1

U.S. Department of the Treasury 

State Small Business Credit Initiative (SSBCI) Investing in America Small Business Opportunity 

Program

Frequently Asked Questions

January 24, 2024

Contents

PROGRAM OVERVIEW..........................................................................................................................3

1. What is the SSBCI Investing in America Small Business Opportunity Program (SBOP)? 

[01/09/2024].....................................................................................................................................3

2. What are the objectives of the SSBCI Investing in America SBOP? [01/09/2024] .........................3

3. What are some examples of opportunities resulting from or aligned with investments under recent 

federal legislation? [01/09/2024].....................................................................................................4

4. How is the SSBCI Investing in America SBOP different from the SSBCI TA Grant Program 

awards that are already being distributed to eligible recipients? [01/09/2024]................................5

5. Can a Treasury staff member or contractor help me develop my project or application strategy? 

[01/09/2024].....................................................................................................................................5

6. What is the expected period of performance for grants awarded under this program? [01/09/2024]

.........................................................................................................................................................5

7. Can all jurisdictions apply jointly? If not, how can a jurisdiction receive the extra points for 

regional programs described in the NOFO? [01/09/2024]...............................................................5

8. Must applicants develop new programs and partnerships for SSBCI, or may they apply to expand 

existing programs and partnerships? [01/24/2024]..........................................................................6

9. Our jurisdiction does not currently have relevant TA programs in place; can it still apply for a 

grant under the SSBCI Investing in America SBOP? [01/24/2024]................................................6

10. Our jurisdiction is relatively small. Can we compete with larger jurisdictions that have established 

programs? [01/24/2024]...................................................................................................................7

11. How directly must programs align with federal investments? [01/24/2024]....................................7

12. Do non-federal matching funds need to be newly committed for this purpose? [01/24/2024].........7

13. To receive points for a regional focus, can a jurisdiction apply in coordination with a 

municipality? [01/24/2024]..............................................................................................................8

ELIGIBILITY.............................................................................................................................................8

1. Who is eligible to apply for funding under the SSBCI Investing in America SBOP? [01/09/2024] 8

2. Who are eligible beneficiaries? [01/09/2024]...................................................................................8

3. Who are eligible TA providers? [01/09/2024]..................................................................................8

4. How does Treasury define a “legal, accounting, or financial advisory firm” (LAF firm) for this 

program? [01/09/2024] ....................................................................................................................9

5. Does an applicant have to have an active System for Award Management (SAM) registration to 

apply? [01/09/2024].......................................................................................................................10
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6. Are investment fund managers eligible beneficiaries of TA services under the program? 

[01/24/2024]...................................................................................................................................10

CO-APPLICANTS, CONTRACTORS, AND SUBRECIPIENTS.......................................................10

1. Are eligible applicants allowed to apply with co-applicants or as a part of a consortium? 

[01/09/2024]...................................................................................................................................10

2. What types of non-jurisdiction entities are eligible to serve as contractors that provide TA 

services? [01/09/2024]...................................................................................................................11

3. Who is eligible to serve as a subrecipient? [01/09/2024] ...............................................................11

4. Can an application include subawards to political subdivisions of the applying state? [01/09/2024]

.......................................................................................................................................................12

5. Are there any requirements applicable to procurements under an award? [01/09/2024]................12

6. Who can submit an application on behalf of a consortium? [01/09/2024] .....................................13

7. May a jurisdiction make a subaward to a non-federal entity that is not a jurisdiction entity or an 

LAF firm? May that intermediary make further subawards to eligible TA providers? [01/09/2024]

.......................................................................................................................................................13

8. What information about identified subrecipients must an applicant have at the time of application? 

[01/24/2024]...................................................................................................................................13

APPLICATION MATERIALS AND SUBMISSION PROCESS ........................................................14

1. If my application proposes matching funds, how should I document those funds in the application? 

[01/09/2024]...................................................................................................................................14

2. When is the deadline for submission and where do I submit the application? [01/09/2024]..........15

3. How are applications reviewed? [01/09/2024] ...............................................................................15

4. What is the Program Design and Substance section of the application, and what information must 

it contain? [01/09/2024].................................................................................................................16

5. Can a jurisdiction use its existing designation letter under the SSBCI Capital Program or

formula-based TA Grant Program for purposes of its Investing in America SBOP application? 

[01/24/2024]...................................................................................................................................16

FUNDING AND BUDGET ......................................................................................................................17

1. How many awards will Treasury make and how much funding will be awarded per award? 

[01/09/2024]...................................................................................................................................17

2. What are non-federal matching funds, and are they required in my application? [01/09/2024].....17

3. If I include non-federal matching funds in my application, what documentation is required? 

[01/09/2024]...................................................................................................................................17

4. Are in-kind contributions allowed under this funding opportunity? [01/09/2024].........................18

AWARD NOTIFICATION......................................................................................................................18

1. When and how will applicants be notified of results? [01/09/2024]...............................................18

CONTACT US ..........................................................................................................................................19
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1. What is the easiest way to contact Treasury with questions during the application process? 

[01/09/2024] ................................................................................................................................... 19

For each of these FAQs, please see the SSBCI Investing in America SBOP Notice of 

Funding Opportunity (NOFO)1 for more information, including definitions of key terms.

