Guest Post by Ashley Zumwalt-Forbes, a critical minerals leader and energy executive, currently COO and Director for variety of mining and mineral companies. Ms. Zumwalt-Forbes formerly served as the US’ Deputy Director for Batteries and Critical Materials, overseeing the deployment of ~$6B in non-dilutive equity and ~$10B in tax credits into the US battery supply chain.

The United States has quietly built the early stages of a minerals sovereign wealth fund, and it is already showing paper gains for taxpayers. The government now holds equity positions in several strategic critical minerals companies, yet these stakes sit across multiple agency balance sheets, each with different terms, different disclosure practices, and no unified structure that allows the public to understand the actual value being created. If these investments were managed together on one balance sheet, with consistent terms and transparent reporting, the United States would get credit for what is becoming one of the most innovative approaches to rebuilding domestic minerals capacity.

The reason is simple: the market itself is distorted. The People’s Republic of China (PRC) has spent decades building scale across the midstream and downstream, spreading fixed costs across enormous volumes, locking in offtake, and tolerating weak (or negative) margins when it serves a strategic purpose. When one country with a government-directed economy dominates refining and processing of rare earths, lithium chemicals, graphite, and permanent magnets (to only name a few), it can set price expectations in markets that are inherently thinly traded. No private investor can finance billion-dollar projects when the PRC can push prices lower during construction or commissioning to make the economics collapse at the point of maximum vulnerability.

Against that backdrop, the United States government stepped in, not because public equity ownership is a preferred or popular model, but because it was the best tool available that could keep strategically important projects alive. Under the Biden Administration, most support flowed through tax incentives, grant programs, and debt facilities created under the BIL and IRA. These tools helped midstream and downstream facilities but were structurally mismatched for developing mines because they depended upon narrow applicability definitions in the legislation. Equity solves a different problem. It provides capital at the riskiest stage of a mine’s life, lowers the cost of capital, and sends a clear market signal that the federal government is aligned with private investors on long-term project viability. In 2025, the federal government became an equity holder in three listed American critical minerals companies as well as private vehicles tied to cornerstone projects, while also taking minority positions in funds like TechMet, Appian, and Orion. Taken together, these positions behave like the early architecture of a sovereign wealth fund focused on minerals, whether anyone says it out loud or not.

The Anchor Positions and What They Show on Paper

The United States has now taken equity or equity-linked positions across a range of public and private critical minerals companies. For this analysis, I focus only on the stakes the USG has taken in public critical minerals companies. To illustrate what this model is already producing, the three publicly traded names provide the clearest mark-to-market read: MP Materials, Trilogy Metals, and Lithium Americas. These marks reflect fully diluted outcomes, meaning they incorporate the new shares created for the USG and the impact of warrants. Even with dilution, taxpayers are showing paper gains in aggregate, and in two of the three cases, shareholders are as well.

MP Materials (MP) – MP is focused on neodymium-praseodymium (NdPr) and other key rare earths used in permanent magnets for EVs, wind turbines, drones and advanced defense systems.

The Department of War (DoW) investment of $400M in MP was structured as newly-created preferred stock with warrants, allowing conversion at $30.03, the last reported sale price before execution of the agreement [2]. MP traded above the strike price immediately, so it is appropriate to treat both the preferred and the full warrant package as exercised. On that basis, the government’s economic exposure is roughly 15%, consistent with public reporting.

With MP trading at $59.04 as of November 24, 2025 [6], the shareholder impact is clear. A pre-announcement 1% holder dilutes to about 0.87% after the preferred and warrant shares are added to the total share count. Using the pre-announcement reference price of $30.03, that original 1% stake was worth $0.3003 per share-equivalent. On November 24, 2025, 0.87% × $59.04 is worth roughly $0.514, which is a 71% increase in value even after dilution.

For taxpayers, the investment marks from $400M to roughly $520M, a paper gain of about $120M. This figure excludes the value of the NdPr floor price, the long-term magnet offtake, and the strategic benefit of standing up a domestic rare earth and magnet platform outside PRC control. The market has already priced in enough to show a clear financial result.

Trilogy Metals (TMQ) – TMQ is focused on copper, cobalt and associated critical co-products in Alaska’s Ambler district, a high-grade frontier asset unlocked by infrastructure.

The USG committed $35.6M in two parallel TMQ transactions. In the first transaction, $17.8M went directly into TMQ through the purchase of 8,215,570 newly-issued units at $2.17. Each unit consisted of one new common share plus three-quarters of a 10-year warrant (6,161,678 warrants total). The remaining $17.8M purchased 8,215,570 existing TMQ shares from South32 and included a 10-year call option to acquire an additional existing 6,161,678 South32-held shares at $0.01 once (and if) the Ambler Road is constructed [3][4].

