position paper presented to ipo on rc termination
TRANSCRIPT
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 1 OF 15
Submitted by:
Joseph P. Whalen
238 Ontario Street, No. 6
Buffalo, NY 14207
(716) 604-4322 (cell)
(716) 768-6506 (land-line)
IMMIGRANT INVESTOR PROGRAM OFFICE (IPO)
U.S. CITIZENSHIP AND IMMIGRATION SERVICES (USCIS)
DEPARTMENT OF HOMELAND SECURITY (DHS)
131 M Street NE
3rd Floor, Mailstop 2235
Washington, DC 20529
POSITION PAPER
ON CONSIDERATIONS FOR TERMINATION
OF REGIONAL CENTER DESIGNATION
I. What are the Primary Purposes of an EB-5 Regional Center?
Under Section 610(a) of the Appropriations Act of 1993, an EB-5 Regional Center is
to principally serve as a conduit for “concentrating pooled investment in defined economic
zones.” The Regional Center Model offers immigrant investors “already-defined”
investment opportunities, thereby reducing each investor's responsibility to identify
acceptable investment vehicles. In a broader sense, the Regional Center is intended to
support “the promotion of economic growth” on a regional (or national) scale; potentially
including: increased export sales; improved regional productivity, job creation, and/or
increased domestic capital-investment. Collectively, the aforementioned attributes describe
what was originally known as the “Immigrant Investor Pilot Program”. Congress officially
dropped the word “Pilot” from the legislation when it extended the Program in 2012, but
did not make the Program permanent nor incorporate it into the Immigration and
Nationality Act (INA). Effectively, the “EB-5 Regional Center Program” remains in
“Pilot” mode. See generally: Matter of A-L-V- LLC, ID# 15160 (AAO June 20, 2016); 8
C.F.R. § 204.6 (m) (3); and Pub. L. 102–395, title VI, § 610, Oct. 6, 1992, 106 Stat. 1874,
(Appropriations Act of 1993), as amended. [8 U.S.C. § 1153 Note: Immigration Program].
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 2 OF 15
Creating an EB-5 suitable and compliant offering is a great beginning but it is only one
of the purposes of a Regional Center. In order to be able to fulfill its continuing
responsibilities and future obligations, a Regional Center must have in place a careful plan
for oversight. The Regional Center must track data and collect evidence to support its EB-5
investors’ I-829 petitions and its own I-924A annual report forms. It is through the
information reported on the I-924A forms that USCIS begins its inquiry into the question
of whether or not the Regional Center is promoting economic growth. The surest indicator
of whether or not a Regional Center is meeting its basic obligation is the rate at which its
investors receive approval of their I-829 petitions and have their conditions lifted from
status. I find this to be the best indicator because in order to have conditions lifted, the
evidence supporting the I-829 must show full and proper expenditure of the minimum
investment amount and creation or preservation of the minimum of ten (10) permanent full-
time jobs.
USCIS inherited INS’ definition of a “Regional Center” which is found at:
8 C.F.R. § 204.6(e) Definitions. ……
“Regional center means any economic unit, public or private, which is
involved with the promotion of economic growth, including increased
export sales, improved regional productivity, job creation, and increased
domestic capital investment.”
The above regulatory definition largely parrots the statute which, in my opinion,
means that this definition is unworthy of Chevron1 deference. It is unworthy because it fails
to provide any useful interpretive value so as to inform applicants, or guide adjudicators. See
Fogo de Chao (Holdings) Inc. v. U.S. Dep 't of Homeland Sec., 769 F. 3d 1127, 1135 (D.C.
Cir. 2014) (…No deference is due, however, to an agency’s interpretation of its own
1 Chevron U.S.A., Inc. v. NRDC, 467 U.S. 837 (1984) is the Supreme Court case which describes a
methodology for evaluating agency interpretations, especially where there is ambiguity in the statute, and
declares generally that the interpretations made by an agency entrusted with enforcing a particular statute are
entitled to deference if the interpretation is reasonable.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 3 OF 15
regulation when, “instead of using its expertise and experience to formulate a regulation, it
has elected merely to paraphrase the statutory language.” In re Polar Bear Endangered
Species Act Listing & Section 4(d) Rule Litig., 709 F.3d 1, 18 (D.C. Cir. 2013) (quoting
Gonzales v. Oregon, 546 U.S. 243, 257 (2006)).)”
Compare the regulatory definition above to the statutory language below. The bulk of
the regulatory definition was lifted from § 610(a) except INS changed one word, a very
important word. INS changed the word “or” to “and” which by itself, is enough for any
District Court Judge to declare the definition ultra vires, beyond statutory authority. That
small but significant change added a burden “above and beyond” the statutory requirement.
It changed various alternatives into “all inclusive” components. The question is then
whether a requirement imposed in the relevant regulation crosses the line from permissible
statutory interpretation by the responsible agency to ultra vires regulation contrary to the
clear intent of Congress. See Shalom Pentecostal Church v. U.S. Dep 't of Homeland Sec.,
783 F.3d 156, 165-67 (3d Cir. 20 15).
II. Section 610(a) Factors
This paragraph of § 610, provides the closest thing to a statutory definition to be
found. It also provides the clearest statement of a Regional Center’s, and the Program’s
purpose.
“….. Such program shall involve a regional center in the United States,
designated by the Secretary of Homeland Security on the basis of a
general proposal, for the promotion of economic growth, including
increased export sales, improved regional productivity, job creation, or
increased domestic capital investment. A regional center shall have
jurisdiction over a limited geographic area, which shall be described in the
proposal and consistent with the purpose of concentrating pooled
investment in defined economic zones. The establishment of a regional
center may be based on general predictions, contained in the proposal,
concerning the kinds of commercial enterprises that will receive capital
from aliens, the jobs that will be created directly or indirectly as a result of
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 4 OF 15
such capital investments, and the other positive economic effects such
capital investments will have.”
The function of the Regional Center as it relates to the purpose of the overall EB-5
Regional Center Program2 is larger than a single development project. However, with that
said, there has to be a starting point which means that there must be an initial pooled
investment for the Regional Center to begin to have any effect upon the defined economic
zone. In other words, the Regional Center provides the mechanisms through which this
Investment Immigration “Program” will achieve its goal of promoting economic growth
within its limited geographic area. The primary measure of success for this Program is
employment creation. Employment creation is, of course, the title of the EB-5 visa category
as found in the INA.
III. Section 610(c) Factors
This paragraph of § 610, modifies the mechanisms by which the EB-5 investors may
demonstrate job creation. More precisely, it gives what little statutory guidance there is as
to the factors to be considered when estimating indirect job creation.
“In determining compliance with section 203(b)(5)(A)(iii)[(ii)] of the
Immigration and Nationality Act [8 U.S.C. 1153(b)(5)(A)(iii)[(ii)]], and
notwithstanding the requirements of 8 CFR 204.6, the Secretary of
Homeland Security shall permit aliens admitted under the program
described in this section to establish reasonable methodologies for
determining the number of jobs created by the program, including such jobs
which are estimated to have been created indirectly through revenues
2 For practical purposes of this discussion and to aid the reader’s understanding, the program under
examination is labelled simply as “Immigration Program” in the United States Code, but in the 2012
program extension, Congress referred to an “EB-5 Regional Center Program”. Colloquially, this program is
called the “Immigration Investment Program”, “Investment Immigration Program”, or “Immigrant Investor
Program”.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 5 OF 15
generated from increased exports, improved regional productivity, job
creation, or increased domestic capital investment resulting from the
program.”
While Congress was originally interested in emphasizing “exports”, it has since
backed away from that stance. Various indirect jobs resulting from the program may now
be attributed to various alternatives factors and still count towards the individual investor’s
eligibility requirement for the lifting of conditions from lawful resident status. For
example, the input category of “revenues generated” often used in economic models
predicting employment creation, can come from any of the enumerated alternatives:
A. increased exports,
B. improved regional productivity,
C. [direct] job creation, or
D. increased domestic capital investment.
These data points, and others, are used as acceptable inputs in models, in order to generate
economic impact analyses, all of which have been previously examined by USCIS and
found to be “reasonable methodologies” for estimating indirect job creation, and “other
positive economic effects” mentioned in § 610(a), above.
