State Small Business Credit Initiative: Implementation and Funding Issues

December 18, 2013 – July 25, 2022 R42581

State Small Business Credit Initiative:
July 25, 2022
Implementation and Funding Issues
Robert Jay Dilger
Congressional interest in small business access to capital has always been high,
Senior Specialist in
primarily because small businesses are viewed as a means to stimulate economic activity
American National
and create jobs, but it became especially acute in the wake of the Coronavirus Disease
Government
2019 (COVID-19) pandemic’s widespread adverse economic impact on the national

economy.
Grant A. Driessen
Specialist in Public Finance
In recognition of small business’s economic difficulties, Congress passed budget

reconciliation legislation (P.L. 117-2, the American Rescue Plan Act of 2021) that
Adam G. Levin
includes an appropriation of $10 billion for another round of funding for the State Small
Analyst in Economic
Business Credit Initiative (SSBCI). The SSBCI was originally authorized by P.L. 111-
Development Policy
240, the Small Business Jobs Act of 2010, as a means to assist small businesses

following the Great Recession (2007-2009). The $1.5 billion program was administered

by the Secretary of the Treasury from 2010 through September 27, 2017.
The original SSBCI provided funding, allocated by formula and distributed in one-third increments, to states,
territories, and eligible municipalities (hereinafter referred to as states) to expand existing or create new state
small business investment programs, including state capital access programs, collateral support programs, loan
participation programs, loan guarantee programs, and venture capital programs. In most instances, the initial
round of funding (called a tranche) took place in FY2011. Most states received their second tranche during
FY2013 and their third tranche during FY2015.
SSBCI participants were (and continue to be) expected to leverage their SSBCI funds to generate new small
business lending that is at least 10 times the amount of their SSBCI funds. The original SSBCI program’s
participants leveraged $8.95 in new financing for every $1 in SSBCI funds. Forty-seven states; American Samoa;
the District of Columbia; Guam; the Northern Mariana Islands; Puerto Rico; the U.S. Virgin Islands; Anchorage,
Alaska; two consortiums of municipalities in North Dakota; and a consortium of municipalities in Wyoming
participated in the program.
P.L. 117-2 provides $6.5 billion for an SSBCI capital allocation grant, $1.5 billion to address the needs of business
enterprises owned and controlled by socially and economically disadvantaged individuals (SEDI-owned
businesses), $1.0 billion for an incentive allocation for participants that demonstrate robust support for SEDI-
owned businesses, $500 million for very small businesses (VSBs), and $500 million for technical assistance
funding.
This report examines the SSBCI and its implementation, including lessons learned from the original SSBCI
program’s implementation. For example, audits of the original SSBCI program indicated that Treasury’s program
oversight could have been improved and that performance measures were needed to assess the program’s efficacy.
Congressional Research Service

State Small Business Credit Initiative: Implementation and Funding Issues

Overview
Congressional interest in small business access to capital has always been high, primarily because
small businesses are viewed as a means to stimulate economic activity and create jobs, but it
became especially acute in the wake of the Coronavirus Disease 2019 (COVID-19) pandemic’s
widespread adverse economic impact on the national economy.
In recognition of small business’s economic difficulties, Congress passed budget reconciliation
legislation (P.L. 117-2, the American Rescue Plan Act of 2021) that includes an appropriation of
$10 billion for another round of funding for the State Small Business Credit Initiative (SSBCI).
The SSBCI was originally authorized by P.L. 111-240, the Small Business Jobs Act of 2010, as a
means to assist small businesses following the Great Recession (2007-2009). The $1.5 billion
program was administered by the Secretary of the Treasury from 2010 through September 27,
2017.1
The original SSBCI provided funding, allocated through a statutorily created formula and
distributed in one-third increments (called tranches), to states, the District of Columbia (DC),
eligible territories, and eligible municipalities (hereinafter states) to expand existing or create new
state small business investment programs, including capital access programs, collateral support
programs, loan participation programs, loan guarantee programs, and venture capital programs. In
most instances, states received their initial tranche in FY2011, with more than $366 million in
SSBCI funds transferred to states.2 At that time, Treasury anticipated providing another $859
million in SSBCI funds to states in FY2012.3 However, because it took states longer than
anticipated to expend, transfer, or obligate their first tranche of SSBCI funds, Treasury transferred
less SSBCI funding to states in FY2012 than in FY2011 ($187 million, for a total of $553
million).4 Treasury transferred $364 million in SSBCI funds to states (totaling $917 million) in
FY2013, $229 million in FY2014 (totaling $1.146 billion), $216 million in FY2015 (totaling
$1.362 billion), and $50 million in FY2016 (totaling $1.412 billion).5
As of December 31, 2016 (the latest available data), Treasury had disbursed $1.43 billion, or
about 98%, of the $1.45 billion available to states ($1.5 billion minus Treasury’s administrative

1 P.L. 111-240, the Small Business Jobs Act of 2010, limited Treasury’s role in administrating the State Small Business
Credit Initiative (SSBCI) program to seven years from enactment (September 27, 2010). As a result, Treasury role in
administering the program sunset on September 27, 2017.
2 U.S. Office of Management and Budget (OMB), Appendix, Budget of the U.S. Government, FY2013: Department of
the Treasury, p. 1061, at http://www.gpo.gov/fdsys/pkg/BUDGET-2013-APP/pdf/BUDGET-2013-APP.pdf.
3 OMB, Appendix, Budget of the U.S. Government, FY2013: Department of the Treasury, p. 1061.
4 OMB, Appendix, Budget of the U.S. Government, FY2014: Department of the Treasury, p. 991, at
https://www.gpo.gov/fdsys/pkg/BUDGET-2014-APP/pdf/BUDGET-2014-APP.pdf.
5 U.S. Department of the Treasury, State Small Business Credit Initiative, FY2016: President’s Budget, p. 6, at
http://www.treasury.gov/about/budget-performance/CJ16/18.%20SSBCI%20FY%202016%20CJ.pdf; U.S. Department
of the Treasury, State Small Business Credit Initiative: A Summary of States’ Quarterly Reports as of September 30,
2015, p. 1, at https://www.treasury.gov/resource-center/sb-programs/DocumentsSBLFTransactions/
SSBCI%20Quarterly%20Report%20Summary%20September%202015_FINAL.pdf; and U.S. Department of the
Treasury, State Small Business Credit Initiative: A Summary of States’ Quarterly Reports as of September 30, 2016, p.
1, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI%20Quarterly%20Report%20Summary%20September%202016_Final.pdf.
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State Small Business Credit Initiative: Implementation and Funding Issues

costs).6 As of December 31, 2016, all 57 participants had received their first tranche, 56 had
received their second tranche, and 53 had received their third tranche.7
States were expected to leverage their SSBCI funds to generate new small business lending that is
at least 10 times the amount of their SSBCI funds (a leverage ratio of 10:1). As of December 31,
2016, SSBCI participants had leveraged $8.95 in new financing for every $1 in SSBCI funds.8
There were 57 participants: 47 states; American Samoa; DC; Guam; the Northern Mariana
Islands; Puerto Rico; the U.S. Virgin Islands; Anchorage, Alaska; two consortiums of
municipalities in North Dakota; and a consortium of municipalities in Wyoming.
During congressional consideration, advocates argued that the SSBCI would promote economic
growth and job creation by enhancing small business access to capital. Opponents argued that the
SSBCI did not address the need to stimulate demand for credit by small businesses, which, in the
opponents’ view, was the core issue affecting the role of small business in job creation. They
argued that “the solutions to America’s economic problems do not lie in more taxpayer-funded
bailouts” and advocated small business tax reductions as a more effective means to stimulate job
creation and economic growth.9 For additional discussion of these different approaches to
stimulate job creation and economic growth, see CRS Report R40985, Small Business: Access to
Capital and Job Creation, by Robert Jay Dilger and Anthony A. Cilluffo.
It is difficult to determine the full extent of the SSBCI’s effect on small business lending. As of
December 31, 2016, states had spent or obligated about 88% of the $1.45 billion available ($1.27
billion of $1.45 billion), which is sufficient to provide an indication of the program’s impact on
small business lending.10 However, determining the program’s influence on small business
lending is likely to be more suggestive than definitive because differentiating the SSBCI’s effect
on small business lending from other factors, such as changes in the lender’s local economy, is
methodologically challenging, especially given the relatively small amount of financing involved
relative to the national market for small business loans. In 2017, the SSBCI’s $1.5 billion in
financing represented about 0.24% of outstanding nonagricultural small business loans.11

