Treasury, The Tribal Housing Stability Report
Summary
Treasury's Tribal Housing Stability Report, dated December 2023 and written by its Office of Tribal and Native Affairs, on supporting Tribal housing stability with pandemic response funds. It focuses on the SLFRF, HAF and ERA1 programs and notes that the American Rescue Plan Act (ARPA) included a set aside of approximately $21.5 billion for Tribal governments. Chapters cover Tribal consultation, the state of housing in Indian Country, investing recovery funding in Tribal housing needs, housing stabilization, home preservation and new housing construction by Tribal governments and Tribally Designated Housing Entities (TDHEs). It quotes the U.S. Commission on Civil Rights (USCCR) 2018 report Broken Promises on the economic challenges Indian Country faces.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Treasury, The Tribal Housing Stability Report.”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-the-tribal-housing-stability-report-858849dd5c/
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TRIBAL HOUSING STABILITY REPORT
SUPPORTING TRIBAL HOUSING STABILITY
WITH PANDEMIC RESPONSE FUNDS
DECEMBER 2023
TRIBAL HOUSING STABILITY REPORT
SUPPORTING TRIBAL HOUSING STABILITY WITH
PANDEMIC RESPONSE FUNDS
DECEMBER 2023
Note: The Tribal Housing Stability Report presents Treasury’s federal financial assistance programs aimed at meeting
a range of Tribal housing needs. Eligible use projects and services (e.g., home preservation, housing stability services
and needs, and essential home repairs to maintain habitability of a home) are not distinctly categorized among the
HAF, SLFRF, LATCF, and ERA1 programs. For information about specific eligible uses categories and other program
requirements, Tribal governments, as well as other readers of the report, should refer to the SLFRF final rule and
program guidance and the LATCF, HAF, and ERA1 programs’ guidance available at https://home.treasury.gov/policy-
issues/coronavirus. Please contact Treasury’s Office of Tribal and Native Affairs at tribal.consult@treasury.gov if you
have questions about the data provided in this report.
Photo Credit of Secretary Yellen by Kevin Abourezk
CONTENTS
Introduction................................................................................................... 1
Tribal Consultation Engagement to
Promote Equitable Outcomes.................................................................. 3
State of Housing in Indian Country. ..................................................... 6
Investing Recovery Funding to
Address Tribal Housing Needs................................................................ 10
Housing Stabilization................................................................................. 13
Home Preservation...................................................................................... 14
New Housing Construction. ..................................................................... 16
Continuing to Support Tribal Housing Stability............................... 18
About the Office of Tribal and Native Affairs.................................... 19
Introduction
On President Biden’s first day in office, he signed funding is administered by the Office of Recovery
Executive Order 13985 – Advancing Racial Equity and Programs (ORP) within Treasury. ARPA authorized five
Support for Underserved Communities Through the critical Tribal recovery programs: Coronavirus State
Federal Government. This executive order calls for a and Local Fiscal Recovery Funds (SLFRF), Homeowner
comprehensive approach for the Federal government Assistance Fund (HAF), Local Assistance and Tribal
to prioritize fairness and equity for all, including for Consistency Fund (LATCF), State Small Business Credit
people of color and others who have been historically Initiative (SSBCI), and Capital Projects Fund (CPF).
underserved, and to embed these principles into the ORP oversees two additional recovery programs for
implementation of Federal programs and services. Tribes – Emergency Rental Assistance (ERA1)1 and the
Coronavirus Relief Fund (CRF)2 that were authorized
Included in these efforts, the Biden-Harris
by legislation enacted before ARPA and implemented
Administration championed equity through the
by the Biden-Harris Administration. These programs
landmark American Rescue Plan Act (ARPA). The ARPA
are intended to assist Tribal governments, their
contained economic and recovery programs managed
communities, Tribal citizen-owned businesses, and
by the U.S. Department of the Treasury (Treasury),
households with accessing relief.
including a set aside of approximately $21.5 billion for
Tribal governments. This historic pandemic relief
TABLE 1
Summary of Tribal Grantee Recovery Funding Data
1 Two separate ERA programs have been established: the ERA1 program was authorized by the Consolidated Appropriations Act of 2021.
The ERA2 program was authorized by the American Rescue Plan Act of 2021. ERA1 awards were provided directly to Tribal governments or
their Tribally Designated Housing Entities, states, the District of Columbia, U.S. territories, and certain local governments with 200,000 or
more residents, and in the case of ERA2, the awards were provided directly to states, the District of Columbia, U.S. territories, and certain
local governments.
2 The Coronavirus Relief Fund was authorized by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
1
Secretary Yellen and Treasurer Chief Lynn Malerba meeting with a Tribe in the Great Plains. Photo Credit Kevin Abourezk
To support the implementation of these programs avoid foreclosure and eviction, stabilize the country’s
for Tribal governments and other Tribal entities, the housing market, and improve the nation’s economy
Secretary of the Treasury, Janet L. Yellen, created as it recovers from the effects of the COVID-19
the Office of Tribal and Native Affairs, which is pandemic. The Report features housing construction,
overseen by the Treasurer of the United States, Chief preservation, and stability projects and services
Marilynn Malerba, the first Native American to hold planned or underway by Tribal governments and
this position. The Office’s purpose is to serve as a Tribally Designated Housing Entities (TDHEs) to reduce
permanent hub for Tribal policy within Treasury. This barriers to affordable housing and keep people in
Tribal Housing Stability Report (Report), authored their homes. The highlighted housing projects and
by the Office of Tribal and Native Affairs, focuses housing stability services are among many that Tribal
on the SLFRF, HAF, and ERA1 programs, which are recipients have invested in with their SLFRF, HAF, and
a critical part of the Biden-Harris Administration’s ERA1 awards.
