FY2022 Annual Report of the Visa Office for EB-5 visas issued by country
March 6, 2023 41 Comments
The Department of State has finished publishing its Report of the Visa Office 2022. The report covers EB-5 visas issued from October 2021 to September 2022, with breakdown by country of origin, path (consular processing or status adjustment), and category (direct, regional center, TEA, reserved, unreserved). I’ve been waiting anxiously for the report, wondering about visa wastage, Integrity Act implementation, and impacts on the visa backlog and EB-5 visa wait times for China, India, and Vietnam.
This post comments on highlights, followed by data tables summarized from the reports.
FY2022 EB-5 Visa Issuance and Wastage
USCIS actually issued 10,885 of the unusually-high 19,987 EB-5 visas available in 2022. Of the 9,102 EB-5 visas that didn’t get issued in FY2022, 6,396 couldn’t have been issued because segregated in newly-created set-aside categories. (The unused set-asides should carry over in future years, though the FY23 visa limits report doesn’t show the carryover.) The remaining 2,706 unused EB-5 visas in FY2022 were permanently lost to EB-5. (FY2022 is still much better than FY2021, when EB-5 lost 15,673 total visas, and FY2020, when EB-5 lost 7,498 visas.)
Visa wastage particularly affected countries with mostly regional center applicants using consular processing. For example, South Koreans got 695 EB-5 visas in 2019 (the most recent “normal” year) but only 396 visas in 2022 (86% by consular processing), despite the fact that 909 South Korean EB-5 applicants were ready and registered at the National Visa Center at the start of 2022. Hong Kong likewise suffered, with only 142 EB-5 visas issued in FY2022 despite 866 Hong Kong applicants ready at NVC at the start of the year. Meanwhile Indians, many adjusting status in the U.S., managed to get a record 1,381 visas in 2022 – even more than technically available to them under the year’s unreserved visa limit.
Reasons for FY2022 EB-5 Visa Wastage
EB-5 visa issuance in FY2022 was as low as it was largely due to the unfortunately protracted regional center program expiration, and the policy that prevented visas from being issued to regional center applicants from October 2021 to May 2022. (I wish that policy could be litigated on behalf of the over 18,000 EB-5 visas lost during the expiration.) Monthly visas statistics show that all regional center visas issued in FY2022 were packed into just four months: June to September 2022.
The government had the entire year to issue direct EB-5 visas, but only issued 621, likely constrained by low demand (i.e. few direct I-526 filed and even fewer making it through I-526 processing to the visa stage). By comparison, 414 direct EB-5 visas were issued in the last normal year of FY2019.
Consular processing numbers were also depressed overall compared with FY2019, reflecting on-going struggles with post-COVID backlogs. For color on why the steps in consular processing remain so slow and problematic, see questions and answers in the Department of State/AILA Liaison Committee Meeting February 9, 2023, the NVC Immigrant Visa Backlog report (look at trends in the number of interview appointments, and compare appointment volume with backlog size), and the October 2022 Update on Worldwide Visa Operations. Those in or approaching consular processing should be aware of the NVC Timeframes page, with information on process status and times. The bright side is that consular problems affect not only EB-5 but also family-based visa issuance, and EB-5 benefits in 2023 from a share in FB visas that went un-issued in 2022 (as reflected in 2023’s unusually high EB visa limit).
High Volume of EB-5 Status Adjustments in FY2022
EB-5 visa issuance in FY2022 was as high as it was thanks to an unprecedented high number of status adjustments (37% of the total, as compared with 17% in 2019). For example comparing 2022 with 2019 visa issuance, China got fewer visas last year through consular processing but five times as many visas through status adjustment.
The unusually high AOS numbers reflect the fact that USCIS got political pressure and made herculean efforts at the end of FY2022 to step up work on employment-based status adjustments, even as consular processing continued to struggle post-COVID.
Direct EB-5 (and the visa bulletin even briefly becoming Current for China direct EB-5) did not contribute much boost. China ended the year with only 199 direct EB-5 visas issued – not much higher than usual, and not explaining the unexpected thousands of Chinese who adjusted status in 2022.