6 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ Quarterly Reports as
of December 31, 2016, p. 1, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI_Quarterly_Report_Summary_December_2016.pdf.
7 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ Quarterly Reports as
of December 31, 2016, p. 1.
8 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ 2016 Annual Reports,
p. 2, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI%20Summary%20of%20States%20Annual%20Report%202016_508%20Compliant.pdf.
9 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, report to accompany H.R. 5297, 111th Cong., 2nd
sess., May 27, 2010, H.Rept. 111-499 (Washington: GPO, 2010), pp. 37, 38.
10 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ Quarterly Reports as
of December 31, 2016, p. 1, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI_Quarterly_Report_Summary_December_2016.pdf. In addition, as of December 31, 2016, 34 states reported
that they had spent about $279.9 million for new State Small Business Credit Initiative (SSBCI) supported loans and
investments using recycled SSBCI funds generated from SSBCI loan repayments and returns on SSBCI investments.
11 Federal Deposit Insurance Corporation, “Statistics on Depository Institutions,” at https://www5.fdic.gov/sdi/
main.asp?formname=compare. As of December 31, 2017, there was $627.8 billion in outstanding nonagricultural small
business loans (defined as the sum of “total loans secured by nonfarm nonresidential properties of $1,000,000 or less”
and “total commercial and industrial loans to U.S. addressees of $1,000,000 or less”).
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Treasury has reported that SSBCI funds supported more than 21,000 loans and investments in
small business totaling over $10.7 billion, with more than 80% of the funds and investments
made to small businesses with 10 or fewer full-time employees. Treasury has also reported that
small business owners indicated that the funds helped them to create or retain 240,669 jobs
(79,193 new jobs and 161,476 retained jobs).12
The Obama Administration recommended in its FY2015, FY2016, and FY2017 budget requests
that another $1.5 billion round of funding take place. Under their proposal, $1 billion would have
been competitively awarded to states “best able to target local market needs, promote inclusion,
attract private capital for start-up and scale-up businesses, strengthen regional entrepreneurial
ecosystems, and evaluate results,” and $500 million awarded “by formula based on economic
factors such as job losses and pace of economic recovery.”13
Legislation containing provisions similar to the Obama Administration’s proposal was introduced
during the 113th Congress (H.R. 4556, the Small Business Access to Capital Act of 2014, and S.
2285, its companion bill in the Senate), the 114th Congress (S. 1901, the Small Business Access to
Capital Act of 2015, H.R. 5144, the Jumpstart Housing Opportunities Utilizing Small Enterprises
Act of 2016, and H.R. 5672, the Small Business Access to Capital Act of 2016), the 115th
Congress (S. 1897, the Small Business Access to Capital Act of 2017), and the 116th Congress (S.
3551, the Small Business Access to Capital Act of 2020).14
This report examines the current SSBCI provision (P.L. 117-2, round two) and its legislative
origins and the implementation of the original SSBCI (P.L. 111-240, round one), including
Treasury’s response to initial program audits conducted by the U.S. Government Accountability
Office (GAO) and Treasury’s Office of Inspector General (OIG). These audits suggested that
states generally met the statute’s requirements, but there were some compliance problems. They
also indicated that Treasury’s oversight of the program could have been improved and that
performance measures were needed to assess the program’s efficacy.
Legislative Origins
On February 4, 2021, Senator Gary Peters, who sponsored legislation establishing the original
SSBCI (see the Appendix for the original SSBCI’s legislative origins), introduced S. 258, the

12 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ 2016 Annual Reports,
pp. 2, 3, 15, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI%20Summary%20of%20States%20Annual%20Report%202016_508%20Compliant.pdf.
13 OMB, The Appendix, Budget of the United States Government, Fiscal Year 2017: Department of the Treasury, pp.
1034, 1035, at https://www.gpo.gov/fdsys/pkg/BUDGET-2017-APP/pdf/BUDGET-2017-APP.pdf.
14 H.R. 5144, the Jumpstart HOUSE Act of 2016, added a provision (Section 3. Support for affordable housing
projects) designed to facilitate the financing of affordable housing projects: “ ... to develop, acquire, construct,
rehabilitate, maintain, operate, or manage housing projects that provide housing that is affordable for low- or moderate-
income households, as determined by the Secretary, in consultation with the Secretary of Housing and Urban
Development.”
H.R. 5672, the Small Business Access to Capital Act of 2016, added a provision (Section 2. New tranches of capital for
successful State programs) that would have included competitive award factors designed to provide preference to
participants based on their plans to (I) leverage private sector capital; (II) create and retain jobs during the 2-year period
beginning on the date of the award; (III) serve small businesses that have been incorporated or in operation for not
more than 5 years; (IV) serve low- or moderate-income communities; (V) serve minority- and women-owned small
businesses; and establish or continue a robust self-evaluation of their use of awarded funds; provide nonfederal funds in
excess of the amount required; and the extent to which the participant expended, obligated, or transferred their 2010
allocation.
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Small Business Access to Capital Act of 2021.15 The bill would provide $10 billion for another
round of SSBCI funding ($5 billion in formula-based allocations and an additional $5 billion in
competitive grants for states that have already capitalized the financing received from the 2010
program).16
Several organizations indicated their support for the bill. For example, the Council of
Development Finance Agencies (CDFA) argued that
A $10 billion infusion in a reauthorized SSBCI Program would provide immediate access
to capital for small businesses that desperately need it. The programs created by states
under the original SSBCI are still in operation and would be ready to immediately deploy
capital to businesses in need. There would be no need to create new rules and regulations
should this option be enacted. States are prepared to receive an infusion of SSBCI funding
immediately.17
There were disagreements concerning whether a reauthorization of the SSBCI should be included
in the budget reconciliation bill. Generally speaking, Democrats argued that the SSBCI should be
included in the reconciliation bill because the program
 had a proven track record of assisting small businesses create and retain jobs; and
 required states to develop programs that targeted the needs of underserved
communities, which, they argued, had not been adequately addressed by the
Small Business Administration’s Paycheck Protection Program (PPP), which
provides forgivable loans to small businesses adversely affected by COVID-19.18
Republicans generally argued that the SSBCI should not be included in the reconciliation bill
because the program
 was an extraneous matter that did not directly address COVID-19 and would
make funding available for years after the pandemic’s expected duration;
 was duplicative of the PPP, which had, at that time, $140 billion in lending
authority still available; and
 had limited oversight, did not meet all of its statutory objectives, was slow to
launch and inefficient at deploying capital, and had a questionable effect on job
creation.19