PROGRAM OVERVIEW

1. What is the SSBCI Investing in America Small Business Opportunity Program 

(SBOP)? [01/09/2024]

The SSBCI Investing in America SBOP is a federal assistance program under which Treasury 

intends to award $75 million in federal grants to eligible applicants to support programs that 

propose innovative and high-impact models for delivering technical assistance (TA) in the areas 

of legal, accounting, and financial advisory services to very small businesses (VSBs) and 

businesses owned and controlled by socially and economically disadvantaged individuals 

(SEDI-owned businesses), as those terms are defined in the NOFO, applying for SSBCI capital 

programs or other federal or other jurisdiction small business programs. 

Any state, territory, the District of Columbia, or Tribal government (each a “jurisdiction”) that 

has been approved as a participating jurisdiction in the SSBCI Capital Program is eligible to 

apply. Jurisdictions that are not yet approved as participating jurisdictions in the SSBCI Capital 

Program, but that have submitted complete and timely SSBCI Capital Program applications (or 

are part of a joint Tribal government application) are also eligible to apply; however, to receive a 

SSBCI Investing in America SBOP award, a jurisdiction must be approved as a participating 

jurisdiction in the SSBCI Capital Program.

The SSBCI Investing in America SBOP is related to and supports the SSBCI Capital Program 

and the allocation formula-based SSBCI TA Grant Program. The SSBCI Capital Program 

supports credit and investment programs for eligible small businesses, and the formula SSBCI 

TA Grant Program funds the provision of TA services in the areas of legal, accounting, and 

financial advisory services to eligible small business beneficiaries applying for SSBCI funding 

and other government small business programs. 

2. What are the objectives of the SSBCI Investing in America SBOP? [01/09/2024] 

Treasury seeks to advance the following objectives through the SSBCI Investing in America 

SBOP:

• Connect VSBs and SEDI-owned businesses with loans or investments supported by the 

SSBCI Capital Program or other federal or other jurisdiction small business programs. 

• Assist VSBs and SEDI-owned businesses to secure financing so they can access, 

leverage, and scale into business opportunities arising from legislation such as ARPA, the 

1 https://home.treasury.gov/system/files/136/Competitive-TA-NOFO-FINAL-Oct-25-2023.pdf. 
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Bipartisan Infrastructure Law (BIL), the Creating Helpful Incentives to Produce 

Semiconductors and Science Act (CHIPS and Science Act), or the Inflation Reduction 

Act (IRA). 

• Incentivize innovation in the delivery of TA services through collaborations with other 

jurisdictions, SEDI-owned- legal, accounting, and financial advisory (LAF) firms, 

non-traditional TA providers, educational institutions, and community-serving 

organizations. For example:

o An applicant may propose a partnership, which may occur through a subaward or 

contract, with Community Navigators or other intermediaries that work with 

networks of TA providers, to quickly identify for the applicant SEDI-owned 

businesses and VSBs in need of TA services. 

o An applicant may show how an existing economic development cluster might 

leverage the reach of their proposed TA project. 

• Scale the impact of SSBCI Investing in America SBOP awards through matching funds, 

including from the private sector.

3. What are some examples of opportunities resulting from or aligned with 

investments under recent federal legislation? [01/09/2024]

As noted above, one objective of the SSBCI Investing in America SBOP is to support eligible 

businesses as they connect and scale into opportunities resulting from or aligned with 

investments under federal legislation. Examples of such opportunities are: 

• Business opportunities related to BIL include high-speed internet expansion, road 

construction, airport modernization, power grid updates, and public transit expansion, 

all of which may include construction, engineering, installation, and manufacturing 

work.

• Business opportunities related to CHIPS include fabrication of semi-conductors, 

including the related supply chain logistics and needed service providers. 

• Business opportunities related to the IRA include the development or installation of 

renewable energy technologies; building weatherization and energy efficiency 

services; and manufacturing of batteries, solar, and wind parts and the development of 

technologies like carbon capture systems and electrolyzers to make hydrogen, all of 

which may include construction, engineering, manufacturing, supply chain, and 

logistics work. 
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4. How is the SSBCI Investing in America SBOP different from the SSBCI TA Grant 

Program awards that are already being distributed to eligible recipients?

[01/09/2024] 

The existing SSBCI TA Grant Program is an allocation formula-based grant program, which 

means that funds were allocated to all eligible jurisdictions. Under the formula TA Grant 

Program, all eligible jurisdictions that submitted complete and approvable applications are 

generally recommended for funding. Treasury works closely with jurisdictions throughout the 

award approval process. 

Unlike the formula TA Grant Program, the SSBCI Investing in America SBOP is a competitive 

grant program, which means that complete and timely applications from eligible applicants are 

evaluated based on the criteria specified in the NOFO, and only certain applicants will be 

selected for funding. Out of fairness to all applicants, Treasury staff cannot provide strategic 

assistance to prospective applicants and anticipates answering common applicant questions via 

publication of updates to this set of FAQs. 

5. Can a Treasury staff member or contractor help me develop my project or 

application strategy? [01/09/2024] 

Due to the competitive nature of this program, Treasury staff or contractors cannot offer strategic 

assistance. Treasury staff members are available to provide applicants with assistance regarding 

technical aspects of the application process and requirements and anticipate answering common 

applicant questions via publication of updates to this set of FAQs. 

As specified in the NOFO, throughout the application review and selection process, Treasury, at 

its sole discretion, may seek clarification, including but not limited to written clarifications and 

corrected or missing documents, from applicants whose applications are being reviewed and 

considered and require that applicants provide such clarifications or corrections to continue to be 

considered for an award. 

6. What is the expected period of performance for grants awarded under this 

program? [01/09/2024]

Treasury anticipates awarding grants under this NOFO that will have a performance period of up 

to three years. The length of the period of performance should be based on the assessed needs of 

the jurisdiction’s eligible small businesses and must be clearly articulated in all budget 

documents.

7. Can all jurisdictions apply jointly? If not, how can a jurisdiction receive the extra 

points for regional programs described in the NOFO? [01/09/2024] 

Groups of Tribal governments may apply jointly (i.e., in consortia). States, territories, and the 

District of Columbia may not apply jointly, but an application from these applicants or from 

Tribal governments will receive more points if the TA program is designed to serve eligible 

small businesses in multiple jurisdictions within the same region. Cities and other municipalities 
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(within or outside of a state applicant) are not themselves eligible applicants but are considered 

jurisdictions for the limited purpose of awarding regional collaboration points to eligible 

applicants. This may be achieved in one of four ways:

a. Only one collaborating jurisdiction submits an application, but includes letters of support 

from other jurisdictions detailing how the non-applying jurisdictions will support and be 

involved in the effort, including by providing independent non-SSBCI matching capital 

funds to leverage the SSBCI Investing in America SBOP award.

b. Only one collaborating jurisdiction submits an application, but commits to making a 

subaward to another jurisdiction (consistent with Section C.3 of the NOFO) to support a 

regional program.

c. Multiple Tribal governments submit a joint application.

d. Multiple states, territories, or the District of Columbia submit separate applications, but 

coordinate on a common plan and clearly indicate that their applications should be 

considered in concert. Because joint applicants are not permitted for these jurisdictions, 

Treasury reviewers will read these separate applications in concert but score them 

separately. Additional points for regional collaboration will only be awarded if multiple 

coordinating jurisdictions are strong enough to be recommended for funding in 

accordance with the Senior Leadership Review described in Section E.2.c of the NOFO. 

If only one of the collaborating jurisdictions is slated to be recommended for funding, 

then no regional collaboration points will be awarded to any of the applicants and each 

application will be scored on its own merits. 

8. Must applicants develop new programs and partnerships for SSBCI, or may they 

apply to expand existing programs and partnerships? [01/24/2024]

There is no requirement in the SSBCI Investing in America SBOP NOFO that an applicant 

propose a new program or new partnerships. An applicant may propose an expansion of existing 

work with existing partners. However, please review the evaluation criteria in Section E.1 of the 

NOFO carefully; one application criterion is how the application effectively provides TA for 

SEDI-owned businesses and VSBs and identifies how the proposed project will improve 

outcomes from prior efforts. 

For example, if an applicant proposes to expand work under existing programs or partnerships, 

the applicant may wish to describe what it will do differently to effectively reach SEDI-owned 

businesses and VSBs, such as engaging new partners or developing a new outreach strategy.

9. Our jurisdiction does not currently have relevant TA programs in place; can it still 

apply for a grant under the SSBCI Investing in America SBOP? [01/24/2024]

Yes. There is no requirement that a jurisdiction have relevant TA programs in place to be eligible 

to apply for a grant under this program. Please review the evaluation criteria in Section E.1 of the 

NOFO carefully.
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10. Our jurisdiction is relatively small. Can we compete with larger jurisdictions that 

have established programs? [01/24/2024] 

Treasury will take into consideration the geographic coverage of awards, including a diversity of 

service area types, and whether potential recipients represent a range of sizes (by jurisdiction 

population) and poverty rates. 

11. How directly must programs align with federal investments? [01/24/2024] 

Through the SSBCI Investing in America SBOP, Treasury seeks to advance programs that 

“support eligible businesses as they connect and scale into opportunities resulting from or 

aligned with investments under federal legislation” (see Section A.3 of the NOFO). Treasury 

expects that the strongest applications will identify specific opportunities to connect businesses 

to capital needed to participate in an existing economic development cluster or to participate in 

manufacturing, supply chain, or contracting opportunities, particularly including opportunities 

generated by recent federal legislation (see the evaluation criteria in Section E.1 of the NOFO). 

12. Do non-federal matching funds need to be newly committed for this purpose?

[01/24/2024] 

Any non-federal matching funds (i.e., funds that will cover a portion of project costs not paid for

by federal funds) must be committed to an applicant’s proposed project. Non-federal matching 

funds may include cash commitments from businesses, non-profit organizations, philanthropic 

partners, and the jurisdiction’s own non-federal funds. 

If an applicant includes proposed matching funds in the project budget, all proposed non-federal 

matching funds must be documented with a letter of commitment from the provider of the funds 

and signed by an authorized representative of the contributing organization and should include 

that organization’s contact information, to enable Treasury to verify the terms in the document. 

Each letter must clearly: 

• State the complete value of the cash matching funds. 

• State or evidence that, at the time of award, the matching funds: 

o Are committed to the project; 

o Will be available as needed; and 

o Are not conditioned or encumbered in any way that would preclude their use 

consistent with the requirements of an SSBCI Investing in America SBOP award.

Matching funds that do not have corresponding letters of commitment will not be 

considered in the application review process. 

See Section D.2.b.ix.a of the NOFO. 
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13. To receive points for a regional focus, can a jurisdiction apply in coordination with 

a municipality? [01/24/2024]

Yes. Section C.1 of the NOFO states, “Cities and other municipalities (within or outside of a 

state applicant) are not themselves eligible applicants but are considered jurisdictions for the 

limited purpose of awarding regional collaboration points to eligible applicants.” In other words, 

cities and other municipalities may be considered partners for purposes of a regional 

collaboration under the NOFO. Such cities and other municipalities may be located within or 

outside of the applicant jurisdiction.

