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U.S. Department of the Treasury

State Small Business Credit Initiative Program

Allocation to Tribal Governments

Updated November 10, 2021

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) 

Program. The ARPA provides up to $10 billion for state, territory, and Tribal governments to 

help address the economic fallout of the COVID-19 pandemic and lay the foundation for a strong 

and equitable recovery by providing support to jurisdictions for programs that increase access to 

credit for small businesses. This document describes Treasury’s methodology for allocating the 

funds to Tribal governments.1

The ARPA allocates $500 million for Tribal government programs as part of the main capital 

allocation. Tribes may also receive more funding as part of the very small business allocation, 

allocation for business enterprises owned and controlled by socially and economically 

disadvantaged individuals (SEDI-owned businesses), and incentive funds related to SEDI-owned 

businesses. The addition of Tribal governments significantly expands the number of eligible 

jurisdictions to receive SSBCI funds, compared to the previous SSBCI implementation under the 

SBJA. Tribal governments are expected to use their allocated funds to facilitate capital access 

programs, provide collateral support, facilitate loan participations, or enable credit guarantee or 

other credit support programs to support small businesses’ lending and investment.

Consultation Process 

In accordance with Treasury’s Tribal consultation policy, Treasury hosted an information session 

for Tribal governments on May 13, 2021, and a Tribal consultation on May 27, 2021, to gather 

input from Tribal leaders on allocation methodologies, the design of programs, and 

administrative functions, such as the application process, reporting, and compliance. Over 200

participants attended the consultations, and 17 Tribal leaders or designees provided input. 

Treasury also received nine 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. 

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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Main Capital Allocation Methodology

Key Principles

ARPA provides that Treasury will allocate the $500 million among the Tribal governments “in 

the proportion the Secretary determines appropriate, including with consideration to available 

employment and economic data regarding each such Tribal government.”

2 Treasury was guided 

by several key principles in determining how to allocate these funds, given the limitations on 

available and consistent economic data across Tribes. These key principles are informed by the 

statutory purpose of SSBCI, comments provided through the consultation process, and 

Treasury’s engagement with Tribes related to the Coronavirus State and Local Fiscal Recovery 

Funds (FRF) program methodology:

• The methodology should be informed by the Tribal consultations and should reflect 

Tribal sovereignty.

• The methodology should be based on data that allows Treasury to calculate Tribal 

allocations in a timely manner.

• The methodology should be fair and equitable.

Consistent with these key principles, Treasury has decided to allocate payments using a formula 

that is based on enrollment data, subject to a minimum amount to be allocated to each Tribal 

government.

• Tribal leaders provided recommendations covering several topics, including regarding the 

use of enrollment data, small business needs, and a minimum allocation amount in the 

allocation formula.

• As discussed below, enrollment data is generally available and will enable timely

allocation calculations.

• 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 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 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 (collectively, Tribal Small Businesses), 

which are the small businesses the allocation is designed to support. Tribal enrollment 

provides a useful measure for this purpose because Tribes with larger enrollment 

generally are expected to have a greater number of Tribal Small Businesses to support.

Allocation Formula

Treasury will allocate amounts to a Tribal government based on that Tribal government’s 

enrollment divided by the enrollment of all Tribal governments, subject to a minimum allocation 

2 Section 3003(b)(2) of the SBJA, as amended by section 3301(a) of ARPA.
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percentage for Tribal governments based on the SSBCI main capital allocation’s statutory 

minimum (Section 3003(b) of the SBJA, as amended by ARPA). Treasury determined the 

preliminary minimum allocation amount by (1) multiplying the statutory minimum allocation

percentage (0.9%) for each state, territory, and the District of Columbia by 56 to determine the 

aggregate minimum allocation percentage for those SSBCI participants, (2) dividing the resulting 

figure by the number of Tribal governments participating in SSBCI to determine the proportional 

minimum percentage allocation for each Tribal government, and (3) multiplying the result by the 

Tribal allocation ($500 million) to determine the dollar amount of the minimum allocation for 

each Tribal government.

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 This approach yields a preliminary minimum allocation amount for 

each Tribal government of $432,000. This minimum allocation amount will increase if some

Tribal governments do not participate in the program. After allocating the minimum amounts, 

the remaining funds will be allocated, as described above, based on enrollment data.4 

Subsequent recalculations of the main capital allocation will use this same methodology.

Tribal Enrollment Data

The SSBCI statute’s definition of “Tribal government” includes “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).”