15 Sen. Gary Peters introduced similar legislation (S. 3551, the Small Business Access to Capital Act of 2020) during
the 116th Congress. That bill would have appropriated $3 billion for another round of SSBCI funding (on March 20,
2020).
16 Sen. Gary Peters, “Peters, Stabenow Reintroduce Legislation Providing $10 Billion to Support Small Business
Lending,” press release, February 5, 2021, at https://www.peters.senate.gov/newsroom/press-releases/peters-stabenow-
reintroduce-legislation-providing-10-billion-to-support-small-business-lending.
17 Council of Development Finance Agencies, “Small Business Access to Capital Act,” at https://www.cdfa.net/cdfa/
cdfaweb.nsf/pages/SSBCI.html.
18 For further information and analysis of the Paycheck Protection Program, see CRS Report R46284, COVID-19 Relief
Assistance to Small Businesses: Issues and Policy Options, by Robert Jay Dilger and Bruce R. Lindsay.
19 U.S. House of Representatives, Committee on Financial Services, “Supporting Small and Minority-Owned
Businesses Through the Pandemic,” majority staff hearing memorandum, February 1, 2021, at https://democrats-
financialservices.house.gov/UploadedFiles/020421_NSIDMP_Small_Biz_Hrg_Memo.pdf; U.S. House of
Representatives, Committee on Financial Services, Subcommittee on National Security, International Development and
Monetary Policy, “Supporting Small and Minority-Owned Businesses Through the Pandemic,” subcommittee hearing,
February 4, 2021, at https://financialservices.house.gov/calendar/eventsingle.aspx?EventID=407099; U.S. Senate,
Committee on Banking, Housing and Urban Affairs, “The Coronavirus Crisis: Next Steps for Rebuilding Main Street,”
committee hearing, February 25, 2021, at https://www.banking.senate.gov/hearings/the-coronavirus-crisis-next-steps-
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During their internal negotiations on the reconciliation bill, Democratic congressional leaders
amended S. 258 to reserve
 $2.5 billion for businesses owned and controlled by socially and economically
disadvantaged individuals, including minority-owned businesses ($1.5 billion in
an initial allocation, plus $1 billion for an incentive program for states that
demonstrate “robust support,” as defined by the Secretary of the Treasury, for
businesses owned and controlled by socially and economically disadvantaged
individuals);
 $500 million for tribal governments;
 at least $500 million for businesses, including independent contractors and sole
proprietors, with fewer than 10 employees (very small businesses, VSBs); and
 $500 million for technical assistance to small businesses that need legal,
accounting, financial, and other kinds of advice in applying for small business
support programs.
Also, like the original SSBCI initiative, the program was provided a sunset date. The Secretary of
the Treasury is required to complete all SSBCI disbursements and remaining obligations before
September 30, 2030. Any amount that remains unexpended, whether obligated or unobligated, on
September 30, 2030, is to be rescinded and deposited into the general fund.
Among other things, the amended bill, as developed in the House, would have required states and
other jurisdictions to submit a plan on how they would expeditiously deliver funds to help small
businesses respond to and recover from the pandemic and a plan to encourage program
participation by minority depository institutions (MDIs) and community development financial
institutions (CDFIs). The amended bill would have also authorized Treasury to create a multi-
state participation program that would allow states to automatically deem a person or business
eligible for their SSBCI program if that person or business were already participating in the other
state’s SSBCI program. These provisions were included in the House-passed version of the bill,
but were later removed by the Senate.
The House Committee on Financial Services included the amended SSBCI bill language in its
portion of the budget reconciliation bill (H.R. 1319), which was agreed to (29-24) on February
10, 2021, and reported to the House Committee on the Budget. The House Committee on the
Budget agreed to the budget reconciliation bill (19-16), which included the amended SSBCI bill
language, on February 22, 2021, and reported the bill to the full House on February 24, 2021. The
House passed H.R. 1319 (219-212) on February 27, 2021. On March 6, 2021, the Senate replaced
the text of the House-passed bill with S.Amdt. 891, then agreed to a number of additional
amendments before passing the measure (50-49). The bill then went back to the House, which
voted 220-211 to concur with the Senate amendment (i.e., S.Amdt. 891, as amended) on March
10, 2021. President Biden signed the bill into law (P.L. 117-2) on March 11, 2021.
SSBCI Programs
The SSBCI provides funding to expand existing or create new state small business lending and
investment programs, including state capital access programs (CAPs) and other credit support
programs (OCSPs).

for-rebuilding-main-street; and Sen. Pat Toomey, “Toomey Opening Statement at Banking Hearing on COVID and
Small Businesses,” February 25, 2021, at https://www.banking.senate.gov/newsroom/minority/toomey-opening-
statement-at-banking-hearing-on-covid-and-small-businesses.
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State Capital Access Programs
State CAPs provide portfolio insurance to lenders to encourage them to lend to small businesses.
Under a state CAP, when a participating lender originates a loan, the lender and borrower
combine to contribute a percentage of the loan or line of credit (together up to 7% of the loan or
line of credit amount) into a reserve fund, which is held by the lender. The SSBCI then matches
the aggregate borrower/lender contribution on a 1:1 basis and sends that amount to the lender,
who deposits the funds into the lender-held reserve fund. State CAPs encourage lending to small
businesses because the reserve fund reduces the lender’s risk of losses by being available to cover
any losses on any of the loans in the lender’s state CAP portfolio. Interest rates, maturity,
collateral, and other loan terms are negotiated between the lender and the borrower within limits
set by Treasury.20
Under the SSBCI, approved state CAPs are eligible for federal funding equal to the amount of the
insurance premiums paid by the borrower and the lender into the lender-held reserve fund, as
calculated on a loan-by-loan basis. The state may use SSBCI funding to make its contribution to
the lender-held reserve fund. States may also supplement the federal contribution with state or
private funds if they choose to do so.21
Subject to some restrictions, SSBCI state CAP loans may be used for most business purposes,
including, “but not limited to: start-up costs, working capital, franchise fees; and acquisition of
equipment, inventory, or services used in the production, manufacturing, or delivery of a
business’s goods or services, or in the purchase, construction, renovation, or tenant improvements
of an eligible place of business that is not for passive real estate investment purposes.”22 In
addition, the borrower must have 500 employees or fewer at the time that the loan is enrolled in
the program and the loan amount may not exceed $5 million.23
Other Credit Support Programs
State OCSPs are programs that (1) are not a state CAP program, (2) use public resources to
promote private access to credit, and (3) meet certain eligibility criteria. State OCSPs may include
loan programs, investment programs, or other credit or equity support programs, such as
collateral support programs, loan participation programs, state-sponsored venture capital
programs, loan guarantee programs, or other similar programs.24

20 U.S. Department of the Treasury, “State Small Business Credit Initiative: Capital Program Policy Guidelines,”
November 10, 2021, p. 14, at https://home.treasury.gov/system/files/256/SSBCI-Capital-Program-Policy-Guidelines-
November-2021.pdf (hereinafter U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines”).
21 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” pp. 11-12.
22 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 15.
23 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 14.
24 Collateral support programs help viable businesses that are struggling to obtain credit because the value of the
collateral they hold is below the lender’s standards. The collateral support provides banks greater confidence in
extending credit to these borrowers.
Loan participation programs entail risk sharing among financial institution lenders and the participating state. States
typically structure loan participation programs in two ways: (1) by purchasing a portion of a loan originated by a lender
(also known as a purchase transaction or purchase participation) or (2) by participating in the loan as a co-lender (also
known as a companion loan).
State-sponsored venture capital programs typically “entail joint public-private investment programs focused on
“seeding” small businesses with high-growth-potential.”
Loan guarantee programs “provide an assurance to lenders that they will be partially repaid in the event of default, after
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Each OCSP must demonstrate (1) a reasonable expectation that it will achieve a 10:1 private
financing ratio (the ratio of small business lending and investment to the federal contribution
amount) and (2) that, at a minimum, each $1 of public investment by the state will cause and
result in at least $1 of new private credit.25
OCSPs are required to
 target an average borrower or investee size of 500 employees or less,
 not extend credit support to borrowers that have more than 750 employees,
 target support towards loans or investments with an average principal amount of
$5 million or less, and
 not provide credit or investment support if a given transaction exceeds $20
million.26
SSBCI Funding
As mentioned, P.L. 117-2 appropriated $10 billion for the SSBCI program in FY2021, with the
funding available until expended (except that all disbursements and remaining obligations on
September 30, 2030, “shall be rescinded and deposited into the general fund of the Treasury”).
Application Process
States, American Samoa, DC, Guam, Puerto Rico, the Northern Mariana Islands, and the U.S.
Virgin Islands were required to file a notice of intent to apply for SSBCI funding with Treasury
by December 11, 2021, and to apply for SSBCI capital grants by February 11, 2022, and SSBCI
technical assistance grants by June 30, 2022.27 Their deadline for applying for SSBCI technical
assistance grants was subsequently extended to September 1, 2022.
Municipalities may apply for funding only in the event their state does not participate in the
program. Municipalities are eligible to apply for funding up to the total amount of their state’s
SSBCI allotment, with the final approved amounts apportioned based on their proportionate share
of the population of all approved municipal applicants in that state, based on the most recent
available decennial census.28 Eligible municipalities were required to submit to Treasury an
application for funding by March 11, 2022.
Tribal governments were required to submit a notice of intent to apply for SSBCI funding with
Treasury by December 11, 2021, and to initiate and apply for SSBCI capital grants by May 11,
2022, and SSBCI technical assistance grants by July 11, 2022. Their deadlines for applying for