ELIGIBILITY

1. Who is eligible to apply for funding under the SSBCI Investing in America SBOP?

[01/09/2024]

Any state, territory, the District of Columbia, or Tribal government (each a “jurisdiction”) that 

has been approved as a participating jurisdiction in the SSBCI Capital Program is eligible to 

apply. Jurisdictions that are not yet approved as participating jurisdictions in the SSBCI Capital 

Program, but that have submitted complete and timely SSBCI Capital Program applications (or 

are part of a joint Tribal government application) are also eligible to apply; however, to receive a 

SSBCI Investing in America SBOP award, a jurisdiction must be approved as a participating 

jurisdiction in the SSBCI Capital Program.

2. Who are eligible beneficiaries? [01/09/2024]

Eligible beneficiaries of TA services under the program are VSBs and SEDI-owned businesses 

that are applying for funding under a jurisdiction’s SSBCI capital program or other federal or 

other jurisdiction small business program. See the “Key Terms” section of the NOFO for the

definitions of “VSB” and “SEDI-owned business.” 

Some businesses may qualify as both VSBs and SEDI-owned businesses. A recipient can 

consider these businesses as VSBs, SEDI-owned businesses, or both for all purposes for grants 

made under this NOFO.

3. Who are eligible TA providers? [01/09/2024]

A recipient may (1) provide TA services itself under the SSBCI Investing in America SBOP

award, (2) make a subaward for certain subrecipients to provide TA services under the SSBCI 

Investing in America SBOP award, (3) contract with third-party LAF firms to provide the 

TA services, or (4) make a subaward to a non-federal entity (as defined at 2 CFR § 200.12

) that is 

2 The regulation at 2 CFR § 200.1 defines “non-federal entity” as a state, local government, Indian tribe, institution 

of higher education, or nonprofit organization that carries out a federal award as a recipient or subrecipient.
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not an entity of the recipient (e.g., a state entity or other jurisdiction entity) or LAF firm, 

provided that:3

• A subrecipient must be either an entity of the recipient (e.g., a state agency or 

government corporation) or an LAF firm. 

• A third-party contractor must be an LAF firm. 

• In a subaward to a non-federal entity that is not an entity of the recipient or LAF firm, the 

subrecipient must act in an administrative role as a pass-through entity and must contract 

with or make subawards to jurisdiction entities or LAF firms that serve as TA providers 

that will provide the TA services.4 This includes subawards to other jurisdictions.5

4. How does Treasury define a “legal, accounting, or financial advisory firm” 

(LAF firm) for this program? [01/09/2024] 

A legal, accounting, or financial advisory firm (LAF firm) is a for-profit or nonprofit entity that 

meets at least one of the following criteria: 

• A primary purpose of the entity or a central part of the entity’s mission is to provide 

legal, accounting, and/or financial advisory services, 

• The entity regularly markets or publicizes itself as providing legal, accounting, and/or 

financial advisory services, or 

• At least 25% of the entity’s revenues or staff are dedicated to providing legal, 

accounting, and/or financial advisory services. 

See also FAQ # 2 “How does Treasury define a ‘legal, accounting, of financial advisory firm’ for 

purposes of the TA Grant Program?” under Section III. Eligible Recipients, Beneficiaries, and 

TA providers at https://home.treasury.gov/system/files/136/SSBCI-FAQs.pdf, which will apply 

to applications and grants under the SSBCI Investing in America SBOP. 

3 Note that examples of potential TA providers or subrecipients used throughout these FAQs and the SSBCI 

Investing in America SBOP NOFO, such as Community Navigators, are only eligible to the extent that the specific 

proposed entity meets the criteria described in the NOFO.

4 For example, a jurisdiction may make a subaward to a nonprofit entity that is not an LAF firm, which then makes a 

subaward to or contracts with LAF firms to provide TA services. The nonprofit entity will be responsible for the 

oversight of TA providers and reporting to the recipient. 

5 A subaward from a recipient jurisdiction to another jurisdiction or an entity of another jurisdiction is permissible if 

the subrecipient will act in an administrative role and will contract with or make subawards to LAF firms that serve 

as TA providers that will provide TA services (rather than providing TA services itself). Any subaward agreement 

must incorporate all the terms and conditions of the SSBCI Investing in America SBOP grant agreement and must 

include the information listed in 2 CFR § 200.332(a). A pass-through entity must require a subrecipient, including a 

lower-tier subrecipient, to comply with the terms and conditions of the SSBCI Investing in America SBOP grant 

agreement, including the applicable requirements of the Uniform Guidance (2 CFR Part 200). In accordance with 

2 CFR § 200.332, pass-through entities must monitor subrecipients’ use of SSBCI Investing in America SBOP funds 

to ensure the subrecipients’ compliance with all SSBCI Investing in America SBOP award terms and conditions.
10 

5. Does an applicant have to have an active System for Award Management (SAM) 

registration to apply? [01/09/2024]

Yes. In accordance with the Federal Funding Accountability and Transparency Act of 2006, 

applicants are required to (i) be registered in SAM before submitting an application; (ii) provide 

a valid unique entity identifier (UEI) in the application (a valid UEI is also required for 

subrecipients); (iii) make certain certifications; and (iv) continue to maintain an active SAM 

registration with current information at all times during which they have an active federal award 

or an application or plan under consideration by a federal awarding agency. In addition, 

pass-through entities must ensure that any subrecipient is registered in SAM.gov before 

disbursing any award funds to that subrecipient. 

