EB-5 Commentary

A Reminder About Industry and Geographic Restrictions and Amendments

Posted by Phil Cohen on Wed, Nov 11, 2015 @ 01:33 PM

Here is a reminder regarding amendments, which is worth noting...

In its EB-5 Policy Memorandum of May 30, 2013, USCIS put forward an important change to this requirement. Therefore, when an EB-5 regional center wishes to expand its industry codes, it may now do so with an investor's I-526 submission.  As a result, the formal amendment process (and the very significant wait time that it used to imply) is no longer required as a separate action by the regional center.  The result is a considerably higher degree of flexibility afforded to regional centers who may wish to expand their geographic or industry sphere of focus.

There is, however, still value, however, to the formal amendment process.  The main value is that investors can be more certain of the approval of the new areas of focus when a regional center has received approval of a formal amendment in advance of the investor submitting their I-526.

Ultimately, for the regional center, it is a judgment call whereby the 'saleability’ of a deal would need to be traded off against the delays involved in seeking a formal amendment.

USCIS has also provided some indication (although this appears not to be definitive in how it was presented) that a regional center’s geographic area of focus may also be expanded via an investor's I-526 petition.  In order to do so the geographic area must be contiguous with the existing regional center boundaries and would require a justification for expansion to the new boundaries.  Similar to what has been described above for expansion of industries of focus, investors will be taking a risk that the justification provided will be accepted by USCIS.

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

 

 

Tags: amendment application, EB5 Regional center, EB-5 explained, I-526, EB-5 Business plan

See our Latest Article in EB5Investors Magazine

Posted by Phil Cohen on Mon, Aug 10, 2015 @ 07:10 AM

See our latest EB-5 article in EB5Investors magazine.  The article discusses tips on avoiding and dealing with RFEs: www.eb5investors.com.

 

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

Tags: amendment application, EB-5 investors, I-526, applications, I-924, EB-5, EB-5 Business plan

(Updated) The Cost of Raising Money via EB-5

Posted by Phil Cohen on Mon, Mar 23, 2015 @ 08:11 AM

describe the imageIf you are an entrepreneur looking to attract investors to your project, becoming an EB-5 regional center can create a very compelling reason for foreign investors to provide you with financing.

Many people, however, don’t fully understand the complexities of the EB-5 regional center application process, or the costs involved.  One can apply to become an approved EB-5 regional center through the U.S. Citizenship and Immigration Services (USCIS) using form I-924.

The filing cost of form I-924 is $6,230. However, many entrepreneurs don’t account for the other costs of a successful regional center proposal which include:

  • The services of an economist to provide the detailed economic impact analysis required by USCIS
  • The services of immigration, securities and business attorneys to develop and thoroughly vet the documents associated with the proposal
  • A detailed business plan outlining capital mix, return forecasts, exit strategy and other investment metrics
  • Possibly the services of a firm who will spearhead the management and coordination of your application
  • The services of an experienced EB-5 project manager are strongly recommended, especially for those new to the process
  • We also suggest that the regional center's website be up and running prior to the submission of an I-924

As a general rule of thumb, we encourage clients to anticipate a budget between $125,000 and $175,000 to get a full regional center application prepared and submitted, including the first 'exemplar' project plan. This cost can vary mostly according to the costs of the various professionals involved.

If a client wants to work with an existing regional center and not form their own, we would recommend budgeting between $70,000 and $150,000, in addition to the cost charged by the regional center (regional center charges and deal structures (as well as included services such as marketing) for taking on a project vary quite considerably.

Once approved, or at least once marketing starts, there are other costs to consider as well:

  • Agency fees for each successful investor (this is mostly the case for China, although agents can be found in other countries)
  • Marketing costs (including brochures, travel, DVDs, information packets, Powerpoint presentation, translation of materials, etc.)
  • Escrow fees, as appropriate
  • Insurance costs
  • Administrative costs for tracking and reporting to investors and USCIS
  • Interest to investors

Clearly there is much to consider when evaluating the ROI on EB-5, however, this is where an experienced team provides value in terms of saving unnecessary costs and avoiding pitfalls.

