IIUSA has responded to USCIS request for comments and they have created a very indepth analysis of the positive and negative effects of the proposed rule making.
Their comments include analysis on the major hot buttons in EB-5 including:
- The EB-5 visa minimum investment amount
- The EB-5 project target employment areas (TEA designations)
- The EB-5 visa priority date retention capability (due to material changes)
- EB-5 visa retrogression
- EB-5 investor fraud recovery provisions – relief for defrauded investors
The download for IIUSA’s comments is attached here: