Mid-November news

This week I don’t have much to report except what’s missing.

IIUSA held its teleconference this week on the I-924a form (annual reporting requirement for Regional Centers), and we discovered that the even the experts don’t know how those blanks are “supposed to be” filled in.  The official instructions don’t define or explain the questions, and the form runs into basic ambiguities in the program such as “what is a RC direct job?” and “how do we define and identify the entities relevant to RC job creation?” The IIUSA panel basically advised regional centers to report whatever they individually judge should be reported, and accompany answers with notes explaining how the RC interpreted the I-924a questions. That way (in case USCIS reviews the forms in police mode) the RC can at most be charged with innocently misunderstanding the question, not with providing misinformation. Another rule of thumb is that the safest answer to any question is probably the answer most consistent with information previously filed by the RC with USCIS. [Update: see the I-924a Questions and Answers published on 12/06/11 by USCIS]

And now this weeks’ EB-5 tragedy: the USCIS list of approved Regional Centers has been completely reformatted, and currently lists only the names of Regional Centers! I wonder if the webmaster got sick of being called on to change phone numbers and fix spelling mistakes. What will I do for entertainment now that I can’t stalk RC contact people? How will we know the industries and geographic areas being approved for each center?  I hope that the full directory is restored to us soon!

But not to forget the good news: we have a golden opportunity to help flesh out the new draft EB-5 Adjudications Policy. The comment period ends December 9, 2011.

Joseph Whalen, who manages to keep up with the Federal Register, reminds me that USCIS published this week an Information Collection on the Form I-526, which means an opportunity for the public to suggest changes to the form. Relevant info is published at at www.regulations.gov.