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U.S. Department of the Treasury

State Small Business Credit Initiative Technical Assistance Grant Program

Summary of May 5, 2022 Tribal Consultation

Overview

The American Rescue Plan Act of 2021 (ARPA) reauthorizes and amends the Small Business 

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

ARPA provides a $500 million SSBCI capital allocation for Tribal governments1 to help address 

the economic fallout of the pandemic and lay the foundation for a strong and equitable recovery 

by providing direct support to Tribal governments for programs that increase access to credit for 

small businesses (capital program).

ARPA also provided funding for technical assistance (TA) (12 U.S.C. § 5708(e)). 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 $14.73 million of TA Grant Program funding for distribution to Tribal governments.

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. 

Tribal nations in the United States operate as sovereign nations with vastly different structures, 

economies, and populations. The feedback delivered by Tribal leaders both during the 

consultation and in writing reflect this diversity. Treasury appreciates the many perspectives 

brought to the consultation.

Feedback from Tribal Leaders

Allocation methodology

Commenters expressed that the total funding for Tribal governments under the TA Grant 

Program is relatively small and not in proportion to the need in Indian Country. Some expected 

Tribal TA programs to be oversubscribed due to demand. Others requested that Tribal programs 

should be eligible for more funds proportionally than the states given that states have more 

TA infrastructure and experience with the first iteration of SSBCI.

1 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).
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Commenters asked whether Treasury could hold back TA funding to enter contracts with 

TA providers directly. 

Commenters generally expressed support for an equitable division of funding among Tribal 

governments. Some commenters requested an equitable division but did not specify features of 

the final methodology. Some commenters asked that the TA funding be allocated in the same or 

a similar manner in which the SSBCI capital program funding was allocated, based on current 

enrollment divided by the combined enrollment numbers for all eligible Tribal governments. 

Others asked for an equal split of the TA funding to Tribes. 

Some commenters asked that Tribes participating in joint SSBCI applications be allocated TA 

Grant Program funding in the same manner as Tribes that submitted individual applications, 

rather than have separate allocation methodologies for Tribes opting for individual versus joint 

capital programs. 

Use of Funds

Commenters emphasized the importance of bolstering small business credit markets in Indian 

Country, a significant need for TA, and the impact of the pandemic. Commenters said that 

programs like the SSBCI capital program and TA Grant Program are valuable given the 

discrimination Native Americans and Tribes face from lenders.

Commenters asked that Treasury give more examples of eligible services. Commenters asked 

that coaching, wraparound, incubator, counseling related to employment agreements, business 

licenses and permits, and intellectual property filings; other accounting services, including, but 

not limited to, tax filings, payroll, and human resources; and other financial advisory services, 

including, but not limited to, risk management and insurance services for small businesses be 

considered allowable uses for the TA Grant Program. Commenters asked for flexibility in 

pursuing TA services beyond those that are expressly enumerated to better allow Tribes to use 

the funds for their unique needs. Commenters asked for clarification about the role of the 

MBDA in Tribal SSBCI technical assistance.

Commenters asked for clarification on the scope of qualifying other federal or other jurisdiction 

small business programs under the TA Grant Program.

Commenters asked for TA reporting requirements to be minimized given the size of the 

allocations and limited staff capacity at many Tribes.

Commenters said that education for lenders was also needed.

Commenters emphasized the need for TA in Indigenous languages. Commenters also 

emphasized the challenge of delivering TA in the most remote regions, like Alaska.

Tribes asked questions for clarity on how to use the funds, including:
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• Is the TA Grant Program a reimbursement type program, whereby the qualifying business 

will have to incur the costs and then request reimbursement? 

• Does an external vendor have to be hired to provide the service(s) or can the Tribal 

government provide the service?

• If the Tribal government does provide the service(s), what rules or regulations apply 

around pricing and reimbursements?

Technical Assistance Grant Program Application

Participants requested that the TA Grant Program application be streamlined for Tribal 

applicants given the small set aside for Tribal governments, stating that there is no statutory 

requirement for the current application requirements and that the current level of detail required 

by the application is burdensome in proportion to the potential grant sizes. Commenters asked 

that that Treasury not unnecessarily require Tribes to justify their TA need through a “datadriven assessment of the needs of eligible beneficiaries.” One commenter expected that the cost 

of a data-driven assessment of TA needs for a Tribal economy would exceed the TA Grant 

Program awards for most Tribes and that Treasury should automatically assume that Tribes have 

urgent demand for TA dollars.

Commenters asked that additional TA funds be disbursed directly to Tribes without additional 

application processes. Commenters asked that, if a Tribal application is rejected, Treasury work 

with that Tribe to bring the application into compliance with the program requirements.

Tribes commented on joint applications, asking that joint applications be able to apply without 

additional complications. Commenters expressed that requirements for Tribal resolutions and 

delegation documentation on the TA Grant program in addition to the resolutions and delegation 

documentation for the capital program is onerous and requested a less burdensome standard. 

Tribes also requested simplified portal access.

Administrative Challenges

Commenters pointed out that the statutory caps on administrative costs in the capital program 

particularly impacted Tribal recipients as Tribal allocations are lower than those for states and 

made it challenging to operate the SSBCI program, either using Tribal staff or a third party, like 

a community development financial institution. It was noted that this is a greater challenge for 

Tribes without internal finance experts. One Tribe said that it was struggling to design an SSBCI 

program that was financially self-sustaining.

Commenters also stated that implementing the TA Grant Program could be difficult given the 

lack of Indian Country TA providers and infrastructure.

Joint applications were discussed as a solution both to the lack of providers and the 

administrative cost challenges. Other commenters said that joint applications generally were not 

sufficiently flexible or individualizable to be useful.
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Many Tribes also noted challenges in standing up a capital program under SSBCI and stated that 

most Tribes were considering loan guarantee, loan participation, and collateral support programs.