croix Reservation. 

i. The center created 90 full-time jobs.

ii. The transaction involved two CDEs: Forward Community Investments, Inc. and 

Bremer CDE, LLC. The QLICIs were closed in 2017.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 32

h. The Wa She Shu Travel Plaza has a fuel station, convenience store, dining options, and 

overnight parking for trucks and RVs. The travel plaza is situated next to the western 

Nevada-based Washoe Tribe’s Wa She Shu Casino.

i. The travel plaza created 27 new full-time jobs, and brings in over $1 million 

annually in revenue for the tribe, while serving 1,550 tribal members annually. 

ii. Clearinghouse CDFI, acting as the CDE, combined federal and Nevada state 

NMTCs to fund this project, and revenue from a state of California program 

was used as collateral for the leverage loan. The QLICI was closed in 2015.

i. West Hawaii Community Health Center is a federally qualified health center established in 

2006 on Hawaiian Home Lands property, which is subject to unique regulations. It provides 

integrated medical, dental, and behavioral health services to primarily low-income 

individuals and families in three clinic locations on the Big Island of Hawaii, with a part-time 

mobile dental clinic that serves homeless individuals five hours a week at a shelter in Kailua 

Kona. 

i. The new medical center building, the La’i’Opua Health Center, provides 

medical and dental care to approximately 4,300 patients a year. The center 

created 35 new permanent positions. 

ii. Three CDEs provided allocations: Nonprofit Finance Fund, Punawai 'O 

Pu'uhonua, LLC, and USBCDE, LLC.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 33

V. Findings, Best Practices, and Recommendations

This section discusses the findings from the online survey and interviews with key participants in 

the nine case study projects, as well as interviews with other parties involved in previous NMTC 

transactions in Native Areas. It augments those findings with takeaways from other components 

of the NMTC Native Initiative, including the Market Research Report and (to a lesser extent) the 

Analysis of Summary Data. This section highlights themes and experiences shared by key 

participants that will provide guidance for CDEs investing or seeking to invest in Native Areas, 

recommendations for tribes and QALICBs, and insights into systemic challenges hindering 

greater utilization of the NMTC Program in Native Areas.

Following each of the key findings are either: 

● A description of a practical solution, or best practice, developed by one or more NMTC 

participants that enabled them to overcome the specific challenge or obstacle summarized 

in that finding; 

● A recommendation directed to the CDFI Fund or Congress for a policy or legislative 

change that would diminish or eliminate that challenge or obstacle; and/or

● Recommendations for how Native CDEs and potential CDEs, conventional lenders, 

and/or investors can facilitate greater investment in Native Areas and Native projects. 

1. Online Surveys

Full responses to the CDE survey can be found in Appendix B to this report. The survey acted as 

a precursor to the interview, wherein CDEs were given significantly more opportunity to expand 

on their experience working on the specified NMTC project. Deeper analysis of the findings can 

be found in Subsection 2 of this section, which summarizes findings from the follow-up 

interviews. The online survey offered structure and guidance for these conversations, as well as 

the ability to aggregate quantitative data to the extent that the sample size of nine CDEs allowed. 

The following are the key findings from the CDE survey:

● CDEs associated with the case study projects were most likely to specialize in deploying 

NMTC capital for not-for-profit or community facilities and/or health clinics. Among the 

respondents, 89% stated that these are areas of specialization for their organizations and 

67% noted economic development and owner-occupied real estate as areas of 

specialization.

● Two-thirds of responding CDEs did not act in any other roles besides CDE for the case 

transaction. One-third of responding CDEs also acted as the leverage lender, and 11% 

served as the investor for the transaction.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 34

● Two-thirds of responding CDEs had more than ten years of experience lending/investing 

in Native Areas prior to the case transaction.

● Nearly 80% of responding CDEs retain staff members or consultants to advise on 

projects in Native Areas.

● No CDE indicated that the amount of private or conventional (i.e., non-NMTC) capital 

available for the project exceeded the project’s need. Fifty-six percent noted that project 

capital was available but not to the extent necessary, 22% stated that project capital was 

not available, and 22% found that the amount of capital available matched but did not 

exceed the project’s need. 

● More than half (56%) of these CDEs stated that they encountered tribal cultural or legal 

matters that had to be addressed as part of the project process. 

● More than 20% of interviewed CDEs had a pre-existing relationship with the tribe or 

project sponsor involved in the case study project. 

● More than half (56%) of the CDEs answered that NMTC regulations18 (e.g., risk of 

recapture; the “substantially all” requirement; QALICB eligibility criteria) posed a 

greater challenge in attracting interest from a tax credit investor or closing the transaction 

for the case project than for projects outside of Native Areas. (Further discussion of this 

topic is available in Appendix B).

● The most common reasons CDEs gave for deciding to provide capital to the case study 

project were that the QALICB otherwise had limited or no access to capital, the CDEs 

had an organizational commitment to supporting Native projects, and the project was 

likely to generate significant community impacts/outcomes.

● Two-thirds of responding CDEs would request future allocations to finance other NMTC 

projects in Native Areas based on their experience with the project in question. 

2. Interviews

As noted in the methodology section, the research team conducted a series of virtual interviews 

with representatives of the CDEs involved in each of the projects, as well as with representatives 

of several borrowers (tribal sponsors or QALICBs), tax credit investors in the transactions, and 

other individuals with experience working to provide NMTC capital to projects in Native Areas. 

The research team believes that the individuals interviewed represent a good cross-section of 

participants in Native NMTC transactions but recognizes that their experiences may not be 

wholly reflective of the experiences of all those involved in Native projects. Similarly, the 

18 26 U.S. Code § 45D: 

https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=26-USC375442294-

332392142&term_occur=999&term_src=title:26:subtitle:A:chapter:1:subchapter:A:part:IV:subpart:D:section:45D
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 35

selected case study projects represent a sample of those closed in Native Areas and on behalf of 

Native populations, but they are by no means exhaustive of the types of transactions that have 

used NMTCs.

With those caveats, the following subsections describe the themes that emerged over the course 

of these interviews. They offer guidance for other CDEs interested in working in Native Areas, 

recommendations to tribes and QALICBs that are considering utilizing the program to fund 

projects in their communities, and insights into the challenges preventing greater NMTC use in 

Native Areas. They also include policy and programmatic recommendations for the CDFI Fund 

and Congress to address the identified challenges.

A. Challenges Native or Tribally Focused CDEs Face in Obtaining NMTC Allocations

Several interviewees for both the Market Research Report and the case studies noted that Nativefocused CDEs received few NMTC allocations in recent years. The Congressional Native 

American Caucus also has noted the lack of NMTC allocations awarded to CDEs whose primary 

mission is to serve Native Areas.19 In the CY 2020 Application Round, the CDFI Fund awarded 

an NMTC allocation to Alaska Growth Capital BIDCO, Inc., an Anchorage-based Native 

owned/controlled CDE and CDFI. It was the first allocation secured by a Native CDFI or Nativeowned/controlled CDE since 2017.20

The lack of awards has generated considerable resentment on the part of tribal members and their 

advocates. Some claimed that the CDFI Fund has not viewed the NMTC Program in terms of the 

government’s responsibility to serve as a trustee for Native lands and indigenous populations. 

Interviewees perceived several reasons for the dearth of allocations going to Native-oriented 

CDEs:

1. Human Resource Constraints: Several CDE representatives and NMTC consultants 

noted that many tribes do not have the staffing resources necessary to develop the most 

compelling applications or to deploy the requested allocation effectively and efficiently. 

The NMTC Program is inherently complex, from identifying eligible transactions to 

piecing together the necessary capital, to ensuring that the CDE and the QALICB comply 

with all program regulations. Even many of the larger and more sophisticated CDEs need 

to pay attorneys, accountants, and other financial consultants for assistance with their 

allocation applications, the development of their investment infrastructure, and the 

monitoring of program compliance.

19 “Lawmakers Call for Expanded NMTC Access for Native Communities,” Tax Notes, September 28, 2020,

https://www.taxnotes.com/research/federal/legislative-documents/congressional-tax-correspondence/lawmakerscall-for-expanded-nmtc-access-for-native-communities/2d088 (cited in Community Economic Development in 

Indian Country: Market Research Report, July 2023., p. 10).

20 https://nativecdfi.net/blog/2021/09/03/native-cdfi-network-statement-on-new-market-tax-credit-allocations/
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 36

Many Native or Native-oriented CDEs and other financing entities have small staffs, in 

part because of their comparatively limited amount of assets under management 

(typically $10 million or less, according to CDEs and investors interviewed). Moreover, 

the bulk of these financing entities historically have tended to focus more on small/micro 

business financing and /or consumer financing. These organizations do not necessarily 

have the capacity in-house to underwrite and monitor the larger commercial, community 

facility, and real estate projects that receive the bulk of NMTC capital. In effect, the 

tribes with the fewest resources have the least ability to participate in a program intended 

to boost economic development in Low-Income Communities.21

○ Recommendation 1: Provide Ongoing Training to Tribes and Tribal CDEs 

about Development Financing. 

As the research team found in the course of developing the Market Research 

Report and conducting the NMTC Technical Workshops, knowledge of and 

access to development finance varies widely across Native Areas. While some 

tribes have very sophisticated capital programs, other tribal governments have 

never used third-party loan capital for projects, relying almost exclusively on 

grant or government program capital in the past. The unfamiliarity with debt 

contributes to several of the other challenges described earlier.

NMTC project underwriting involves not only the typical issues of collateral, cash 

flows, borrower credit history, and the like, but also the complexity of tax credits 

and the potential recapture thereof. For some tribes, the shift from entitlement or 

grant capital to entrepreneurship capital (i.e., underwriting against the risk of nonrepayment) requires considerable education and training before the process can be 

fully and successfully institutionalized.

This training can and should be provided by several entities, including Native 

organizations and coalitions, the CDFI Fund and other federal agencies, 

community and economic development trade associations, and consultants and 

investors within the NMTC industry. It is important that the training is culturally 

appropriate and competent for recipients. And while the ultimate goal is to 

prepare Native entities for participation in the NMTC Program, the training may 

be best structured by focusing first on the principles of community and economic 

21 Low-Income Community: (1) In general. The term “low-income community” means any population census tract 

if— (A) the poverty rate for such tract is at least 20%, or (B) (i) in the case of a tract not located within a 

metropolitan area, the median family income for such tract does not exceed 80% of statewide median family 

income, or (ii) in the case of a tract located within a metropolitan area, the median family income for such tract does 

not exceed 80% of the greater of statewide median family income or the metropolitan area median family income. 