RIA Implementation, Reserved Visas, and Country Caps
Report of the Visa Office 2022 does segregate EB-5 visas into “5th Unreserved” and “5th Set-Aside” categories, reflecting changes to visa availability made by the EB-5 Reform and Integrity Act enacted March 15, 2022. Of course, no visas were issued in 2022 in the “5th Set-Aside” categories, since no applicants who filed I-526 after March 15, 2022 could have reached the visa stage in time. And according to Department of State interpretation, all EB-5 applicants with pre-March 2022 priority dates can only now qualify for a visa in the new 68% unreserved category, regardless of whether they invested in a TEA that matches new definitions. (I think this interpretation can and ought to be challenged, at at least one lawsuit by DRVC is challenging it, but it’s the fact for now.)
In theory, country caps further restrict availability within each category. Thus pending applicants from any one country can only expect up to 7% of the 68% unreserved EB-5 visas (with “otherwise unused” unreserved numbers going to the oldest priority dates i.e. Chinese).
In 2022, this theory held true for Vietnam but not for India. While both countries have excess demand for unreserved visas, and large NVC backlogs, the government in fact issued 815 EB-5 visas to Vietnam (about 7% of unreserved EB-5 visas) and 1,381 EB-5 visas to India (about 7% of total EB-5 visas). Hmmm…
Was this different treatment of Indians and Vietnamese an oversight, with the government remembering the unreserved limit in the new law for Vietnam while forgetting it for India? 2022 was naturally confusing for the Visa Office, which had to deal with a mid-year law change and leadership change. Or did many Indians get lucky just because they happened to be in the US, unlike most Chinese and Vietnamese EB-5 applicants with earlier priority dates? I wonder if maybe Indians got assigned “otherwise unused” numbers at the end of the year that should’ve gone by right to earlier Chinese priority dates, but practically couldn’t because the consulate in China lacked capacity to hold more interviews in time while the California Service Center had capacity to complete more I-485 and help avoid wastage. (I also wonder if a difference between consular and USCIS capacity to issue visas at the end of the year could explain the unusually high number of Chinese regional center applicants who were able to adjust status in FY2022 — more applicants than one would expect from priority date order.)
Country Diversity
FY2022 was similar to previous years in terms of countries claiming the most EB-5 visas. As in 2019, the top users in 2022 were (in descending order): China, India, Vietnam, South Korea, Brazil, and Taiwan. Meanwhile, Mexico, Canada, Russia, and Iran moved a few notches up the list in 2022, while Venezuela, South Africa, Great Britain, and Japan moved a few notches down. I was surprised mainly by the number of Canadians on this year’s list (why, Canada?) and Iranians (considering the often arduous source of funds path).
Visa Demand Context
For a reminder of the size of the visa queue before FY2022 visa issuance, see the presentation by Charles Oppenheim for IIUSA in November 2021. At that time, Oppenheim estimated the EB-5 backlog (including applicants already registered at NVC and potential future applicants associated with I-526 pending at USCIS) at 57,253 visa applicants for China, 7,418 for India, 3,954 for Vietnam, and 18,054 for other countries (see Slide 10).
Visas issued in 2022 reduced those queues by 6,125 visas to China, 1,381 visas to India, and 815 visas to Vietnam. (I assume that I-526 filings in 2022 didn’t grow the queues very much, unless it turns out that most of the 829 receipts last year came from Indians).
The future wait times associated with that scary queue depend on (1) how many petitioners/applicants in the queue will ultimately give up/lose eligibility before they can clam a visa (likely a large number given the untenable wait times looming for Chinese and Indians near the end of the queue), and (2) how many EB-5 visas will be issued per year from now on, with the base case being 9,940 EB-5 visas * 68% unreserved * 7% country cap = up to 473 to applicants of each country. The actual number of visas available per-country in a given year can be significantly higher than the 473 base case based on carryover of family-based visas (as happened in FY2022 and happening again in FY2023 due to COVID-19), carryover of reserved visas (as should happen in 2024 and 2025 assuming law compliance and continued slow I-526 processing), and unreserved visas leftover after country caps (which should increasingly benefit China in coming years). But even with the most optimistic assumptions on future visa availability, Chinese who filed I-526 from October 2016-March 2022 and Indians who filed I-526 from November 2019-March 2022 could face five or more years of waiting just for conditional permanent residence. Or would face that wait, except that it exceeds what many applicants (not to mention their RCs, projects, and investments) can practically bear, predictably leading to many queue-shortening drop-outs/failures. Meanwhile, new investors in reserved categories have to sweat over limited availability (with just 20%, 10% or 2% of visas available in each new lane, further restricted under the 7% country cap) and guessing the time for I-526 filings to invisibly build and max out that limited availability. I’ll write more about unreserved and reserved visa availability and wait time issues in separate articles.
