4/22 Meeting Statements, New RCs, RC Terminations

Note that the prepared remarks of Chief Colucci and Deputy Chief Harrison from the April 22 EB-5 Stakeholder Meeting have been posted on the USCIS website. So long as stakeholder engagements are about making statements, it is very nice to get these statements in written form.

New & Removed Regional Centers
Additions to the USCIS Regional Center List, 4/13/2015 to 4/27/2015

• Hana Financial Regional Center (California): www.hanafinancial.com
• Pan-Pacific Regional Center (California)
• West Coast Regional Center, Inc. (California, Nevada): www.pathwayseb5.com

Additions to the USCIS Terminated Regional Center List 3/28/2015 to 4/21/2015

• Nevada California Regional Center (California, Nevada)

Regional Centers spooked by the growing list of terminations may be interested in Robert Divine’s article “Regional Center Terminations” on p. 18 of the March 2015 Regional Center Business Journal. Mr Divine discusses the process, reasons for, and consequences of termination. Recall that blatant securities violations are just one reason for termination, with others including lack of activity, failure to file Form I-924a, USCIS rejection of the model used for project development, and USCIS accusations of misreporting or mismanagement. In the April 22nd EB-5 stakeholder meeting, Chief Colucci revealed that the majority of recent Regional Center terminations have been associated with the Form I-924A, based on lack of filing or on matters raised during I-924A review. With that in mind, the article “Form I-924A as a National Security and Fraud Detection Tool” by Andersson and Bulter (p. 21 in the March 2015 RCBJ linked above) is also essential reading for Regional Centers. The article describes the I-924A review process as revealed by published DHS reports and an internal USCIS document (included, probably by accident, in a response to an IIUSA FOIA request). Reading about the process, it’s clear that USCIS is trying to be serious about Regional Center oversight. They will not only read the Form but screen program principals and investment entities through TECS (the modified Treasury Enforcement Communications System), coordinate with USCIS Fraud Detection and National Security in case of any questions, examine the Regional Center website for red flags (including use of USCIS logo, implication of USCIS endorsement, and guarantee of repayment or visa), perform Internet searches for derogatory information, scrutinize foreign ownership, and examine results from USCIS’s iCLAIMS database.