broad strategy to help homeowners and renters
2
Tribal Consultation Engagement to Promote
Equitable Outcomes
Treasury is committed to strengthening its relationships The U.S. Commission on Civil Rights (USCCR) 2018
with Tribal governments and Indian Country.3 Executive report,4 Broken Promises, reported:
Order 13175 and President Biden’s Memorandum
for Tribal Consultation and Strengthening Nation-to- “Indian Country faces many economic
Nation Relationships charge Treasury with engaging in development challenges. Over 25 percent of
regular, meaningful, and robust consultation with Tribal Native Americans live in poverty, which is higher
officials. Consultation recognizes Tribal sovereignty and
than the poverty rate of any other racial group
the political Nation-to-Nation relationship between the
in the U.S. Approximately 12 percent of Native
United States and Tribal Nations. It acknowledges that
the United States maintains certain treaty and trust Americans are unemployed, more than double
responsibilities to Tribal Nations. the national average. For Native Americans
living on reservations, the unemployment rate is
Honoring these commitments, Treasury prioritized
around 50 percent, and for certain reservations,
Tribal engagement and feedback to better understand
and respond to Tribes regarding requirements set the average unemployment rate is much higher,
forth in applicable regulations, legislative comments, hovering around 80 percent and up…”
proposed legislation, and policy statements that have
Tribal implications, as well as those having a direct To that end, Treasury recognized that pandemic
and identifiable economic impact on Tribes or that responses funded by ORP programs would need to
preempt Tribal law. The Office of Tribal and Native be adapted to varying needs across Indian Country.
Affairs, in partnership with ORP, conducted nine Tribal To promote more equitable outcomes and a stronger
consultations on ORP programs, held over 300 one- recovery, Treasury sought ways to support self-
on-one sessions, and partnered with the White House governance and self-determination by increasing
Council on Native American Affairs and numerous flexibility in Tribes using their award funds under ORP
Tribal-led national and regional organizations to programs and decreasing administrative burdens
provide direct engagement. where possible.
A key consideration throughout the development Tribes form for-profit businesses to fund the provision
of ORP’s program regulations, published guidance, of government services to their citizens, to support
and other actions has been ensuring fairness and public safety, road and infrastructure maintenance,
promoting equitable outcomes. Tribal leaders housing, education, social services, healthcare,
expressed in each consultation that business closures and other programs and projects that benefit the
caused significant deterioration to the Tribal economy, community. Unlike state and local governments,
adding to preexisting unmet needs. At the start of the Tribes have the additional responsibility of restoring
pandemic, Native Americans faced overcrowding in language, preserving culture and traditions, and
homes and an inequity in healthcare services and safeguarding sacred sites. Tribes generally have no
health status as compared to other Americans. Beyond property tax base to fund these government services
healthcare, other determinants such as education, because the United States owns trust lands. Further,
access to nutritious foods, criminal and social justice over 40 percent of Tribal governments are located
issues, and unemployment contributed to inequities.
3 In this Report, the term “Indian Country” is used to mean Tribal areas, including Alaska Native Villages.
4 U.S. Commission on Civil Rights. (2018). Broken Promises: Continuing Federal Funding Shortfalls for Native Americans.
3
Unlike state and local governments, Tribes have the additional responsibility of restoring language, preserving culture and traditions,
and safeguarding sacred sites.
in states5 that do not have a sales tax, which makes household income was at or below 80 percent of
instituting Tribal sales tax an unreliable revenue Area Medium Income (AMI). In response, Treasury
strategy. As a result, Tribes rely on for-profit business permitted Tribal entities under the ERA1 program
revenue in place of a solid tax base. Over 30 percent to rely on the methodology authorized by the U.S.
of Tribal businesses reported laying off or furloughing Department of Housing and Urban Development
80 to 100 percent of their workforce at the beginning (HUD) for its Indian Housing Block Grant8 (IHBG)
of the pandemic.6 The financial viability of some of program to determine the AMI for Tribal members
these businesses was threatened, especially for those applying for ERA1 assistance. By aligning with IHBG,
businesses that were already operating on small profits Tribes could serve more families facing homelessness.
because of their intent7 to provide governmental Following this practice, the HAF program also used
services and create jobs for the community. IHBG as one of the methodologies to determine
eligibility. Alongside work to strengthen its guidance,
Tribal leaders shared that including Tribal
Treasury moved to improve program capacity. In
government-owned businesses in the definition
consultations, Tribal leaders in areas with limited
of “general revenue” in the SLFRF 2022 Final Rule
broadband access explained that despite significant
was of utmost importance to creating economic
progress in them making contractual obligations
recovery and growth. The SLFRF 2022 Final Rule
to pay rental assistance to eligible households
also provided recipients the option to either elect a
and employing every effort possible to fast-track
standard allowance of up to $10 million or complete
applications submitted for assistance, it was
a full revenue loss calculation. The standard
challenging to kick off the ERA1 program during
allowance option dramatically simplified the program
the height of the pandemic, which impacted the
administration and ease of use, with 54 percent of
pace at which the ERA assistance was disbursed to
Tribal governments having a total SLFRF award of
eligible households. Subsequently, Treasury did not
under $10 million.
involuntarily recapture unused ERA1 award funds
Early on, Treasury heard from Tribal leaders that low- from Tribes as part of the statutory reallocation
income families living in overcrowded households process while Tribes’ programs were still in progress
were declined for ERA1 assistance. These families but instead provided a reasonable approach to a
would have qualified for assistance if their overall voluntary return of unused ERA1 award funds.
5 There are 248 Tribes in states with no general statewide sales tax: Alaska, Montana, and Oregon.
6 Lozar, C., Colombe, J., Feir, D. (2020). Federal Reserve of Minneapolis, Center for Indian Country Development. COVID-19: A deep economic
crisis in Indian Country.
