The case, in numbers
The leak
When a community bank sells the guaranteed portion of an SBA 7(a) loan, the premium it may keep is capped at 110 — half of anything above goes back to SBA. A strip of about 1.00% a year leaves with the sale. Pools of guaranteed loans — the institutional-grade product — require at least four loans and $1 million of guaranteed principal, a threshold a bank making a handful of loans a year cannot reach, so it takes an outside broker's bid or doesn't sell at all. And it keeps, always: the unguaranteed slice, all of the servicing, and all of the risk that the guaranty will be repaired or denied.
The Bureau of Indian Affairs loan guaranty program — the one written for Indian Country, up to 90% guaranteed, with a $1.5 billion statutory cap — has no secondary market at all. It typically guarantees 22 to 35 loans a year.
The fix
A Guarantee Desk, operated inside a bank services corporation owned by the member banks themselves under the Bank Service Company Act (12 U.S.C. §§ 1861–1867): aggregated execution and pool assembly, institutional-grade program administration, and a guaranty-defense quality-control function on every file — with servicing that never leaves the originating bank. Because the costs are shared, the same company carries the highly technical compliance services — BSA/AML, examination evidence, Opportunity Zone reporting — that no small bank can staff alone.
According to the research record behind this program, no such member-owned wholesale layer has ever been built for America's tribal and Black-owned banks. A sister company opens partnership participation to tribal governments, CDFIs, and credit unions, and a bankers' bank charter (12 U.S.C. § 27(b)) is the later stage, when volume earns it.
The roadmap
Roll-up investment packages of government-guaranteed paper for insurance companies and other institutional investors. Treasury products built for the buyers who now hold government securities at the largest scale — including stablecoin companies. Real-world-asset tokenization inside the regulated perimeter. Custody with two-of-three multi-signature control. Each stage gated on the law and the licenses it requires — stages, not promises.
The card program — the grease
The desk is the anchor. The card program is what brings tribal governments and political support to the table. The federal government disbursed about $1.91 billion in Indian trust funds in FY2025 — $825 million of it through Individual Indian Money accounts, roughly 388,000 accounts holding $1.63 billion (audited figures: KPMG, via the Interior Department's Inspector General). The debit cards carrying that money are issued today by Pathward and Flagstar under a U.S. Treasury program — no Native or minority bank participates at any point. Tribal per-capita distributions move the same way: Warm Springs and Suquamish both moved their citizens' payments onto non-Native card issuers in 2025.
The consortium's card program — one national platform, issued through member minority banks — is built for those flows: financial-agent readiness on the federal side, Buy Indian priority where Interior itself buys, and per-capita programs won tribe by tribe. A citizen's per-capita card with a Native bank's name on it is the visible proof that this institution moves real money for real communities.
The coalition
Founding recruitment starts where the banks and the need already coincide: eastern Oklahoma (ten of the twenty Native MDIs), Robeson County, North Carolina, and the Michigan corridor (Detroit to the Upper Peninsula). A consortium Academy — mentorship for the desk's craft, and self-paced online education across all areas of banking — trains the workforce from the communities served.
This page presents a planning program and published research. It is not an offer of securities, not investment advice, and not a solicitation. Figures are drawn from FDIC, Federal Reserve, NCUA, CDFI Fund, SBA, and GAO sources as dated in the program's research, October 2026, and from the KPMG audit of the Indian trust funds transmitted by the U.S. Department of the Interior, Office of Inspector General (Report 2025-FIN-021), November 2026 update.