Understanding the Application Process

While the filing fee for form I-924 is a fixed cost, these other costs may vary depending on the size and complexity of your project and business plan. It’s important to understand the full scope of the application process to determine the costs involved.

Becoming an EB-5 regional center can be a powerful attractor for foreign investment, in units of $500,000 or $1,000,000.  The regional center designation can attract high net-worth investors that would otherwise not target your enterprise as an investment opportunity. However, the process of achieving this designation is not easy, and requires your full understanding to ensure success.

To fully unlock the potential of the EB-5 program, you need to arm yourself with the right information; ill-informed entrepreneurs can waste thousands of dollars and many hours trying to navigate the I-924 process.  Gain a full understanding of the EB-5 program with the EB-5 Definitive Guide.

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 


Download Your Free Paper:  9 Things to Know  Before Going Down  The EB-5 Road

Tags: EB-5 Regional Center Application Cost, EB5 Regional center, regional center EB5, EB-5 Team, EB-5 investors, EB-5 Business plan, EB-5 Regional Center, EB5

Chinese EB-5 Visa Retrogression Shouldn't be Stopping You

Posted by Phil Cohen on Mon, Mar 09, 2015 @ 08:50 AM
describe the image

As a follow up to a blog article posted here on September 9th, 2014 (Some Deeper Implications of Chinese EB-5 Visa Retrogression), I want to reiterate what many in the industry are already saying in order to help quell some fears associated with Chinese visa retrogression and to help make sure that those who are new to the EB-5 community understand that retrogression is not the death knell of EB-5.

Retrogression does not mean that investors cannot have their I-526 petitions processed and approved. It only means that they won't get their green cards right away upon I-526 approval.

Retrogression probably does not mean that Chinese investors will lose interest in EB-5 any time soon, perhaps even the contrary.  If anything, the Canadian program demonstrated the propensity for Chinese investors to wait in line.  When the Canadian program was cancelled, there were over 60,000 investors in line, willing to wait up to seven years to be processed. Arguably, the EB-5 program might be slightly less of a draw because of the 'at risk' requirement, but being the only North American game in town worth mentioning these days in addition to the still-increasing base of HNW individuals in China I would suggest that there may well be a rush to get in line over the next 2 to 3 years.

Retrogression does not mean that projects should stop marketing in China, the source of 85% of EB-5 investors today.  For the reasons stated above Chinese demand is not expected to abate.  For the medium and longer term, however, those who expect to be involved in EB-5 for the forseeable future should expand their marketing horizons.  Bear this in mind, when developing your EB-5 business plan.

Retrogression does not mean that projects will be delayed in getting money into their projects (yet).  Funds can be released to a project upon I-526 approval and because there will be no additional delay in processing of I-526 petitions from Chinese applicants once retrogression kicks in, funds can be released on schedule.  Over time, this may change as the backlog grows.

 

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

 Download Your Free Paper:  9 Things to Know  Before Going Down  The EB-5 Road

Tags: capital raise, EB5 capital, Chinese Investors, EB-5 Project, EB-5 investors, I-526, USCIS, EB-5, EB-5 Business plan

The Importance of a Buffer in EB-5 Job Creation

Posted by Phil Cohen on Mon, Feb 23, 2015 @ 06:17 AM

This a re-post of an earlier blog article, but because of its importance to investors, we felt it was worth mentioning it again.

When starting an EB-5 regional center or EB-5 project, many look to the regulations as the Start EB 5 Buffer resized 600guideline to what is required to have a successful EB-5 offering.  The guidelines, however, are only the beginning.  Starting an EB-5 project requires thinking that will not only get USCIS approval but which will also win over investors.  To this end, it is wise to consider the job creation component with the inclusion of a buffer of extra jobs.

Why Have a Buffer at All?