7 GASB Codification 2600.116.
8 See HUD Office of Native American Programs, Program Guidance No. 2021-01, June 22, 2021.
4
Some Tribes quickly exhausted their ERA1 award with a large population of citizens at risk of eviction
funds but still had a high need for the ERA1 assistance and demonstrated success in implementing their ERA1
in their communities. Treasury listened to concerns awards. Over $85 million in ERA1 award funds from
and recommendations from Tribal leaders and states and Tribes that were voluntarily returned to
incorporated comments into the ERA1 reallocation Treasury were reallocated to other Tribes that may have
process. Treasury established an internal process to otherwise gone unused, ensuring rapid deployment of
reallocate the unused ERA1 award funds to Tribal areas resources across Indian Country. For example:
• The Chippewa Cree Housing Authority was
awarded ERA1 reallocation funding to continue
supporting families after it had expended its
original award. Each of the 725 households
assisted had the opportunity to receive
financial education. Intending to improve
housing stability, applicants received financial
education materials and had check-ins with
housing staff members.
Treasury officials and CFPB Director Rohit Chopra toured the • The White Mountain Apache Housing
ancient Pueblo of Acoma, where the traditional Puebloan Authority is located in rural Arizona, where
housing and cultural structures served as a model for modern the area median income for a household is
Tribal apartments.
$16,3139. After successfully administering its
ERA1 award, the Housing Authority received
• The Pueblo of Acoma Housing Authority’s
ERA1 reallocation funding. The Housing
mission is to create housing opportunities
while embracing the traditions and culture of Authority took a multi-pronged outreach
the people. As such, it focused on community approach to ensure all citizens needing
engagement and outreach to target populations emergency rental and utility services knew
needing ERA1 assistance and to structure about its ERA program. Staff hand-delivered
the program to maximize the delivery of rent applications to elders, people with disabilities,
and utility support in a culturally appropriate and those who do not have transportation to
way. With the addition of two rounds of ERA1 help explain the program and assist citizens
reallocation funding, the Housing Authority was with applying for the ERA assistance. As a
also able to partner with local governments result, the Housing Authority provided nearly
to target Tribal members who were unhoused $9 million in services to those in danger of
or living in hotels to get them into apartments facing evictions and disconnection of utility
and provide stable rental homes for citizens in services.
recovery rehabilitation programs.
9 The University of Arizona-Native American Advancement, Initiatives and Research. (2018). White Mountain Apache Tribe Community
Profile: https://naair.arizona.edu/white-mountain-apache-tribe
5
Tribal leaders and their representatives also related financial hardships and household income.
emphasized the need to reduce the administrative Additionally, Treasury created Tribal-specific
burden of implementing their ERA1 and HAF awards reporting requirements10 for ERA1 and HAF awards
received from Treasury. Treasury’s goal has been and hosted weekly open office hours to support the
to accelerate support and maximize available implementation of the Tribal recipients’ housing
resources for homeowners and renters. Consistent programs. These and other modifications provided
with that goal, Treasury permitted Tribal recipients flexibility so that each government has discretion on
to serve qualifying Tribal citizens wherever they the best use of funds and has greater autonomy and
lived and allowed self-attestation of COVID-19- responsibility in implementing their recovery plans.
State of Housing in Indian Country
Stable housing is one of the primary factors driving10 The “Termination Era” radically changed the lives of
economic well-being in Tribal communities. It is often many Native Americans. From 1953-1968, Congress
cited as an important social determinant of health,11 “terminated” or withdrew federal recognition of over
recognizing a range of ways that overcrowding, 100 Tribal governments, which ended the federal aid
poor housing conditions, and a lack of housing can and services that came with recognition. Over 3 million
negatively affect health and well-being. Complex legal acres of land12 were relinquished during this period.
and other constraints, such as fractionated land, are After the termination policy ended under President
critical to understanding the housing problems and Richard Nixon, many Tribes fought a long, complex, and
needs on Tribal lands. costly legal battle to regain federal recognition. Few
have had their lands restored, while most have not.
Federal policies, including the General Allotment Act of
1887 (also called the Dawes Act), resulted in 90 million Recently, there has been a “land back” movement
acres of Indian land taken out of Indian ownership across Indian Country where Tribes are acquiring their
and control, with 60 million being sold or transferred ancestral lands through private capital and federal
to non-Indians. Later, the Burke Act of 1906, gave programs. Because Tribes have been deprived of the
the Secretary of the Interior the power to issue fee- vast majority of their traditional land base, purchasing
simple titles to any Indian deemed “competent and back lands near or adjacent to their reservations
capable” regardless of Tribal citizenship, thus making is a shared priority. Tribes have commented that
even more Indian land available for sale or lease. As landowners will often take advantage of this fact
a result, some of the reservation land remaining was and charge a premium to the prospective Tribal
divided up and allotted to individual Tribal members, purchaser.13 Today, the 56 million acres of reservation
causing a “checkerboard” pattern of land status. land currently under Indian ownership is held in
Checkerboarding impairs the ability of Tribes and trust for Indian people by the federal government.
individual Tribal citizens to use the land for housing, Consequently, the Secretary of the Interior must
ranching, and other economic development that approve nearly all land-use transactions, including
requires contiguous sections of Indian trust land. leasing to potential homeowners, consolidating and
selling trust land, and business development.
10 Tribes allocated less than $5 million in HAF award funds must only submit the third quarter report (Quarterly) and the Annual Report
once a year. Tribes that are allocated more than $5 million in HAF award funds must submit the Quarterly report four times a year and the
Annual Report once a year. For ERA1, demographic data collection was reduced for Tribal recipients.
11 World Health Organization. (2008). Closing the gap in a generation: Health equity through action on the social determinants of health.
12 National Archives. Bureau of Indian Affairs Records: Termination. (July 2023). https://www.archives.gov/research/native-americans/bia/termination.