the lender makes every reasonable effort to collect, helping small businesses secure loans that may have otherwise been
inaccessible or prohibitively expensive.”
See U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 2; and U.S. Department of the
Treasury, “State Small Business Credit Initiative (SSBCI) Program, Fact Sheet,” November 2021, at
https://home.treasury.gov/system/files/256/State-Small-Business-Credit-Initiative-SSBCI-Fact-Sheet.pdf.
25 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” pp. 22, 24.
26 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 26.
27 U.S. Department of the Treasury, “State Small Business Credit Initiative, 2021 Archive,” at
https://home.treasury.gov/policy-issues/small-business-programs/state-small-business-credit-initiative-ssbci/ssbci-
2021.
28 12 U.S.C. §5703(d)(6). If more than three municipalities or combinations of municipalities from the same state are
approved, Treasury is required to allocate federal funds to the three municipalities (or combination of municipalities)
with the largest populations. See 12 U.S.C. §5703(d)(5).
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SSBCI capital grants and technical assistance grants were subsequently extended to September 1,
2022.
The application for funding requested information concerning such items as
 the amount requested;
 how the funds are to be used (state capital access program, collateral support
program, loan participation program, loan guarantee program, venture capital
program, or other small business support program);
 confirmation that, at a minimum, $1 of public investment will result in at least $1
of new private credit; that there is a reasonable expectation the funding will result
in new small business lending of at least 10 times the amount of the SSBCI
federal contribution; that the funding targets small businesses with 500
employees or fewer, does not support borrowers that have more than 750
employees, targets loans with an average principal of $5 million or less, and does
not extend credit support to loans that exceed $20 million;
 documentation describing the operational capacity, skills, and experience of the
applicant’s management team in operating capital access and other small
business capital support programs;
 documentation describing the internal accounting and administrative control
systems used to safeguard against waste, loss, unauthorized use, and
misappropriation; and
 documentation describing how the participant planned to use the funds “to help
provide access to capital for small businesses in low- and moderate-income,
minority, and other underserved communities, including women- and minority-
owned small businesses.”29
All 50 states, DC, and the territories filed a notice of intent to apply for SSBCI funding.30
In addition, 415 Indian tribes filed a notice of intent to apply for SSBCI funding.31
The Capital Grants’ Funding Formula
The SSBCI’s allocation formula for the distribution of $6.5 billion in main capital funds takes
into account a state’s 2020 job losses in proportion to the aggregate job losses of all states in
2020. Each state, DC, and territory is guaranteed a minimum allocation of 0.9% of the $6.0
billion allocation available for states (not including tribal governments). Treasury made a separate
allocation to tribal governments based on tribal enrollment, with a preliminary minimum
allocation of approximately 0.09% of the $500 million available for tribal allocation (see Table
1).32

29 U.S. Department of the Treasury, “2021 State Small Business Credit Initiative: Application Instructions,” at
https://home.treasury.gov/policy-issues/small-business-programs/state-small-business-credit-initiative-ssbci/2021-
ssbci/program-materials/application-material.
30 U.S. Department of the Treasury, “List of Proposed Programs and Contacts (updated July 22, 2022),” at
https://home.treasury.gov/system/files/256/List_Proposed_Programs_Contacts.pdf.
31 U.S. Department of the Treasury, “State Small Business Credit Initiative (SSBCI) Tribal Government Notice of
Intent (NOI) Submissions,” at https://home.treasury.gov/system/files/136/Tribal-Government-NOI-Submissions.pdf.
32 12 U.S.C. §5702(b). State employment decline is defined as the excess (if any) of (i) the number of individuals
employed in such state determined for December 2019; over (ii) the number of individuals employed in such state
determined for December 2020.
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Funding is provided in three approximately equal installments (called tranches): 33%, 33%, and
34%. The first tranche is provided immediately following the receipt of the fully signed
Allocation Agreement. Allotment agreements describe how states are to comply with program
requirements and are signed after the state’s application was approved.
Prior to the receipt of the second and third tranches, each state is required to certify that it has
expended, transferred, or obligated at least 80% of the previous disbursement to, or for the
account of, one or more approved state programs.33 Treasury is authorized to recoup misused
funds should the state be found in default of the allocation agreement.34
To encourage states to utilize their funds expeditiously, P.L. 117-2 requires states to receive their
second tranche (second one-third allotment) within three years and their third and final tranche
(last one-third allotment) within six years of their approval date to participate in the program.
States failing to do so must return their remaining SSBCI funds to Treasury, and Treasury is
required to either return the funds to the general fund or reallocate the funds to other participating
states.
On May 19, 2022, Treasury announced the first five SSBCI capital grant allocations (Hawaii,
Kansas, Maryland, Michigan, and West Virginia). Nine more grant allocations (Arizona,
Connecticut, Indiana, Maine, New Hampshire, Pennsylvania, South Carolina, South Dakota, and
Vermont) were announced on July 18, 2022.35
Set-Asides for SEDI-Owned Businesses, Incentive Allocation for
SEDI-Owned Businesses, VSBs, and Technical Assistance
P.L. 117-2 requires Treasury to set aside $1.5 billion in SSBCI funding to address the needs of
business enterprises owned and controlled by socially and economically disadvantaged
individuals (SEDI-owned businesses), $1.0 billion for an incentive allocation for participants that
demonstrate robust support for SEDI-owned businesses, $500 million for very small businesses
(VSBs), and $500 million for technical assistance funding.
SEDI-Owned Businesses
Treasury allocated the $1.5 billion set-aside for SEDI-owned businesses into a portion for states,
DC, and territories and a portion for tribal governments, consistent with the division of funds
under the main capital allocation.36
Each state, DC, or territory’s share of these jurisdictions’ portion of the $1.5 billion SEDI
allocation is “based on the percentage of the jurisdiction’s total population residing in
Community Development Financial Institution (CDFI) Investment Areas, as defined in 12 C.F.R.

33 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 3.
34 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 7.
35 U.S. Department of the Treasury, “Treasury Announces First State Small Business Credit Initiative Awards to
Support Underserved Entrepreneurs and Small Business Growth in Key Industries,” May 19, 2022, at
https://home.treasury.gov/news/press-releases/jy0795; and U.S. Department of the Treasury, “Treasury Approves Nine
Additional State Plans to Support Underserved Entrepreneurs and Small Business Growth Through the State Small
Business Credit Initiative,” July 18, 2022, at https://home.treasury.gov/news/press-releases/jy0875.
36 Treasury determined “that these portions reasonably reflect the needs of SEDI-owned businesses in the respective
jurisdictions, because these portions, determined by statute for the main capital allocation, generally reflect small
business financing needs in these jurisdictions.” See U.S. Department of the Treasury, “SSBCI: Capital Program Policy
Guidelines,” p. 5.
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§1805.201(b)(3)(ii), relative to the total population residing in all CDFI Investment Areas.”37
Each tribal government’s share of the tribal government portion of the $1.5 billion SEDI
allocation is “determined using the same formula as the main capital allocation, based on
enrollment data, except without the minimums” (see Table 1).38
Each state’s SEDI allocation will be transferred in three approximately equal tranches: 33%,
33%, and 34%. The first allocation will be disbursed when the state is approved for participation
in the SSBCI. The second and third disbursements will occur when the state certifies that it has
deployed 80% of its prior tranche of SSBCI funds.
Incentive Allocation for SEDI-Owned Businesses
P.L. 117-2 requires Treasury to set aside $1 billion to increase the amount of SSBCI funds that
states can obtain, beyond their allocated amounts for the second and third tranches of main
capital, “for states that demonstrate “robust support” for SEDI-owned businesses in the
deployment of prior allocation amounts.”39 Of this amount, Treasury will use $500 million to
provide states additional funds for each of the second and third tranches of main capital.40
Each state’s initial eligible amount was determined in the same manner as the $1.5 billion
SEDI allocation methodology.41 For each of the second and third tranches of main capital,
Treasury will increase the amount of SSBCI funds that a state can obtain using a two-step
process:
First,
each state should aspire to expend a certain percentage (the SEDI Objective) of its SSBCI
funds that have been expended since the state’s prior disbursement of main capital
allocation, SEDI allocation, and VSB allocation funds for meeting the needs of the SEDI-
owned businesses within its state. For states of the United States, the District of Columbia,
and territories, the SEDI Objective equals the population of the jurisdiction that are
residents in CDFI Investment Areas, as defined in 12 C.F.R. §1805.201(b)(3)(ii), divided
by the jurisdiction’s total population. For Tribal governments, the SEDI Objective is 100
percent.... 42
For each of the second and third tranches of main capital, $400 million of the $500 million
of additional funds will be available as initial eligible amounts. Each state’s initial eligible
amount will be determined in the same manner as the $1.5 billion SEDI allocation
methodology described above, as that methodology reflects the needs of SEDI-owned
businesses.43