Creating a buffer of more jobs than are actually required by the program has the benefit of added security to investors, which in turn means added security for the project in terms of its ability to win investor interest in the first place and ultimately to maintain a reputation for successfully delivering job creation to investors, the core measure of success to all future investors.

Having a buffer of more jobs than are required by the program means that if things don't go to plan and not all the direct jobs that were originally planned can be created, investors will not lose the opportunity to have the conditions removed from their green cards at the I-829 stage.

Where indirect jobs are concerned, job creation counts will be dependent on fulfilling the inputs that the economist had used to develop the indirect job creation calculation.  Most business people will take a conservative approach to planning their businesses, which means guessing high on costs and guessing low on revenues.  If costs are over-estimated, however, and these costs were counted as the input of investment used by the economist in his or her calculation, this conservative approach can backfire.  While coming in under budget is certainly a respectable and desirable outcome in almost any business scenario, a lower investment input to the project can mean that the originally-calculated number of indirect jobs may have to be revised downward to match the revised input, thereby meaning less jobs to go around for EB-5 investors.

How Much is Enough?

A good rule of thumb for a job creation buffer is to plan to create 20% more jobs than needed, or a total of 12 jobs per investor.  This is not a hard and fast rule but certainly 15%-20% is  recommended for those newer to the space as a minimum in order to be competitive.  With proven experience and track record, more leeway can be taken in the fullness of time.  Bear this in mind when developing your EB-5 business plan and financial projections.

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

 

Download Your Free Paper:  9 Things to Know  Before Going Down  The EB-5 Road

 

Tags: EB5 capital, EB-5 Project, EB-5 explained, EB-5 investors, I-526, EB-5 Business plan, EB-5 Regional Center, job creation, What is EB-5?

A Reminder About Bridge Financing in EB-5

Posted by Phil Cohen on Mon, Feb 09, 2015 @ 07:12 AM

bridge

The good news for those who would look to put bridge financing in place ahead of attaining EB-5 capital is that the bridge financing now only has to have been considered as temporary financing at the time that it is put in place (May 30th, 2013 USCIS Policy Memo), and the deal for that financing should somehow reflect the fact that it is short term or bridge financing. 

By definition then, anyone who is looking to get a deal going under the EB-5 program using bridge financing to get started more quickly, should be able to move forward to replace that bridge financing with EB-5 capital even if using EB-5 capital specifically was not the plan initially.  In turn, this means that EB-5 business plans can be developed with more definitive development schedules, and even better, that indirect jobs based on economic impact models that use investment dollars as an input can start to claim job creation even before investors are found.

It should also be noted, however, that commonly the farther back in time that one goes (i.e. the distance in time from the date that EB-5 funds are expected to be raised and used to relieve the use of funds from bridge financing), the more challenging it becomes to show sufficient 'nexus' (or the connection between how the EB-5 funds/ bridge funds lead to the creation of jobs).  If you are using bridge financing be sure to have an in-depth discussion with your attorney to make sure it is set up properly so that you will not have problems down the road.

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

 

Download Your Free Paper:  9 Things to Know  Before Going Down  The EB-5 Road

Tags: capital raise, EB5 capital, EB5 Regional center, bridge financing, EB-5 investors, USCIS, EB-5 Business plan

Good News From USCIS Regarding EB-5 RFE Analysis (and Prevention)

Posted by Phil Cohen on Wed, Jan 14, 2015 @ 07:10 AM

analysis resized 600Good news! On the USCIS call engagement of December 5th, 2014, USCIS indicated that they will try and analyze EB-5 project and regional center RFE trends in order to narrow down some of the “pain points” and educate the community on those issues.

When this initiative is carried out we think this will have the preventative effect of reducing the number of RFEs and will enhance the EB-5 program overall, including clarity regarding the development of Business Plans, beyond the somewhat dated (and not always relevant) Matter of Ho guidance. This will give additional comfort to EB-5 investors and the EB-5 community overall as they start on the development of EB-5 initiatives and business plans.

