Letter submitted June 30, 2025
Letter
U.S. Department of the Treasury
Re: Comments on Executive Order 14247 – “Modernizing Payments To and From America’s Bank Account,” Submitted by the Coalition of Large Tribes
Docket Number: TREAS-DO-2025-0004
To Whom It May Concern:
I write as Chairman of the Coalition of Large Tribes (COLT)—an intertribal organization representing the interests of the more than 50 tribes with reservations of 100,000 acres or more, encompassing more than 95% of the Indian Country lands and more than half the Native American population—to express COLT’s concerns in response to the Department of the Treasury’s Request for Information regarding Executive Order 14247, which mandates the elimination of federal paper checks by September 30, 2025.
While we understand the need for modernization efforts, this transition presents significant challenges for Tribal communities. Tribal populations have disproportionately high rates of unbanked and underbanked individuals, limiting their access to electronic payments. Even those with bank accounts still face limited local banking infrastructure, often necessitating long-distance travel to reach the nearest bank branch or ATM (think many dozens of miles on average). Additionally, broadband access continues to lag within Indian Country. The inadequate broadband and cellular service on Tribal lands restricts the use of online banking and mobile payment options. These problems are especially acute for the large land base reservation communities COLT represents.It is no exaggeration to state that the majority of our citizens receive critical payments by check, such as their lease payments made on Individual Indian Money (IIM) accounts. Likewise, Tribal citizens typically receive their Social Security and Veterans benefits by check rather than electronic remittances.
Critical accommodations are needed for this transition to be effective. A significant portion of federal benefit recipients are elderly, who may be less comfortable with online systems and require additional support and education to navigate new payment methods. Cultural values also shape many Tribal citizens’ financial behaviors and contribute to the reliance on cash-based transactions within Tribal communities.
To ensure an equitable transition, we urge the Treasury Department to:
- Adopt a more realistic timeline that accounts for community needs and readiness.
- Implement targeted outreach and education campaigns to support Tribal communities, especially elderly populations and unbanked and underbanked individuals in adapting to electronic payments.
- Provide hardship exemptions or alternative payment options for those who cannot access electronic payments.
- Support the development and expansion of Tribal financial and broadband infrastructure and services.
- Engage in meaningful consultation with Tribal governments and stakeholders throughout the implementation process.
The amount of time, attention, and resources required for the Administration to facilitate this transition would be minimal given Tribal citizens’ relatively small representation in the U.S. population as a whole. And of course, many federal payments stem from the United States’ solemn Treaty and Trust responsibilities to Indian Country, making our requested modest accommodations both reasonable and consistent with binding federal obligations. Thank you for the opportunity to submit these comments. We look forward to working with the Department to ensure that large land base Tribal citizens in rural communities are not disadvantaged with respect to access to federal payments.
Very respectfully,
J. Garret Renville, Chairman, Coalition of Large Tribes
Chairman, Sisseton Wahpeton Oyate of the Lake Traverse Reservation, South Dakota