Helgeson

This appeal challenges the denial of an Indian Revolving Fund loan application by the Bureau of Indian Affairs (“BIA”). The district court granted the BIA summary judgment, holding that its actions were not arbitrary, capricious or an abuse of discretion. We agree, albeit on a somewhat different ground.

I

Dora Helgeson, the eighty-year-old mother of Kenneth, Gene, and Leon Helgeson (the *1002 latter three are collectively referred to as the “Helgesons”), owned a cattle ranch encompassing 1444 acres of trust property on the Fort Belknap Indian Reservation in Montana. One mortgage on this property secured a delinquent debt of approximately $220,000 that Dora owed to the Federal Land Bank (“FLB”), while a second mortgage secured another debt of approximately $103,-000 to the Farmers Home • Administration (“FmHA”). The. delinquent FLB debt was in the process of foreclosure. In addition, Kenneth owned 240 acres of trust land that was also mortgaged to secure the FLB debt. Kenneth and Florence were contractually liable for the entire amount of the FLB debt.

To fulfill them goal of taking over and operating Dora’s ranch, the Helgesons, all enrolled members of the Assiniboine Tribe,…