 

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Phil Cohen is the founder and President of Strategic Element, a company that focuses on developing regional centers, EB-5 business plans, economic impact reports, feasibility studies and custom 'direct' EB-5 projects for its clients (www.strategicelementconsulting.com). 

 

Tags: EB-5 Project, EB-5 investors, I-526, USCIS, EB-5 regional centers, I-924, EB-5, EB-5 Business plan

Unofficial Dec. 5 USCIS EB-5 Stakeholder Call Transcript Available

Posted by Phil Cohen on Tue, Dec 16, 2014 @ 12:17 PM

eb 5 stakeholders call resized 600USCIS December 5th, 2014 Stakeholder Call Unofficial Transcript Notes

From Strategic Element, your source for EB-5 Business Plans

 

Please Note:

  • Strategic Element does not make any representation or warranties about the accuracy of this transcription or any of the statements or claims represented therein.
  • Strategic Element does not have permission to represent any of the names of any of the participants in the call so aside from USCIS employees, the names are not mentioned in the transcript that follows.  If you were one of the attendees who asked a question represented herein and you would like it attributed to you, please contact us at inquiries@strategicelementconsulting.com.  We will only include names and company names at your request.
  • Strategic Element did not include questions that were not answered or sufficiently addressed by USCIS on the call, and omitted any irrelevant comments.
  • Strategic Element attempted to transcribe the call as closely as possible to what was said by each speaker, including grammatical inaccuracies, but some comments, statements and/or questions were not audible.

 

Mariela Melero: I want to thank every single one of you for joining us today; I want to thank those you that are here but also those that are joining us telephonically. My name is Mariela Melero  and I am the Associate Director of USCIS Customer Service and Public Engagement. Our engagement today, my distinguished colleagues and friends from the immigrant investor program office, Nicholas Colucci who is the Chief of the Immigrant Investor Program Office and Julia Harrison, who is the Deputy Chief of the Immigrant Investor Program Office. In addition, we are extremely honored to have with us today USCIS Director Leon Rodriguez who will be addressing us shortly.

 

Mariela Melero went on to state that the members of the media who were joining them in the room or over the phone could contact the USCIS at 202-272-1200 for additional information.

 

I would also like to take just one minute to go over today’s agenda. The first thing that we are going to have is the opportunity, as I just mentioned a second ago, to hear from our  Director. Following the Director’s remarks, we will hear from both Nick and Julia, who will highlight various EB-5 program updates and several upcoming initiatives. After their presentations, we will move fairly quickly into a question and answer session with them and with some of our SMEs that are here as well to allow amole time to address every single one of your questions. Now we will turn the session over to our Director Leon Rodriguez.

 

Leon Rodriguez:

 

Good afternoon, it’s great to see everybody. This afternoon was supposed to be my introduction to you and your introduction to me. What has been very interesting just about the last ten minutes is that in all the stakeholder gatherings that I’ve had since becoming USCIS’s Director five months ago, this is the one in which I knew the most people. So as I worked the room when I first walked in I actually had a number of prior interactions, dealings, relationships with so many of you in this room and one in particular [INAUDIBLE] my days as the County Solicitor Montgomery County Marilyn really reminded me of a critical theme for the discussion we are going to have today and really for my attitudes and perspectives of the EB-5 program.

 

When I was County Solicitor, a big part of our role was supporting the County Office of Economic Development, supporting the County Executive as he travelled all over the world to stimulate foreign investment in Montgomery County, from China, from Korea, from Israel, from all over really seeking those business relationships with other parts of the world and they have formed in me the seeds of a belief that this is a program that is very critical to the economic development of our communities because it can mean investment, it can mean jobs if you look at the EB-5 program just in the last year talking about 5.5 billion dollars in potential investment in our communities; so I really have the desire to not merely be an operator of the EB-5 program, not merely a manager of the EB-5 program but really to be an enthusiast of the EB-5 program, to really champion the potential that it represents for our communities in the United States, subject of course to the fact that we have to do our jobs with respect to national security, with respect to the integrity of the program. So my commitment to you is to find that appropriate balance in the program between making sure that we realize the full potential of this program with full intent that the Congress had when it passed this program, but really managing it in the most efficient and appropriate way that we can with respect to the program.