The bottom line is that EB-5 suffers from a supply problem. EB-5 needs more visa numbers in order to accomplish what regional centers, investors, and public policy all require: a stable and predictable immigration opportunity that can accommodate new investors plus prevent a despairing rush for the exits for past investors/investment.
EB-5 Updates 
Suzanne, you are simply amazing with your insights and analysis. You are the only one who can do this.
Thanks Suzanne for sharing! Our I-526 petition was approved last Nov and we still not yet received a welcome letter from NVC. We are from Hong Kong, so there is no visa backlog problem.
We contacted NVC but they have no records that USCIS has transferred them our petition. We tried USCIS hotline, it is just an AI agent. She is not able to solve our problems or transfer us to a real person agent.
It is almost 4 months. Our lawyer also seems not able to check our case with USCIS. We are pretty upset and shall appreciate your suggestions on what else we could do to keep our case moving.
Many thanks!
Here are the steps that Department of States suggests taking, according to a Q&A with AILA in June 2022 (https://travel.state.gov/content/travel/en/News/visas-news/department-of-state-aila-liaison-committee-meeting-06-09-2022.html):
16. AILA members have seen multiple examples where USCIS approved a petition and the priority date is current, but no NVC case number has been issued, preventing the case from moving forward as no fee can be paid, no DS-260 can be prepared, and no documentation can be submitted to the NVC. Attorneys have followed up multiple times through the appropriate attorney form online, requesting the case number to be issued, and sent emails to the NVC research box. Unfortunately, responses from the NVC continue to state that “(I)t can take up to six weeks for an approved petition from USCIS to arrive at the NVC…” How can AILA members obtain a case number for cases where it has been more than six weeks or longer since the petition approval and efforts following the previously advised protocols have not seemed to resolve the issue?
Response: NVC is unable to create a case or issue a case number until it receives an approved petition from USCIS. There is a known issue with some approved petitions transferring from USCIS to NVC. USCIS has made changes to their system and is working with DOS to fix the remaining petitions. If it has been more than sixty (60) days after receiving an I-797 Approval Notice from USCIS, and NVC did not receive your client’s approved petition, we recommend emailing NVCResearch@state.gov for assistance. Please provide a copy of your client’s I-797 Approval Notice and any additional information you may have about the petition. NVC will work with USCIS on your client’s behalf to locate the petition and have it transferred to NVC.
See also comments in the February 2023 meeting: https://travel.state.gov/content/dam/visas/AILA/AILA-Agenda-02-09-2023.pdf
Who knows why the communication between USCIS to Department of State is so slow and problematic, since the February 2023 meeting reveals that USCIS sends the I-526 approvals by email!
EB5 petitions can run to thousands of pages. I wonder if USCIS is manually scanning them before transferring them to NVC? Could explain the delays we are seeing?
Thank you!
Experience of Telegram EB5 Consular Processing group shows that USCIS is taking around 6 months to transfer approved I526 to NVC. We currently have members still waiting for NVC welcome letter after receiving I526 approval in October 2022
NVC told us 2 weeks ago that they would check which USCIS office has our petition and request them to send through our case.
Do you know how we could speak to a real person agent by calling the USCIS hotline? The AI agent just won’t connect us to a real person. We really wish to check directly with USCIS to see why they are not transferring our case.
Thanks
Try saying ‘Infopass’. Sometimes this will connect you to live agent at USCIS
Thank you! Shall try.
Thanks Katy! We finally managed to speak to a real person over the hotline. They confirmed that our petition is still with USCIS, and that they received our inquiry but we have to wait till end of Mar (30 biz days) for a formal reply. We just do not understand why they are not even able to offer a reason why our petition is being hold. It is 112 days now since approval.
Hi Johnny,
May I know your priority date of your I-526?
I am also a HK investor but I have not received any update on my I-526. My priority date is Nov 2019.
Dec 2018
Thanks Suzanne for your continued analysis !
Is there any way to predict when I 485 ( India) will be approved . It has been submitted in 2019 May ( almost 4 years ) .