37 Treasury indicated that “the population in CDFI Investment Areas serves as a proxy for the needs of SEDI-owned
businesses because these areas are generally low-income, high-poverty geographies that receive neither sufficient
access to capital nor support for the needs of small businesses, including minority-owned businesses.” See U.S.
Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 5.
38 Treasury indicated that “the use of enrollment data reflects the needs of Tribal SEDI-owned businesses, as Tribal
members and communities have faced widespread and long-standing lack of access to capital and investment, such that
a population-based approach provides a reasonable proxy for the extent of the needs of these businesses.” See U.S.
Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” pp. 5-6.
39 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 7.
40 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 7.
41 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 8.
42 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 8.
43 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 8.
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Second,
for each of the second and third tranches of main capital, Treasury will make a second
disbursement from these additional funds, totaling $100 million in the aggregate plus any
other residual funds, to states that have requested their Step 1 disbursement by the date that
Treasury sets for the second disbursement. For the second tranche of main capital, the
residual funds will include only initial eligible amounts unachieved by the states that have
requested their Step 1 disbursement. For the third tranche of main capital, the residual funds
will include any remaining (unachieved and un-drawn) amount of the $400 million for the
second tranche of main capital and any remaining (unachieved and un-drawn) amount of
the $400 million for the third tranche of main capital.44
Very Small Businesses
P.L. 117-2 requires Treasury to set aside $500 million to states to be expended for VSBs. The
allocations for VSBs are determined according to the same formula as the state’s main capital
allocation, except without the minimums for the tribal government portion. Each state’s VSB
allocation will be transferred in three approximately equal tranches, 33%, 33%, and 34%. The
first tranche will be disbursed when the state is approved for participation in the SSBCI. The
second and third tranches will be disbursed when the state certifies that it has deployed 80% of its
prior tranche of disbursed SSBCI funds (see Table 1).
States are not required to establish a separate VSB program, but must maintain records of the
total amount of its SSBCI funds expended for VSBs.
Technical Assistance
P.L. 117-2 requires Treasury to set aside $500 million for state administrative costs. These costs
are capped by statute (see 12 U.S.C. §5702(c)(3)(C)-(D)). Specifically, administrative costs
may not exceed 5% of SSBCI funds for the first tranche and 3% for the second or third
tranche.
State-by-State Allotments
Table 1 shows the amount of SSBCI funding available to each state (not including administrative
awards, which will be determined later). As shown in Table 1, California is eligible for the largest
allotment ($1.18 billion) and the Northern Mariana Islands is eligible for the smallest allotment
($57.06 million).

44 U.S. Department of the Treasury, “SSBCI: Capital Program Policy Guidelines,” p. 8.
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Table 1. SSBCI Allocation Table
(preliminary estimates)
Total
Initial
Potential
Eligible
Funding
Amounts
Amount
($800
(excluding
Very Small
million of
Technical
Technical
Main Capital
Business
SEDI
incentive
Assistance
Assistance
State
Allocation
Allocation
Allocation
funding)
Grants)
Grants
AL
$52,092,000
$4,142,176
$27,201,417
$14,507,422
$97,943,015
$3,139,321
AK
$52,092,000
$4,142,176
$2,394,597
$1,277,118
$59,905,891
$654,712
AS
$52,092,000
$4,142,176
$553,430
$295,163
$57,082,769
$470,304
AZ
$54,546,269
$4,337,331
$34,009,405
$18,138,349
$111,031,354
$3,840,744
AR
$52,092,000
$4,142,176
$16,557,075
$8,830,440
$81,621,691
$2,073,202
CA
$829,050,641
$65,923,238 $187,189,392
$99,834,342
$1,181,997,613
$25,351,336
CO
$70,278,471
$5,588,301
$18,852,249
$10,054,533
$104,773,554
$2,447,924
CT
$93,906,484
$7,467,119
$11,766,086
$6,275,245
$119,414,934
$1,926,365
DE
$52,092,000
$4,142,176
$3,090,605
$1,648,322
$60,973,103
$724,423
DC
$52,092,000
$4,142,176
$3,777,969
$2,014,917
$62,027,062
$793,268
FL
$300,311,399
$23,879,723 $107,149,207
$57,146,243
$488,486,572
$13,123,637
GA
$109,140,449
$8,678,471
$53,346,483
$28,451,457
$199,616,860
$6,212,315
GU
$52,092,000
$4,142,176
$1,588,530
$847,216
$58,669,922
$573,977
HA
$52,092,000
$4,142,176
$3,774,640
$2,013,141
$62,021,957
$792,935
ID
$52,092,000
$4,142,176
$6,158,721
$3,284,651
$65,677,548
$1,031,720
IL
$261,128,465
$20,764,032
$47,435,265
$25,298,808
$354,626,570
$6,830,727
IN
$57,461,660
$4,569,152
$24,167,552
$12,889,361
$99,087,725
$2,878,220
IA
$78,036,450
$6,205,188
$7,735,439
$4,125,567
$96,102,644
$1,396,269
KS
$52,092,000
$4,142,176
$8,714,786
$4,647,885
$69,596,847
$1,287,731
KY
$75,985,059
$6,042,069
$22,888,318
$12,207,103
$117,122,549
$2,897,619
LA
$68,793,015
$5,470,182
$25,309,701
$13,498,507
$113,071,405
$3,082,861
ME
$52,092,000
$4,142,176
$3,912,223
$2,086,519
$62,232,918
$806,715
MD
$154,429,827
$12,279,725
$20,670,917
$11,024,489
$198,404,958
$3,300,281
MA
$125,977,247
$10,017,275
$21,258,689
$11,337,967
$168,591,178
$3,132,548
MI
$162,909,105
$12,953,968
$39,866,007
$21,261,870
$236,990,950
$5,290,360
MN
$69,777,312
$5,548,450
$14,143,588
$7,543,246
$97,012,596
$1,972,321
MS
$52,092,000
$4,142,176
$19,463,655
$10,380,616
$86,078,447
$2,364,320
MO
$52,092,000
$4,142,176
$25,188,018
$13,433,609
$94,855,803
$2,937,663
MT
$52,092,000
$4,142,176
$3,322,039
$1,771,754
$61,327,969
$747,603
NE
$52,092,000
$4,142,176
$5,068,397
$2,703,145
$64,005,718
$922,515
NV
$85,277,686
$6,780,986
$13,629,033
$7,268,818
$112,956,523
$2,044,233
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Total
Initial
Potential
Eligible
Funding
Amounts
Amount
($800
(excluding
Very Small
million of
Technical
Technical
Main Capital
Business
SEDI
incentive
Assistance
Assistance
State
Allocation
Allocation
Allocation
funding)
Grants)
Grants
NH
$52,092,000
$4,142,176
$3,413,648
$1,820,612
$61,468,436
$756,778
NJ
$197,308,382
$15,689,280
$27,521,719
$14,678,250
$255,197,631
$4,327,941
NM
$52,092,000
$4,142,176
$11,905,193
$6,349,436
$74,488,805
$1,607,277
NY
$349,347,050
$27,778,868
$81,170,522
$43,290,945
$501,587,385
$10,912,188
NC
$111,588,774
$8,873,153
$53,110,274
$28,325,479
$201,897,680
$6,208,156
ND
$52,092,000
$4,142,176
$1,570,218
$837,449
$58,641,843
$572,143
NMI
$52,092,000
$4,142,176
$537,122
$286,465
$57,057,763
$468,670
OH
$106,498,285
$8,468,375
$43,944,282
$23,436,950
$182,347,892
$5,249,563
OK
$52,092,000
$4,142,176
$16,573,324
$8,839,106
$81,646,606
$2,074,829
OR
$52,092,000
$4,142,176
$17,782,859
$9,484,191
$83,501,226
$2,195,974
PA
$191,483,931
$15,226,140
$39,866,127
$21,261,934
$267,838,132
$5,517,949
PR
$52,092,000
$4,142,176
$34,655,800
$18,483,093
$109,373,069
$3,885,940
RI
$52,092,000
$4,142,176
$3,581,833
$1,910,311
$61,726,320
$773,623
SC
$56,224,591
$4,470,785
$26,509,098
$14,138,185
$101,342,659
$3,102,893
SD
$52,092,000
$4,142,176
$2,462,790
$1,313,488
$60,010,454
$661,542
TN
$60,573,813
$4,816,620
$33,612,467
$17,926,649
$116,929,549
$3,848,992
TX
$265,398,300
$21,103,554 $121,038,443
$64,553,836
$472,094,133
$14,236,704
UT
$52,092,000
$4,142,176
$8,329,451
$4,442,373
$69,006,000
$1,249,137
VT
$52,092,000
$4,142,176
$1,117,696
$596,105
$57,947,977
$526,819
VI
$52,092,000
$4,142,176
$1,060,678
$565,695
$57,860,549
$521,109
VA
$174,537,551
$13,878,622
$27,403,585
$14,615,245
$230,435,003
$4,134,756
WA
$115,269,784
$9,165,854
$25,450,902
$13,573,814
$163,460,354
$3,467,156
WV
$52,092,000
$4,142,176
$10,350,406
$5,520,216
$72,104,798
$1,451,552
WI
$52,092,000
$4,142,176
$14,929,240
$7,962,261
$79,125,677
$1,910,161
WY
$52,092,000
$4,142,176
$1,429,764
$762,541
$58,426,481
$558,076
Indian
$499,999,621
$39,757,972 $110,488,814
$58,927,240
$709,173,647
$14,731,879
Tribes
Total
$6.288 billion
$0.5 billion
$1.5 billion
$0.8 billion
$9.088 billion
$0.2 billion
Source: U.S. Department of Treasury, “Allocations for States, Territories, Washington DC, and Tribal
Governments,” at https://home.treasury.gov/system/files/256/Updated-Preliminary-Allocations-Table-Nov-
2021.pdf; and U.S. Department of Treasury, “State Small Business Credit Initiative Preliminary Technical
Assistance Grant Program Allocation Table,” April 28, 2022, at
https://home.treasury.gov/system/files/216/PreliminaryTechnicalAssistanceAllocations-April-2022.pdf.
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Lessons Learned from Round One Audits and
Evaluation Reports
P.L. 111-240 required Treasury’s OIG to conduct, supervise, and coordinate audits and
investigations into the use of SSBCI funds. The act also required GAO to perform an annual audit
of the SSBCI program. P.L. 113-188, the Government Reports Elimination Act of 2014, later
eliminated this requirement.
Treasury’s OIG released its first evaluation report of Treasury’s implementation of the SSBCI on
August 5, 2011, and its first audit of a state’s use of SSBCI funds (California) on May 24, 2012. It
completed audits of 24 participants’ use of SSBCI funds (California, Montana, Vermont,
Michigan, Texas, Massachusetts, Delaware, New Jersey, Alabama, Missouri, Washington,
Kansas, Florida, West Virginia, Illinois, South Carolina, American Samoa, North Carolina, Idaho,
Indiana, Tennessee, the North Dakota Mandan consortium, Rhode Island, and New York).45
GAO released annual audits of the SSBCI program on December 7, 2011, December 5, 2012,
December 18, 2013, and December 11, 2014.
GAO’s Audits
GAO’s audits indicated that the SSBCI program got off to a relatively slow start for a number of
reasons:
 Treasury’s revisions to its policy guidelines and application paperwork led
several states, worried that they might be found in noncompliance with
Treasury’s rules and regulations, to postpone their SSBCI applications until
Treasury finalized its policy guidance. Thirty-seven states waited to submit their
applications until June 2011, the final month that applications were allowed.46
 Many states did not have preexisting small business programs in place and lacked
the administrative infrastructure necessary to distribute SSBCI funds quickly.
Instead of immediately disbursing funds, many states conducted outreach to
lenders to make them aware of their SBCI programs and to encourage them to
commit to small business lending.47
 Some states reported that some large, multi-state banks were reluctant to
participate in the program due to the variation of SSBCI programs across the
nation and the need to “tailor different processes to each SSBCI participant’s
program.”48