 

Now one of the things that I really want to accomplish this afternoon, unfortunately I am not going to be able to stay here for the entire time, is really take the advantage of sitting in this environment to hear the kinds of things that we are going to talk about, the kinds of concerns that you may be raising; I look forward to a de-briefing after because I think it’s you who are really going to present to us the critical perspectives on how this program can run best, how it can run better.

 

I do think that the decision that we made to bring the program here in Washington, its process by the way not a complete process just yet, represents the right way to treat this critical program and so I’m gratified to see that our goals to further staff up the program, that those goals are moving closer and closer to  fruition; I actually had the opportunity to be a little cheeky with one of you and to say well what should I talk about and you said well how about you talk about that fourteen month wait and that’s why it’s critical to point out that we are still building the program, we are still getting it up its full level of staffing and so really hopeful that once we reach that full level of staffing that those waits will become a thing of the past. We know that that’s among the many issues that we need to work on – that’s a critical one that we do need to work on. So I look to hearing feedback, exactly like that feedback, because it gives us the opportunity to do better; it gives me the opportunity to as the new Director to really immerse myself in this really critical program.

 

By the way, I would take a close look at the president’s executive action; there are a couple of things in there – I think the business visa stuff is stuff that you were following all along but there are a couple of entrepreneur programs and investor programs that I think are going to be important to your community; so I would commend you attention to those programs as well and that signals my moment to be quiet and start listening. So I just want to thank you all for being here today and I look forward to a long and fruitful relationship. Thank you.

 

[Nicholas Colucci] :

 

Thank you Director. Good afternoon everybody; it’s really nice to see you all here in person. We’ve done three of these now and they’ve all been a few of sitting in a speaker room talking  to 500-600 people  so it’s nice to get some audience reaction. The 50 or so of you in this room are joined by about 500 individuals on the phone line; it includes are colleagues within IPO as well as the administrative appeals office and other colleagues across the agency.

 

Before we begin, I’d like to introduce just a few members of the IPO staff they are going to join me today in the stakeholder engagement; you met Julia, the Deputy Chief of the program. We have our three division chiefs here as well [INAUDIBLE NAME]  and Lori Melton are here. They are division chiefs over the adjudicators and then John Lion is our chief of the economists or leads the economist group.

 

I’m going to start today by looking at fiscal year fourteen which just by way of background for us ran October 1st, 2013 to September 30th of 2014. I’m sure you will all agree that it was a particularly noteworthy year for the EB-5 program, just with respect to the administration of the program to the program side some of the things that the Director talked about in terms of building the program and getting staffing together. We have excelled in our new space; we moved about a month and a half ago and it’s much more conducive to sort of our work flow needs, as well as our file storage needs; we’re happy to have that. I’m also happy to inform you that as of September 30th, all of the forms have now been transitioned to the immigrant investor program office. As you will recall, the 829 was being worked at the California service center that is since been transitioned.

 

You know one of the things that was critical throughout the year was, as the Director mentioned, was really building our staff and we were able to really recruit train and hire, not necessarily in that order, but recruit, hire and train really capable and motivated staff. I can’t speak enough of their talents to adjudicate these applications and petitions. At the end of the fiscal year 14’, we had 83 individuals on board with the program and that’s specific to IPO. With respect to our fraud detection and national security officers who support the program, thirteen of them were on board at the end of fiscal year 14’, and with respect to chief council we had eleven attorneys on board; again these groups provide direct support to the program. Today IPO stands at 94 strong and we are working to bring on board ten employees on board in the next few weeks and we do enjoy that same level of support that I’ve talked about from chief council and FDNS.