Yes, but it’s complicated. In theory your I-485 time should be a function of visa availability not processing capacity, though that might end up not the case in practice due to non-FIFO I-526 processing. For a visa availability estimate I start from number of Indian I-526 filings since 2016, estimate with reference to visa issuance and periodic per-country I-526 inventory reports how many of those investors are likely still in the system today, estimate attrition and family per principal, and then line up that that total estimated pending Indian visa demand through May 2019 with estimated annual visas available to India going forward. So many assumptions are baked in that I’ve hesitated to just put my estimate model out on the internet without being able to explain/qualify it to people one by one (which I don’t have time to do in volume), to avoid misinterpretation and undue reliance. But FYI next year is what the current version of my model guesses for you. AIIA is working on analysis to share with investors.
Suzanne, thank you so much for sharing your analysis .
Thanks Suzanne, your analysis are excellent. Your blogs are most awaited for me. Your blogs are so easy to understand to layman like me.
In this blog, small confusion I am having is on estimate demand as of 2023 which is at 75793. I think two input items are missing from this estimate-
1. Rejection/ withdrawal of I-526 (Rejection has been high in last 12 to 18 months and you too have written about it)
2. New cases of I-526 added during this period.
Do let me know if I am missing something in my observation, your clarification always helps.
Thanks once again and my best wishes to you for your brilliant work.
Hi Suzanne,
First, I really appreciate your work on this blog, which includes valuable topics and responses to inquiries about EB-5.
Basically, we have I-526 petition that is very complicated and troubling to us, and I’d like to present it for here :-
Our I-526 Petition (P D is 01/19/2018) filing made by our ex-lawyer (he is also the Developer). He received $20,000 to do that.
We got (NOID) on 11/20/2020 .There were numerous omissions and mistakes. They issued the NOID So we decided in consultation with the Regional Center to select another immigration attorney.
We paid ($15,000) additional Legal Fee to an attorney in a famous law firm in New York to correct I-526 filing made by our ex-lawyer (the Developer).
Also we paid $7,500 for Funding of Econometric Job Study (he initially paid for the study, but his check was denied by the bank for insufficient funds).This is a requirement of USCIS as stated in the NOID.
And we paid $4,500 for a new revised business plan as prescribed in the NOID issued by USCIS.
The response was delivered to USCIS on 02/21/2021. While we are waiting for approval based on the expectation of lawyers, or at least a RFE, we are surprised we got another NOID on 1/5/2023 with a number of strange requests and exaggerations in strictness in the SOF, although the notes contain a number of obvious errors, and we do not know if there were other errors in complex things. It seems to us that who review our case is inexperienced or a beginner .
We are really stuck with a former immigration attorney who is also the developer, the regional center that we do not know what his responsibility is, and the USCIS.
I paid large amounts of money, which caused me debts, which later forced me to take out a loan to pay them off. I am a retired employee and my wife and I put all our savings into this investment. It is very difficult for us to pay again if we may lose.
I hope to find advice from you, as you are an expert in this field, how to deal with these complications, and where to start, or a road map, especially since the deadline is close.
Note:
Ready to communicate with you if you do not mind and send a copy of the first NOID with the response and a copy of the second NOID.
I am so sorry to hear of this sad (and all-to-common) story! I will email you.
Hello Suzanne,
Thanks for your in-depth analysis and easy to understand articles to explain these complex issues.
My Priority Date is 7-Dec-2021 and after implementation of RIA Act, I was hoping to do AOS but India back-logged to 8-Dec-2019.
Any predictions from your end sighting previous years’ visa bulletin’s when India will become “Current” again for unreserved category (for Direct project, not RC)?
Any guidance will really help. Thanks.
Past visa bulletins indicate nothing for the future. In principle, your wait time is a function of visa demand from applicants with priority dates earlier than yours, and visa supply going forward. Visa bulletin dates will only show a smooth trend if past I-526 filings and past/future visa availability have a smooth trend, but they do not.
First for the theory… If few Indians who filed I-526 before March 2022 drop out, and if the law doesn’t reshuffle visa availability again, then the theoretical calculation suggests that India should be “Current” in the unreserved category Chart A by about 2031. In theory the Visa Bulletin should show final action available to December 2021 Indian applicants some time between 2028 and about 2031, depending on how many I-526 were filed by Indians in 2021/2022. (I only have data on India I-526 receipts through September 2020, so priority dates after 9/2020 take more guesswork.)
