EB5AN is pleased to announce that we have received I-956 approvals for all of our regional centers. This means that USCIS has vetted each regional center and found it compliant with the new policies of the EB-5 Reform and Integrity Act of 2022 (the RIA).
Many regional center operators own only a few regional centers covering a limited geographic area. But EB5AN’s regional centers cover the entire continental United States, making this achievement even more noteworthy.
With this milestone, EB5AN can sponsor best-in-class EB-5 projects anywhere in the continental United States.
“Receiving I-956 approvals for 100% of our regional centers is a rare milestone in the EB-5 industry,” notes EB5AN managing partner Sam Silverman. “We’re simply continuing our perfect track record of USCIS approvals for our regional centers and EB-5 projects.”
“EB5AN’s investors can be confident that we will spare no effort in ensuring compliance with USCIS policies—with the goal of helping as many investors as possible get U.S. Green Cards under the EB-5 program.”
In this post, we explore EB5AN’s impressive history of USCIS approvals and the requirements for regional center designation through Form I-956. We then show why I-956 approval is often a key indicator of a regional center’s ability to sponsor successful EB-5 projects.
EB5AN’s Strong Record of USCIS Approvals
Requirements for Regional Center Designation Through Form I-956
What EB5AN’s Form I-956 Approvals Mean for Our EB-5 Investors
Choose a Regional Center Operator with A Solid Track Record
EB5AN’s Strong Record of USCIS Approvals
EB5AN Submits Form I-956 on Day 1
USCIS released Form I-956, Application for Regional Center Designation, on May 13, 2022. The RIA had been signed into law in March 2022, only a few weeks before.
USCIS required all EB-5 regional centers to submit Form I-956 to demonstrate their compliance with the RIA. Even if a regional center was in good standing, it would lose its USCIS designation if it failed to submit Form I-956.
Additionally, Form I-956 introduced multiple new requirements for applicants, including several new reporting and transparency policies, more rigorous standards to justify economic impact and job creation, and detailed background information on individuals involved with a regional center.
While most of the EB-5 industry was still struggling to adjust to the RIA, EB5AN had proactively adjusted its internal procedures to comply with the new rules.
Despite the extensive amount of documentation required, we submitted our first I-956 petition on May 14, 2022—only one day after USCIS released the new application.
Our application comprised more than 1,000 pages, including a new, RIA-compliant Policies and Procedures manual, detailed business plans, economic impact reports, and other supporting evidence.
USCIS approved our first I-956 petition only five months after filing, with no RFEs or additional questions.
I-956 Approvals for Regional Centers Covering the Entire Continental U.S.
This I-956 approval—one of the first in the EB-5 industry—would set the foundation for the rest of our successful I-956 submissions.
None of our regional centers lost their USCIS designation, and all remain in good standing with USCIS. And, after multiple I-956 approvals, EB5AN’s regional centers now cover the entire continental United States.
Despite a strict regulatory environment, EB5AN has significantly expanded its regional center coverage under the RIA.
Based on publicly available information, we are the only EB-5 operator whose regional centers cover 100% of the continental United States.
EB5AN’s Track Record of USCIS Compliance
In addition to our recent I-956 submissions, EB5AN has consistently obtained USCIS approval for all of its regional centers and projects.
Requirements for Regional Center Designation Through Form I-956
Background Information for Individuals Involved with the Regional Center
Form I-956 must identify all individuals involved with the regional center. Additionally, anyone with “substantive authority” in the regional center must submit more details in a separate application, Form I-956H.
Form I-956H, Bona Fides of Persons Involved with Regional Center Program, requires individuals to submit their background information and their biometrics.
Only U.S. citizens and lawful permanent residents are allowed to be involved with an EB-5 regional center.
Demonstrating Economic Impact and Job Creation
Form I-956 requires regional centers to demonstrate how their projects will have an economic impact and create jobs throughout their coverage area.
USCIS expects I-956 submissions to include business plans and economic impact reports showing the kinds of EB-5 projects that will be sponsored by the regional center. These documents must also describe what kinds of direct and indirect jobs will be created.
Compliance with the RIA and Other USCIS Requirements
The RIA introduced multiple new reporting and oversight requirements for regional centers. Among other measures, regional centers must now send periodic reports to USCIS and to their investors on the status of the EB-5 funds.
I-956 applications must “describe the policies and procedures in place reasonably designed to monitor new commercial enterprises and any associated job-creating entity.” These policies and procedures must ensure that the EB-5 funds are managed transparently and in compliance with securities laws.
In their Policies and Procedures manuals, I-956 applicants should also describe their standard operating procedures, internal controls, and measures for detecting or deterring fraud.
Since our first I-956 submission, USCIS has consistently approved EB5AN’s policies and procedures under the RIA, showing our strict commitment to managing our investors’ funds responsibly.
What EB5AN’s Form I-956 Approvals Mean for Our EB-5 Investors
USCIS has raised the standard for regional centers under the RIA, with rigorous new requirements for Form I-956.
To a large extent, an EB-5 investor’s success depends on the regional center he chooses to work with. If a regional center sponsors financially stable EB-5 projects and is committed to USCIS compliance, its investors will be more likely to qualify for U.S. Green Cards.
Reliable regional centers make sure that all of the EB-5 funds are disbursed to the EB-5 project entity and used to create EB-5-eligible jobs. Job creation is one of the key requirements to gain U.S. Green Cards through the EB-5 program.
An investor’s financial success also depends on the careful oversight of EB-5 funds, following the RIA’s transparency and accounting procedures.
When one EB-5 regional center achieves I-956 approval, this can be a good sign that it will handle funds responsibly and remain compliant with USCIS policies.
But if all of an EB-5 operator’s regional centers receive I-956 approval, this is an even stronger indication of professionalism, attention to detail, and ultimately, trustworthiness.
With I-956 approvals for every single one of our regional centers, EB5AN has taken USCIS compliance to the next level. USCIS has carefully vetted our economic projections and determined that our regional center projects can indeed create EB-5-eligible jobs.
Coupled with our flawless track record of USCIS approvals, investors can be confident that our projects and regional centers will help them get U.S. Green Cards through the EB-5 program.
Choose a Regional Center Operator with A Solid Track Record
A regional center operator’s track record can be an important indicator of future success.
If a regional center has not yet received I-956 approval, EB-5 investors should be cautious before investing in its projects.
Or a regional center operator may have I-956 approval for some of its regional centers, while others have been denied. Perhaps the regional centers that were approved received multiple requests for evidence (RFEs) or notices of intent to deny (NOID).
These could all be red flags indicating that the operator does not understand USCIS policies or lacks experience in the EB-5 industry.
We advise EB-5 investors to examine their regional center operator’s history of I-956 approvals and denials. An experienced operator should have I-956 approval for most, if not all, of its regional centers.
“Our I-956 approvals give our investors peace of mind,” explains Mike Schoenfeld, managing partner of EB5AN. “USCIS has vetted our internal procedures and our potential to create jobs, proving our ability to sponsor successful EB-5 projects.”
“We spare no effort in making sure we remain USCIS-compliant, all to the benefit of our investors. Our priority will always be to help our investors achieve their main goals: get U.S. Green Cards and a timely repayment of their funds.”
Form I-956 approval is only one of the many factors EB-5 investors should consider when selecting an EB-5 project and a regional center. To learn more about the best practices for planning an EB-5 investment, schedule a free consultation with EB5AN.