Subparagraph (B) shall be applied using possession wide median family income in the case of census tracts located 

within a possession of the United States. 26 USC § 45D(e)(1): https://www.law.cornell.edu/uscode/text/26/45D#e_1
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 37

development planning, access to third-party capital, project underwriting, and 

collaborative relationships as vehicles for capital access.

○ Recommendation 2: Provide Funding to Help Native CDEs Access Technical 

Assistance in Preparing for NMTC Applications. 

Several workshop attendees and interviewees reported that they and other Native 

CDEs have hesitated to apply for NMTC allocation authority because managing 

an allocation requires them to incur the cost of developing and/or obtaining 

expertise with no guarantee of receiving subsequent awards. Native CDEs 

recognize that lack of scale and experience may result in less competitive 

applications until they have built a track record with repeated awards. At the same 

time, limited staff resources often prove to be a significant obstacle in preparing a 

competitive application. The CDFI Fund should consider making technical 

assistance funding available to Native CDEs so their staff members can attend 

NMTC industry conferences and workshops, access consulting services, and 

otherwise keep up with changes to the application process. 

2. Limited Track Record Financing NMTC-Type Projects: Compared to other NMTC 

applicants, many Native CDEs often have a more limited track record financing 

NMTC-eligible or other community development activities. This results in part from 

their emphasis on consumer and small business financing. Relatively few Native CDEs 

(or potential CDEs) have significant experience making loans or equity investments of 

greater than $100,000; the typical consumer or micro-business loan usually is for less 

than $20,000. According to CDFI Fund and industry data,22 many Native CDFIs have 

total portfolios of less than $5 million. Their business model, while significant and 

appropriate for the low-income communities they serve, does not necessarily lend itself 

to being competitive in the NMTC allocation process. A typical NMTC QLICI tends to 

be $5 million or more, and applicants generally receive allocations in amounts 

consistent with their recent deployment track record.

A related issue is that many tribes have a limited pipeline of NMTC-eligible transactions, 

given the nature of their activities. Again, this can make them less competitive relative to 

applicants with much larger pipelines. 

○ Recommendation 1: Native CDEs Can Develop NMTC Experience by 

Participating in Transactions as a Secondary CDE.

In this scenario, the Native CDE (or potential CDE) works with one or more third 

party CDEs to include the Native CDE as a Secondary CDE for projects on 

22 According to CDFI Fund Snap Stats 2016, 87% of CDFI assets were held by banks and credit unions, 13% held 

by loan funds. Of the loan funds, the median size of total assets was $7,007,023. Oweesta.org surveyed the 2020 

year-end financial reports of 28 Native CDFI revolving loan funds and one Native CDFI bank and reported average 

asset size of $8,061,065 and average portfolio size of $4,393,042.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 38

Native Lands and/or benefiting Native populations. In this role, the Native CDE 

receives NMTC capital from an allocatee CDE and uses that capital to invest in a 

Native project. Such participation builds the Native CDE’s track record and 

experience raising and deploying NMTC capital.

The Native CDE adds value to the transaction because of its knowledge of the 

project and local tribal and/or community dynamics. It presumably has strong 

experience lending on trust lands, and it has institutionalized practices for 

managing leasehold security, sovereign immunity, and other issues that might be 

obstacles for lenders or CDEs inexperienced in Native Area lending. 

Non-Native CDEs can include making investments in Secondary (Native) CDEs 

in future applications. Allocatees can use up to 15% of their authority in a manner 

that was not described in their application to implement Secondary CDE 

transactions while continuing to meet the conditions of their Allocation 

Agreement with the CDFI Fund and the NMTC Allocation Application 

requirements.

Native CDEs desiring to build an NMTC track record should work with tribes and 

other sponsors of prospective NMTC projects to let them know about the 

Secondary CDE option. Having a Secondary CDE conversant in Native issues 

may make it easier for the project in question to attract financing from non-Native 

CDEs and investors. Such outreach also can help the Native CDE build 

relationships that can lead to future pipeline transactions. Native CDEs should 

also seek out allocatees and investors to build relationships.

○ Recommendation 2: Native CDEs Can Participate as a Partner/Collaborative 

Lender to a Native QALICB.

Native CDFIs/CDEs can work together through loan participation arrangements 

to provide capital at a meaningful scale to NMTC projects as leverage, source, or 

direct lenders. Native CDEs may not have enough capital to meet the entire loan 

need of the NMTC borrower but could participate with other CDEs or interested 

lenders to provide the required amount. In such a scenario, the Native CDE 

serving a Native Area by itself or with another Native CDE could take advantage 

of its network of Native CDFI relationships and work with NMTC experts to 

develop a source-lender participation program. The resulting participation 

structure provides: 

● The tribe or Native enterprise with better access to source loan capital 

because the lead Native CDE lender has the expertise to negotiate loan 

security and can provide security for additional non-Native capital through 

intercreditor agreements; and
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 39

● Increased NMTC lending opportunities for Native CDEs and prospective 

CDEs whose portfolio scale precludes them from making direct loans in 

amounts suitable for leverage debt. 

Loan participation arrangements provide each Native lender with some exposure 

and track record, while managing the scale of its loan in the context of its 

portfolio. Loan participation arrangements also build relationships among Native 

CDEs and Investors, and they increase the expertise of non-Native CDEs, lenders, 

and investors in managing Native Area lending issues.

○ Recommendation 3: Native CDEs Can Provide Leverage and/or Source 

Loans to NMTC Project Sponsors.

The Native CDE could provide a loan to the tribe or tribal enterprise serving as 

the project sponsor, either as part of the NMTC structure (as a leverage lender) or 

outside of the NMTC structure (as a source lender). In the latter case, the 

borrower would use the loan proceeds as leverage debt within the NMTC 

transaction. In either scenario, the Native CDE is exposed to the NMTC 

transaction and develops experience in the structuring of NMTC-related 

financing. 

Each of these approaches was addressed as part of the individual technical assistance 

sessions following the technical workshops conducted as part of the NMTC Native 

Initiative. 

3. Unrelated Entities Requirement: The NMTC statute requires the CDFI Fund to give 

priority to applicant CDEs that commit to use 85% (“substantially all”) of their allocation 

to finance unrelated entities. The CDFI Fund awards NMTC applicants five priority 

points in the application if they commit to financing unrelated entities,23 making it very 

difficult to obtain a competitive score without providing that commitment. This 

commitment also becomes a condition of the Allocation Agreement, and Allocatee CDEs 

are measured on compliance with that condition.

Some, if not most, Native CDEs and potential CDEs are created and controlled by 

affiliated tribes that expect to finance projects on their reservation if the CDE receives an 

NMTC allocation. The CDE’s financing of that tribe’s businesses or projects frequently 

constitutes a related party transaction, which precludes the CDE from obtaining the 

application’s 5-point unrelated entity bonus. 

Many tribes do not find the cost and risk of an application worth it when the unrelated 

entity commitment prevents them from financing their own tribally sponsored projects, 

23 “New Markets Tax Credit: Frequently Asked Questions,” CDFI Fund, U.S. Department of the Treasury, 

September 2020, https://www.cdfifund.gov/sites/cdfi/files/documents/nmtc-compliance-monitoring-faq-16sept2020-

final.pdf
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 40

even though many of those projects would provide necessary community or commercial 

goods and services and would not be pursued by non-tribal businesses.

○ Recommendation: Provide More Flexibility for Native CDEs in the 

Definition of Related Entities. 

The CDFI Fund, Internal Revenue Service, and the US Treasury Office of Tax 

Policy should research and determine if there are any flexibilities within the 

NMTC statute and IRS regulations to allow tribally controlled CDEs to finance 

NMTC-eligible projects without the QALICBs and CDEs being viewed as related 

parties. 

Tribal governments are multi-faceted organizations with discrete business units. 

The administrators of the NMTC Program should assess whether the CDFI Fund 

can treat these distinct businesses (e.g., CDE, cultural center, construction firm) as 

separate entities. If it is possible within the statutory framework to treat these 

separate functions as unrelated, then tribally controlled sponsors or QALICBs 

could be treated as unaffiliated third parties relative to a tribally controlled CDE. 

Such separation would allow the CDE to finance the QALICB without violating 

the related entity provision in the allocation agreement, thus enabling the CDE to 

claim the priority points in the application.

4. Insufficient Understanding of Native Issues on the Part of NMTC Allocation 

Application Reviewers: Several interviewees and technical workshop attendees feel that 

the application reviewers are insufficiently educated about the specific nature and 

severity of the challenges affecting Native Areas. As a result, they may not appreciate the 

social and economic dynamics in Native Areas or the importance of the projects being 

described for the tribes and their members.

○ Recommendation: Train NMTC Application Reviewers about Community 

Economic Development in Native Areas. 

The CDFI Fund should provide training for application reviewers about 

community economic development in Native Areas and seek out more reviewers 

with experience in Native Areas. (This suggestion was made in some of the 

interviews as well as in discussions conducted by the research team for the 

Market Research Report.)

5. Perceived Limited Consideration of Qualitative Community Need/Outcomes: 

Interviewees felt that the NMTC Allocation Application’s emphasis on quantifying 

projected community outcomes puts many Native CDE applicants at a disadvantage. 

Many projects in these CDEs’ pipelines do not generate easily quantifiable outcomes (a 

cultural or community center, for instance). The direct quantifiable outcomes also can 

seem small in comparison to those of projects in non-Native Areas.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 41

These respondents indicated that in many cases, the outcomes associated with a Native 

project are more qualitative, indirect, or difficult to quantify. For example, 

● Providing broadband to remote Alaska Native communities enables local residents 

to tap into remote learning opportunities, expand the market for local businesses, 

and generally obtain more exposure to the outside world; and 

● Developing a community center provides an opportunity for tribal members to 

gather for the passing on of oral traditions, and the general strengthening of the 

tribe’s social connections. 

● Developing a child care center frees up parents to take on a job, work more hours, 

and/or pursue their own education. The center helps the children build academic 

and social skills while teaching them about their culture and heritage.

While the importance of remote learning and passing on oral traditions (among other 

outcomes) are not easily quantifiable, they are very important for the tribe’s longer-term 

economic and social sustainability.

A common perception is that applicants must include job generation as a community 

outcome to be scored highly enough to receive an allocation. As illustrated in Part IV 

above, most of the CDEs involved in the case study projects included job figures in their 

project summaries, even if employment was not the project’s primary focus. If job 

generation is selected as an outcome in an NMTC application, it must be quantified and 

compared to objective third-party metrics. While the CDFI Fund’s guidance is clear that 

all community outcomes are viewed equally, this misperception by applicants means some 

CDEs are reluctant to invest in QALICBs that do not have or anticipate creating a 

significant number of high-quality, accessible jobs. Several of the CDEs interviewed 

commented that they likely would not include their selected case study project in a 

prospective NMTC application now because of the projects’ lack of easily quantifiable 

outcomes.

