On the heels of the Department of Energy’s publication of the government-wide “Common Investment – Initial Screening Application”,¹ the Pentagon’s Office of Strategic Capital (“OSC”) posted a formal Notice of Funding Opportunity (“NOFO”) for the OSC’s National Security Fund Finance Program (“NSFF”) on August 20, 2026.

While most Trump Administration investment has come in the form of loans, loan guarantees, and equity investments in individual companies, the NSFF provides a funding opportunity for investment funds to directly participate in investment around the defense industrial base.

The program represents a federal initiative to deploy substantial lending capacity in support of restoring domestic critical mineral supply chains vital to U.S. national security. The NSFF is designed to provide capital support to qualified credit funds addressing shortages, gaps, and vulnerabilities in critical minerals essential to United States national security. Most importantly, the NSFF operates as a fund-level financing vehicle: the OSC lends to qualified investment fund managers, who then combine OSC loans with private capital to make portfolio investments in companies focused on addressing critical minerals and materials shortages. Together with the OSC’s longstanding partnership with the Small Business Administration (“SBA”) to back investment funds investing in critical technologies, and a newly-announced SBA partnership with the Department of Energy, the NSFF encourages additional investor participation by making additional federal financial tools available to the critical minerals sector.

Complete proposals must be submitted by 5:00 p.m. ET on November 1, 2026. All applicants must be professional managers of debt investment funds duly formed under U.S. law and registered with the System for Award Management. The application is detailed, requiring four proposal volumes covering firm information and eligibility, investment strategy to address critical minerals and materials supply chain gaps, and substantial supporting documentation. Given the complexity of the OSC’s requirements, we recommend that interested parties begin planning their proposals promptly.

Our National Security Investments Group is ready to advise companies exploring this significant opportunity. With considerable experience guiding clients through federal funding programs and complex critical minerals transactions, our team is well positioned to help develop tailored, competitive proposals that stand out in a rigorous selection process. Baker Botts also has extensive experience in critical minerals, metals, and materials projects, helping us ensure clients’ approaches to federal investment programs are aligned with contemporary needs.

If you are interested in hearing more about this opportunity or our capabilities at Baker Botts, please contact Special Counsel Eric Robinson. For more information about our critical minerals and metals practice, please contact Partner Rebecca Seidl Inglesby.

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¹For more information regarding the Common Investment – Initial Screening Application, see our alert published on August 12, 2026 – Trump Administration Opens New Multi-Agency Federal Investment Application.

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