A. Sec. 203(b)(5)(A)(ii) [8 U.S.C. § 1153(b)(5)(A)(ii)]
The employment-based, fifth-preference immigrant visa classification, or as
more commonly, and simply, known as the “EB-5” visa is defined at INA
§203(b)(5) [8 U.S.C. §1153(b)(5)]. This visa classification was created by
Congress in the Immigration Act of 1990 (IMMACT90) and is a permanent part
of the INA. This visa classification has no “sunset date” unlike the EB-5
Regional Center Program which currently does have a “sunset date”. This
statutorily defined classification is entitled “employment creation”, and requires,
inter alia, the investment of a defined amount of capital that results in the
creation of “… full-time employment for not fewer than 10 United States citizens
or [selected classes of] aliens lawfully admitted…” and work authorized.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 6 OF 15
B. Notwithstanding the Requirements of 8 CFR § 204.6
Congress sought to soften those parts of the original regulations,
promulgated by INS in response to the Immigration Act of 1990 (IMMACT90),
that they thought were too harsh and restrictive. Any part of the present EB-5
regulations relating directly to Regional Centers was written in response to
Congressional intent behind the program created through the Appropriations Act
of 1993, so none of those Regional Centers-specific regulations can be
challenged under this clause.
C. 8 CFR § 204.6(m)(6) & 5 U.S.C. § 551 (8)-(11)
The regulation at 8 C.F.R. § 204.6(m)(6) relating to the termination of
regional center status states:
To ensure that regional centers continue to meet the requirements of
section 610(a) of the Appropriations Act, a regional center must provide
USCIS with updated information to demonstrate the regional center is
continuing to promote economic growth, improved regional
productivity, job creation, or increased domestic capital investment in
the approved geographic area. Such information must be submitted to
USCIS on an annual basis, on a cumulative basis, and/or as otherwise
requested by USCIS, using a form designated for this purpose. USCIS
will issue a notice of intent to terminate the participation of a regional
center in the pilot program if a regional center fails to submit the
required information or upon a determination that the regional center no
longer serves the purpose of promoting economic growth, including
increased export sales, improved regional productivity, job creation, and
increased domestic capital investment.
Additional authority to check up on a Regional Center’s activities and to
determine if it is living up to its end of the bargain derives from a generally
applicable statutory provision of the Administrative Procedures Act (APA).
When viewed realistically, USCIS Designation of a Regional Center is a form of
licensure. Since INS failed to affirmatively define Regional Center designation
as licensure from the start, this realization came about after-the-fact, and after the
rulemaking concluded, and for that matter, for nearly two decades thereafter.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 7 OF 15
As a refresher, 5 U.S.C. § 551 is the definitions section of the APA and
states, in pertinent part, as follows:
“(8) "license" includes the whole or a part of an agency permit,
certificate, approval, registration, charter, membership, statutory
exemption or other form of permission;
(9) "licensing" includes agency process respecting the grant, renewal,
denial, revocation, suspension, annulment, withdrawal, limitation,
amendment, modification, or conditioning of a license;
(10) "sanction" includes the whole or a part of an agency-
(A) prohibition, requirement, limitation, or other condition affecting
the freedom of a person;
(B) withholding of relief;
(C) imposition of penalty or fine;
(D) destruction, taking, seizure, or withholding of property;
(E) assessment of damages, reimbursement, restitution, compensation,
costs, charges, or fees;
(F) requirement, revocation, or suspension of a license; or
(G) taking other compulsory or restrictive action;
(11) "relief" includes the whole or a part of an agency-
(A) grant of money, assistance, license, authority, exemption,
exception, privilege, or remedy;
(B) recognition of a claim, right, immunity, privilege, exemption, or
exception; or
(C) taking of other action on the application or petition of, and
beneficial to, a person;” …..
USCIS needs to incorporate some of the guiding principles found in the
APA, into new EB-5 regulations. Licensing is the most critical concept needed in
new regulations.
D. INA § 216A [8 U.S.C. § 1186b]
This statutory provision imposes conditions upon the status of EB-5
entrepreneurs or investors and their dependent family members. The same
section also provides the rules for lifting those conditions. This is therefore, a
very necessary consideration when judging the success and viability of a
Regional Center. Failure to deliver on the final prize does not bode well for the
continued participation of a Regional Center in the Program.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 8 OF 15
IV. Termination For Cause
Beyond termination for the technical violation of a Regional Center’s failure to timely
file an annual reporting form, Regional Center Designation may be terminated for cause.
The general reason for such termination is that “the regional center no longer serves the
purpose of promoting economic growth” but it is that phrase that causes debate. How does
the agency determine when “the regional center no longer serves the purpose of
promoting economic growth”? Maybe the question should be “How should the agency
determine when “the regional center no longer serves the purpose of promoting economic
growth”?” We are not left completely in the dark on this question, but the factors listed in
the statute, and merely parroted in the regulations, need further exploration and adequate
explanation.