At closing, the USG owned roughly 10% of shares on issue with only ~8.2M shares being newly issued. The share count increased from 161.4M to 169.6M, resulting in 5% shareholder dilution. A shareholder who owned 1% pre-announcement now owns roughly 0.95%. Using the pre-announcement reference price of $2.17, that original 1% stake was worth $0.0217 per share-equivalent. At the November 24, 2025 close of $3.90 [6], 0.95% × $3.90 is worth ~$0.0371, which is roughly a 71% increase in value even after dilution. That move is exactly what you would expect when a major permitting overhang is lifted.

If the Ambler Road is built and the USG exercises all TMQ warrants and all South32 call-option shares, only the warrant shares increase the share count because the South32 shares already exist. Under this scenario, total shares outstanding would increase from 169.6M to 175.8M, and the USG would own 28.75M shares, or ~16.4% of the company. A pre-announcement 1% shareholder would dilute to roughly 0.92%. At the same $3.90 share price, 0.92% × $3.90 = $0.0359, a ~65% increase in value even after dilution, and that understates the likely outcome because full warrant exercise would almost certainly coincide with road approval and a higher stock price.

For taxpayers, the math is straightforward. The 16,431,140 shares the USG acquired (8.2M new + 8.2M existing) at $2.17 revalue from $35.6M at acquisition to $64.1M as of November 24, 2025, a gain of roughly $28.5M.  This is about as close as the government gets to a classic deep-value entry, amplified by federal de-risking.

The pairing of direct equity, long-dated warrants, and a federal greenlight on the Ambler Road reset market expectations for the entire district overnight.  That immediate repricing is the point: remove structural risks private capital simply cannot solve on its own.

Lithium Americas (LAC) – Lithium Americas is developing Thacker Pass in Nevada, one of the largest known lithium resources in the United States.

DOE did not purchase equity in LAC. Instead, as part of the amended ~$2.2B loan package, DOE received warrants with an exercise price of $0.01 per share, equal to a 5% equity interest in the parent company and a 5% economic interest in the GM joint venture [1]. These warrants increase the fully diluted share count once exercised, but, because the exercise price is de minimis, the taxpayer’s cost basis is effectively zero.

These warrants are not immediately exercisable. Under the disclosed terms, LAC will issue the warrants within a defined window after the amended loan documentation is executed and related conditions are met, including the corporate approvals associated with the amendment. The JV warrants add a second mechanic. If the JV reaches substantial completion, GM has the option to purchase DOE’s JV interests, and if the two sides cannot agree on valuation, the instruments can settle into common equity under the dispute process. The practical takeaway is simple: the warrants only matter if the project advances. If Thacker Pass stalls, taxpayers are effectively flat. If it advances, the equity becomes real.

LAC traded around $5.74 the day before the DOE announcement and closed at $4.87 on November 24, 2025 [6]. On a fully diluted basis that incorporates DOE’s parent-level warrants, a pre-announcement 1% shareholder dilutes to roughly 0.95%. The true economic dilution is larger but hard to quantify without modeling JV cashflows, since shareholders would also now own a smaller percentage of the actual Thacker Pass JV (DOE is to receive warrants worth 5% of the JV). Each LAC share now carries a smaller claim on project-level cash flows than it did pre-announcement.

The shareholder outcome reflects both effects. A position that was worth 1% × $5.74 = $0.0574 per share-equivalent is now worth roughly 0.95% × $4.87 = $0.0463, a decline of about 20% driven by both dilution and the share price move.

For taxpayers, the position is a mark, not a loss. No USG capital was deployed to obtain either the parent-level or JV warrants, so the downside is limited to mark-to-market noise. The real upside only materializes if Thacker Pass becomes a producing asset with stable offtake, at which point the warrant structure becomes extremely attractive for taxpayers.

Portfolio View

Across these three companies, the financial outcomes point in the same direction. Using only capital actually deployed, the USG has a combined paper gain of roughly $148M. MP contributes ~$120M. TMQ contributes ~$28.5M. LAC shows a mark-to-market decline relative to its pre-announcement reference price, but because the USG paid nothing for the warrants, there is no capital at risk.

Shareholders largely mirror this pattern. MP and TMQ delivered real value for existing holders even after dilution due to the appreciation in share prices. LAC did not show the same outcome, but, unlike MP and TMQ, the USG did not deploy new equity capital into LAC; the warrants were an add-on to an existing loan package. The equity underperformance likely reflects a combination of project-specific uncertainty as well as some market discomfort with the government’s participation.