One factor undermining the theoretical data-based calculation is that it has to assume that visas get issued in priority date order. But USCIS has confused that by slow and disordered I-526 processing. The Visa Bulletin will move more quickly than the theoretical calculation if many Indian I-526 remain prevented by slow processing from reaching the visa stage. Some Indians will get visas more quickly than expected based on filing date so long as USCIS continues to process I-526 and advance people to the visa stage out of FIFO order. These effects have been on display in the past few years. So there’s still a chance for you to get lucky if I-526 processing volume remains low and your I-526 gets processed much before others — especially, if you can manage to get an approval in advance of the huge surge of Indians who filed I-526 in late 2019. Once many Indian I-526 from 2019 get approved and reach the visa stage, then the visa bulletin will move very slowly for India.
Also, the theoretical calculation assumes that known demand today perseveres to the visa stage. But since the calculated wait is obviously way too long for many people or projects to take in practice, I expect that high drop-out and failure rates will in fact reduce the queue and thus wait times for those who don’t withdraw/lose eligibility. I’ve made a model that pieces all the available data on visa supply and demand for assessing the wait time situation, and I expect AIIA and/or IIUSA to come out with that model soon. But the reality is that no matter the demand/supply numbers, people will wait exactly and only as long as they can bear to wait for visas, and no longer.
And so many things can change over time! The last time I offered an EB-5 timing estimate service was 2019, and my careful data-based calculations at that time failed to predict that a global catastrophe would nearly shut down consular processing around the world for two years, that the regional center program would expire for almost a year, and that the law would change to take EB-5 visa availability away from 2019 applicants in order to set aside more visas to to 2022+ applicants instead. Those factors combined to make the Visa Bulletin open for India for years even though India had already built up a 7-year backlog as early as 2019, and resulted in unnaturally lengthening wait times for some while shortening them for others. So now I’m more hesitant about sharing data-based estimates about the future!
Thank you for sharing. I am having a problem that my document was DQed on Sep 2022, but still waiting IL. Do you have any estimation about this? My embassy is in Vietnam
Thanks for all your help. Is there a reason why Korea’s numbers were far below its quota when other backlogged countries weren’t? Do you expect Korea’s numbers to remain below quota this year, and would you expect an Oct 2019 PD from Korea to receive approval in the next 12 months?
The theory I put forward in the post is that consulates were less able than USCIS to scale up to issue a year’s worth of visas in just four months. This would result in relatively few visas for Korean investors, who mostly get visas through consular processing, versus Indian investors, many of whom are in the US adjusting status at USCIS. The regional center program expiration for most of FY2022 was to blame for leaving regional center applicants only four months to receive visas in FY2022, and that factor is no longer at play this year. I’d expect that you should get an interview in the next year if you’re registered at NVC and ready to go (the country limit for S. Korea this year is greater than the number of Korean applicants registered at NVC). But if you don’t have I-526 approval yet (and I guess you wouldn’t, since USCIS is still mostly processing I-526 up to early 2019), the situation is more complicated. South Korea recently had over 1,000 I-526 pending adjudication, and that crowd will trigger the visa bulletin if advanced to the visa stage all in one year. If USCIS keeps up with its extremely low-volume I-526 processing (i.e. advancing people to the visa stage at a very low rate), then South Koreans may wait so long for I-526 processing that they avoid a visa number wait at the visa stage.
Hi Suzanne, thank you as always. any idea how long I-526 approval is taking investors from Canada? We filed in 2020.
I post information related to I-526 processing on this page: https://blog.lucidtext.com/processing-data/ In theory it’s not country-specific except for countries with cut-off dates in the Visa Bulletin Chart B.
Hi Suzanne,
Thank you for all the inputs i EB-5.
I’m a Taiwan petition, PD: 4/SEP 2018 RFE: 2/JAN 2021 Received RFE:28/MAY 2021
Do you have any idea or insight why taking so long for final decision? Is it possible to get final decision in the upcoming JUN. or before the end of this year, thanks.
The time between RFE response and decision should not normally exceed a year, and I wonder whether your file could’ve been misplaced. (IPO lost many adjudicators in 2021/2022, which gave ample opportunity for in-process files to slip through the cracks and not get reassigned when the responsible person quit.) You might talk to your attorney about starting to lodge case status inquiries starting with the IPO Customer Service mailbox, so that at least your I-526 gets found.