45 U.S. Department of the Treasury, Office of Inspector General (OIG), Small Business Lending Fund Program
Oversight Office, Small Business Lending Fund Oversight Reports, at https://oig.treasury.gov/Office-of-Small-
Business-Lending-Fund-Program-Oversight. An audit of Louisiana’s use of SSBCI funds was issued on January 9,
2014, and removed from the Treasury OIG’s website on February 19, 2015, pending further review. The OIG later
determined that the work performed was not sufficient to support the findings and conclusions in the report under
generally accepted government auditing standards. The audit report will not be reissued.
46 GAO, State Small Business Credit Initiative: Opportunities Exist to Improve Program Oversight, GAO-12-173,
p. 14, at https://www.gao.gov/products/gao-12-173.
47 GAO, Small Business Lending: Opportunities Exist to Improve Performance Reporting of Treasury’s Programs,
GAO-13-76, December 5, 2012, p. 22, at http://www.gao.gov/assets/660/650555.pdf.
48 GAO, State Small Business Credit Initiative: Opportunities Exist to Enhance Performance Measurement and
Evaluation, p. 16.
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None of these implementation impediments is expected to affect the latest round of funding.
States and lenders have become familiar with the SSBCI regulations and guidelines, and states
now have infrastructures in place to enable them to process applications and awards.
GAO also encouraged Treasury to develop SSBCI performance measures to enable it to “be in a
position to determine whether the SSBCI program is effective in achieving its goals.”49 In
response, in January 2012, Treasury adopted three performance goals to measure its
administration of the program and four performance indicators to measure SSBCI outcomes.
The three administrative performance goals were
 90% of requests for modifications to allocation agreements are approved or
rejected within 90 days of receiving a final submission;
 90% of requests for subsequent disbursements under existing allocation
agreements are approved or rejected within 90 days of receipt of a formal
submission; and
 90% of quarterly reports are received within five days of the deadline.50
Treasury tracked these performance goals continuously and reported 12-month data to the Office
of Management and Budget as part of its annual budget submission.
The four performance indicators were
 the amount of SSBCI funds used over time, as reported on SSBCI quarterly
reports;
 the volume and dollar amounts of loans or investments supported by SSBCI
funds, as reported on SSBCI annual reports;
 the amount of private sector leverage, as reported on SSBCI annual reports; and
 the estimated number of jobs created or retained, as reported on SSBCI annual
reports.
Treasury reported this performance data internally to the Assistant Secretary of Financial
Institutions on an annual basis. After GAO recommended this data be made public, on September
25, 2013, Treasury officials made SSBCI performance information publicly available by releasing
the first of what would become an annual summary report of performance information drawn
from SSBCI participants’ annual reports.51
Treasury’s Inspector General Evaluation Report and State Audits
On August 5, 2011, Treasury’s OIG released an evaluation report examining the SSBCI
program.52 Treasury’s OIG made a number of recommendations for improving program guidance
language and to improve SSBCI program oversight. In response, Treasury redefined several terms

49 GAO, State Small Business Credit Initiative, GAO-12-173, p. 21.
50 U.S. Treasury, “Correspondence with the author,” June 22, 2012. For the first two goals, the measurement period
starts once all required documentation from the requesting participating state is received.
51 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ 2012 Annual Reports,
September 25, 2013, at http://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI%20Summary%20of%20States%202012%20Annual%20Reports%20FINAL.pdf.
52 U.S. Department of the Treasury, OIG, “State Small Business Credit Initiative: Treasury Needs to Strengthen State
Accountability for Use of Funds,” August 5, 2011, at https://oig.treasury.gov/sites/oig/files/
Audit_Reports_and_Testimonies/SBLF11002.pdf.
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and conditions in its guidance documents and established minimum standards for participating
state oversight of SSBCI recipients.53
On May 24, 2012, Treasury’s OIG released the first of a series of audits of state use of SSBCI
funds, starting with California.54 Treasury’s OIG completed audits of 24 participants’ use of
SSBCI funds (California, Montana, Vermont, Michigan, Texas, Massachusetts, Delaware, New
Jersey, Alabama, Missouri, Washington, Kansas, Florida, West Virginia, Illinois, South Carolina,
American Samoa, North Carolina, Idaho, Indiana, Tennessee, the North Dakota Mandan
consortium, Rhode Island, and New York).55 A summary of the OIG’s findings for each state
follows, starting with California.
In each audit, the OIG reviewed a judgmental sample of small business loans or investments to
“determine whether [the loans or investments] complied with program requirements for loan use,
capital at risk, and other restrictions.”56 Treasury was required to recoup any funds the OIG
identified as intentionally or recklessly misused.57 Only Texas, New Jersey, West Virginia, and the
North Dakota Mandan consortium were found to be in full compliance with all SSBCI
requirements.
These audits revealed that states generally did not intentionally or recklessly misuse SSBCI
funds. Nonetheless, Treasury’s OIG found many instances where states did not fully comply with
SSBCI rules and regulations, especially early in the program’s implementation. For example,
Treasury’s OIG determined that California had properly used the majority of the $3.6 million in
SSBCI loans examined, but it identified $133,250 in loan loss reserves funded under California’s
Small Business Loan Guarantee Program that did not comply with SSBCI program
requirements.58 The OIG indicated that these noncompliant expenditures “constitute a ‘reckless’
misuse of funds as defined by Treasury guidance, which under the provisions of the Small
Business Jobs Act must be recouped.”59 The OIG also identified $160,988 in administrative
expenses charged to the SSBCI program that were “not adequately supported by actual expenses
incurred or with proper documentation to validate the costs claimed.”60 In addition, the OIG
reported that “42 or approximately 58 percent, of the 73 loans [OIG] tested lacked all of the
required borrower and lender assurances.”61