○ Recommendation: Give Greater Weight to Qualitative Project Outcomes in 

the NMTC Allocation Application. 

Virtually all the CDEs and QALICBs interviewed for the case studies noted the 

challenges of relying primarily on quantitative outcomes of Native projects when 

preparing NMTC applications. Many projects in a CDE’s pipeline do not create 

significant numbers of jobs; in fact, some critical infrastructure projects may 

ultimately result in net job losses. Tribal community facility projects may not 

serve large numbers of people due to the low population density of tribes in rural 

areas. Compared to many of the non-Native NMTC projects highlighted in 

allocation applications, the quantitative outcomes of Native projects may seem 

meager. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 42

Incorporating more distinct opportunities for applicants to discuss the qualitative 

outcomes of projects in Native Areas – the importance of providing reliable 

broadband access or the important cultural role of a community center, for 

instance – would allow Native CDEs to make a stronger case for the importance 

of projects for their tribes and communities. There is precedent for this approach; 

previous allocation applications included questions that allowed applicants to 

discuss outcomes not otherwise listed by the CDFI Fund as well as an opportunity 

to talk about longer-term, “spillover” benefits of specific projects. Such questions 

could provide an additional opportunity for the Native CDE to educate unfamiliar 

reviewers about the unique challenges affecting Native Areas, including the 

critical importance of cultural preservation.

B. Regulatory/Programmatic Challenges to Financing Native Projects 

1. Categorization of Native Projects: The CDFI Fund has recently encouraged more 

NMTC financing in Native Areas by making several changes to the NMTC application. 

In the 2017 Round, it identified providing financing to Native Areas as a distinct activity 

under the “innovative investments” section of the application. In the 2021 Round, 

financing Native-controlled businesses became a distinct community outcome, one that is 

different from financing other Minority-controlled businesses. The CDFI Fund also 

included Allocatees investing in a Minority or Native CDE as a new category of 

“innovative investment” in the NMTC Program Application to encourage the Secondary 

CDE strategy described above.

Ironically, some interviewees feel that the changes highlighted above may have resulted 

in less focus on Native projects among non-Native CDEs. When Nativeowned/controlled projects were included within the “Financing Minority-Owned or 

Controlled Businesses” category, organizations felt comfortable selecting the outcome 

because of their general focus on serving disadvantaged communities of color. They did 

not fear the ramifications of not being able to close Native transactions because they 

could “replace” them with Black or Hispanic-controlled projects. By specifically calling 

out Native project financing, the CDFI Fund has forced CDEs to decide whether they will 

deliberately target projects in Native Areas (as opposed to considering those they may 

come across naturally). Unless they already have an infrastructure for identifying, vetting, 

and closing Native projects, organizations may hesitate to assume the risk associated with 

committing to finance Native deals. And without such a commitment, it often proves 

easier to focus on transactions that do not come with the built-in complications of those 

in Native Areas.

○ Recommendation: Do not change the categorization of projects at this time.

While noting the potential unintended consequence of the deliberate targeting of 

Native projects, interviewees also noted the benefit of highlighting and separately 

tracking Native Area and Native Business investments. They believed that over 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 43

time the CDFI Fund’s emphasis on Native projects with separate categorization 

likely will result in greater Native investment. If other recommendations can be 

implemented, such as training in best practices, more lending opportunities, and 

secondary CDE involvement, interviewees believed that the aforementioned 

changes to the application should result in a net increase in investment in Native 

Areas and Native-owned/controlled businesses. 

2. Timing Challenges: To be eligible to receive a subsequent allocation, Allocatees must 

use a certain amount of prior allocations to issue QEIs to investors and make QLICIs 

with the QEI proceeds by a certain date. Yet as described in more detail below, multiple 

factors beyond the control of the CDE can delay the closing of transactions in Native 

Areas. Due to unexpected delays in closing such a transaction, one of the interviewed 

CDEs missed the CDFI Fund’s deadline for closing the required amount of prior 

allocation. It conceivably could have met the threshold by using its allocation for one or 

more non-Native projects but had committed to provide a portion of its allocation to the 

tribe/QALICB. As a result, the CDE was unable to obtain a new/additional allocation to 

finance several other high-impact Native projects in its pipeline. 

○ Recommendation 1: Promote Greater Collaboration Among Federal 

Agencies Involved in Native Area Transactions.

For investors and CDEs, the greatest uncertainty (and thus the greatest risk) 

associated with projects in Native Areas is the timing of land/lease approvals from 

the Bureau of Indian Affairs (BIA). The ability or willingness of the United States 

Department of Agriculture (USDA) and other public agencies to allow their funds 

to be used in NMTC transactions also can be problematic. In some cases, the 

delays result from insufficient understanding of the NMTC Program or 

incompatible regulations. The CDFI Fund could convene representatives from the 

various federal agencies to identify ways to streamline relevant approval 

processes. For example, the BIA might establish a policy for streamlining 

approval of leasehold mortgages for tribally sponsored NMTC projects, and the 

USDA might approve the use of some of its loan program funds to be used as 

leverage debt in NMTC transactions.

o Recommendation 2: Tribes that have not obtained HEARTH Act authority24

to issue commercial leases without BIA approval should consider doing so.

If tribes use this authority, their policy guidelines for lease terms and conditions 

and the requirements of leasehold mortgage provisions should be made available 

to funders early in financing processes. This may help streamline the approval 

process. 

24 The HEARTH Act is described more fully in the subsection related to land issues in Native Areas (Subsection D).
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 44

3. Limited Timeframe to Reimburse Prior-Incurred Costs: Starting with the 2015-2016 

Application Round, Applicant CDEs have been required to commit that if Qualified LowIncome Community Investment (QLICI) proceeds are used to repay or refinance any 

prior expenses: 

i. The QLICI proceeds are used to repay documented reasonable expenditures that 

are directly attributable to the qualified business of the QALICB, and such 

reasonable expenditures were made no more than 24 months prior to the QLICI 

closing date; or 

ii. No more than 5% of the QLICI proceeds are used to repay or refinance prior 

investment in the QALICB. 

The CDFI Fund’s decision to limit the time prior to NMTC closing during which 

expenditures incurred can be reimbursed, sometimes called the “lookback period,”25 to 24 

months has made it difficult for some otherwise eligible Native projects to benefit from 

the NMTC Program. Projects in Native Areas often take longer to close an NMTC 

investment than projects elsewhere in the country, largely due to the various external 

approvals the sponsor must obtain (from BIA, USDA, and/or other agencies). It is not 

uncommon for sponsors to allocate considerable expenditures on a project as much as 

five years prior to closing, simply because of approvals that can take 12 months or more 

to obtain. (This is especially common for projects in Hawaiian Home Lands.) Many of 

these costs are incurred well before the start of the 24-month NMTC “lookback” window.

Predevelopment project funding is challenging to obtain in many areas, but can prove 

especially nettlesome in Native Areas because of difficulty collateralizing the subject 

property (subsequent sections address this further). Many Native Area projects therefore 

rely heavily on grants to cover predevelopment costs. Yet each grant may cover only a 

few costs, or a single step of predevelopment. Only when that step is complete can the 

sponsor apply for another grant for the next step. This funding pattern draws out the time 

needed to get a project to a stage where it can close on third-party financing. Whereas 

projects in areas with greater access to predevelopment capital typically can move to 

closing within two years, Native projects often take 3–5-years.

The current NMTC Program regulations allow NMTC capital to finance already incurred 

project costs, provided they were incurred within 24 months of closing. In effect, the 

project sponsor/QALICB receives loan proceeds that reimburse its expenditures. Since 

expenses incurred prior to the start of the 24-month window cannot be 

25 New Markets Tax Credit Compliance Monitoring and Evaluation Frequently Asked Questions. updated 

December 2022, FAQ #42: https://www.cdfifund.gov/sites/cdfi/files/2022-

12/NMTC_Compliance_Monitoring_FAQ_2022_Final_0.pdf
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 45

covered/reimbursed by an NMTC investment,26 the benefits of NMTC financing cannot 

be optimized in projects with a longer predevelopment period.

○ Recommendation 1: Extend the Prior-Incurred Cost Reimbursement Period. 

Seek public comment about a) extending the cost reimbursement period for which 

incurred costs on Native projects can be reimbursed with a NMTC investment, 

and b) whether there is consensus that this can reduce difficulties for otherwise 

eligible projects located in Native Areas. Such an extension may be warranted 

given the special circumstances surrounding project approvals and the extent to 

which Native Area projects rely on grant funding instead of private 

predevelopment capital.

• Recommendation 2: Work with Other Agencies to Make Other Sources of 

Capital for Native Areas More Compatible with the NMTC Program. 

To the extent possible under Agency statutory constraints, encourage lending and 

guarantor agencies to make their programs more compatible with NMTC 

financing structures, particularly with the leverage loan. For instance, a guarantor 

agency could recognize the Sub-CDE as an eligible lender so that a guarantee 

could attach to a QLICI. This would allow the guaranteed loan to remain in place 

after the NMTC wind-up, which tends to create a significant economic benefit for 

the sponsor.

Alternatively, an Agency could allow a low-cost or guaranteed loan to be used in 

the leverage loan position and be assumable by the sponsor at NMTC wind-up; 

this would allow the sponsor to benefit from the terms of that loan for its 

maximum possible duration. 

Collaboration among lending or guaranteeing agencies to homogenize their 

requirements pertaining to NMTCs would improve capital efficiency and reduce 

complexity.

C. Project Viability Challenges 

Interviewees from both the case studies and the Market Research Report identified common 

obstacles and themes that might appear unrelated in a cursory review but that arise out of the 

similar characteristics of remote, low-population areas. They are:

● Inability to finance adequate infrastructure based on user fees or special assessments 

because low-income people in sparsely populated areas cannot afford the fees necessary 

26 New Markets Tax Credit Compliance Monitoring and Evaluation Frequently Asked Questions. updated 

December 2022, FAQ #44
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 46

to amortize many of the infrastructure project’s costs.27 Communities in which there is a 

higher concentration of development can impose permit fees or systems development 

charges on new projects in order to be reimbursed for the cost of development, or to build 

a fund for anticipated future development costs, for infrastructure such as water, roads, 

power, and wastewater treatment. Most cities have ordinances that schedule fees to be 

imposed based upon a user’s impact on infrastructure systems. Low concentrations of 

development in rural areas also means systems development charges will not accumulate 

quickly enough, or in high enough amounts, to support the cost of needed infrastructure.