 

Now to turn to the program itself, as you know, the program just experienced really unprecedented growth in fiscal year 14’. The number of approved regional centers at the end of the fiscal year neared 600. This is an increase of nearly 230 from the end of fiscal year 13’; so a significant increase year over year. We received nearly 11,000 immigrant investor petitions throughout the fiscal year. These ranged a great number of projects and a wide variety of industries; things from huge infrastructure projects, commercial construction, mining operations, the entertainment industry; these types of projects really do run the gamut of the American economy.

 

Just another interesting statistic, the 11,000 petitions that we received, equalled greater than one quarter of the petitions that we’ve received since the program began in 1990. So again just  a remarkable year; and as a result, I know as you are all aware, for the first time the program used an allocation of approximately 10,000 visas which became unavailable as we closed out the fiscal year. As you also know, those visas are now available once again. One thing I want to mention about the fiscal year 14’, is we undertook a fairly comprehensive review of the regional center population to determine continued eligibility to the review of  the I-924 As that were submitted by the all of the active regional centers at the end of fiscal year 13’. As a result of this review, we terminated seven regional centers for failing to file the I-924A. We also issued 28 notices of intent to terminate to regional centers that no longer served to promote economic growth. We’re currently the reviewing the responses to some of those and we’ll take any appropriate final actions in the coming months. While we are on the topic of the 924A, some of you mayors have received on Wednesday an alert that went out just reminding those regional centers that were active and had an active designation at the end of fiscal year 14’, that the I-924A is due on Dec 29th. So please try to get those in by that day if you haven’t already. And then finally on the 924A, in preparation of this engagement we received a number of questions and more of the questions, actually more of the comments, asked us to revise the 924A we organize it and just to let you know the 924, the regional center application and the I-924A are currently open for public comment. We have made revisions to both of those forms. Any event you don’t know; if you have any suggestions on how we can improve the forms please do visit the [INAUDIBLE]  register and leave a comment. For those of you in the room we have the site on a slide in the room; for those of you on the telephone, we’re going to provide that after the call.

 

Before we begin a look at 15’, I just want to take a few more minutes to again look at the growth of the program in 14’. As I mentioned, we received, again 11,000 petitions. We also received, and as the Director mentioned, that represents nearly 5.5 billion dollars of potential investment in the United States economy. We also received 270 924s either applications or amendments to regional centers and more 2500 petitions to remove conditions. Let me just go over those again; I know those of you on the phone are probably writing things down – Nearly 11,000 petitions, 270 applications or amendments to regional centers and more than 2500 petitions to remove conditions.

 

Just to give you an idea of the year over year growth in each of those form charts, form fiscal year 13’ to 14’, that’s a 72% growth in the I-526, again greater than 70%. For the I-924, it’s a  34% growth and then finally 829 106%. We do a number of briefings on the EB-5 program and one of the things we emphasize is the growth of the program and I think one of the most telling statistic is the one that we use when we compare what we have now compared to just 2007 which was just a short time ago. In 2007 we had eleven active regional centers. We received fewer than 800 immigrant investor petitions, the 526s and received fewer than 200 of the 829s. So again that just speaks to the explosive growth of the program.

 

Just to talk a little bit about, very quickly about the processing time and I’ll address it in a few minutes as well. As the Director said, our 526 processing time stands at 14.3 months at the end of the fiscal year. On the 829s we’re at 6.8 months and then finally for the 924 8.5 months and those processing times are available on our website.

 

Now to look at fiscal year 15’, one of the things we did this year as a staff is we put together an operational plan that is going to help guide our work, measure our progress because as you know what gets measured, gets done and then finally keep our collective eye on the ball; we don’t want to get distracted by shiny objects; so, we want to make sure we have this plan to guide our work. We wanted to do this so that we can communicate to all of our stakeholders within the agency, the department, members of congress and all of you some of the things that are important to us and we’re trying to get down in fiscal year 15’. Two of our priorities are internally focused: maintaining a strong infrastructure and assuring that we continue to develop our workforce and I’m not going to spend a lot of time discussing them today; I would know however that with respect to both of those, we want to continue to attract, retain and develop top talent and this has become increasingly important as the complexity and the size of the projects we’re seeing continue to increase. In terms of what I’ll call the initiatives a little bit more operational in nature, we’re going to focus on three primary areas: improving customer service and outreach, providing high quality services and strengthening program integrity. I’m going to spend a few minutes discussing a component or two under each one of these areas.