53 U.S. Department of the Treasury, OIG, “State Small Business Credit Initiative: Treasury Needs to Strengthen State
Accountability for Use of Funds,” pp. 10, 20.
54 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, May 24, 2012, at https://oig.treasury.gov/sites/oig/
files/Audit_Reports_and_Testimonies/OIG-SBLF-12-003.pdf.
55 U.S. Department of the Treasury, OIG, Small Business Lending Fund Program Oversight Office, Small Business
Lending Fund Program and State Small Business Credit Initiative Oversight Reports, at https://oig.treasury.gov/Office-
of-Small-Business-Lending-Fund-Program-Oversight.
56 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, p. 2.
57 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, p. 1.
58 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, p. 3.
59 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, p. 3.
60 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
Programs Participating in the State Small Business Credit Initiative, p. 3.
61 U.S. Department of the Treasury, OIG, Small Business Lending Fund: California Needs to Improve Its Oversight of
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Similarly, Treasury’s OIG found that Michigan had used the majority of the $38.5 million in
SSBCI loans it examined properly, but it identified “approximately $2.524 million in misuse, of
which $2.5 million was used to finance lender purchase transactions that did not involve
extensions of additional credit to borrowers; $3,000 supported a partner buy-out, a prohibited use;
and $21,000 was used to pay the CAP insurance premium on a loan closed and funded prior to
Michigan’s acceptance into the SSBCI program and Treasury’s allocation of funds to the State.”62
The OIG determined the $21,000 used to pay the CAP insurance premium was a “reckless”
misuse of funds that must be recouped. Although the OIG did not find the $2.5 million used to
finance lender purchase transactions that did not involve extensions of additional credit to
borrowers to be a similarly reckless misuse of funds, it did question whether the purchase
transactions were “consistent with the intent of the [Small Business Jobs] Act to help small
businesses expand, grow, and create jobs.”63 It recommended that Treasury develop guidance for
such transactions. In addition, the OIG found $8,506 in administrative expenses charged to the
SSBCI program that were incurred prior to the date Michigan was approved to participate in the
program and notified of its SSBCI allocation. The OIG recommended that those expenses be
disallowed.64
Treasury agreed to issue guidance to address the conditions under which loan purchase
transactions would be permitted.65 Treasury also agreed to recoup the $21,000 used to pay the
CAP insurance premium on a loan closed and funded prior to Michigan’s acceptance into the
SSBCI program and Treasury’s allocation of funds to the state and to disallow the $8,506 in
administrative expenses that were incurred prior to the date Michigan was approved to participate
in the program and notified of its SSBCI allocation.66
Most of the issues raised by the Treasury OIG’s state audits became lessons learned for SSBCI
participants. SSBCI advocates might point to the state’s previous SSBCI experiences as an
indication that there will be fewer implementation problems during round two than there were in
round one. Nevertheless, these previous audits reveal that programs with multiple actors (federal
and state officials, hundreds of lenders and venture capital companies, and thousands of small
businesses) are likely to encounter implementation issues even under the best of circumstances.
Concluding Observations
The original SSBCI was enacted as part of a larger effort to enhance the supply of capital to small
businesses. Advocates argued that the SSBCI would help to address the then-recent decline in
small business lending and create jobs. Opponents were not convinced it would enhance small
business lending and worried about the program’s potential cost to the federal treasury.

Programs Participating in the State Small Business Credit Initiative, p. 3.
62 U.S. Department of the Treasury, OIG, State Small Business Credit Initiative: Michigan’s Use of Federal Funds for
Capital Access and Other Credit Support Programs, December 13, 2012, pp. 2-3, at https://oig.treasury.gov/sites/oig/
files/Audit_Reports_and_Testimonies/OIGSBLF13002.pdf.
63 U.S. Department of the Treasury, OIG, State Small Business Credit Initiative: Michigan’s Use of Federal Funds for
Capital Access and Other Credit Support Programs, p. 3.
64 U.S. Department of the Treasury, OIG, State Small Business Credit Initiative: Michigan’s Use of Federal Funds for
Capital Access and Other Credit Support Programs, p. 3.
65 U.S. Department of the Treasury, OIG, State Small Business Credit Initiative: Michigan’s Use of Federal Funds for
Capital Access and Other Credit Support Programs, p. 13.
66 U.S. Department of the Treasury, OIG, State Small Business Credit Initiative: Michigan’s Use of Federal Funds for
Capital Access and Other Credit Support Programs, pp. 15-16.
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It is difficult to determine the full extent of the program’s effect on small business lending. As
mentioned, as of December 31, 2016, states had spent or obligated about 88% of the $1.45 billion
available ($1.27 billion of $1.45 billion), which is sufficient to provide some insight. For
example, as mentioned, Treasury reported that SSBCI funds supported more than 21,000 loans
and investments in small business amounting to over $10.7 billion, with more than 80% of the
funds and investments made to small businesses with 10 or fewer full-time employees. Treasury
also reported that small businesses indicated that SSBCI funds helped them to create or retain
240,669 jobs (79,193 new jobs and 161,476 retained jobs).67 But, as Treasury also noted,
determining the SSBCI’s influence on small business lending is likely to be more suggestive than
definitive because differentiating the SSBCI’s effect on small business lending from other,
exogenous factors, such as changes in the lender’s local economy and changes in the demand for
small business loans, is methodologically challenging, especially given the relatively small
amount of financing involved relative to the national market for small business loans.68 As
mentioned, the SSBCI’s $1.5 billion in financing at that time represented about 0.24% of
outstanding nonagricultural small business loans.
Treasury’s OIG’s audits of 24 states’ implementation of their SSBCI programs suggest that many
states experienced difficulty reaching full compliance with the program’s administrative
requirements, which were designed to reduce the likelihood of loan defaults, investment losses,
and fraudulent use of funds. That should be less of an issue during round two, because states now
have experience with, and are accustomed to, the SSBCI’s rules and regulations. However, given
the relatively large increase in proposed funding, the large number of small business investment
programs receiving SSBCI funding, and the large number of entities involved in the program
(state officials, hundreds of lenders and investment companies, and thousands of small
businesses), SSBCI program oversight is likely to remain a congressional interest.

67 U.S. Department of the Treasury, State Small Business Credit Initiative: A Summary of States’ 2016 Annual Reports,
pp. 3, 15, at https://www.treasury.gov/resource-center/sb-programs/Documents/
SSBCI%20Summary%20of%20States%20Annual%20Report%202016_508%20Compliant.pdf.
68 U.S. Treasury, “Correspondence with the author,” June 22, 2012.
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Appendix. The Original SSBCI’s Legislative Origins
On January 27, 2010, then-President Obama announced in his State of the Union Address that
because “financing remains difficult for small business owners across the country, even those that
are making a profit,” he would send Congress several legislative proposals designed to enhance
small business access to capital, including a proposal to establish a $30 billion Small Business
Lending Fund (SBLF).69 On May 7, 2010, the Obama Administration sent Congress draft
legislation to establish the SBLF and the State Small Business Credit Initiative (SSBCI).70
On May 13, 2010, Representative (now Senator) Gary Peters introduced H.R. 5302, the State
Small Business Credit Initiative Act of 2010. The bill would have authorized a $2 billion SSBCI
modeled on the President’s SSBCI proposal. That same day, then-Representative Barney Frank,
then-chair of the House Committee on Financial Services, introduced H.R. 5297, initially titled
the Small Business Lending Fund Act of 2010. Based on the President’s SBLF proposal, the bill
was designed to encourage lending to small businesses by creating a $30 billion SBLF to make
capital investments in eligible community banks with total assets of less than $10 billion.71 On
May 18, 2010, the Committee on Financial Services held a hearing on H.R. 5297 and the
following day, approved the bill, 42-23, as amended.72 Perhaps the most significant amendment
approved was an amended version of the $2 billion State Small Business Credit Initiative Act of
2010. It was approved by a vote of 39-23.73
SBLF and SSBCI advocates argued that the programs were necessary because “many companies,
particularly small businesses, claim that it is becoming harder to get new loans to keep their
business operating and that banks are tightening requirements or cutting off existing lines of even
when the businesses are up to date on their loan repayments.”74 In their view, the SBLF and
SSBCI would promote economic growth and job creation by enhancing small business access to
capital.
The House Committee on Financial Services’ Republicans indicated in the report accompanying
H.R. 5297 that they “were unanimous in our opposition to this misguided legislation.”75 They