● Projects in non-metro areas frequently have increased costs of transportation of materials, 

temporary location of certain skilled workers, mobilization of major equipment, and other 

categories.

● Projects in sparsely populated areas may not have enough patronage revenue to support 

the necessary cost of the facility, such as a health care facility that must have expensive 

imaging equipment and surgical suites but serves fewer patients than a similarly equipped 

urban facility.

● Some operating costs may be higher because of the need for higher wages to attract 

skilled professionals, temporary housing costs, and related expenses.

These issues may not all be present in all the projects, but they can combine to render projects 

infeasible without subsidy. This makes these projects candidates for NMTCs, but can be 

important obstacles to the rest of the financing needed for the project. 

1. Infrastructure

Interviewees from both the case studies and the Market Research Report described how 

many NMTC projects in Native Areas tend to focus on the development or enhancement 

of basic infrastructure. Tribal communities often suffer from inadequate access to socalled horizontal infrastructure, such as roads, broadband, water, and wastewater 

treatment. The NMTC-subsidized capital can help make the development of such 

infrastructure economically feasible in low-income areas where ratepayers alone cannot 

provide enough revenue to meet the necessary debt service. This infrastructure helps 

address immediate needs and has the potential for long-term social and economic 

benefits. 

So-called vertical infrastructure includes facilities that deliver community services, 

including education and health care. Health care facilities often employ many full-time 

individuals who can be hired from within the tribe. The tribal lands typically qualify as 

medically under-served and are often surrounded by similarly under-served rural 

27 See discussion of infrastructure in Community Economic Development in Indian Country: Market Research 

Report, Section 4, Essentials of Community Economic Development.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 47

communities. A new or expanded health care facility can help address the unmet medical 

needs not only of the tribe’s members, but also of other rural residents. 

2. Rural Location Construction Cost Premium

Native and other rural projects often experience higher costs than similar types of 

projects in more urban areas. The remoteness and relative inaccessibility of many Native 

Areas leads to higher construction expenses; it costs more to get machinery, labor, and 

materials to these areas. At the same time, even non-infrastructure projects may require 

the development of some infrastructure like roads, sewers, or rail spurs to be viable. The 

Wa She Shu Travel Plaza in Nevada, for instance, necessitated the construction of onand off-ramps to Route 375. These higher project costs can make it more difficult to 

obtain necessary project financing because project revenues are derived from goods or 

services provided and the market price for those goods or services. Projects become 

unaffordable when debt service costs are added for expensive infrastructure that does not 

contribute directly to generating business revenue. 

3. Rural Location Operating Cost Premium

Remoteness can also increase operating costs, including the cost of retaining qualified 

professional staff. The projects’ geographic remoteness can also hamper operators’ 

ability to find and retain staff. Rural communities frequently suffer from a shortage of 

health care providers (and are designated as “health professional shortage areas” by the 

Federal Department of Health and Human Services). NMTC financing does not 

necessarily address the challenge of attracting and keeping medical professionals, but 

reduced occupancy costs created by real estate subsidies improve net operating income, 

making more cash available for staff. 

4. Low-Population Census Tract Issues

Some Native and rural infrastructure projects can struggle to meet NMTC eligibility 

criteria because they are located in census tracts that have enough middle- or upperincome residents to push their poverty and median income figures over the NMTC 

thresholds. The NMTC Program offers a solution for this problem. Projects that serve, 

employ, or are owned by low-income persons may qualify based on the Targeted 

Population provisions.28 Alaska Growth Capital (AGC) BIDCO has financed multiple 

broadband projects to bring higher-speed internet access to Alaskan Native communities. 

Connecting these communities to the provider’s existing network has involved laying 

cable across multiple geographies – both land and water. Not only has Alaska Growth 

Capital (AGC) BIDCO had to determine which census tracts encompass the ocean areas, 

28

 Final Regulations for Targeted Populations, Internal Revenue Service: 

https://www.cdfifund.gov/sites/cdfi/files/documents/nmtc_irs-federal-register-120511.pdf
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 48

but it also ensured that its NMTC capital went to areas that are within NMTC-eligible 

tracts or the project can be documented as serving Targeted Population. 

● Best Practice: Sponsors Must Use Conventional Debt Underwriting 

Standards to Ensure the Project Can Meet Basic Lending and NMTC

Program Underwriting Principles and Criteria. 

NMTC financing is generally delivered in Qualified Low-Income Community 

Investment(s) (QLICIs) that are structured as debt. Since grants are not an eligible 

form of QLICI, they must be either debt or equity. Nonprofit QALICBs cannot 

accept equity because they are not owned by shareholders, and many tribal 

sponsors decline to have non-tribal shareholders or equity partners in their forprofit ventures. CDEs and their tax credit equity investors have the regulatory 

benefit of the so-called Reasonable Expectations Test if the CDE holds less than 

30% equity in the QALICB.29 The Reasonable Expectations Test is an important 

element of an NMTC closing because it may be used to protect the investor from 

recapture of the value of the tax credits by the IRS, in some circumstances.

For these and other business reasons, most QLICIs are structured as debt and not 

equity. This means the transactions must meet IRS requirements to be 

characterized as debt, which include conventional underwriting standards. Thus, 

project sponsors will be asked to provide construction, financial, property title and 

related information, and tenant information if applicable, just as they would for a 

conventional lender. 

Before engaging with a lender, the sponsor should evaluate the project’s operating 

costs and likely revenue stream to determine whether its revenue supports at least 

a 1.25 Debt Service Coverage Ratio.30 If it does not, consider other resources that 

might be brought to bear for the project. Create a financing strategy that is likely 

to result in successful operations and creditworthiness, and gain preliminary 

internal approval for that strategy. 

Identify assets or resources that can help secure the requested loan. These could 

be leasehold mortgages or pledges of revenue. Such security is essential to assure 

a lender that resources are available to resolve its debt if the business or activity 

should have a revenue shortfall. Another alternative, though usually not preferred 

29 IRC Section 45D(d)(2) sets forth the tests for the borrower to be a QALICB; generally, if any of these tests is not 

satisfied during the compliance period, the borrower will fail to be a QALICB. Section 1.45D-1(d)(6)(i) of the 

Treasury Regulations (Treas. Reg.) sets forth an exception to this general rule (the reasonable expectations test) and, 

subject to certain control prohibitions, generally provides that if the CDE reasonably expects that the borrower will 

remain a QALICB during the period the QLICI remains outstanding, the borrower will be treated as a QALICB even 

if the borrower later fails the QALICB status tests. 

30 Debt Service Coverage Ratio: A measurement used to decide whether a person, company, or country can afford to 

pay back a loan, calculated by dividing the income that is available by the total amount of payments owed each year 

for the loan. https://dictionary.cambridge.org/us/dictionary/english/debt-coverage-ratio
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 49

or in some cases even acceptable to a tribe, is a general guarantee of the loan 

principal.

Avoid burdening projects with excessive off-site infrastructure costs. Consider 

adopting a Systems Development Charges Reimbursement methodology that 

apportions infrastructure costs based on a specific project’s projected burdens on 

infrastructure, not on overall community infrastructure needs. In such cases, costs 

for infrastructure can be advanced by the project if possible, or if not possible by 

the tribe, and reimbursed from the systems development charges paid by future 

projects. Such a plan would likely require an ordinance or statute specifying the 

methodology.

Determine if the project is located in an NMTC Qualifying Census Tract, or 

Distressed Census Tract, or that it will serve a Targeted Population and that 

service can be documented.

● Best Practice: Utilize Targeted Populations as an Alternative to Census Tract 

Qualification. 

Per the NMTC Program Allocation Application and as defined in 12 U.S.C. 

4702(20) and 12 C.F.R. 1805.201, the term “Targeted Population,” means 

individuals, or an identifiable group of individuals, including an Indian Tribe, 

who A. are Low-Income Persons; or B. otherwise lack adequate access to loans or 

investments.31 When a census tract does not in itself qualify for use of NMTCs, 

the project may still qualify if it is:

● At least 50% owned by low-income persons; 

● At least 40% of the projects’ employees are low-income persons at the 

time of hire; or 

● At least 50% of the projects’ gross income is derived from sales, rentals, 

services, or other transactions to customers who are low-income persons,32

as in the case of the Maniilaq Nursing Home.

D. Land Issues

In discussions with Community Development Entities (CDEs), interviewees noted numerous

land-related obstacles to obtaining financing. NMTC and other financing for tribal business 

creation and economic development efforts is made more complicated because the tribe is the 

landlord and, in many cases, cannot consent to alienation of the land, so the only mortgage-type 

security available is a leasehold mortgage. Bureau of Indian Affairs (BIA) regulations generally 

limit commercial leases to twenty-five years with extensions or renewals, whereas the Helping 

31 NMTC Program 2022 Allocation Application. https://www.cdfifund.gov/sites/cdfi/files/2022-

11/CY_2022_NMTC_Program_Application.pdf

32 Ibid.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 50

Expedite and Advance Responsible Tribal Home Ownership (HEARTH) Act allows for 75-year 

terms.33, 34, 35

Sponsors of projects on Hawaiian Home Lands have to navigate a different process. An 

interviewee described how sponsors seeking to finance a project within these lands must submit 

a homestead development plan to the Department of Hawaiian Home Lands. Department 

officials must approve the project as benefiting Native Hawaiian organizations and communities 

and then approve a sub-lease to the actual project/Qualified Active Low-Income Community 

Business (QALICB). In effect, an entity such as the West Hawaii Community Health Center, a 

nonprofit whose purpose is to serve Native Hawaiians, is treated as a guest on the Hawaiian 

Home Lands, subject to a costly and months-long approval process.

The complexity of land ownership structures is another land-related challenge making it difficult 

to use reservation land as mortgage collateral, and insufficient commercial codes can create 

uncertain circumstances for loan defaults.36 Tribes in rural areas may have difficulty establishing 

adequate water, wastewater, power, transportation, and other infrastructure to support industrial 

development.

Not all territory within Native lands is held in trust for tribes, however, as most reservations are a 

patchwork of trust and fee lands. Crain Manufacturing, a non-tribal entity operating in Choctaw 

territory, owned the land on which its facility was located. Similarly, the Makah Pier in Neah 

Bay, WA serves and benefits the Makah Tribe, but it is not technically located on Makah-owned 

land. About 90% of the students at the Minnewaukan Public School in North Dakota are 

members of local tribes, but the school itself is owned and operated by the Minnewaukan Public 

School District. Each interviewee noted that projects located on fee simple land as opposed to 

tribal trust land typically move forward much more quickly, simply because there is no need to 

obtain the approval of the public trustees of the land. In the case of the Minnewaukan Public 

School, the Minnewaukan Public School District already had a well-established process for 

borrowing money for capital improvements. It also had assets (including designated tax 

revenues) that it could pledge as collateral.