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 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 selfcertified enrollment data, Treasury will use enrollment data submitted to Treasury in 2020 under 

the Coronavirus Relief Fund.6 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 programs if those entities have recognized governing bodies. 

This is the same approach as under the FRF program and will provide a consistent approach 

across programs for allocating funds to Tribal governments. 

Alternative Methodologies Considered 

Treasury considered using employment data but determined that there were no available 

employment data that are appropriate to measure need for small business credit support across all 

Tribal governments. The Tribal employment data used for the FRF program’s Tribal allocations 

were limited to employment of the Tribal governments and of Tribal government-owned 

3 Tribal minimum allocation amount = (0.009*56/(the number of participating Tribal governments))*$500 million 

4 The minimum allocation was identified via an iterative process, where the minimum allocation was arrived at 

based on the enrollments of participating Tribal governments before calculating the pro rata amounts of the 

remaining funds to be allocated to the remaining Tribal governments.

5 12 U.S.C. § 5701(19). 

6 Some eligible Tribal governments did not submit enrollment data in 2020 or 2021. For these Tribal governments, 

Treasury will use enrollment data from HUD’s Indian Housing Block Grant program. 
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entities,7 which do not reflect the employees of all small businesses owned by individual Tribal 

members or of other small businesses in the area where Tribal lands or Tribal members are 

located. Accordingly, Treasury determined that Tribal enrollment is a more appropriate measure 

for SSBCI because it is expected to reflect credit needs of Tribal Small Businesses. However, in 

recognition that this employment data reflects a diversity of employment conditions and that 

Tribes with small populations often make significant contributions to local economies, this 

methodology incorporates a minimum allocation to provide each Tribal government with a 

baseline level of funding to establish SSBCI programs. 

Treasury also considered alternative metrics for the formula, but determined there were no other 

available metrics that appropriately and consistently reflected employment and economic 

conditions across all eligible Tribal governments. These measures included land size, COVID19 incidence rates, and Tribal expenditures. These metrics do not adequately relate to Tribal

Small Business closures, job losses resulting from the economic effects of the COVID–19 

pandemic, or Tribal Small Businesses’ credit needs. Moreover, land size and COVID-19 

incidence rates presented significant drawbacks: the varying distribution of land holdings by 

Tribes raised concerns about the fair and equitable distribution of funds, and the lack of 

consistent data on COVID-19 incidence rates by Tribal governments precluded their use. 

Treasury also determined that collecting Tribal expenditure data from Tribes would not provide 

an advantage as compared to the enrollment information. 

Very Small Business Allocation

The preliminary allocations to Tribal governments include amounts allocated for very small 

businesses under Section 3003(f) of the SBJA, as amended by ARPA. Approximately $40 

million of the total very small business allocation has been reserved for Tribal governments, 

which is in proportion to Tribal governments’ main capital allocation relative to the main capital 

allocation for states, the District of Columbia, and territories under Section 3003(b) of the SBJA. 

The statute does not specify an allocation methodology for very small businesses, and Treasury 

will use the same enrollment-based methodology as the main capital allocation described above,

except without a minimum allocation per Tribal government for this allocation. Treasury has 

already informed Tribal governments of the amounts of these allocations. Subsequent 

recalculations of the very small business allocation will use this same methodology.

Allocation for SEDI-owned Businesses

Section 3003(d) of the SBJA, as amended by ARPA, provides that Treasury must allocate $1.5 

billion based on the needs of business enterprises owned and controlled by socially and 

economically disadvantaged individuals (SEDI-owned businesses). As with the very small 

business allocation, Treasury will divide this amount into a portion for states and territories and a 

portion for Tribal governments in a manner consistent with the division of funds under the main 

capital allocation. Treasury determined that these allocations reasonably reflect the needs of 

SEDI-owned businesses in these jurisdictions and are also consistent with the purpose underlying 

7 See Coronavirus State and Local Recover Funds Tribal Government Allocations (May 10, 2021), 

https://home.treasury.gov/system/files/136/Tribal-Government-Allocation-Methodology.pdf. 
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the statutory main capital allocation. Thus, approximately $100 million of the total SEDI 

allocation will be allocated among Tribal governments.

Each Tribal government’s share of these funds will be determined using the same enrollmentbased methodology as the main capital allocation described above, except without a minimum 

allocation per Tribal government for this allocation. Subsequent recalculations of the allocation 

for SEDI-owned businesses will use this same methodology. 