13 Treasury Tribal Consultation on the Tax Status of Tribally Chartered Corporations. (June 2023). https://home.treasury.gov/system/
files/136/Tax-Status-of-Tribally-Chartered-Corporations-Consultation-Summary.pdf
6
According to HUD, Indian Country had a deficit made it challenging to socially distance. Many Tribal
of 68,000 housing units as of 2015, which is likely citizens living on reservations could not work from
undercounted.14 In the USCCR’s Broken Promises home due to a lack of broadband access and having
report,15 it was noted that flat funding of HUD a larger proportion of service-oriented roles. These
programs combined with inflation in construction factors created additional exposure to the virus, with
costs over time has resulted in a sharp decrease in people crowded together in the evening and on the
the number of affordable housing units developed frontlines during the day.
in Indian Country in recent years. According to HUD,
unless additional funding is allocated for its programs, TABLE 2
affordable housing development and assistance Native American Population Growth19
services in Indian Country “will continue to erode.”16
Compounding the housing problems due to land
constraints and insufficient federal funding is the
fact that the Native American population is rapidly
growing. To assess overcrowding and the housing
shortage, it is important to note that the Native
American population is growing at twice the rate of
the national average. In 2020, the number of people
who identified as Native American and Alaska Native
alone and in combination with another race was 9.7
million.17 Approximately 60 percent of Native people
live on or near reservations, with 30 percent nationally TABLE 3
being younger than 18 compared to 24 percent for the 65.2% of those who live in overcrowded housing also
non-Native population. live with an essential worker20
Nationally non-native households have just 2.2
percent overcrowding, whereas 16 percent of
households on a reservation are overcrowded.
Living with extended family is common in Tribal
communities to prevent homelessness. The role of
multigenerational households and overcrowded
homes was a risk factor for developing more severe
forms of COVID-19,18 since reduced personal space
14 U.S. Department of Housing and Urban Development. (2017). Housing Needs of American Indians and Alaska Natives in Tribal Areas: A
Report from the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs.
15 U.S. Commission on Civil Rights. (2004). Broken Promises: Evaluating the Native American Health Care System.
16 HUD, F.Y. 2017 Congressional Justifications, supra note 795, at 11-5.
17 U.S. Census Bureau. (2020). 2020 Census Results.
18 U.N. Emeruwa, S. Ona, J.L. Shaman, et.al. (2020). Associations between built environment, neighborhood socioeconomic status, and
SARS-CoV-2 infection.
19 U.S. Census Bureau reported that it undercounted approximately 4.9% of the Native American population in prior counts at U.S. Census
Bureau. (2012). Census Bureau Releases Estimates of Undercount and Overcount in the 2010 Census. [CB12-95]. https://www.census.gov/
newsroom/releases/archives/2010_census/cb12-95.html
20 IPUMS-USA; University of Minnesota.
7
Additionally, families in Tribal communities are five Alaska Native Villages in particular face uncommon
times more likely to live in poor housing conditions circumstances in obtaining home building supplies
than the general population.21 For instance, and challenges with maintaining their homes. Over
Tribal area households lack basic plumbing, face 70 percent of Alaska communities are not connected
mold issues, and are 1,200 times more likely to by roads,25 with most dependent on costly barge
have heating problems. Many homes have other shipments and air service for materials and services.
condition problems, defined as having at least five The unique conditions of Alaska’s hard-to-reach
of the following maintenance problems: leaks from villages, some accessible only by plane throughout the
outdoors, holes in the floor, holes or open cracks in year or boat in summer months, contribute to lengthy
the walls or ceiling, more than one square foot of delays in fire services. In some cases, homeowner
peeling paint or plaster, rats in the past 90 days, or insurance companies will not offer policies or
leaks from the inside (such as broken pipes or water will do so at a premium because fire protection
heaters, backed up plumbing, or water from another and emergency services are limited. The lack of
unit22). More than 56 percent of Tribal area households homeowner insurance options can be a barrier to
also have one or more identified housing problems obtaining home loans.
of any kind, compared with 40 percent of the United
Citizens living in Tribal communities also face
States overall.23 Other specific inadequacies include
development barriers with remodeling and
broken heating equipment and having no electricity
constructing new housing because of insufficient
or other electrical problems. The hardest hit Tribal
infrastructure for water, sewer, electricity, gas, and
communities are those with harsh weather conditions
roads. Home ownership or construction on existing
– Alaska, the Great Plains, and the Southwest.
homes can be obstacles because both depend
These staggering statistics represent longstanding
on access to private capital. In 2016, a report26
challenges facing Tribes and a lack of sufficient
commissioned by Treasury’s Community Development
investment to address these challenges.
TABLE 4
Housing Problems in Tribal Areas24
Native American Housing in Tribal Areas Total US
Facilities Problems
Heating 12.00% 0.10%
Kitchen 6.60% 1.70%
Plumbing 5.60% 1.30%
Electrical 1.10% 1.40%
Conditions Problems 8.10% 0.08%
21 U.S. Department of Housing and Urban Development. (2017). Housing Needs of American Indians and Alaska Natives in Tribal Areas: A
Report from the Assessment of American Indian, Alaska Native, and Native Hawaiian Housing Needs.
22 Id. at 66.
23 Id. at 68.
24 Urban Institute Household Survey 2013-2015. American Housing Survey, 2013.
25 Alaska Rural Health Plan. (2001). Alaska’s Plan for Participating in the Medicare Rural Hospital Flexibility Program.
26 The University of Arizona, Native Nations Institute. (2016). Access to Capital and Credit in Native Communities.
8
Financial Institutions Fund (CDFI Fund) identified however, trust land bureaucratic processes can
that financial institutions were hesitant to provide seriously delay closing. Certified Title Status Reports
lending services in Indian Country due to a poor (TSRs) from the Bureau of Indian Affairs (BIA) are
understanding of Tribal sovereignty, the absence required for underwriting trust land home mortgages
of a politically independent judicial and dispute and for selling those mortgages into the secondary
resolution system, and the lack of certainty in Tribal market.28 These transactions require that holders
commercial law. Trust land and jurisdictional issues of trust land receive a leasehold interest from the
also contribute to the higher cost of home financing Tribe to use collateral and then go through various
and the reliance on manufactured homes. As a result, environmental reviews, appraisals, and approval from
Tribal citizens attempting to obtain a home loan on a the BIA – processes that non-Tribal citizens are not
reservation are 55 percent more likely to have a higher subject to.
priced loan than borrowers outside of a reservation,
Although efficient land management and the need to
and these higher priced loans have average interest
improve housing inventory will require longer-term
rates nearly two percentage points higher than other
reforms, Tribal governments are pooling their award
nearby loans.27
funding from ORP programs with a focus on housing
Federal programs such as the Section 184 Indian stability and using it in conjunction with other funding
Home Loan Guarantee Program and USDA Rural sources to respond to housing needs and supply.