The requirement for Bureau of Indian Affairs (BIA) or similar agency approval injects a degree 

of uncertainty into the NMTC closing process that can dissuade investors and Community 

Development Entities (CDEs) from financing Native projects. Even when the approval is 

relatively smooth, the wait can add months to the closing process. Coupled with the need for the 

various attorneys in the transaction to review the various tribal and agency documents, the 

33 “Business Leasing on Indian Lands Handbook,” Bureau of Indian Affairs, September 30, 2021, 

https://www.bia.gov/sites/default/files/dup/assets/public/raca/handbook/pdf/52%20IAM%2014-

H_Business%20Leasing%20Handbook_FINAL_signed_w.footer_508.pdf. 

34 “Indian Affairs approves three Tribal Nations’ HEARTH Act regs,” Bureau of Indian Affairs, U.S. Department of 

the Interior, February 25, 2022, https://www.bia.gov/news/indian-affairs-approves-three-tribal-nations-hearth-actregs.

35 Community Economic Development in Indian Country: Market Research Report, p. 23.

36 Community Economic Development in Indian Country: Market Research Report, p. 19.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 51

process could, in some cases, add up to 10% to the overall project cost. CDEs providing 

financing to projects on tribal trust lands and Hawaiian Home Lands should add time to the 

closing process for these issues, or verify that they have been addressed prior to closing. 

● Best Practice: Tribe Facilitates Access to Leasehold Mortgage Security. 

Some tribes have Helping Expedite and Advance Responsible Tribal Home Ownership 

(HEARTH) Act authorization.37 This allows them to enter into commercial or residential 

leases of lands held in trust by the Bureau of Indian Affairs (BIA) without the need for 

the BIA’s individual review and approval. Other tribes must take each transaction to the 

BIA for approval. In concept, tribes with HEARTH Act authority are able to act more 

quickly, though internal tribal governance and decision-making may render the approval 

process as slow and unpredictable (or even more so) than the BIA approval process. 

When obtaining HEARTH Act authorization is feasible and appropriate, tribes should do 

so and streamline their internal review process and develop specific policies regarding 

risk management, key business terms, and leasehold mortgagee protection provisions. 

Tribes that elect not to pursue HEARTH Act authority should prepare guidelines for nontribal participants that inform them of the process, timeframes, and requirements for tribal 

and BIA approval of a leasehold mortgage.

E. Project Collateral 

Case study interviewees noted that some tribes or tribally sponsored projects have difficulty 

meeting lenders’ requirements for collateral, such as a first position trust deed on land, because 

of either the trust status of land and/or the inability of tribes to offer guarantees. Since most 

NMTC transactions involve the financing of real estate development, lenders typically rely on 

the financed property as the primary source of collateral. To the extent additional security is 

needed, the lender will try to take a lien on other assets of the sponsor/Qualified Active LowIncome Community Business (QALICB) and/or rely on any available guarantees. 

Collateralizing developments in non-metropolitan areas can be challenging simply because of the 

difficulty of defining rural land values. The relative paucity of transactions in sparsely populated 

areas makes it challenging to obtain accurate appraisals, and relatively low economic activity 

likely impairs the value of real estate as collateral because redeployment of the premises to 

another owner or occupant is less certain than it is in a more robust commercial market. CDEs 

and investors consequently look to augment any underlying real estate with other assets to help 

protect themselves against capital loss. 

Tax credit investors generally determine their return on their NMTC equity investment based on 

the “price” they pay for the tax credits - i.e., the amount of equity they invest for the value of the 

37  Helping Expedite and Advance Responsible Tribal Home Ownership Act of 2012 (HEARTH Act), 126 Stat 

1150, Pub. L. 112–151 (July 30, 2012). https://www.congress.gov/112/plaws/publ151/PLAW-112publ151.pdf
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 52

credits received. Most tax credit investors ultimately sell, or “put” their equity interest to the 

QALICB or one of its affiliates. As a result, the collateral issue is most acute for the leverage 

lender(s) in the NMTC structure because its debt is unlikely to be fully amortized during the 

seven-year compliance period. This means the leverage lender must underwrite the project and 

its sponsor to be creditworthy and able to pay or refinance the leverage debt at the end of the 

compliance period.38

While each transaction presents different underwriting facts or sources of funds for leverage 

debt, the overall summary is that to obtain third-party capital, project sponsors must have a 

sustained revenue stream sufficient to pay off the loan, whether that revenue comes from the 

project, the tribe itself, or some other business venture in control of the tribe. The typical 

workaround has involved the tribe and/or the project sponsor providing the leverage loan and 

assuming the risk of repayment. Some capital available to tribes cannot be used for leverage 

debt. Other solutions might include a master-lease of the facility by the tribe, which sub-leases to 

the operating business/sponsor. In that scenario, the tribe’s capacity to make the master lease 

payments becomes the credit underwriting question.

One interviewee who served as an underwriter for a large bank for several years noted that, in 

her experience, there are few leverage lenders to tribes who require repayment. Most of the 

leverage debt comes from unsecured tribal capital. Project underwriting consequently involves 

taking a very close look at a tribe’s balance sheet and financial experience. 

If the tribe cannot provide the leverage debt, the most likely source(s) of such financing tends to 

be CDFI or other bank loans backed by various public guarantees. One attorney who has helped 

close dozens of Native NMTC transactions noted the creativity with which people have secured 

their leverage loans. Several entities have taken advantage of U.S Department of Agriculture 

(USDA) guarantees. 

For example, Clearinghouse CDFI took advantage of the Washoe Tribe’s standing as both a 

California and Nevada tribe to make a leverage loan in the Wa She Shu Travel Plaza transaction. 

It collateralized its $5.4 million leverage loan with a lien against future revenues the Washoe 

were due from the Reserve Sharing Trust Fund, a California program that uses some of the 

earnings from gaming tribes to subsidize tribes not involved in the gaming industry. The Navajo 

Tribal Utility Authority provides utilities to most of the Navajo Nation and has an effective 

monopoly. This created a secure and predictable revenue stream that could be pledged as 

security, similar to the way in which proceeds from infrastructure fees can be pledged to 

bondholders in a revenue bond transaction. Both of these are innovative solutions for the 

leverage loan. 

● Best Practice: Tribal Sponsors Should Identify and Develop Processes for

Enforceable and Adequately Secured Promissory Notes and Loan Agreements.

38 See: GAO-10-334 New Markets Tax Credits, pp 15 - 19, January 2010
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 53

Each tribe’s statutes and practices may be different. For instance, some tribes require 

legislative or tribal council approval for contracts or borrowings in excess of set 

thresholds. Tribes may have different thresholds for which approval is required. Some 

may vest general authority with the executive to act, provided the action is within the 

approved budget. 

It is critical for tribal governments and their project sponsors to inform and provide 

guidance to the CDE, lender and investor early in the transaction negotiation process, so 

the capital provider team understands the steps and timing necessary for an enforceable 

agreement.

F. Uncertainty Surrounding Tribal Corporations

There remains uncertainty within the NMTC industry regarding the eligibility of tribal 

corporations as Qualified Active Low-Income Community Businesses (QALICBs). While some 

do not see an issue, many NMTC attorneys have opted to eliminate any doubt by requiring 

sponsors of Native projects to create limited liability companies or other entities organized under 

the respective state law. Not only does the process undermine tribal sovereignty, but it also adds 

additional time and costs to the transaction. In addition to creating and incorporating the state 

law entity, attorneys may need to negotiate an agreement/structure in which the tribal entity 

leases from the QALICBs to achieve the desired outcomes. In the case of the Makah Tribe’s 

commercial fishing dock project, for instance, the tribal entity leased from the special-purpose 

entity created to be the QALICB. The tribe used the revenues from the pier to make the lease 

payments, which in turn were passed through to the CDE and the leveraged investment fund. 

● Recommendation: Participants Should Work with Treasury/IRS to Prioritize 

Creating Greater Clarity Regarding the Eligibility of Tribal Corporations to be 

QALICBs. 

The IRS - and the CDFI Fund, to the extent it is willing and able - should work to clarify 

whether and in what circumstances tribal corporations can be eligible QALICBs. Once 

the IRS has ruled, the CDFI Fund should publicize that ruling in printed guidance.

G. Sovereign Immunity

Tribes and tribal nations are sovereign governments subject to their own sets of laws and dispute 

resolution processes.39 Investors and many Community Development Entities (CDEs) are 

uncomfortable financing projects within Native lands that are subject primarily to tribal or 

Native laws, requiring instead that any conflicts be resolved under existing state law and judicial 

systems. This typically requires the project sponsors and the supporting tribe to waive their 

sovereign immunity with respect to the specific transaction and agree to be subject to state law.

39 Market Research Report, p. 28
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 54

Such an outcome, while common, creates resentment among many tribal members. For example, 

representatives from the Navajo Nation wanted any issues associated with the Navajo Tribal 

Utility Authority project to be resolved in the Navajo Nation’s tribal courts, not state courts in 

New Mexico; the Nation finally acquiesced after extensive internal debate. One interviewee who 

works at a CDE that has financed several Native projects acknowledged that the limited waiver 

of sovereign immunity “flies immediately in the tribe’s face” and can have a negative impact on 

the tribe’s sense of identity. The interviewee recognized the unwillingness of lenders and 

investors to be subject to legal systems with which they are unfamiliar. Another interviewee 

similarly described the inherent sensitivity of the issue. The interviewee emphasized the 

importance of being respectful to the tribe while still meeting the lending thresholds of 

fundamentally conservative bank investors.

Negotiating the limited waiver of sovereign immunity can take time and add both costs and 

delays to a project in a Native Area. For many interviewees, the process underscores the 

importance of ensuring that the project has strong support within the tribe and clearly addresses 

an identified need. That helps justify the means of reaching the desired end. Interviewees also 

emphasized the importance of building trust and understanding with key tribal members and 

program staff through open and ongoing dialogue and education about the project and the NMTC 

process.

● Best Practice: Tribes Consider Limited Waivers of Sovereign Immunity. 

Sovereign immunity is a critical issue for most tribes because respect for their 

sovereignty acknowledges their status as a governmental entity separate from that of the 

United States. Such sovereignty is foundational to their identity as tribes and sovereign 

nations. Yet, a lender needs to be able to recoup its debt, and if it is unable to bring suit to 

collect on a defaulted loan, it has no way of enforcing its promissory note. This can 

dissuade lenders from working in Native Areas and severely limit these areas’ access to 

outside capital. 