Thanks Suzanne.
My petition was just approved in 13 MAR. Hope I can get my green card early May.
Getting the GC by May is a very aggressive expectation. Our case was approved in Nov 2022. It is almost 4 months, USCIS not even transferred our case to NVC.
Suzanne have you been following the EB5 implications of the Signature Bank failure? Many RCs are holding investors funds with pending I526 in escrow in that bank.
I have watched the situation with concern, but have no inside info. As if RCs and investors were not already overburdened with risks!
Hi Suzanne,
Thanks for all the data and insight you’ve been sharing with us. I am from Turkey and my priority date is Feb. 2019. Is there are light at the end of the tunnel? Thanks for your time…
The largest number of I-526 decisions last month were on cases filed in February and March 2019, so there’s hope! But no assurance, since the Investor Program Office is far from following FIFO discipline (last month also saw decisions filed as long ago as 2015 and as recently as 2022).
Thx for the reply. One last question. Do you think USCIS prioritizes Adjustment of status applicants over applicants seeking Consular Processing?
Hi Suzanne,
my I-526 priority date is Nov 2019 and Hong Kong-born. Although the current 80% processing time shown in USCIS website was 58.5 months, I have waited for over 36 months.
I am currently in the US with F1 visa. The attorney helped us to file I-485 (concurrent filing), EAD card, and AP (was considered to be combo card before but right now USCIS has split it into two cards and two processing cases). I have got my EAD card already.
Conservatively, how long do I have to wait for I-526 to be approved and in turn I-485? Thank you.
Our case is similar, except I-526 PD Oct 2018 Taiwan born. Can I-485 (concurrent filing) be approved with a pending I-526?
Hi Suzanne,
Thanks once again for your analysis and views. I have posted my journey with dates earlier and would like to do so again as information for everyone.
Country- India
I526(through RC) filing and priority date- Nov 29 2018
Approval date- Apr 7 2021
Case transferred to Dept of State- 30 Dec 2021
NVC Case creation date- 6 May 2022
DS-260, fee payment and Civil Docs submission date- 28 Jun 2022
No response from NVC until Dec 2022. Turns out that we were expected to email documents to NVC since the case was subject to electronic processing. This was not stated in any of their letters/communication.
It took assistance sought by me personally from a Congressman’s office to find this issue out.
Documents emailed on- 18 Jan 2023
Additional docs requested by NVC on- 26 Jan 2023
Additional docs sent to NVC on- 28 Jan 2023
Document complete email received- 15 Feb 2023
Letter from NVC confirming interview received on- 7 Mar 2023
With a few weeks to go for the interview and just when we see light at the end of the tunnel, the final action date for I5(Unreserved) has retrogressed to June 2018. We were thinking of flying out by June end and I don’t think that looks likely.
Hi Suzanne,
Thank you for your blogs. These are very informative, especially for newbies like me.
I am a prospective EB5 investor from India. I am already in the US on H1b visa and a EB2 priority date of August 2015.
I see both TEA and rural categories are current for India, and I know it doesn’t indicate the number of applicants who already filed their I-526E. But do you know if applying in either category will make any significant difference if I file in next 30-45 days?
The reason I am asking is rural projects seem finically riskier, but can provide quicker I-526 approval. But if TEA is likely to see major backlog soon, there is no point going with it. Going from one backlog (EB2) to another will be devastating, but also don’t want to increase the risk of losing the entire investment.
I am trying to evaluate financial vs. immigration risk. Any suggestion you can provide will be really helpful.
Whether you would find yourself caught in a backlog for rural depends on how many people file I-526E and get I-526E ahead of you in rural projects. We have no data yet for number of rural I-526/I-526E filings, so the size and country composition of the backlog is unknown. The speed of I-526 processing is only helps to avoid backlogs if it’s a differentiator, and advances some people to the visa stage ahead of others. But in the rural context, every rural I-526 is supposed to receive priority processing, so it’s not a relative advantage in competing for rural visas. Considering that marketing seems overwhelmingly focused on Indians, and very limited per-country visas availability under country caps, I’m very concerned about the potential of Indians repeating the the history of Chinese in EB-5.
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