Pooled investments made via Regional Centers are, in part, intended to aid alien
investors obtain EB-5 visas. The geographic regions wherein Regional Centers sponsor
those pooled investments, are intended to reap a variety of benefits. Congress expressed its
hope in the statute that these large capital expenditures, i.e. pooled investments, would
help the region by promoting economic growth through, and as evidenced by:
a. new revenues being generated,
b. (sometimes) increased export sales,
c. improved regional productivity,
d. job creation (direct, indirect, induced), and/or
e. increased domestic capital investment.
The above factors, and others, provide potential metrics or data points for measuring
results. Legacy INS listed more factors in the regulations, that it hoped would indicate that
a Regional Center has had, is having, or will have, a positive impact on the regional or
national economy in a general sense. Legacy INS envisioned that “other positive economic
effects” besides jobs, might be observed and measured, by tracking such factors as:
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 9 OF 15
a. increased household earnings,
b. greater demand for:
i. business services,
ii. utilities,
iii. maintenance,
iv. repair, and/or
c. construction, both within and without, the defined region.
See generally 8 C.F.R. § 204.6(m)(3).
The decision to “Terminate a Regional Center’s USCIS-Designation and participation
in the Immigrant Investor (EB-5) Program” is not a decision to be pursued, made, or taken
lightly. None of the various items listed above should be viewed in isolation. None of
them should be taken as an absolute indicator of success, or failure. All of them, and
probably many other factors not listed here, need to be viewed in their proper context, and
in the totality of the circumstances.
In my view, since Termination is such a harsh consequence, it is best for USCIS to be
strict up-front, making every effort to ensure that only the honest and competent
Regional Center Applicants will be rewarded with the privileges, and saddled with
burdens, inherent in Regional Center Designation. Among the privileges of Regional
Center Designation are inexpensive financing, and eager investors with low financial
expectation for returns on their investments. Those eager investors have their eyes on a
different prize; immigrant visas to the United States for themselves and their immediate
families.
Foremost among the burdens of Regional Center Designation is the necessity to
produce concrete results towards the Program’s goals. Regional Centers have an initial
obligation towards their potential EB-5 investors. They must take great care in evaluating
investment vehicles that will be offered to would-be immigrants. Said investment vehicles
need to fully comply with the letter and spirit of EB-5 law in order to have the best chance
for success. In that EB-5 jurisprudence is limited and uncertain, and usually in a state of
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 10 OF 15
flux, compliance can be difficult. That being the case, an overabundance of caution is the
safest approach for all parties. It would ensure smoother processing for applications and
petitions, swifter release of fund if held in (optional3) escrow, and greater economic
benefits to the U.S. regional and local communities. As of July 5, 2016, USCIS’ list shows
847 approved regional centers; with 59 terminations, as of July 13, 2016. Given the
limited annual number of EB-5 visas, there are far too many EB-5 Regional Centers which
indicates a strong likelihood that more terminations are on the horizon.
V. Collateral Damage – Denied I-829 Petitions
Assuming arguendo, that a Regional Center is properly “Terminated”; regardless of
the basis for that action; “What happens to that Regional Center’s EB-5 investors?” This
question has been asked with more frequency of late, in tandem with efforts by USCIS-
IPO to more seriously examine the viability of the growing ranks of EB-5 Regional
Centers. Some EB-5 stakeholders attempt to differentiate between those pooled
investments that fail, and those situations where investors have been defrauded. Others,
like myself, do not differentiate between them, however, there are differences as to how
we would treat these investors’ cases.
Some in the EB-5 stakeholder community advocate that investors involved in failed
projects should be rewarded with I-829 approvals regardless of their failure to meet the
legal requirements of INA § 216A [8 U.S.C. § 1186b] necessary for lifting conditions
from status. Some of them would base I-829 approval on some type of “hardship waiver”
(which does not exist in EB-5 law). Others would only offer “waivers” to one subset or the
other but not both. I advocate that both groups should be treated the same and be allowed
to try again with a new investment. My preferred course of action would only require a
policy to exercise Prosecutorial Discretion by refraining from terminating conditional
3 While escrow is not a legal requirement, it has been widely accepted as a best practice and has become
an expectation among alien investors. Use of escrow came into use in order to show compliance with the
“commitment of funds” requirement in I-526 adjudications.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 11 OF 15
status for a short time while the investor re-files a new I-526 petition. The sad part of this
approach are those cases where children might “age-out” but it would take Congressional
action to fix that issue. While it is far from perfect, absent a legislative fix, the
Prosecutorial Discretion approach, appears to be the only ameliorative option that is
currently possible under the existing EB-5 legal framework.