The solution is for the tribe to select specific assets and revenues that may be subject to 

collection, and then to craft a limited waiver of sovereign immunity that applies only to 

those specified assets and revenue the tribe is willing to place at risk for purposes of the 

project or activity. Ideally, the tribal government will adopt policies in advance that guide 

its risk management, negotiation, and implementation of transactions involving outside 

financing.

H. Understanding NMTC Regulations and CDE Requirements

Interviewees for this report and the Market Research Report noted that NMTC transactions tend 

to be complicated, with multiple sources of capital common in transactions. As a federal tax 

credit program, it carries potentially severe financial penalties if one or more of the parties 

violates program regulations. Even the most efficient closing processes take months to perform 

due diligence, obtain legal opinions, and negotiate the approvals necessary to satisfy the various 

parties. 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 55

The intricacies and logistics of the NMTC - and the accompanying IRS regulations - have 

generated an entire sub-industry of accounting, legal, and other specialists. Even the most 

frequent users of or participants in the program often rely on outside experts to help them 

negotiate specific transactions. It is not surprising, therefore, that tribes with comparatively little 

exposure to the program frequently take longer to understand the program’s nomenclature, 

regulations, and compliance issues.

Staff turnover within tribes and their economic development departments can widen the 

knowledge gap. With smaller entities in particular, as well as those with limited engagement in 

the program, the loss of a key staff member or two can eliminate much of the institutional 

memory and knowledge about the NMTC Program. Such a scenario played out with the Washoe 

Tribe of Nevada and California. The new director of the Washoe Development Corporation, who 

had no previous experience in the NMTC Program, had to educate herself and others about not 

only the program’s nuances, but also the particular methods employed or approaches taken in the 

structuring and closing of the Wa She Shu Travel Plaza. She described the recent unwinding of 

the transaction at the end of its 7-year compliance period as “hellacious,” largely due to a lack of 

institutional memory or clear documentation around how the transaction had been structured by 

previous leadership and the reasoning for their decisions. 

Similarly, there has been considerable confusion about the exit fees associated with the Maniilaq 

Health Center project in Alaska. These experiences are far from unique. Several other 

interviewees noted the wide variation in staff capacity among tribal economic development 

officials and NMTC Program sponsors. In many cases, projects are driven largely by outsiders, 

with the tribal members being relative bystanders in the process. Key tribal officials were 

presented with documents to sign but they did not have an in-depth understanding of the 

rationale and ramifications associated with some of the agreements. 

● Best Practice: Tribal Sponsors and Potential CDE Applicants Should Evaluate the 

Cost and Benefit of Engaging NMTC Experts.

Because most Qualified Active Low-Income Community Businesses (QALICBs) and 

project sponsors are one-time users of the NMTC Program, they frequently come to the 

process with little (if any) experience closing NMTC transactions and face a steep 

learning curve. 

These realities underscore the potential benefit of taking advantage of outside NMTC 

expertise. Several experienced project consultants, attorneys, and accountants active in 

the NMTC field have particular expertise in helping to shepherd Native-sponsored 

projects to completion. Engaging legal counsel that is familiar with both the NMTC 

Program and some of the nuances of tribal law proves especially helpful in negotiating 

issues of sovereign immunity and lender loan security. Project consultants can prove 

invaluable in helping sponsors structure transactions and identify CDEs and leverage 

lenders to finance them. It should also be noted that fees charged and scope of services 

provided by these experts and consultants span a wide range. Some Native CDFIs and 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 56

CDEs have experience with the NMTC Program and can be resources themselves or in 

making referrals. 

Native CDEs and potential CDEs considering applying for their own certification and/or 

allocation would be well-served to interview qualified service providers to form their 

optimal team of advisors.

I. Tribal Politics 

Several of the Community Development Entity (CDE) staff members interviewed in the case 

studies noted the importance of face-to-face connections when working with Native 

communities, as well as the value of working with someone familiar with the community and 

Native Area. Facilitating understanding among all of the parties involved, including new 

leadership, is important to keep the project moving forward and meeting the various deadlines 

involved.

Changes in tribal leadership – through elections or other transitions – can delay the closing of 

NMTC transactions in Native Areas. The new leadership may not understand the NMTC 

Program and the steps necessary to attract investment capital. They may not be as supportive of 

these steps – or even the project itself – as the previous administration. The need to work through 

such internal politics delayed several of the case study projects. Timing is important to the 

NMTC process at every step, from meeting application deadlines to the seasonal nature of 

construction projects, and changes in governance can lead to a lack of synchronization between 

parties. 

Tribal approval processes are not homogenous. Some have centralized project approvals, others 

require local community approval before the project will be considered, or approval by an entire 

Tribal Council or legislature. 

The CDE for the Makah commercial fishing dock project has not experienced any significant 

local political differences in its Native and non-Native transactions. Several interviewees noted 

that a project’s location on tribal or Native lands may actually speed up some of the permitting 

and other approvals required for closing because these approvals are in the control of the tribe. 

The authority for such approvals tends to be more centralized within a tribal sovereign nation 

than in a non-tribal jurisdiction.

● Best Practice 1: Cohesive Tribal Governance and Economic Development 

Strategies.

Tribal project sponsors need to address the context in which a project or activity is 

proposed to demonstrate the need for the proposed community outcomes. Context may 

include political support for a comprehensive economic and community development 

plan, studies or assessments that demonstrate the need to be filled by the project, or a 

shared vision among several agencies or departments within tribal government. 

Regardless of the mechanics of establishing a shared vision in support of the project, that 

vision is an important predicate because many tribes (and non-tribal governments) take 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 57

too much time to come to agreement about the need for, scope, design, and goals of a 

project if those issues are examined for the first time when project approval is requested.

In his keynote comments for the first NMTC Native Initiative Technical Workshop, 

Chairman John A. Barrett of the Citizen Potawatomi Nation discussed this as both a 

strategic-level and tactical-level issue for tribal governments looking to promote 

economic development. He explained the importance of reviewing projects in the context 

of an economic and community development strategy that has political approval, as he 

experienced first-hand the political dysfunction that can cause difficulty not only in 

making decisions but also in implementing them.

Chairman Barrett indicated that his solution 30 years ago was to create a constitutional 

government, with a clear separation of authority among the Legislative, Executive, and 

Judicial branches within the Citizen Potawatomi Nation. This structure solidified the 

roles and responsibilities of each branch and prevented overlapping authority that had 

created conflicting or unpredictable outcomes. He credits this governing structure as the 

fundamental step that enabled Citizen Potawatomi Nation to grow. The tribe now has 

more than $2 billion in assets, employs more than 2,500 people (the most of any entity in 

its region), and generates more than $600 million in economic activity each year. Citizen 

Potawatomi Nation owns and operates several businesses, including medical clinics, 

banks, grocery stores, other retailers, entertainment venues, a water treatment plant, and 

manufacturing facilities. It operates the largest non-depository Native-owned CDFI in the 

country. 

This record of economic and community development results from a cohesive strategy 

that has been systematically implemented. Among the key components of the Citizen 

Potawatomi structure are:

1. Stable and reliable government decision-making processes 

2. Institutionalized core financial management skills and practices, such as 

legislative and executive agreement about the circumstances under which limited 

waivers of sovereign immunity are to be granted, appropriate HEARTH Act 

authorizations, and risk management 

3. Political agreement on the following goals and principles of a long-term economic 

development strategy:

a. A diverse economy made up of employers requiring entry-level, unskilled, 

skilled, and professional workers in retail, commercial, manufacturing, 

and service businesses;

b. Access to appropriate workforce training;

c. Adequate infrastructure;
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 58

d. Availability of capital for business growth and individual credit needs;

e. A concentration of qualified resident workers and consumers to support 

local businesses, supported by adequate housing stock and community 

amenities (schools, grocery, pharmacy, medical, recreation, etc.); 

f. Availability of a variety of goods and services to attract visitors; and

g. An economy in which capital revolves twice or more locally before going 

outside.

This strategy combines preparedness for capital with prioritization in the use of capital.

Such governing practices must be institutionalized so that they are clear, widely 

understood, and replicable. Ideally, the responsible governing body (legislative or 

executive) should publish them in adopted economic and community development plans, 

third-party leasing policies or guidelines, policies regarding limited waiver of sovereign 

immunity, and similar related documents. 

● Best Practice 2: Determine Acceptable Practices Regarding Choice of Venue and 

Applicable Law; Establish These Policies Before Working with Third-Party 

Lenders. 

Some non-tribal capital providers (lenders, NMTC participants, or grant providers) will 

be unfamiliar with tribal courts or laws. Their comfort about having an enforceable 

contract likely will depend upon their understanding of how the contract would be 

interpreted and enforced. Non-tribal capital providers are typically more comfortable 

with transactions governed under non-tribal law, in a court with which they have 

experience. Tribes that are willing to consent to transactions being subject to federal 

jurisdiction and applicable state laws generally find it easier to attract outside capital. 

Some tribes require exhaustion of tribal remedies before federal jurisdiction is available. 

It is quite helpful to non-tribal capital providers, developers, and project sponsors for 

tribes to resolve these issues internally before a project or financial relationship is 

presented, and to be able to inform non-tribal participants of the tribe’s expectations.

J. Lender Familiarity with Native Areas

There are relatively few non-Native CDEs that have consistently received allocations and have 

deliberately focused on serving Native Areas and Indian Country at large. Clearinghouse CDFI, 

Dakotas America, Rural Enterprises of Oklahoma (REI), Travois, and Ecotrust were among the 

CDEs that interviewees mentioned in this category. Many CDEs do not have Native Areas 

within their market footprints, lack the experience identifying and closing transactions in these 

areas, and/or do not have the capacity or willingness to negotiate Native-specific issues. One 

longtime consultant for various tribes considers one of their missions to increase the number of 

CDEs willing to take on Native transactions.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 59

Similarly, there are relatively few large national or regional banks that have a track record of 

actively investing in Native Areas through the NMTC Program. CDEs providing NMTCs in 

Native Areas identified Wells Fargo and US Bank are the two largest and most active Native 

NMTC investors. Wells Fargo has become comfortable with these transactions largely because it 

has a Native lending group within the bank. Even with that experience, the bank utilizes outside 

counsel to navigate tribal governance and lien issues – a requirement that adds transaction costs 

to the project.

Despite the additional transaction costs, neither bank prices its tax credit for higher income from 

Native projects. US Bank may give such projects a somewhat higher priority internally because 

of their ability to address needs in severely distressed communities. Wells Fargo also gives 

Native projects extra points in its internal selection scoring system, in large part because the 

projects enable the bank to meet its rural and minority business commitments. Wells Fargo has 

even offered slightly better pricing to Native projects as a way of building its brand in Native 

Areas and generating positive public relations.

