Under the Tribal Realty Code of certain tribes, an individual possessory holding pertains to reservation land titled in the United States but parceled out to individual tribal members. The individual possessory holdings are tribally recognized by Certificates of Possessory Holding, and are used by the owners for homesites, limited farm and forestry activities, as well as commercial purposes.
Possessory holdings may be leased with the permission of the Secretary of the Interior. Possessory holdings are permanent and may never ripen into a fee title. (Amy T. Critzer v. the United States, 1977 U.S. Ct. Cl. Lexis 556)