U.S. Department of the Treasury

State Small Business Credit Initiative Technical Assistance Grant Program

Updated Preliminary Allocations to Tribal Governments

July 14, 2023 

The American Rescue Plan Act of 2021 (ARPA) reauthorized and amended the Small Business 

Jobs Act of 2010 (SSBCI), which established the State Small Business Credit Initiative (SSBCI). 

Of the amounts ARPA provided for SSBCI technical assistance (TA) funding, Treasury has 

allocated $200 million for the SSBCI TA Grant Program, under which eligible jurisdictions 

provide legal, accounting, and financial advisory services to qualifying small businesses 

applying for SSBCI capital programs or other jurisdiction small business programs. Treasury has 

reserved approximately $35.73 million1

 of TA Grant Program funding for distribution to 

Tribal governments.2

 This document describes Treasury’s methodology for allocating the SSBCI 

TA Grant Program funds to Tribal governments.

Consultation Process

In accordance with Treasury’s Tribal consultation policy, Treasury solicited letters and held a 

consultation on May 5, 2022, to gather perspectives from Tribal leaders on allocation 

methodologies for the TA Grant Program funds. Around 70 Tribal representatives joined the 

consultation. Three Tribes and Tribal organizations submitted written comments. Treasury 

appreciates the participation of all who helped to inform this process. Treasury has also 

considered relevant information received in Treasury’s other programs that provide support for 

Tribal governments. 

TA Grant Program Allocation Methodology 

Analysis 

To allocate TA Grant Program funding to Tribal governments, Treasury is applying a 

methodology that is based on Tribal enrollment data, subject to certain minimum and maximum 

levels as described below. Use of Tribal enrollment information is fair and equitable because 

these metrics are expected to correlate generally with a Tribe’s need for funding and to reflect 

the credit needs of Tribal small businesses, including privately owned small businesses. 

Enrollment is also expected to correlate generally with the amount of resources needed for small 

businesses that interact with Tribal populations and encompass the wide array of businesses that 

1 Treasury had previously reserved approximately $14.74 million of TA Grant Program Funding for distribution to 

Tribal governments. Treasury subsequently reallocated to Tribal governments an additional amount of 

approximately $21 million in TA Grant Program funding that was declined or unclaimed by certain other 

jurisdictions.

2 The term “Tribal government” means the recognized governing body of any Indian or Alaska Native tribe, band, 

nation, pueblo, village, community, component band, or component reservation, individually identified (including 

parenthetically) in the list published as of March 11, 2021 pursuant to section 104 of the Federally Recognized 

Indian Tribe List Act of 1994 (25 U.S.C. § 5131). See 12 U.S.C. § 5701(19).
provide goods and services to Tribal populations, including small businesses on Tribal lands, in 

areas where Tribal lands or members are located, and for small businesses owned by Tribal 

members. Tribal enrollment provides a useful measure for this purpose because Tribes with 

larger enrollment generally are expected to have a greater number of small businesses to support. 

Allocation Formula

For the TA Grant Program allocation, Treasury used an allocation methodology analogous to the 

SSBCI Capital Program’s main capital allocation to Tribal governments, subject to an additional 

maximum adjustment as described below.3 The first step in this methodology involves allocating 

funds to each Tribal government based on that Tribal government’s enrollment divided by the 

enrollment of all eligible Tribal governments, subject to a minimum allocation percentage for 

Tribal governments based on the SSBCI main capital allocation’s statutory minimum for states, 

territories, and the District of Columbia. Second, Tribal governments with allocations above $1 

million are decreased to $1 million. Third, the funding left after the maximum is applied is 

reallocated on a pro-rata basis to Tribal governments with allocations less than the maximum. 

Finally, steps two and three are repeated until allocations remain unchanged from one iteration to 

the next, and the allocations are rounded down to nearest dollar. 

Tribal Enrollment Data

The Bureau of Indian Affairs collected enrollment numbers from these recognized governing 

bodies in April 2021 and communicated to Tribes that this information may be shared with other 

federal agencies. The Bureau of Indian Affairs has shared this data with Treasury. For a small 

subset of Tribal governments that did not provide self-certified enrollment data, Treasury will 

use enrollment data submitted to Treasury in 2020 under the Coronavirus Relief Fund.4

 Finally, 

Treasury does not have self-certified or other enrollment data for some component bands and 

component reservations, which are known as subcomponents of Tribes, identified in the 

published list. Therefore, the Tribal government allocations will be made to the Tribal 

governments for which enrollment data is available.

Treasury expects that Tribes will cooperate with their component bands and component 

reservations in establishing SSBCI TA Grant Programs if those entities have recognized 

governing bodies. This is the same approach as under Treasury’s State and Local Fiscal 

Recovery Funds program and provides a consistent approach across programs for allocating 

funds to Tribal governments. 

Alternative Methodologies Considered

As with the Capital Program preliminary allocations, Treasury was unable to identify alternative 

data sources to enrollment that were appropriate, accurate, and comprehensive measures of need 

across eligible Tribal jurisdictions. 

3 See https://home.treasury.gov/system/files/256/Updated-Tribal-Methodology-document-Nov-2021.pdf. 4 Some eligible Tribal governments did not submit enrollment data in 2020 or 2021. For these Tribal governments, 

Treasury will use enrollment data from the Department of Housing and Urban Development’s Indian Housing Block 

Grant program.
Treasury considered an approach similar to certain other SSBCI Capital Program allocations, 

where funding would be allocated entirely pro rata; however, this approach would result in some 

Tribal governments receiving allocations that would be too small to enable the effective 

implementation of a TA Grant Program. Additionally, Treasury considered allocating funding 

equally among the Tribal governments that are potentially eligible to apply for the TA Grant 

Program. While this approach would result in higher allocations for many Tribal governments, 

Treasury does not believe an equal split of funding would be an equitable division given the vast 

differences in sizes and resources among Tribal governments. 

Compared to each of the alternative methodologies considered above, Treasury believes that the 

selected methodology is more responsive to the requests for an equitable distribution of 

TA Grant Program funding among Tribal governments. The minimum adjustment will allow 

smaller Tribes to provide a meaningful amount of TA to small businesses. The maximum 

adjustment is designed to be responsive to requests for an equitable distribution of TA funding 

among Tribal governments. The ceiling will help more Tribes with a greater need for TA to 

receive adequate TA funding. 

Communication of Allocation Amounts

Treasury will communicate to Tribal governments the amount of their potential funding through 

the TA Grant Program application portal. This preliminary allocation is subject to change 

depending on a variety of factors, including participation rates in the TA Grant Program. Please 

note that Treasury may revise these allocations and will publish any changes to this methodology 

on its website and any changes to individual allocations on the TA Grant Program application 

portal. We encourage you to check the website and portal periodically for any changes.