Project approvals and other key decisions may not be as predictable to non-tribal lenders 

working in Native Areas because Native governments frequently add cultural impacts into their 

analysis. While tribal governments work towards economic growth, they are also focused on 

preserving tribal culture, identity, sovereignty, population, and land, creating a unique balance of 

priorities that is distinct from other rural communities. All components of community economic 

development in Native Areas are also considered through a cultural lens by tribal actors, helping 

to explain some of the economic decisions made by tribal governments. For example, many 

tribes might make an active choice to avoid developing or exploiting their natural resources, such 

as minerals, water, or forests, for economic gain. They may choose to site a project in a less 

favorable location because of cultural values related to an alternative site. While natural 

resources are a common economic resource for most rural areas, land itself, in its unspoiled state, 

often holds significant historical, cultural, and spiritual meaning for tribes. Therefore, the 

appropriate choice for a tribe might be to preserve the land rather than site a project in a 

particular location, or develop its resources for economic growth. Tribes might also decide to 

invest resources into acquiring more land, especially land of historic significance, rather than 

investing in other economic ventures.40

Those interested in partnering on projects in Native Areas can benefit from enhanced cultural 

understanding. When surveyed, Native American nonprofit leaders stressed the desire for 

funders and foundations to have already conducted background research before establishing 

relationships, so that connections are cultivated based on deepened understanding of the specific

community.41 Outreach to Native tribes needs to be consistent and thorough while 

40 Community Economic Development in Indian Country: Market Research Report, p. 90.

41 Ellie Buteau, Hannah Martin, and Katarina Malmgren, “Overlooked (Part Two): Foundation Support for Native 

American Leaders and Communities,” Center for Effective Philanthropy, 2021, 

http://cep.org/wp-content/uploads/2021/07/CEP_Overlooked_Native_American.pdf. (Cited in Community 

Economic Development in Indian Country: Market Research Report, p. 91.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 60

acknowledging the wide perspectives and unique experiences and complexities of each tribe and 

community.

● Recommendation: Lenders Serving Native Areas Can Take Steps to Facilitate 

Better Relationships with Native Entities.

The discussion above focuses on steps tribal governments and project sponsors can take 

to improve their access to outside capital. Yet capital provision is a two-way street, and 

the findings from the Market Research Report, case studies, and the Technical 

Workshops completed within the scope of the NMTC Native Initiative project clearly 

demonstrate that lenders themselves can benefit from adjustments to their practices with 

improved transaction efficiency and tribal relationships. Developing such practices and 

relationships can help the financial institutions better address the capital needs of underserved parts of their market, generate additional business, and enhance their Community 

Reinvestment Act activities.

Each of the country’s 574 federally recognized tribes is a distinct government. Each 

represents a people with its own history and culture. While many tribes may have 

similarities, and there are a few common characteristics and issues such as BIA 

relationships and sovereign immunity, the tribes are far from homogeneous. 

Just as lenders develop general expertise in dealing with other groups of borrowers –

there are common underwriting practices within specific asset classes such as 

manufacturing or multifamily housing, for instance – they can develop elements of 

general expertise with respect to tribes. To the extent that expertise can be 

institutionalized into common practices, it is likely to result in streamlined transactions. 

At the same time, the unique aspects of each tribe require an investment in relationship 

building that lenders should not ignore or undervalue. 

There are a limited number of non-tribal CDEs and investors that consistently work with 

tribes in the NMTC Program. Expanding the number of such entities – and thus 

expanding the availability of NMTC capital for Native projects – requires that these 

currently active lenders and investors institutionalize and highlight their effective 

practices. They need to be able to describe their underwriting and loan security needs 

succinctly, with appropriate respect for the larger context of dealing with a sovereign 

government. The most effective CDEs and investors: 

1. Recognize that there are cultural and governmental issues, not just contractual 

issues, which require an investment of time and respect if the lender is to work 

successfully with a tribe.

2. State their expectations clearly and early in a transaction to build trust and assure 

a smooth closing.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 61

3. Do not assume that a method or contractual outcome that worked for one tribe 

will be completely transferable to another tribe. Inquire early in the relationship 

about approval and other processes, agree on steps and timelines.

4. Invest in tribal specialists whose expertise can support their colleagues’ lending to 

tribes.

5. Institutionalize lending practices to streamline:

a. standard documents for leasehold security on trust lands, 

b. acceptable waivers of sovereign immunity for various types of contracts, 

c. underwriting tribal governments with their unique distribution of revenues 

among grants, tribal businesses, gaming, and other sources;

d. approvals of venue and choice-of-law provisions;

e. form and extent of tribal guarantees;

f. alternative security, such as pledges of discrete revenue streams in lieu of 

real property security;

g. travel authorization for personnel working with tribes to make site visits; 

and

h. authority for local bankers to consider creative solutions, such as master 

tenancy in lieu of tribal guarantees. 

K. NMTC Native Set-Aside

In the interviews conducted as part of the case studies and during preparation of the Market 

Research Report, as well as in discussions taking place during the Technical Workshops and the 

Individual Training Sessions, participants discussed the various challenges and barriers to 

increasing NMTC investments in Native Areas with allocations provided to Nativeowned/controlled CDEs and Native-serving CDEs. Interviewees noted that a Native set-aside 

could serve as one step toward ensuring that a minimum amount of NMTC investments are 

directed to Native Areas each year. A set-aside refers to the statutory dedication of a specific 

amount of NMTC allocation to projects within Native Areas and/or involving Native 

organizations.

Interviewees acknowledged that a Native set-aside had been addressed and requested in the past 

by Native and Native-serving organizations. They noted that another example of a type of 

NMTC set-aside already exists with respect to non-metropolitan counties (also known as the 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 62

Rural Set-Aside).42 They also recognized that the specific details of and goals for any Native setaside would need to be discussed and resolved by tribal and non-tribal Native-serving 

organizations prior to consideration and adoption by Congress. This would ensure that the 

impacts of the changes in statutory language are appropriately targeted in terms of geography, 

the key tribal and non-tribal participants in projects, and other desired outcomes, such as 

improved access to capital for tribes, expanding relationships with third-party lenders, and 

improving the capacity of Native-owned/controlled CDFIs and CDEs.

Since only Congress can make changes to statutory language though the legislative process, 

these findings are provided to ensure that the research team serves as faithful reporters of the 

information and opinions shared with them by interviewees understanding that this report and 

other project deliverables will likely be shared with and viewed by a wider audience. 

Several interviewees for this project and other Native organizations have requested that Congress 

create a Native set-aside within the NMTC Program, and the research team has included this 

recommendation to report their input. However, it would not be appropriate for the research team 

to opine that Congress create a set aside.

42 The language of the statute does not actually set aside a specific amount of allocation, rather it requires that “nonmetropolitan counties receive a proportional allocation of qualified equity investments.” 26 U.S. Code § 45D(i): 

https://www.law.cornell.edu/definitions/uscode.php?width=840&height=800&iframe=true&def_id=26-USC375442294-

332392142&term_occur=999&term_src=title:26:subtitle:A:chapter:1:subchapter:A:part:IV:subpart:D:section:45D
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 63

VI. Conclusion

Overall, this report uses case study analysis (along with conversations with other knowledgeable 

sources) to examine the use of NMTC financing in Native Area projects, while describing 

challenges and obstacles that were overcome in those projects. The solutions present best 

practices and recommendations that can be applied to other Native Area projects. Interviewees 

also discussed policy obstacles, and in several cases, made recommendations about how policies 

might be revisited to improve availability, relevance, or efficiency of NMTCs for Nativeowned/controlled projects, and those in Native Areas.

The NMTC Program has provided a total of 225 Qualified Low-Income Community Investments 

(QLICIs) and $1.8 billion in NMTC investment across 149 unique projects from 2003 to 2020 in 

Native Areas. By continuing to address the identified challenges and adopting the recommended 

strategies, stakeholders can unlock greater opportunities for economic development and 

improved quality of life in Native Areas. This report serves as a valuable resource for NMTC 

policymakers, community leaders, and stakeholders to help increase NMTC investment in Native 

Areas across the United States.
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 64

Appendix A: Case Study Survey and Interview Guide

The following pages show the questions asked in the online survey and interviews with 

representatives of the CDEs associated with the case studies. The bulk of survey and interview 

responses received were from CDE representatives as opposed to other key participants.

a. Survey Script: CDE

1. How did your CDE become aware of this project? (Was your CDE already connected to 

the QALICB or project sponsor or were you connected for the first time at the beginning 

of this project?)

2. How easy (or challenging) was it to attract leverage debt for this project? Please describe 

your experience.

3. How much capital had the QALICB raised independent of the NMTC transaction? How 

much of a gap needed to be filled by NMTCs?

4. Did you encounter any challenges with closing the project due to its location in <NMTC 

Native Area>? (e.g., land ownership, mortgage, foreclosure, and land leasing 

laws/ordinances; sovereign immunity; Tribal Employment Rights Ordinance/Office)

5. How did closing this deal in Native Areas differ from closing an NMTC project outside 

of Native Areas? 

6. (If applicable based on answer to survey question #3) How did closing NMTC financing 

with this project compare to closing non-NMTC projects in Native Areas?

7. (If applicable based on answer to survey question #3) Have there been post-closing 

challenges with this project that have been different from non-NMTC projects in Native 

areas?

8. Have there been post-closing challenges with this project that have been different from 

projects in non-Native areas? <If applicable, you responded that there were Tribal 

cultural or Tribal legal matters that had to be addressed during the NMTC process. What 

were the issues and how efficiently and effectively were they addressed?>

9. In your experience, have the community outcomes associated with this project differed 

from those associated with projects in non-Native areas? If so, please explain.

10. Based on the lessons you learned in this project, what advice would you have for tribes or 

other project sponsors planning to fund a similar project using NMTCs? (Lessons may 

include NMTC legal structure, improving financial benefits to the project or tribe, serving 

more tribal members, etc.)

11. Based on the lessons you learned in this project, what advice do you have for other CDEs 

interested in financing projects located in Native Areas?
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 65

12. Would you provide NMTC financing to projects located in Native Areas again? 

<Why/Why not>? What would you do differently? 

b. Follow-Up Survey Interview Script: CDE

Thank you for joining us today! Before we get started, do we have your permission to record this 

Zoom call for our internal reference? The recording will not be shared with the Fund, it will just 

aid us as we draft the report based on these case studies.

1. How easy (or challenging) was it to attract leverage debt for this project? Please describe 

your experience. 