Treasury may not make a federal award to an applicant until the applicant has complied with all 

applicable UEI and SAM.gov requirements, and if an applicant has not fully complied with the 

requirements by the time Treasury is ready to make an award, Treasury may determine that the 

applicant is not qualified to receive an award and use that determination as basis for making an 

award to another applicant. If awarded a grant, a recipient will be subject to reporting 

requirements outlined in award terms of the appendices of 2 CFR parts 25 and 170 that will be 

incorporated by reference into the grant agreement. 

6. Are investment fund managers eligible beneficiaries of TA services under the 

program? [01/24/2024] 

If an investment fund manager is a VSB or a SEDI-owned business that is applying on the fund 

manager’s own behalf for funding under a jurisdiction’s SSBCI capital program or other federal 

or other jurisdiction small business program and meets all other program requirements, an 

investment fund manager may be an eligible beneficiary. 

The applicant should carefully review Section F.4 “Conflict of Interest” of the NOFO.

CO-APPLICANTS, CONTRACTORS, AND SUBRECIPIENTS

1. Are eligible applicants allowed to apply with co-applicants or as a part of a 

consortium? [01/09/2024] 

Groups of Tribal governments may apply jointly (i.e., in consortia). For additional requirements 

applicable to joint Tribal applications, please see TA Grant Program FAQ #3 “Can a 

Tribal-affiliated entity or non-Tribal entity apply for a TA grant, sign a TA Grant Agreement, 

and implement the grant on behalf of a group of Tribal governments” under Section III. Eligible 

Recipients, Beneficiaries, and TA Providers at 

https://home.treasury.gov/system/files/136/SSBCI-FAQs.pdf, which will apply to applications 

and grants under this NOFO. 

As noted above in FAQ # 7 under “Program Overview,” states, territories, and the District of 

Columbia may not apply jointly, but an application from these applicants or from Tribal 

governments will receive more points under the NOFO if the TA program is designed to serve 
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eligible small businesses in multiple jurisdictions within the same region (e.g., by demonstrating 

a clear plan to provide services across state lines or by attaching letters from other jurisdictions 

demonstrating a plan to coordinate on a regional approach). 

2. What types of non-jurisdiction entities are eligible to serve as contractors that 

provide TA services? [01/09/2024] 

A third-party contractor that provides TA services (i.e., is a TA provider) must be an LAF firm. 

3. Who is eligible to serve as a subrecipient? [01/09/2024] 

A subrecipient that provides TA services (i.e., is a TA provider) must be either an entity of the 

recipient (e.g., a state agency or government corporation) or an LAF firm. See also FAQ # 1 

“Can a state participating in the TA Grant Program make a subaward to a political subdivision of 

that state?” under Section III. Eligible Recipients, Beneficiaries, and TA providers at 

https://home.treasury.gov/system/files/136/SSBCI-FAQs.pdf, which will apply to applications 

and grants under this NOFO. 

In a subaward to a non-federal entity that is not an entity of the recipient or LAF firm, the 

subrecipient must act in an administrative role as a pass-through entity and must contract with or 

make subawards to jurisdiction entities or LAF firms that serve as TA providers that will provide 

the TA services.6 This includes subawards to other jurisdictions.7 

The regulation at 2 CFR § 200.331 provides guidance on determining when an entity is a 

subrecipient or a contractor. A recipient that makes a subaward to a subrecipient to carry out a 

SSBCI Investing in America SBOP award is also known as a pass-through entity. 

A pass-through entity must execute a subaward agreement with the subrecipient, which is a 

legally binding written agreement that includes a budget consisting of separate line items 

reflecting the budget categories in Section D.2.b.iv of the NOFO, which align with budget 

categories contained in Form SF-424A, or a fixed amount consistent with 2 CFR § 200.332. Any 

subaward agreement must incorporate all the terms and conditions of the SSBCI Investing in 

6 For example, a jurisdiction may make a subaward to a nonprofit entity that is not an LAF firm, which then makes a 

subaward to or contracts with LAF firms to provide TA services. The nonprofit entity will be responsible for the 

oversight of TA providers and reporting to the recipient. 

7 A subaward from a recipient jurisdiction to another jurisdiction or an entity of another jurisdiction is permissible if 

the subrecipient will act in an administrative role and will contract with or make subawards to LAF firms that serve 

as TA providers that will provide TA services (rather than providing TA services itself). Any subaward agreement 

must incorporate all the terms and conditions of the SSBCI Investing in America SBOP grant agreement and must 

include the information listed in 2 CFR § 200.332(a). A pass-through entity must require a subrecipient, including a 

lower-tier subrecipient, to comply with the terms and conditions of the SSBCI Investing in America SBOP grant 

agreement, including the applicable requirements of the Uniform Guidance (2 CFR Part 200). In accordance with 

2 CFR § 200.332, pass-through entities must monitor subrecipients’ use of SSBCI Investing in America SBOP funds 

to ensure the subrecipients’ compliance with all SSBCI Investing in America SBOP award terms and conditions.
12 

America SBOP grant agreement and must include the information listed in 2 CFR § 200.332(a).8

A pass-through entity must require a subrecipient, including a lower-tier subrecipient, to comply 

with the terms and conditions of the SSBCI Investing in America SBOP grant agreement, 

including the applicable requirements of the Uniform Guidance (2 CFR Part 200).

