In-State Investment Program

North Dakota’s In-State Investment Program supports the growth and development of local businesses, communities and industrial projects while generating competitive returns for the state’s Legacy Fund.

• In 2019 the Legacy Fund began investing in Bank of North Dakota’s Match Program with a $200M commitment, raised to $400M in 2020, before the In-State Investment Program existed.
• In 2021 the Legislature created the In-State Investment Program, directing up to 20% of the Legacy Fund to be invested in North Dakota, split evenly between fixed income and equity. The State Investment Board committed $100M to launch the North Dakota Growth Fund and $150M to Bank of North Dakota's Legacy Infrastructure Loan Fund.
• In 2023 lawmakers set fixed dollar targets — $600M in equity and $700M in fixed income — giving the program a steady goal rather than one that rises and falls with the value of the Fund. 
• In 2025 the State Investment Board raised its North Dakota Growth Fund commitment to $250M and launched the North Dakota Real Assets Fund with an initial $150M.

Building a program of this size takes years. Moving too fast would mean putting money into weaker investments, and the Legacy Fund's first obligation is to earn a solid return for the state.

What counts as an "in-state" investment?

An in-state investment is one made in a North Dakota business, project, or community. The program uses four vehicles: private equity and venture capital through the North Dakota Growth Fund; real assets such as real estate, infrastructure, natural resources and agriculture through the North Dakota Real Assets Fund; and loans to North Dakota businesses and communities through Bank of North Dakota's Match Program and Legacy Infrastructure Loan Program.

Who makes the investment decisions?

To prevent conflicts of interest and keep decisions professional, individual investments are selected by experienced managers, not by board members or Retirement and Investment Office staff. Independent firms manage the North Dakota Growth Fund and North Dakota Real Assets Fund, and the Bank of North Dakota administers the loan programs under its lending standards. Learn more on the Investment Strategies page.

Does investing in-state mean lower returns for the Legacy Fund?

The In-State Investment Program seeks competitive returns while investing in North Dakota. Within the targets the Legislature set, in-state opportunities are evaluated by professional managers on their risk and return, and performance is reported against a benchmark like other parts of the portfolio.

How is the program's performance measured and reported?

In-state investments are reported alongside the rest of the Legacy Fund's holdings. The Retirement and Investment Office publishes monthly financial statements and investment performance reports, with fiscal year-end figures (as of June 30) incorporated into its annual financial audit. Learn more on the Reports page.

How often are the investment targets or policy reviewed?

The program has been revisited as it has matured, from its 2021 establishment to 2023 legislation setting specific dollar targets, to a 2025 expansion that added a new manager and increased an existing commitment. The Legacy and Budget Stabilization Fund Advisory Board reviews the Legacy Fund investment policy periodically, and changes are approved together with the State Investment Board.

Is this money separate from the rest of the Legacy Fund?

No. In-state investments are a carve-out within the broader Legacy Fund portfolio, not a separate fund. They are held and accounted for as part of the Legacy Fund's total assets and are subject to the same oversight, reporting, and fiduciary standards as the Fund's other holdings.