IDEA Fund: SSBCI Insider Guidance

State Small Business Credit Initiative (SSBCI) Insider Guidance

The Department of Treasury (Treasury) prohibits funding provided through the State Small Business Credit Initiative (SSBCI) program to be invested in or loaned into a company in which an SSBCI Insider (as defined below) has a personal financial interest. Certain MTC investments are funded through the SSBCI program and, therefore, MTC requires applicants to certify whether the applicant has knowledge of an SSBCI Insider’s investment in, or relationship to, the applicant.

An SSBCI Insider having personal financial interests in an applicant organization will not negatively impact an applicant organizations eligibility to be considered for or awarded economic assistance that may be provided by MTC under a program other than SSBCI. MTC administers an alternative pool of capital to provide economic assistance to the state’s most promising early-stage businesses where SSBCI Insiders have a personal financial interest. In all cases, MTC’s Conflict of Interest Policy applies to all potential relationships between applicants and MTC affiliates.

SSBCI Insiders include any individuals that have direct oversight over the MTC’s SSBCI-funded programs. These individuals include members of MTC’s Board of Directors, MTC staff members and their family members and business partners. Treasury applies the following definitions for such terms:

1. An “SSBCI Insider” is a person who, in the 12 months preceding the transaction in which SSBCI funds are deployed:
(a) was: (i) a manager or staff member, whether by employment or contract, in the state’s SSBCI venture capital program; (ii) a government official with direct oversight or jurisdiction over an SSBCI venture capital program, or such an official’s immediate supervisor; (iii) a member of the board of directors or similar body for a state-sponsored non-profit entity who, through such membership, has authority to vote on decisions to invest SSBCI Funds or has authority over the employment or compensation of staff managing processes related to the investment of SSBCI Funds; (iv) a member of the board of directors or similar body for an independent non-profit or for-profit entity that operates an SSBCI venture capital program; or (v) an employee, volunteer, or contractor on an investment committee or similar body that recommends or approves SSBCI investments under the SSBCI venture capital program; or
(b) exercised a controlling influence on state decisions regarding: (i) the allocation of SSBCI Funds among approved state venture capital programs; (ii) eligibility criteria for the state’s SSBCI venture capital programs; or (iii) the processes for approving investments of SSBCI Funds under the state’s SSBCI venture capital program.
2. A “family member” of an SSBCI Insider includes such person’s spouse, domestic partner, parents, grandparents, children, grandchildren, brothers, sisters, stepbrothers, stepsisters, and other relatives who live in the same household as the SSBCI Insider.
3. A “business partner” of an SSBCI Insider is someone who owns 10% or more of any class of equity interest, on a fully diluted basis, in any private entity in which an SSBCI Insider also owns 10% or more or any class of equity interest on a fully diluted basis.
4. “Personal financial interest” means any financial interest derived from ownership or right to ownership of, or lending to or other investment in an entity that is likely to apply and receive SSBCI Funds as determined by the Organization. Notwithstanding any provision of this Supplement to the contrary, a Personal Financial Interest does not include any bona fide compensation arrangement with such an entity, including but not limited to, compensation in connection with services provided, licensing agreements, or royalty agreements.

A full list of members of MTC’s Board of Directors and MTC staff members (and, where applicable, their principal affiliations) follows.

MTC Board of Directors
• Dr. Dedric Carter (Chairman), Vice Chancellor for Innovation and Chief Commercialization Officer at Washington University in St. Louis
• Dan Cobb (Vice Chair & Investment Committee Chair), Serial Entrepreneur
• Dr. Jim Baker (Secretary/Treasurer), Vice President for Community and Global Partnerships Emeritus at Missouri State University
• Kathryn Allen, Shareholder at Polsinelli
• Allen Dillingham, Director of Government Relations at The Builders’ Association
• Representative Derek Grier, Owner/Broker – Realty ONE Group Dominion
• Senator Dan Hegeman,
• Ajay Jhamb, Technology Executive at Enterprise Holdings
• Maggie Kost, Acting Director of Missouri Department of Economic Development
• Michael O’Connell, Business Representative for United Association
• Stephanie Regagnon, Executive Director of Innovation Partnerships at Danforth Plant Science Center
• Donn Rubin, President & CEO of BioSTL
• Dr. Tom Spencer, Interim Vice Chancellor for Research and Economic Development for the University of Missouri System
• Erv Switer, Officer at Greensfelder, Hemker & Gale, P.C. Attorneys at Law
• Shad Burner, Director of Federal Initiatives at Missouri Department of Economic Development

MTC Staff Members
• Jack Scatizzi, Executive Director
• Erika Fiola, Senior Manager of Ecosystem Engagement
• Amy Steinman, Finance and Compliance Administrator
• Nate Marschalk, Entrepreneurial Ecosystem Grants Coordinator
• Melissa Grizzle, Venture Capital Portfolio Manager

For additional information on the SSBCI program please visit Treasury’s dedicated website.

MTC’s Conflict of Interest Policy (as amended on October 13, 2022) and the SSBCI-specific Supplement (adopted October 13, 2022) are available to review using the following links.

Conflict of Interest Policy
SSBCI-specific Supplement

Contact for Questions
Please email Jack Scatizzi, [email protected]