69 U.S. President (Barack Obama), “Remarks by the President in State of the Union Address,” January 27, 2010, at
https://obamawhitehouse.archives.gov/the-press-office/remarks-president-state-union-address.
70 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, report to accompany H.R. 5297, 111th Cong., 2nd
sess., May 27, 2010, H.Rept. 111-499 (Washington, DC: GPO, 2010), p. 17.
71 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 18.
72 U.S. Congress, House Committee on Financial Services, Incentives to Promote Small Business Lending, Jobs, and
Economic Growth, 111th Cong., 2nd sess., May 18, 2010, Serial no. 111-137 (Washington, DC: GPO, 2010).
73 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, report to accompany H.R. 5297, 111th Cong., 2nd
sess., May 27, 2010, H.Rept. 111-499 (Washington, DC: GPO, 2010), pp. 21, 22.
74 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 16.
75 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 18.
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argued that the SBLF and SSBCI did not address what they considered to be the core issue
affecting small business job creation during the economic recovery—the need to stimulate
demand for credit by small businesses.76 They argued that the bill would fail to help small
businesses or create jobs, would succeed in adding billions of dollars to the national debt, and
concluded that “the solutions to America’s economic problems do not lie in more taxpayer-
funded bailouts.”77 Instead of supporting federal spending programs to enhance small business
access to capital, they advocated an extension of a series of small business tax credits as a more
effective means to stimulate small business job creation and economic growth.78
On June 14, 2010, the House Committee on Rules issued a rule for H.R. 5297 (H.Res. 1436),
which provided that “in the engrossment of H.R. 5297, the Clerk shall add the text of H.R. 5486,
as passed by the House, at the end of H.R. 5297 and that H.R. 5486 shall be laid on the table.”79
H.R. 5486, To Amend the Internal Revenue Code of 1986 to Provide Tax Incentives for Small
Business Job Creation, and for Other Purposes, included several tax incentives for small
businesses and several revenue-raising provisions designed to offset the costs of the tax
incentives. Also, at that time, the House Committee on Rules posted on its website legislative
language for a proposed amendment in the nature of a substitute to H.R. 5297, as reported, which
included a proposed $1 billion Small Business Early-Stage Investment Program.
On June 17, 2010, the House passed H.R. 5297 by a vote of 241-182. The engrossed bill, retitled
the Small Business Jobs and Credit Act of 2010, included the language in H.R. 5486 and the
Small Business Early-Stage Investment Program, as well as the $30 billion SBLF and $2 billion
SSBCI.
The arguments presented in the House report accompanying the bill, both for and against the
bill’s passage, also were presented during House floor debate. For example, advocates argued that
the SSBCI would “increase small business lending which will retain and create jobs.”80
Opponents argued that the bill “is repeating the same failed initiatives that have helped our
national debt grow to $13 billion in the past two years” and did not address what they viewed as
the top problem facing small businesses—“the lack of sales and demand.”81
The House-passed version of H.R. 5297 was placed on the Senate Legislative Calendar on June
18, 2010. Following a series of votes on motions to invoke cloture on several amendments in the
nature of a substitute to H.R. 5297 and the August recess, the Senate passed an amended version
of the bill (S.Amdt. 4594, an amendment in the nature of a substitute for H.R. 5297) on

76 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 37.
77 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 38.
78 U.S. Congress, House Committee on Financial Services, To Create the Small Business Lending Fund Program to
Direct the Secretary of the Treasury to make Capital Investments in Eligible Institutions in order to Increase the
Availability of Credit for Small Businesses, and for other Purposes, p. 38.
79 H.Res. 1436. A second rule (H.Res. 1448) was issued on June 16, 2010, to allow consideration of two amendments
that were revised to comply with House “pay-go” rules.
80 Rep. Melissa Bean, “The Small Business Jobs and Credit Act of 2010,” House debate, Congressional Record, vol.
156, no. 90 (June 16, 2010), p. H4514.
81 Rep. Randy Neugebauer, “The Small Business Jobs and Credit Act of 2010,” House debate, Congressional Record,
vol. 156, no. 90 (June 16, 2010), p. H4514, H4515.
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September 16, 2010, by a vote of 61-38.82 The Senate-passed version of the bill, which included
the SSBCI but funded at $1.5 billion instead of $2 billion, was passed by the House on September
23, 2010, by a vote of 237-187. The enrolled bill, retitled the Small Business Jobs Act of 2010,
was signed into law (P.L. 111-240) by President Obama on September 27, 2010.83
The arguments presented during Senate floor debate, both for and against the bill’s
passage, were similar to those presented during House floor debate. One difference was a
greater emphasis by the bill’s advocates in the Senate on the SSBCI’s support of state
loan collateral programs. Several Senators argued that the SSBCI’s support of state loan
collateral programs was needed because, as one Senator pointed out, “just as the
recession has battered the value of our homes, it has also battered the value of business
property such as real estate, factories, and equipment. That has damaged the ability of
small businesses to get bank financing because it has lowered the value of property they
can offer as collateral.”84

82 On June 29, 2010, cloture on a motion to proceed to H.R. 5297 was invoked in the Senate by a vote of 66-33. That
same day, Sen. Harry Reid proposed a motion to commit H.R. 5297 to the Senate Committee on Finance with
instructions to report back forthwith S.Amdt. 4407, an amendment in the nature of a substitute, which included the
Small Business Lending Fund (SBLF) and most of the provisions later included in S.Amdt. 4594. In response to
perceived opposition to the SBLF, S.Amdt. 4407 was withdrawn on July 21, 2010. In its place, Sen. Harry Reid
proposed for Sen. George LeMieux S.Amdt. 4500, to establish the Small Business Lending Fund Program. He also
proposed for Sen. Max Baucus S.Amdt. 4499, an amendment in the nature of a substitute, which contained S.Amdt.
4407, with modifications, minus the SBLF. On July 22, 2010, cloture on S.Amdt. 4500 was invoked in the Senate, by a
vote of 60-37. On July 27, 2010, Sen. Harry Reid withdrew S.Amdt. 4500 and introduced for Sen. Max Baucus
S.Amdt. 4519, which included the SBLF, the provisions in S.Amdt. 4499, with modifications, $1.5 billion in
emergency disaster agricultural assistance, and additional revenue offsets. On July 29, 2010, a motion to invoke cloture
on S.Amdt. 4519 failed by a vote of 58-42. Debate on the motion focused on differences concerning the SBLF and the
number of amendments to be offered. On August 5, 2010, Sen. Harry Reid introduced for Sens. Max Baucus and Mary
Landrieu S.Amdt. 4594, an amendment in the nature of a substitute. It contained the provisions in S.Amdt. 4519,
except that it removed a provision to eliminate the advance payment option for the earned-income tax credit that would
have raised $1.1 billion, removed a provision that would have reallocated $500 million in future spending from P.L.
111-5, the American Recovery and Reinvestment Act of 2009, and removed a provision to provide $1.5 billion in
emergency agricultural assistance funding. On September 14, 2010, the Senate invoked cloture on S.Amdt. 4594, by a
vote of 61-37, and passed it on September 16, 2010, by a vote of 61-38. See Sen. Harry Reid, “Text of Amendments:
SA 4519,” Congressional Record, vol. 156, no. 111 (July 27, 2010), pp. S6309-S6337; Sen. Kay Hagan, “Motion to
Invoke Cloture on amendment No. 4519,” Roll Call Vote No. 221 Leg., Congressional Record, vol. 156, no. 113 (July
29, 2010), p. S6473; Sen. Harry Reid, “Small Business Lending Fund Act of 2010,” Remarks in the Senate,
Congressional Record, vol. 156, no. 113 (July 29, 2010), pp. S6472, S6473; Sen. Mitch McConnell, “Small Business
Lending Fund Act of 2010,” Remarks in the Senate, Congressional Record, vol. 156, no. 113 (July 29, 2010), pp. S
6472, S6473; Sen. Kay Hagen, “Motion to Invoke Cloture on H.R. 5297, the Small Business Lending Fund Act of
2010,” Rollcall Vote No. 236 Leg., Congressional Record, daily edition, vol. 156, part 125 (September 16, 2010), p. S
7158; and Sen. Al Franken, “Small Business Lending Fund Act of 2010,” Rollcall Vote No. 237 Leg., Congressional
Record, daily edition, vol. 156, part 125 (September 16, 2010), p. S7158.
83 Sen. Al Franken, “Small Business Lending Fund Act of 2010,” Rollcall Vote No. 237 Leg., Congressional Record,
daily edition, vol. 156, part 125 (September 16, 2010), p. S7158.
84 Sen. Carl Levin, “Small Business Lending Fund Act of 2010,” remarks in the Senate, Congressional Record, vol.
156, part 124 (September 15, 2010), p. S7123.
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Author Information

Robert Jay Dilger
Adam G. Levin
Senior Specialist in American National Government Analyst in Economic Development Policy

Grant A. Driessen

Specialist in Public Finance

Disclaimer
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under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
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