 

For customer service and outreach we’re going to continue to hold quarterly stakeholder engagements and provide timely responses to the 1000s of inquiries we receive each year. Just by way of background, we set up a customer service branch April of this year and that branch has responded to about 5000 inquiries in that time; so that just speaks to the number of inquiries that the program receives. You know one of the benefits of processing times going down, that number is going to go down as well too. We are going to expand the number of engagements and Julia is going to talk a little bit about some of those in a few minutes; however, one of the new [INAUDIBLE], we’re going do is going to have IPO personnel to travel out to the field to get to know some of our federal and local partners, help them better understand the program which is absolutely critical with a program of this size and scope and then also to establish those relationships.

 

While we are in the area, we do plan to hold outreach events; so, we’ll make everyone aware when we do that. To move to high quality services, this is processing times, we’re going to try to get those forms in processing times while maintaining the high level of quality in all of our adjudications and communications. It’s going to be challenging, I mean honestly, with the processing time for the 526 of 14 months, we’ve got our work ahead of us but we’re going to make every effort to achieve the goal. We just came off of a month where we challenged the entire office, including me, we wanted to get a 1000 actions done in the month of November and we finished the month with a 1048; so, we actually hit that goal and we’re excited about it.

 

Just in terms of the staff that we have working the petitions and applications, we currently have 40 non-supervised re-adjudicators who work with staff, we have four who work the forms and applications, we have four more who are going to be coming on board and we have seventeen non-supervised re-Economists. We had our last group of adjudicators come on between the middle of September and the middle of October and I’m happy to report they’ve already completed training and done mentoring and they’re actively contributing to the program in a huge way so we’re very pleased with the progress of that group and the progress of the direction that we’re going and we expect to see processing times on the 526 come down in the near future.

 

One of the other things with respect to providing high quality services is to issue well-timed guidance and one example of that is guidance on the area of retrogression. We’re certainly aware of the impact that visa retrogression may have on the EB-5 program and we’re working internally to prepare policy guidance on several related issues. We did receive, prior to this engagement, a number of questions on retrogression and we’re going to respond to those later in the session.

 

And finally the last thing I want to talk about in terms of our three operational goals is further strengthen the program integrity in the coming year. As you know program integrity is something that is vital to all of us. For us it continues to be a top priority to collaborate with those law enforcement and regulatory organizations to help prevent fraud and develop new ways to further enhance confidence in the program.

 

In the year ahead, we plan to expand site visits both domestically and abroad to validate supporting documentation, we expect to expand our regional center to comply interviews, that’s the review of 924A, bringing in new commercial and government data sets to assist. Our FDNS team, fraud detection and national security team, is going to continue to expand in size and receive additional training on combating money laundering, fraud and international banking crime to enhance their knowledge and capabilities. They have acquired new software tools to assist them in building cases and they’re going to continue to build their tool box. You know, as you know, maintaining program integrity is not something just that we can do; we have to all work together. You’re going to be in a position to encounter incidences of fraud, whether it’s through prospective partner, potential investor or just something you see on the internet. I urge you to contact us and let us know so that we can work with our partners to investigate the activity.

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Note from Strategic Element: This is the 20 minute mark of the call and concludes our posted portion of the stakeholder’s call.  In order to receive the entire unofficial call transcript note please sign up to our mailing list at: Strategic Element Mailing List 

 

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Tags: amendment application, EB-5 center I-924, escrow, EB-5 investors, I-526, I-924, EB-5, EB-5 Business plan, EB-5 Regional Center