Treasury determined that the use of enrollment data reflects the needs of Tribal SEDI-owned 

businesses, as Tribal members and communities have faced a longstanding lack of access to 

capital and investment. Treasury also determined that such an approach is consistent with the 

key principles set forth above. In particular, (1) this methodology reflects Tribal sovereignty in 

deferring to self-certified enrollment data; (2) Tribal leaders have provided consistent feedback 

that population levels are an important factor in allocation formulas; (3) the methodology allows 

Treasury to calculate this allocation in a timely manner; and (4) and the methodology is fair and 

equitable because enrollment data are expected to correlate with the credit needs of Tribal SEDIowned businesses, including privately owned small businesses, on- and off- reservation. 

Disbursements of this allocation will occur at the same time as the disbursements of the SSBCI 

main capital and very small business allocations.

Incentive Funds

Pursuant to Section 3003(e) of the SBJA (as amended by the ARPA), Treasury will increase the 

amount of SSBCI funds that eligible jurisdictions (including Tribal governments) can obtain, 

beyond jurisdictions’ allocated amounts for the second and third tranches of main capital, for 

eligible jurisdictions “that demonstrate robust support” for SEDI-owned businesses by meeting 

the needs of SEDI-owned businesses in the deployment of prior allocation amounts. A total of 

$800 million of the $1 billion incentive allocation will be available for eligible jurisdictions as 

initial eligible amounts. Treasury will determine and announce the distribution of the remaining 

$200 million at a later date. Of the $800 billion of initial eligible amounts, $59 million will be 

available to Tribal governments, in proportion to Tribal governments’ main capital allocation 

relative to the main capital allocation for states and territories. 

The initial eligible amounts for each Tribal government are based on the same enrollment-based 

methodology, without a minimum per Tribal government, as described above for the $1.5 billion 

allocation for SEDI-owned businesses, which Treasury determined appropriately reflects the 

needs of Tribal SEDI-owned businesses. Subsequent recalculations of the initial eligible amounts 

will use this same methodology.

Initial eligible amounts are not considered allocated; Tribal governments may be eligible to 

receive their initial eligible amounts if they meet the needs of SEDI-owned businesses through 

the processes and disbursement schedule described in the SSBCI Capital Program Policy 

Guidelines on Treasury’s website. 
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Application Timeline

Treasury will communicate to Tribal governments the amount of their allocations by e-mailing 

the Tribal governments directly with their allocation amounts. Tribal governments that are 

interested in participating in SSBCI must submit a Notice of Intent (NOI) to apply by December 

11, 2021. NOIs must be signed by an authorized representative of the Tribal government. If the 

authorized representative is a third party, such as a lawyer, consultant, or intermediary, a Tribal 

resolution or other action delegating authority to sign the NOI also must be submitted.

Tribal governments may apply to SSBCI individually or jointly and may operate programs 

themselves or contract with third parties or other Tribal governments to operate programs. 

Treasury encourages Tribal governments with limited experience in small business financing 

programs to consider joint applications and working with third parties with a strong track record 

operating small business financing programs. SSBCI program applications must be initiated by 

December 11, 2021, and completed by February 11, 2022. Treasury will release additional

guidance on applications in the near future. For more information on SSBCI applications, please 

refer to the notice posted on Treasury’s website at 

https://home.treasury.gov/system/files/136/Notice-Regarding-Applications-for-the-State-SmallBusiness-Credit-Initiative-SSBCI.pdf.

Preliminary allocations are subject to change depending on Tribal government participation, 

actual administrative expenses, and other factors under the SSBCI statute and Treasury guidance. 

Treasury may also recalculate allocations after the December 11, 2021 deadline to submit an 

NOI and initiate an application. If not all Tribal governments participate in SSBCI, a 

recalculation will be performed by Treasury before December 31, 2021, and individual 

allocations will be communicated by e-mailing Tribal governments directly. After the February 

11, 2022 deadline to complete an application, another recalculation may similarly occur.

The first one-third of a Tribal government’s allocation will be distributed after execution of an 

Allocation Agreement, and the Tribal government must demonstrate that, within 90 days of 

execution of the Allocation Agreement, the Tribal government is fully positioned to act on 

providing the kind of credit support that the program was established to provide. Treasury will 

transfer each successive one-third tranche after the Tribal government has certified that it has 

expended, transferred, or obligated 80 percent of the previously transferred one-third for Federal 

contributions to, or for the account of, programs that have delivered loans or investments to 

eligible businesses.