Development provide homeownership opportunities;
Rincon Band of Luiseño Tribal leader and the fire chief discussing land management practices, including wildland fire safety and risk
mitigation, water management, and sustainable energy projects that the Tribe has done to keep citizens on the reservation safe. A
previous fire had left some Tribal citizens without homes, which created many challenges.
27 Feir, D. (2019). Federal Reserve of Minneapolis, Center for Indian Country Development. The Higher Price of Mortgage Financing for Native
Americans.
28 Colombe, J. (2020). Federal Reserve of Minneapolis, Center for Indian Country Development. Shortening the TSR Timeline: A proposal to
end delays that hinder Native Homeownership.
9
Investing Recovery Funding to Address
Tribal Housing Needs
Through funding supported by the SLFRF, HAF, ERA1, and LATCF programs, Tribal governments and their TDHEs
are addressing some of the barriers to housing – including the difficulty of mortgage lending on trust land.
Within the categories of eligible uses established by the American Rescue Plan Act for the SLFRF, LATCF, and HAF
programs, and the Consolidated Appropriations Act, 2021 for the ERA1 program, Tribal governments have broad
flexibility to meet the housing needs of their people.29 These programs can provide support for a household at
multiple points of the housing continuum and relieve pressure on services by keeping people in their homes
through direct financial assistance.
THE TRIBAL HOUSING CONTINUUM30
Housing-Related Eligible Uses:
SLFRF: Address immediate and long-term housing challenges, helping renters, homeowners, and unhoused
individuals weather the pandemic’s harms while tackling the long-standing challenge of insufficient supply of
affordable homes.
HAF: Assistance with mortgage payments, homeowner’s insurance, utility payments, support to make homes
habitable, and other qualified expenses related to mortgages and housing.
ERA1: Support for rent and rental arrears, utility and home energy costs, utility home energy costs arrears, other
expenses related to housing including, payment of rental security deposits, and costs for housing stability services.
LATCF: Funding for any governmental purpose except for a lobbying activity.
Meeting the need for stable, quality, affordable homes and utility support are among the most prominent uses
of SLFRF funds for Tribal governments. Tribes are implementing home improvement programs, weatherization
and energy efficiency projects, assistance with rental payments and utility bills, new construction, and housing
counseling programs. These critical investments with housing-related ORP funding support Tribal families with
the preexisting housing needs and help them recover from the financial impacts of the COVID-19 pandemic.
These projects are being accomplished under the mantle of Tribal self-determination and self-governance with
each Tribe determining how best to meet the housing needs of their people.
29 Guidance, the final rule, FAQs, and resources for each program can be found at https://home.treasury.gov/policy-issues/coronavirus/
assistance-for-state-local-and-tribal-government.
30 Many communities have built prior housing infrastructure on the model of the housing continuum, which support a variety of housing
stability needs and presents a path towards housing stability.
10
TABLE 5 TABLE 6
Summary of ORP Funds Committed to SLFRF Investments in Housing-Related Projects32
Tribal Housing Services
SLFRF Tribal Housing and
Tribal SLFRF Housing-related Infrastructure Projects
Projects and Services Housing Stabilization Programs33 583
$5.3 Billion New Construction and Home
269
Tribal HAF Planned Household Preservation Projects
Assistance Drinking Water Projects 102
$450 Million Clean Water Projects 100
Tribal ERA1 Households Broadband Projects34 54
Receiving Assistance Water and Sewer Projects 43
$611 Million Total SLFRF Tribal Housing and
1,151
Infrastructure Projects
To date,31 Tribal governments have committed funds
for 1,151 housing and infrastructure-related projects The ERA1 program concluded in 2022, and Tribes
with their SLFRF awards. This represents 25 percent of are now in the award closeout phase. Many Tribes
SLFRF award-funded projects implemented by Tribal leveraged the program flexibilities, reallocation
governments thus far. The pandemic dramatically funding, and adopted Treasury’s shared best practices
underscored the intersections between housing, to rapidly disburse assistance to renters in need.
infrastructure needs, and healthcare. Addressing Participating Tribes and TDHEs leveraged ERA1
overcrowding in homes and the need for reliable funding to make over $611 million in assistance
water, sewer, broadband, and safe roads proved to payments to help renters facing eviction with rent,
be the backbone for an equitable recovery. Tribes utilities, and housing stability services.
are investing their SLFRF award funds to find long-
term solutions to address inadequate infrastructure
for Tribal households. SLFRF awards also provide an
opportunity to become more intentional in land use
decisions and find solutions for stable, quality, and
affordable housing.
“Tribal governments have committed funds for
1,151 housing and infrastructure-related projects
with their SLFRF awards.”
31 Data based on the ERA1 Final Report, SLFRF Project and Expenditure Reports, and the HAF Quarterly and Annual Reports submitted to
Treasury for the June 30, 2023, reporting period. The examples included in this Report are based on recipient reports, and their inclusion
in this document does not constitute an explicit approval of these projects by Treasury.