In accordance with 2 CFR § 200.332, pass-through entities must monitor subrecipients’ use of 

SSBCI Investing in America SBOP funds to ensure the subrecipients’ compliance with all 

SSBCI Investing in America SBOP award terms and conditions. 

4. Can an application include subawards to political subdivisions of the applying state?

[01/09/2024] 

Yes. In accordance with the SSBCI Investing in America SBOP NOFO, a subrecipient may be 

an entity of the eligible recipient (e.g., a state entity). For purposes of the SSBCI Investing in 

America SBOP, this includes a city or other entity that is a political subdivision of the applying 

state under applicable state law. Under section 3009(e)(1) of the SSBCI statute (12 U.S.C. 

§ 5708(e)(1)), state entities, including political subdivisions, must carry out the state’s technical 

assistance plan by providing technical assistance to qualifying small businesses directly or 

contracted with legal, accounting, and financial advisory firms. 

5. Are there any requirements applicable to procurements under an award? 

[01/09/2024] 

Yes. In accordance with 2 CFR § 200.317, recipients that are states, the District of Columbia, 

and territories must follow the same policies and procedures they use for procurements from 

their non-federal funds and comply with 2 CFR §§ 200.321, 200.322, 200.323, and 200.327. This 

means that these jurisdictions must use their own policies and procedures, subject to the SSBCI 

statutory prioritization described in the SSBCI Investing in America SBOP NOFO, as applicable. 

Tribal governments must follow the procurement standards in 2 CFR §§ 200.318 200.327, which 

include the requirement that recipients and subrecipients must maintain written standards of 

conduct covering conflicts of interest and governing the performance of their employees engaged 

in the selection, award, and administration of contracts. No employee, officer, or agent may 

participate in the selection, award, or administration of a contract supported by a federal award if 

he or she has a real or apparent conflict of interest. See Section F.4 of the NOFO for further 

information about conflicts of interest. Notwithstanding the above, if awarded, all jurisdictions 

and their subrecipients must maintain a conflict-of-interest policy consistent with 2 CFR 

§ 200.318(c) that is applicable to all activities funded under the SSBCI Investing in America 

SBOP award.

8 See also 2 CFR § 200.101(b)(2) (Applicability to different types of Federal awards), which describes the 

applicability of 2 CFR Part 200 to various types of federal awards, including their application to subrecipients, and 

2 CFR §§ 200.331-333 (Subrecipient monitoring and management).
13 

6. Who can submit an application on behalf of a consortium? [01/09/2024] 

Only Tribal governments can apply jointly (i.e., in consortia). Tribal Governments may designate 

an “Agent for the Tribes” to act on behalf of the group of Tribal governments. For additional 

requirements applicable to joint Tribal applications, please see TA Grant Program FAQ #3 “Can 

a Tribal-affiliated entity or non-Tribal entity apply for a TA grant, sign a TA Grant Agreement, 

and implement the grant on behalf of a group of Tribal governments” under Section III. Eligible 

Recipients, Beneficiaries, and TA Providers, at 

https://home.treasury.gov/system/files/136/SSBCI-FAQs.pdf, which will apply to applications 

and grants under the SSBCI Investing in America SBOP NOFO. 

7. May a jurisdiction make a subaward to a non-federal entity that is not a jurisdiction 

entity or an LAF firm? May that intermediary make further subawards to eligible 

TA providers? [01/09/2024] 

Yes. In a subaward to a non-federal entity that is not an entity of the recipient (e.g., a state entity 

or other jurisdiction entity) or LAF firm, the subrecipient must act in an administrative role and 

must contract with or make subawards to jurisdiction entities or LAF firms that serve as 

TA providers that will provide the TA services. For example, a jurisdiction may make a 

subaward to a nonprofit entity that is not an LAF firm, which then makes a subaward to or 

contracts with LAF firms to provide TA services. The nonprofit entity will be responsible for 

oversight of TA providers and reporting to the recipient. 

8. What information about identified subrecipients must an applicant have at the time 

of application? [01/24/2024] 

Treasury encourages applicants that have identified subrecipients at the time of application to 

provide the UEI and EIN for these proposed subrecipients. In addition, if available, applicants 

should provide a proposed project budget using the line items of Form SF-424A and the budget 

narrative for each identified subrecipient. 

Before entering into a subaward with an entity or person, the recipient must verify that the entity 

or person is not debarred, suspended, or otherwise excluded from or ineligible for participation in 

Federal assistance programs or activities pursuant to Treasury’s implementing regulation at 31 

CFR 19.300. 

In addition, prior to disbursing funds to a subrecipient, the recipient must notify Treasury of the 

identity the subrecipient and provide Treasury with an itemized subrecipient budget using the 

same line items as specified in Section D.2.b.iv of the NOFO, with appropriate justification in a 

budget narrative. Recipients and pass-through entities must execute a subaward agreement with 

any subrecipient. A subaward agreement is a legally binding written agreement that includes a 

budget consisting of separate line items reflecting the budget categories set forth in the SSBCI 
14

Investing in America SBOP NOFO or a fixed amount consistent with 2 CFR § 200.332(a).9 Any 

subaward agreement must incorporate all the terms and conditions of the SSBCI Investing in 

America SBOP grant agreement and must include the information listed in 2 CFR § 200.332(a). 