Relative to broader markets and commodities, the performance is even clearer. From July 10 to November 24, 2025, SPY rose ~8% [7], NdPr oxide was roughly flat to slightly down [10], LME Copper gained ~7% [9], and Lithium carbonate prices increased ~15% [8].

Against those benchmarks, both MP and TMQ shareholders saw gains of ~70% under the baseline dilution scenario. These returns significantly outperform both general equity markets and the relevant commodity performance. The comparison shows that the market is already valuing the removal of geopolitical risk, the de-risking of infrastructure, and the strategic backstop embedded in these transactions. LAC is the outlier in the portfolio, and its underperformance is notable given that lithium carbonate rose ~15% over the same July 10 to November 24 window.

Why We Should Formalize What We Already Built

If the goal is to secure non-FEOC (Foreign Entity of Concern) supply chains for minerals that sit at the center of batteries, data centers, defense platforms, and the grid, then the United States needs to manage these investments as one portfolio. Right now, the equity and equity-linked positions in MP Materials, Lithium Americas, Trilogy Metals, and the other minority allocations all sit on separate agency balance sheets. The structures are inconsistent. Some involve preferred stock and warrants while others involve governance rights or long-term offtake agreements. The investments are monitored by different teams with different frameworks for success. The results have been innovative and impactful, but the upside would be even greater under a coordinated investment structure.

It is time to formalize the model. A single vehicle, the United States Critical Minerals Investment Corporation, would bring all of these stakes into one home. It would apply consistent investment theses and terms, ensure coordination instead of agency silos, and allow the government to deploy its best commercial, financial, and technical expertise. The mandate should be clear: secure non-FEOC supply that can be profitable as close as possible to today’s spot prices, support commercially credible projects that private capital cannot de-risk alone, and preserve taxpayer capital through the cycle.

A unified structure would allow the government to recycle gains, exit positions once the strategic objectives are met, and build institutional memory that survives political transitions. Most important, it would show taxpayers that this model is not only essential for countering the PRC’s market power, but also for generating returns for the public. That credibility breeds license to operate and creates the political room to continue investing in mineral security at a scale that matches the challenge.

The pieces are already in place; what’s missing is the architecture to manage them as one system. The next step is to put them on the same balance sheet, manage them with one strategy, and turn a set of one-off transactions into a durable national asset.

References

[1] Reuters, “US government takes 5% stakes in Lithium Americas and joint venture with GM,” October 1, 2025. https://www.reuters.com/business/autos-transportation/us-government-take-5-stake-lithium-americas-joint-venture-with-general-motors-2025-09-30/

[2] Columbia Center on Global Energy Policy, “US Government Equity Stakes in Critical Mineral Companies,” 2025 Q&A. https://www.energypolicy.columbia.edu/qa-how-the-us-is-using-equity-stakes-to-support-domestic-critical-minerals-development/

[3] Trilogy Metals Inc., “Trilogy Metals Announces Strategic Investment by US Federal Government,” October 2025. https://trilogymetals.com/news-and-media/news/trilogy-metals-announces-strategic-investment-by-us-federal-government/?utm_source=chatgpt.com

[4] Reuters, “Trump orders permits for Alaska mining road, US takes stake in Trilogy Metals,” October 6, 2025. https://trilogymetals.com/news-and-media/news/trilogy-metals-announces-strategic-investment-by-us-federal-government/

[5] DFC and TechMet public materials on critical minerals fund investments. https://www.dfc.gov/media/press-releases/dfc-delivers-us-climate-finance-commitments-cop28-announces-more-37-billion

[6] US exchange pricing for MP, Lithium Americas, and Trilogy as of November 24, 2025. https://finance.yahoo.com/quote/MP/; https://www.investing.com/equities/western-lithium-usa-historical-data; https://www.nasdaq.com/market-activity/stocks/tmq

[7] SPDR S&P 500 ETF Trust (SPY) price history, July–November 2025. https://www.investing.com/etfs/spdr-s-p-500-historical-data

[8] Fastmarkets and Benchmark Mineral Intelligence, lithium carbonate pricing data, July – November 2025.https://www.fastmarkets.com/metals-and-mining/battery-raw-materials/lithium/lithium-carbonate-prices/

[9] LME copper cash settlement data, July–November 2025. https://www.lme.com/en/metals/non-ferrous/lme-copper#Overview

[10] Asian Metal and Shanghai Metals Market (SMM), NdPr oxide pricing data, July – November 2025. https://www.asianmetal.com/Praseodymium-Neodymium-Oxide-Prices-Trend/