32 Data has been aggregated into one or more categories.
33 Housing stabilization projects include payments for mortgage, rent, utilities, and other housing assistance.
34 Broadband projects include expansion of affordable access to broadband internet across the Tribal community.
11
TABLE 7 TABLE 8
ERA1 Stabilization Supports to Tribal Households35 HAF Planned Assistance to Tribal Households for
Stabilization and Preservation
ERA1 Households Receiving
Assistance by Category36 HAF Planned Assistance
Rent 188,631 Mortgage Assistance and
$186 Million
Utility and Home Energy Costs 133,761 Reinstatement
Other Expenses Related to Displacement Prevention,
$97 Million
Housing 22,124 Including Home Preservation
Housing Stability Services 16,315 Utility, Internet, Insurance and
$82 Million
HOA Costs
For the HAF program, Tribal governments have Principal and Interest Rate
budgeted37 over $450 million in mortgage payment $15 Million
Reduction and Loan Assistance
assistance, reductions, or reinstatements and
Property Tax Assistance $15 Million
displacement prevention.
Counseling or Education $2 Million
Program Support $53 Million
Total HAF Planned Assistance $450 Million
While the LATCF program is in its early stages,38 Tribes
have shared that they plan on using funding for land
purchases and housing-related programs.
Photo Credit: Quapaw Tribe
35 The categories of rent and utilities and home energy costs include arrears.
36 ERA1 households may have received more than one category of ERA1 support.
37 The majority of HAF Tribal participants will report their first full year of program data in November of 2023.
38 The majority of Tribal governments received LATCF payments in 2023.
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Housing Stabilization
As the pandemic began, the unemployment rate in the • The Housing Authority of the Sac and Fox
United States hit an unprecedented level at 14.8 percent.39 Nation, located in rural Oklahoma, assisted nearly
In comparison, the Native American unemployment 1,100 native and non-native households with
rate climbed to 28.6 percent40 - with the closure of Tribal rent and utility support with its ERA1 award. With
businesses in gaming and hospitality being a leading pandemic-related moratoriums and utility shut-
factor. These closures pushed many Native households offs for water and electricity expiring, the TDHE
across Indian Country to fall behind on their rent and prioritized getting qualified citizens caught up
mortgages, many of whom already struggled with the with overdue heat, electricity, and water bills.
cost of housing. The negative economic impact of the
pandemic not only impacted renters but also affected the
Tribal governments’ bottom line. With so many families
unable to pay rent and utilities, units owned and operated
by the Tribe or TDHE also saw revenue fall.
Under Treasury’s ORP programs, Tribes pursued housing
stabilization and related services to protect vulnerable
renters and homeowners. For example, ERA1, HAF, and
SLFRF awards have provided stabilization assistance to Nome Senior Apartments, an 18-unit elder housing facility,
owned and managed by BSRHA.
households to keep families in their homes, and Tribes
Photo Credit: Bering Straits Housing Authority
have strengthened wrap-around services for housing
stabilization. These innovations underscore the ability The Bering Straits Housing Authority (BSRHA)
of Tribes to implement ORP programs in adaptable and is headquartered in Alaska and is the Nome
creative ways. community’s primary service provider of affordable
• The Blackfeet Nation is utilizing SLFRF to homes. Through the ERA1 program, the BSRHA
renovate a youth homeless shelter for the over partnered with local social services departments,
300 children who face housing instability yearly on behavioral health services, and reentry
the 1-million-acre reservation, located along the specialists to focus on citizens most in need to get
eastern slopes of the Rocky Mountains. The Tribe them in to stable rental housing. On average, over
sees the shelter as crucial to protecting vulnerable 230 ERA1 applications were received each quarter.
youth seeking safe harbor from dangerous Seventeen previously homeless citizens were placed
living situations. The Tribe is also investing in in rental housing in the Nome area, where average
transitional housing for juveniles. winter temperatures are -2°. The Housing Authority
reported that since BSRHA started the ERA1 program
• The Chignik Bay Tribal Council is located in
and targeted unhoused citizens and those leaving
an area known for extreme cold in Alaska. The
the Anvil Mountain Correctional Center, the number
community depends on a once-a-year shipment
of ambulance calls in the area was cut in half.
of supplies, including fuel oil that generates power
and heats homes. Under the SLFRF revenue loss • The Native Village of Kluti-Kaah, with lands near
eligible use category, the Tribe funded a generator Anchorage, Alaska, has an average temperature for
for the town of Chignik, which supplies central the year of 29.2°F. To support the need for stable
power and heating to individual households. heating, the Tribe is carrying out a firewood program
39 Congressional Research Service. (2021, March 12). Unemployment Rates During the COVID-19 Pandemic: In Brief.
40 U.S. Bureau of Labor and Statistics. (2022). Labor Force Statistics from the Current Population Survey. (LNU04035243) [Data set]. https://
data.bls.gov/timeseries/LNU04035243
13
through its sawmill using SLFRF funds under the homelessness in the summer months when hotels
revenue loss eligible use category. Firewood is an and rental homes significantly increase prices. The
inexpensive and culturally relevant source for both Tribe collaborated with local agencies to create
heating and cooking. The program ensures homes are a rapid response to housing to ensure eligible
heated and creates jobs for Tribal citizens. households under their ERA1 program were not at
• The Otoe-Missouria Tribe of Indians is providing risk of losing their homes.
mortgage, utility, and property tax assistance • The Saginaw Chippewa Indian Tribe of Michigan
with its HAF award to all qualified Tribal citizens who is coordinating with a local non-profit for
live nationwide. Homeowners are eligible to receive outreach and with mortgage servicers to assist
up to $20,000 in assistance. The Tribe has a goal of Tribal homeowners facing financial instability.
preventing at least 50 homes from foreclosures. Their HAF program is helping prevent avoidable
• The Penobscot Nation reservation is in a high- foreclosures and delinquencies. The Tribe’s
cost-of-living area within Maine where many program includes payment assistance for first
citizens rely on hotels and room rentals for mortgages, reverse mortgages, home equity
housing. Due to seasonal tourism, those needing conversion mortgages, contracts for deeds or land,
emergency housing and rentals often face and loans secured by manufactured housing.
The Quapaw Tribe is building tiny homes for victims
of domestic violence with its SLFRF award funds.