2. How much capital had the QALICB raised independent of the NMTC transaction? How 

much of a gap needed to be filled by NMTCs?

3. Did you encounter any challenges with closing the project due to its location in <NMTC 

Native Area>? (e.g., land ownership, mortgage, foreclosure, and land leasing 

laws/ordinances; sovereign immunity; Tribal Employment Rights Ordinance/Office)

4. How did closing this deal in Native Areas differ from closing an NMTC project outside 

of Native Areas? 

5. (If applicable based on answer to survey question #3) How did closing NMTC financing 

with this project compare to closing non-NMTC projects in Native Areas?

6. (If applicable based on answer to survey question #3) Have there been post-closing 

challenges with this project that have been different from non-NMTC projects in Native 

areas?

7. Have there been post-closing challenges with this project that have been different from 

projects in non-Native areas? <If applicable, you responded that there were Tribal 

cultural or Tribal legal matters that had to be addressed during the NMTC process. What 

were the issues and how efficiently and effectively were they addressed?>

8. In your experience, have the community outcomes associated with this project differed 

from those associated with projects in non-Native areas? If so, please explain. 

9. Based on the lessons you learned in this project, what advice would you have for tribes or 

other project sponsors planning to fund a similar project using NMTCs? (Lessons may 

include NMTC legal structure, improving financial benefits to the project or tribe, serving 

more tribal members, etc.)

10. Based on the lessons you learned in this project, what advice do you have for other 

CDEs interested in financing projects located in Native Areas?

11. Would you provide NMTC financing to projects located in Native Areas again? 

<Why/Why not>? What would you do differently?
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 66

12. We also hope to reach out to the other entities that played roles or benefitted from this 

deal to conduct separate surveys. Are you able to provide the contact information for 

those other entities?

Role Name and Title Email Address Phone Number

Investor

Leverage Lender 

(If CDE was 

Leverage Lender, 

please write N/A)

QALICB

Tribal Leader
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 67

Appendix B: CDE Survey Results

In total, nine separate CDEs responded to the survey of CDEs. Their responses are described in 

the following tables and graphs. Some questions allowed respondents to select multiple answers, 

meaning that percentages for some will add up to more than 100%.

Figure 5 | SQ (Survey Question) 1 Does your entity specialize in deploying NMTC capital in any 

of the following areas?

n (number of responses) = 9
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 68

Figure 6 | SQ2 In addition to your role as CDE in this project, what other role(s), if any, did your 

organization play for this project?

n = 9

Figure 7 | SQ3 Prior to this transaction, how long had your institution been lending/investing in 

Indian Country?

n = 9
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 69

Table 2 | SQ4 Does your entity retain staff members or consultants with experience 

lending/investing in Native Areas?

Yes No I don’t know

Does your entity 

retain staff members 

or consultants with 

experience 

lending/investing in 

Native Areas?

78% 11% 11%

Figure 8 | SQ5 To what extent was private or conventional capital (from private lenders or 

banks) available for this project? 

n = 9

Table 3 | SQ6 Did you encounter any Tribal cultural or Tribal legal matters that had to be 

addressed during the NMTC process?

Yes No I don’t know

Did you encounter 

any Tribal cultural or 

Tribal legal matters 

that had to be 

addressed during the 

NMTC process?

56% 33% 11%
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 70

Figure 9 | SQ7 Had your entity invested in Native Areas as a part of an NMTC transaction prior 

to this transaction?

n = 9

Table 4 | SQ8 Did your entity have any pre-existing relationship with the Tribe or the project 

sponsor?

Yes No I don’t know

Did your entity have 

any pre-existing 

relationship with the 

Tribe or the project 

sponsor?

22% 67% 11%
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 71

Table 5 | SQ9 Compared with other transactions you have financed outside of Native Areas, did 

any NMTC regulations (e.g., risk of recapture; the “substantially all” requirement; QALICB 

criteria) pose a concern or challenge in attracting interest from a tax credit investor or closing the 

transaction? 

Yes No I don’t know

Compared with other 

transactions you have 

financed outside of 

Native Areas, did any 

NMTC regulations 

(e.g., risk of 

recapture; the 

“substantially all” 

requirement; 

QALICB criteria) 

pose a concern or 

challenge in attracting 

interest from a tax 

credit investor or 

closing the 

transaction? 

56% 33% 11%

The CDEs that responded “yes” to the question of whether NMTC regulations posed a concern 

in attracting interest or closing a transaction were subsequently asked to explain the 

circumstances. 

“If the project failed and resulted in foreclosure, timely redeployment created significant 

concerns, as the investor would naturally require prompt redeployment to avoid recapture of the 

tax credits. In order to comply with the Native requirements of [our] Allocation Agreement, [we] 

would need to redeploy back into a Native project. If one was Not readily available, [we] would 

be forced to choose between failing to redeploy (in hopes a Native project would surface) or 

redeploying in violation of the Native requirements of [our] allocation agreement.”

"It is always a challenge to obtain NMTC allocation. It is always a challenge to identify and 

close with an NMTC investor. This question seems to assume that our main line of business is to 

finance projects outside Native Areas. We completely specialize in financing projects that serve 

Indigenous communities. Is the purpose of this question to determine whether investors have a 

higher perception of risk of projects that serve Native communities? Because if so, then I would 

say the answer is 1. But when the CDE is one that is 100% focused on serving Native 

communities (Travois, Chickasaw Nation CDE, etc.) then we are able to help them overcome 

those concerns. We are able to bring our experience of working with Tribes to help overcome 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 72

these negative perceptions. As we have discussed in our previous conversations, the best way to 

overcome the barriers to using NMTCs in Native Areas is for the CDFI Fund to allocate NMTCs 

to CDEs whose primary mission is to serve Native communities. This is what the CDE used to do

almost every year between 2006 and 2017. Then the CDFI Fund stopped allocating to CDEs 

with this primary mission. It shifted to a strategy of thinking about Native communities as a 

carve-out or sub-category of National CDEs' allocations. This strategy has Not been effective. 

As we have discussed before, please pass along our feedback that there are numerous CDEs that 

are 100% focused on Native communities. These CDEs... have the capacity to deploy NMTCs 

right now. I don't believe that further investigation or training is required to recognize this. 

Allocations need to be made to these CDEs. Then the issue of access will be addressed.”

“This was a Targeted Population transaction and as a result we collected the tax returns for the 

12 LIC residents of the eldercare facility for the 7-year compliance period.”

“QALICB criteria is a challenge for Native deals. It leads to complicated structuring that may be 

out of the scope of the tribe to maintain due to staff capacity or turnover. It requires additional 

oversight on the part of CDEs and investor.”

Table 6 | SQ10 Compared with other transactions you have financed outside of Native Areas, did 

your entity require any atypical or additional fees, guarantees, or special covenants for this 

project as a condition of investment due to its location within a Native Area?

Yes No I don’t know

Compared with other 

transactions you have 

financed outside of 

Native Areas, did 

your entity require 

any atypical or 

additional fees, 

guarantees, or special 

covenants for this 

project as a condition 

of investment due to 

its location within a 

Native Area?

56% 33% 11%

Figure 10 | SQ11 Did the QEI closing process take longer, shorter, or the same amount of time as 

the process associated with NMTC projects outside of Native Areas? 
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 73

n = 9

Figure 11 | SQ12 Please provide the approximate proportion of capital types in the QEI that 

financed this transaction. The following are averages taken across the nine CDE responses.

n = 8
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 74

Figure 12 | SQ13 Why did your organization decide to provide capital to this project? 

n = 9

Figure 13 | SQ14 To what extent did your organization use specialized expertise for this project 

(e.g., subject matter experts, individuals, or organizations familiar with working in Native 

communities)? 

n = 8
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 75

Table 7 | SQ15 Given your experience with NMTCs in financing a project in a Native Area, 

would your entity request future allocations to finance other NMTC projects in Native Areas?

Yes No Maybe

Given your 

experience with 

NMTCs in financing 

a project in a Native 

Area, would your 

entity request future 

allocations to finance 

other NMTC projects 

in Native Areas?

67% 0% 33%
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 76

Appendix C: Glossary

CDE: Any domestic corporation or partnership if: 

1. The primary mission of the entity is serving, or providing investment capital 

for, Low-Income Communities or Low- Income Persons; 

2. The entity maintains accountability to residents of Low- Income Communities 

through their representation on any governing board of the entity or on any 

advisory board to the entity; and 

3. The entity is certified by the CDFI Fund as a CDE. Specialized Small Business 

Investment Companies (SSBICs) and Community Development Financial 

Institutions (CDFIs) are deemed to be CDEs in the manner set forth in 

Guidance published by the CDFI Fund (66 Federal Register 65806, December 

20, 2001). 

Investor: Provider of NMTC equity into an NMTC project through a Qualified Equity 

Investment.

Leverage Lender: Provider of leverage debt through a loan to the entity that makes a Qualified 

Equity Investment

NMTC: New Markets Tax Credit. The credit provides an incentive for investment in lowincome communities. The US Department of the Treasury competitively allocates tax credit 

authority to intermediaries that select investment projects. Investors receive a tax credit against 

their federal income tax.43

NMTC Program: The program through which NMTCs are administered. The NMTC Program 

incentivizes community development and economic growth through the use of tax credits that 

attract private investment to distressed communities.44

QALICB: Qualified Active Low-Income Community Business/Borrower. Any corporation 

(including a nonprofit corporation) or partnership if, for any taxable year:

1. At least 50% of the total gross income of such entity is derived from the active conduct of 

a qualified business within any low-income community;

2. A substantial portion of the use of the tangible property of such entity (whether owned or 

leased) is within any low-income community;

3. A substantial portion of the services performed for such entity by its employees are 

performed in any low-income community;

43 Tax Policy Center: https://www.taxpolicycenter.org/briefing-book/what-new-markets-tax-credit-and-how-does-itwork

44 CDFI Fund New Markets Tax Credit Program: https://www.cdfifund.gov/programs-training/programs/newmarkets-tax-credit
New Markets Tax Credit Investments in Native Areas // Selected Case Studies and Best Practices | pg. 77

4. Less than 5%of the average of the aggregate unadjusted bases of the property of such 

entity is attributable to collectibles (as defined in IRC §408 (m)(2)) other than collectibles 

that are held primarily for sale to customers in the ordinary course of such business; and

5. Less than 5% of the average of the aggregate unadjusted bases of the property of such an 

entity (as defined in IRC §1397C(e)) is attributable to nonqualified financial property.

Tribe/Tribal Sponsor: The tribe or tribal corporation involved in the transaction/on whose land 

or property the transaction takes place.