Recipients and pass through entities must require subrecipients, including lower-tier 

subrecipients, to comply with all of the terms and conditions of the SSBCI Investing in America 

SBOP grant agreement, including the applicable requirements of the Uniform Guidance 

(2 CFR Part 200).

In accordance with 2 CFR § 200.332(d), recipients and pass-through entities must monitor 

subrecipients’ use of SSBCI Investing in America SBOP funds to ensure the subrecipients’ 

compliance with all award terms and conditions.

APPLICATION MATERIALS AND SUBMISSION PROCESS

1. If my application proposes matching funds, how should I document those funds in 

the application? [01/09/2024]

If an applicant includes proposed matching funds in the project budget, all such funds must be 

documented by a letter of commitment from each provider of the funds, as applicable, that 

clearly:

• States the amount; and 

• States or evidences that the funds are available, committed, and unencumbered. 

Matching funds that do not have corresponding letters of commitment will not be 

considered in the application review process. Applicants are not required to submit a 

corresponding letter if they do not propose matching funds.

Each letter of commitment must be signed by an authorized representative of the contributing 

organization and should include that organization’s contact information, to enable Treasury to 

verify the terms included in the document. Each letter must clearly:

• State the complete value of the cash matching funds.

• State or provide evidence that, at the time of award, the matching funds

o Are committed to the project;

o Will be available as needed; and

o Are not conditioned or encumbered in any way that would preclude their use 

consistent with the requirements of a SSBCI Investing in America SBOP award.

Any proposed matching funds must be clearly identified in the budget narrative. 

9 See also 2 CFR § 200.101(b)(2) (Applicability to different types of Federal awards), which describes the 

applicability of 2 CFR Part 200 to various types of federal awards, including their application to subrecipients, and 

2 CFR §§ 200.331-333 (Subrecipient monitoring and management).
15

2. When is the deadline for submission and where do I submit the application?

[01/09/2024]

The deadline to submit an application is 60 calendar days from the date the SSBCI Investing in 

America SBOP application is available. Treasury will publish a separate notification when the 

SSBCI Investing in America SBOP application is published that specifies the application 

deadline and will update the NOFO and these FAQs accordingly. Treasury anticipates that the 

application deadline will be in the Spring of 2024, and no earlier than March 15, 2024. 

Applications will only be accepted electronically through Treasury’s Portal. Treasury strongly 

recommends that applicants submit applications substantially before the application 

submission deadline. Applications received after the application deadline will not be considered 

for funding. 

An applicant must obtain, complete, and submit an application electronically through Treasury’s 

Portal which will be available at https://portal.treasury.gov/cares/s/ssbci-home-page. Treasury 

will not accept paper, facsimile, or e-mail transmissions of applications unless the means of 

alternate submission has been approved in writing by Treasury prior to the application deadline. 

Treasury will only make exceptions to submission of applications through Treasury’s Portal to 

accommodate applicants’ accessibility requirements. Applicants needing to request such 

accommodation must contact Treasury at ssbci_information@treasury.gov (please reference 

“SSBCI Investing in America SBOP” in the email subject line). Regardless of submission 

method, all application materials must be submitted by the deadline.

Treasury will not accept any unsolicited changes, additions, revisions, or deletions to 

applications or supporting documents after the application submission deadline. Throughout the 

review and selection process, Treasury reserves the right to seek clarification from applicants 

whose applications are being reviewed and considered.

3. How are applications reviewed? [01/09/2024]

Applications submitted for a grant under the SSBCI Investing in America SBOP NOFO will first 

be reviewed for eligibility and completeness, and eligible and complete applications will then be 

reviewed and scored competitively against the evaluation criteria specified in the NOFO, which 

are: 

• Proposed goals and proposed solutions (40 points)

• Organizational Capacity (30 points)

• Budget and Timeline (25 points)

• Project Reach (10 points)

Note that NOFO specifies the factors that Treasury will consider for each criterion. Merit 

reviewers will respond to prompts for each criterion by indicating the extent to which they agree 
16

with the statement as it applies to the application, from “strongly disagree” (1 point) to “strongly 

agree” (5 points). 

For more information about the criteria that Treasury will use to score applications, please see 

Section E.1 of the SSBCI Investing in America SBOP NOFO. 

4. What is the Program Design and Substance section of the application, and what 

information must it contain? [01/09/2024]

The Program Design and Substance is the section of the application where applicants should 

detail their project plan for providing TA services to eligible beneficiaries. It should be a 

maximum of 15 total pages](12-point font, one-inch margins), including any exhibits or 

attachments. Material beyond 15 pages will not be read or considered.

To be considered complete, the Program Design and Substance must include the following 

sections:

• Executive Summary (up to one page)

• Description of Project Service Area and Potential to Connect Eligible Beneficiaries to 

Opportunities

• Proposed Solution

• Key Partners and Project Support

• Organizational Capacity and Experience

• Performance Goals and Measures

For more information about the specific information that should be contained in each section of 

the Program Design and Substance, please visit section D.2.b.iii.b of the SSBCI Investing in 

America SBOP NOFO.