Domestic violence, a leading cause of homelessness
among women and children, increased during the
pandemic. These temporary housing options aim
to reduce the incidence of domestic violence by
supporting victims with a safe space to live and
Construction is underway in Oklahoma for the Quapaw Tribe’s address housing instability. The Tribe will partner
Tiny Homes Village. with social services to provide culturally relevant
Photo Credit: Quapaw Tribe healing and recovery services.
Home Preservation
While many Native American families have a cultural preference for living in multi-generational households and
believe that it enhances family life, overcrowding was a major challenge during the pandemic because of stay-
at-home restrictions. Additionally, homeowners who experienced financial hardship due to the pandemic may
have delayed essential home repairs to pay other bills and obligations.
With these issues in mind, Tribes have looked to use their SLFRF and HAF awards to reduce overcrowding,
without giving up a traditional lifestyle, by extending rooms, renovating spaces to make the home habitable,
and other structural improvements. The HAF program supports home preservation, which is an essential
intervention to prevent displacement. Under the SLFRF program’s housing-related enumerated eligible use
categories and the revenue loss eligible use category, Tribes have broad authority to choose how to implement
affordable housing projects – including serving citizens who live away from their Tribal homelands. Typically,
Native Americans who do not live in Tribal areas do not qualify for other federal home improvement programs
that the Tribe receives. For the first time, Tribal governments have the potential to assist all eligible Tribal
citizens, regardless of their location.
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The All Mission Indian Housing Authority (AMIHA)
serves 14 reservations in three counties in California.
Through the HAF program, AMIHA is providing
mortgage assistance and safe housing for Native
Americans residing on reservations, incorporating
traditional concepts and values in service delivery.
The HAF program has funded repairs to structural
damage and rehabilitation of homes for low-income
Treasury Deputy Secretary Wally Adeyemo talking with members
households impacted by the Salton Sea flood and
of the Torres Martinez Desert Cahuilla Indians about flooring and earthquake damage.
bathroom renovations received through the HAF program.
Photo Credit: Taya Gray/The Desert Sun
• The Fort Belknap Indian Community is using • The Navajo Nation is installing 582 waterlines
SLFRF funds for an elderly housing repair and 478 cistern systems for collecting and storing
assistance program to incorporate accessibility water. The SLFRF project will ensure families can
floorplans, handicap ramps, appliances, and access clean drinking water in their homes.
important age-in-place features that will support • The Pascua Yaqui Tribe is funding a Homeowner
independence. Repair Program for Elders with its SLFRF
• The Native Village of Saint Michael will funds. The program provides funding to improve
rehabilitate 29 homes that have severe structural plumbing, heating, roof repairs, wheelchair ramps
issues and facilities conditions. Funded by a and railings, and other essential repairs for those
combination of its SLFRF and HAF awards, these age 55 and older.
homes will also receive electrical upgrades to • The Winnebago Tribe is committed to providing
ensure the safety of homeowners. affordable, dependable housing on the Winnebago
• The Nez Perce Tribe experienced a devastating reservation. Within the reservation and town
flood in 2019, which caused flood waters to rise boundaries are vacant lots with houses needing
around homes and shut down roads. As a result, repairs and abandoned structures that pose safety
insurance costs have risen. The Tribe is utilizing hazards. SLFRF funds will support renovating
the HAF program to support Tribal citizens with structures and demolishing abandoned
home repairs, homeowner’s insurance, including property. The project aims to increase housing
flood insurance, and other allowable home stability and housing stock within Winnebago.
stabilization costs.
The Chickahominy Indian Tribe spent many years
working on federal recognition. Shortly before the
pandemic, the Tribe gained recognition from the
federal government as a sovereign nation. Despite
being displaced and not having a reservation, the
majority of Tribal citizens still live within five miles
of the Tribal center, which is located near the site of
a pre-contact village. Today, the Tribe is utilizing its
HAF award to prevent homeowner displacement by
Treasurer Chief Lynn Malerba and Deputy Secretary Wally
Adeyemo met with recipients of the HAF program and Tribal
targeting homes with “conditions” to make them
leadership at the Chickahominy Indian Tribe in Virginia. safe and suitable to live in.
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New Housing Construction
The opportunity for new construction for Tribal citizens living on reservations remains limited and expensive.
In July 2022, Treasury expanded the flexibility for recipients to use their SLFRF awards to invest in long-term
affordable housing projects. This flexibility was introduced, in part, after discussions with Tribal leaders and
housing associations who reinforced that additional flexibility was needed to fully leverage their SLFRF awards
for affordable housing construction.
Consistent with the SLFRF program’s flexibility, Tribes are using these fiscal recovery dollars for a wide variety
of housing activities to address the unique access to capital and land challenges in ways that best serve their
communities.
The Karuk Tribe faced a fire that raged through the
ancestral heart of the Tribe in the Klamath Mountains
in September 2020. The wildfire burned over 200
homes in a community of 1,000, causing a rapid
increase in homelessness. The Tribe is investing its
SLFRF award in permanent housing and purchased
temporary travel trailers, including handicap-
accessible options, to meet the needs of families.
Firefighters from the Carson Hotshots in the Klamath
national forest.
Photo Credit: Bryan Denton/The New York Times
• The Delaware Tribe of Indians is devoting its of nearly 500 homes in the community. In addition
SLFRF award funds toward capital resource to addressing overcrowding, the housing shortage
assistance. The Tribe’s down payment assistance makes attracting workers such as teachers,
program is designed to help Tribal citizens healthcare workers, and other professionals a
become home buyers and ease the financial challenge. The Tribe invested SLFRF funds to build
burden of a home purchase. a 40-unit apartment building with one- and
• The Hoh Indian Tribe is located on the Pacific two-bedroom units.
coast of the Olympic Peninsula, where rising sea • The Manchester-Point Arena Band of Pomo
levels have caused erosion and a shortage of Indians is braiding federal funds to alleviate
land for stable housing. The Tribe believes that severe overcrowding. Using SLFRF funds under
climate change has profound implications for how the revenue loss eligible use category, the Tribe
it affects the future way of life and health of Tribal purchased five parcels of land to provide housing
citizens. Over 90 percent of the Hoh reservation and is partnering with Indian Health Service
is located within a 100-year flood plain, and 100 to build the water infrastructure needed to
percent is within a tsunami zone. The Tribe is accommodate the new housing.
using its SLFRF award to invest in infrastructure • The Omaha Tribe of Nebraska is located on
for new affordable homes that will be built at a reservation where much of the land is no
higher elevations. longer tribally owned due to allotment policies.