5. Can a jurisdiction use its existing designation letter under the SSBCI Capital 

Program or formula-based TA Grant Program for purposes of its Investing in 

America SBOP application? [01/24/2024]

The Investing in America SBOP NOFO requires a jurisdiction to submit a designation letter on 

official letterhead signed by, as applicable, the governor of the state, mayor of the District of 

Columbia, or governing official of the territory or Tribal government, stating or evidencing that 

they have designated the eligible applicant to do the following on behalf of the jurisdiction: 

• Submit the SSBCI Investing in America SBOP application;

• Sign the SSBCI Investing in America SBOP grant agreement on behalf of the eligible 

jurisdiction as the grant recipient, if approved;

• Receive and disburse SSBCI Investing in America SBOP funds, if approved; and

• Carry out the grant objectives on behalf of the eligible jurisdiction as the grant recipient, 

if approved.
17 

This letter should include the title of the SSBCI Investing in America SBOP Authorized Official, 

who is the applicant official authorized to sign the application and grant agreement and make 

decisions on behalf of the eligible jurisdiction as the grant recipient under the program. The letter 

should be specific to the SSBCI Investing in America SBOP, so existing SSBCI Capital and TA 

Grant Program application designation letters will generally not satisfy this requirement. 

Treasury, in its sole discretion, reserves the right to determine that an omission of a letter specific 

to the SSBCI Investing in America SBOP is a technical deficiency if it can easily and quickly be 

rectified, but a letter that does not meet all of the above requirements may be deemed insufficient 

and result in the application not being reviewed.

FUNDING AND BUDGET

1. How many awards will Treasury make and how much funding will be awarded per 

award? [01/09/2024] 

Treasury anticipates that it will make between 8 and 15 awards under this NOFO, with individual 

awards ranging from $5 million to $10 million. Treasury anticipates that larger awards will have 

a regional focus that involves collaboration between jurisdictions. The ranges in this paragraph 

are provided only for your information and may prove useful for planning purposes. Actual 

amounts awarded may be higher or lower, including based on the availability of funds. 

2. What are non-federal matching funds, and are they required in my application?

[01/09/2024] 

Non-federal matching funds (also referred to as cost sharing or third-party funds) are not 

required under the SSBCI Investing in America SBOP; however, applicants are encouraged to 

demonstrate an ability to leverage additional sources of funding in conjunction with the SSBCI 

Investing in America SBOP award to increase the impact of the award.10 Applications will be 

scored, in part, based on the extent to which the application is supported by leveraged public or 

private matching fund commitments that will contribute to successful outcomes and project 

long-term sustainability. Examples of private matching fund sources could include commitments 

from businesses, non-profits, including philanthropic partners, and the jurisdiction’s own 

non-federal funds. 

3. If I include non-federal matching funds in my application, what documentation is 

required? [01/09/2024] 

If an applicant includes proposed matching funds in the project budget, all such funds must be 

documented by a letter of commitment from each provider of the funds, as applicable, that 

clearly:

10 Matching funds committed under a SSBCI Investing in America SBOP award will be considered “voluntary 

committed cost sharing,” which is defined at 2 CFR 200.1 as “cost sharing specifically pledged on a voluntary basis 

in the proposal’s budget on the part of the non-Federal entity and that then becomes a binding requirement of 

Federal award.” See also 2 CFR § 200.306. 
18

• States the amount; and 

• States or evidences that the funds are available, committed, and unencumbered. 

Matching funds that do not have corresponding letters of commitment will not be 

considered in the application review process. Applicants are not required to submit a 

corresponding letter if they do not propose matching funds.

Each letter of commitment must be signed by an authorized representative of the contributing 

organization and should include that organization’s contact information, to enable Treasury to 

verify the terms included in the document. Each letter must:

• State the complete value of the cash matching funds.

• State or provide evidence that, at the time of award, the matching funds:

o Are committed to the project;

o Will be available as needed; and 

o Are not conditioned or encumbered in any way that would preclude their use 

consistent with the requirements of a SSBCI Investing in America SBOP award.

4. Are in-kind contributions allowed under this funding opportunity? [01/09/2024]

In-kind services may not be included as non-federal matching funds under this funding 

opportunity. This means that any non-cash contributions to the project must not be 

included in the budget, and will not be considered in the scoring criterion relating to 

leveraged public or private matching fund commitments. However, if project partners are 

providing in-kind contributions such as services, a description could be included in the Key 

Partners and Project Support section of the Program Design and Substance, and letters of 

partnership support could be provided that detail such contributions. 

AWARD NOTIFICATION

1. When and how will applicants be notified of results? [01/09/2024]

It is anticipated that awards will be announced in or after summer 2024. Award notification will 

be sent electronically via email. Any public announcements on awarded applicants will be posted 

on the SSBCI website at https://home.treasury.gov/policy-issues/small-business-programs/statesmall-business-credit-initiative-ssbci.

All award decisions are final and not subject to appeal.

If an application is selected for funding, Treasury will issue a grant agreement for the applicant’s 

signature, which is the notice of award document that includes the award terms and conditions 

and special award conditions applicable to the award. Treasury intends to publish a standard 

template of the TA grant agreement on its website, but will provide each selected applicant’s 

specific and tailored award letter and grant agreement to the applicant’s Authorized 

Representative, such as through Treasury’s Portal. In accordance with 2 CFR § 200.208, 
19

Treasury may impose specific award conditions on a recipient’s award, including as a result of a 

pre-award risk assessment.

CONTACT US

1. What is the easiest way to contact Treasury with questions during the application 

process? [01/09/2024]

For questions concerning this NOFO, you may contact the Treasury at 

ssbci_information@treasury.gov (please reference “SSBCI Investing in America SBOP” in the 

email subject line). Please note that because this is a competitive NOFO, Treasury may only 

provide advice of a technical nature. Questions related to the strategic aspects of project creation 

cannot be answered during the application stage, out of fairness to all applicants.