• The Lac Courte Oreilles Band of Lake Superior Allotment policies, along with an unemployment
Ojibwe estimates that there is a housing shortage rate of 69%41 has made home ownership
41 Chairman Vernon Miller. (2017). Omaha Tribe of Nebraska Testimony to the House Committee on Natural Resources. https://docs.house.
gov/meetings/AP/AP06/20160318/104633/HHRG-114-AP06-Wstate-MillerV-20160318.pdf
16
challenging for Tribal citizens. With its SLFRF • The Suquamish Tribe is leveraging its SLFRF award
award, the Tribe is purchasing surplus homes to address a lack of housing caused by the Tribe’s
within the reservation boundaries that are “checkerboard” reservation, where the Tribe
tax-defaulted properties. The opportunity owns some of the land and some of it is owned by
presents itself not only for permanent affordable non-natives. Historically, this has made building
housing for Tribal citizens but also for reclaiming sustainable housing incredibly difficult. With
the “land back.” SLFRF funds, the Tribe is constructing four multi-
• The Southern Ute Indian Tribe has a territory that family townhome structures with multiple stories.
expands across three counties in Colorado. The Approximately 25 percent of the parking (10 stalls)
Tribe’s “Broadband Band Modernization Project” will include electric vehicle charging stations.
braids its SLFRF award funds with other sources • The Yakutat Tlingit Tribe is located on the
of broadband funding to provide 95 percent of northern coast of the Gulf of Alaska where lands
the reservation’s new construction and existing span over 9,400 square miles. The Tribe recognized
homes with fiber optic internet. that attracting qualified health professionals was
• The Spokane Tribe of Indians is taking proactive an ongoing challenge due to a lack of housing
measures to address water deficiencies for existing options for medical care providers. The Tribe
homes and new home construction. The Tribe is is investing its SLFRF award funds to build
investing SLFRF funds in several water and sewer affordable housing to recruit and retain highly
projects and will make improvements to expand trained medical professionals.
the water system for future home construction.
The Louden Tribal Council (Galena Village) endured
a devastating ice jam on the Yukon River in 2013,
which caused waters to surge more than 15 feet
overnight. An ice jam happens when chunks of ice
clump together to block the flow of a river. The
disaster destroyed many homes and structures,
leaving some community members homeless. The
Tribe is nearly 300 miles from the closest road, and
the remoteness makes purchasing building supplies
unfeasible. Funding from its SLFRF award will build
new homes, and its HAF award will be used to
rehabilitate homes in need of repairs. The
Home built with SLFRF at the Louden Tribal Council (Galena Village). construction is creating jobs and training
Photo Credit: Louden Tribal Council (Galena Village) opportunities for citizens.
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Home built in the Rosebud Sioux Tribe’s high-tech manufacturing Secretary Janet Yellen at the Rosebud Sioux Tribe’s high-tech home
plant. manufacturing plant.
The Rosebud Sioux Tribe is investing SLFRF funds in several substantial housing projects on its reservation,
which spans 922,759 acres in South Dakota. The Tribe is tackling housing shortages and overcrowding by
becoming its own builder. The Tribe is utiliz-ing a Tribal business to manufacture homes, which is also creating
jobs for the community. The 33,600-square-foot facility has the capacity to build as many as 48 homes for low-
income families each year.
Continuing to Support Tribal Housing Stability
The resilience of Tribal communities is evident in their strong responses to the COVID-19 pandemic – as
the importance of federal funding to support the continued economic development of Indian Country. The
ARPA funds and other federal resources administered by the Treasury Department under the Biden-Harris
Administration have often been referred to as an unprecedented “once in a lifetime” opportunity. Guided
by regional priorities and objectives, the ARPA funding has served as a crucial resource for housing stability
and establishing new affordable housing options for disadvantaged families. Constructing new homes and
preserving older ones has created employment for Tribal citizens. These activities have ripple effects on
the Tribal economy – including Native-owned small businesses – as well as surrounding local and regional
economies. The ARPA and other federal funding outlined in this report has been a valuable addition to the
yearly IHBG formula funding, the New Markets Tax Credit Program, the Low-Income Housing Tax Credit
Program, and National Telecommunications and Information Administration broadband grants.
Treasury will continue to engage with Tribal leaders and staff on compliance, assisting recipients on reporting,
and discussing careful stewardship in carrying out the requirements of their awards.
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About the Office of Tribal and Native Affairs
The Office of Tribal and Native Affairs within the U.S. Department of the Treasury is committed to working with
Tribal governments and Indigenous communities to promote economic prosperity. The Office is overseen by
the Treasurer of the United States, Chief Lynn Malerba, the first Native American to hold this position. The Office
was established in September of 2022 by Secretary of the Treasury Janet L. Yellen to serve as a hub for Tribal
policy and is part of the efforts to develop Treasury’s growing relationship with Tribal nations. The Office works
across departmental offices to assist in implementing economic relief and recovery programs, the development
and implementation of tax policies and tax credit programs, and reviewing regulations and rulings that impact
Tribal communities. The staff has hosted numerous consultations on Tribal tax matters, the Inflation Reduction
Act, the CDFI Fund, and recovery funds, ranging from the distribution of funds to guidance to the applicability of
certain compliance standards to support an equitable and swift recovery from the challenges brought on by the
COVID-19 pandemic.
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