VI. Conclusion
In light of the foregoing discussion, it is now time to attempt to answer the main
question posed earlier. How should the agency determine when “the regional center no
longer serves the purpose of promoting economic growth”? It is essential to these
considerations to understand that Regional Centers are not equally situated. Not only are
there differences in geographic areas, by size, composition, and location; and “the kinds of
commercial enterprises that will receive capital from aliens”; there are also different
“levels” of Regional Centers.
By describing Regional Centers as being of different “levels”, I refer to whether the
Regional Center has gained its USCIS-Designation by presenting hypothetical, actual, or
exemplar projects4 or some combination thereof, to USCIS for vetting, whether initially,
or later in an amendment. The controlling USCIS Policy Memorandum for EB-5
Adjudications, in the footnotes on page 14, informs us as follows:
“2 An “actual project” refers to a specific project proposal that is
supported by a Matter of Ho compliant business plan. A “hypothetical
project” refers to a project proposal that is not supported by a Matter of Ho
compliant business plan. The term “exemplar” refers to a sample Form I-
526 petition, filed with a Form I-924 actual project proposal, that contains
copies of the commercial enterprise’s organizational and transactional
documents, which USCIS will review to determine if they are in compliance
with established EB-5 eligibility requirements.
4 EB-5 Adjudications Policy, PM-602-0083, (May 30, 2013), found on the USCIS Website at:
https://www.uscis.gov/sites/default/files/USCIS/Laws/Memoranda/2013/May/EB-
5%20Adjudications%20PM%20%28Approved%20as%20final%205-30-13%29.pdf
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 12 OF 15
3 In cases where the Form I-924 is filed based on actual projects that do
not contain sufficient verifiable detail, the projects may still be approved as
hypothetical projects if they contain the requisite general proposals and
predictions. The projects approved as hypotheticals, however, will not
receive deference. In cases where some projects are approvable as actual
projects, and others are not approvable or only approvable as hypothetical
projects, the approval notice should contain a statement identifying which
projects have been approved as actual projects and will be accorded
deference and those projects that have been approved as hypothetical
projects but will not be accorded deference.”
Based on the above, Regional Center-affiliated investment vehicles clearly have
varying levels of deference. These different levels of deference might, or might not, be a
useful indicator of likelihood of success. There are more factors to be considered.
However, when it comes to the determination of whether or not USCIS should even
consider probing the question of Regional Center viability, the amount of effort
demonstrated towards EB-5 legal compliance will likely be one factor taken into account.
Parlaying off the “deference level”, a logical subsequent consideration would be the
amount of additional time that a newer Regional Center should be allowed to “firm up”
their softer plans and take affirmative steps forward in their planning activities.
Thinking about the issue of which factors matter most to a particular Regional
Center’s viability, when done in the abstract, will likely lead to more questions than
answers. That is because each Regional Center will have its own specific set of issues and
concerns. The possibility of Regional Center Termination is naturally fact-specific, fact-
intensive, and very evidence laden. It will take serious consideration of many issues and
the weighing of a lot of documentary evidence in order to render accurate findings-of-fact
and subsequent conclusions-of-law that lead to a sound judgement on the question of
Termination. I see no bright line on the major issues and questions involved in these
decisions.
How much time may a Regional Center remain idle after attaining initial designation?
Is the answer different when designation was based on a “hypothetical” project versus an
“actual” or “exemplar” project? What are the acceptable signs of progress? When a
developer is progressing through preliminary matters such as obtaining permits, variances,
inspections, or perhaps completing an Environmental Impact Study and mitigation efforts;
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 13 OF 15
how much is enough to justify allowing a Regional Center to remain idle with no I-526
petitions filed? Given that there is a finite number of ~10,000 EB-5 visas, which could
realistically only cover 3,000 to 3,500 investments annually, which by-the-way, could not
possibly satisfy demand for the over 800 currently approved Regional Centers, if they
were active simultaneously; how many Regional Centers can USCIS and its federal
partners effectively “oversee” or “police”?
Let us not forget that every Regional Center must annually file Form I-924A and the
processing eats up agency resources. If only 50 to 100 out of over 800 Regional Centers
actually have a viable development project under way, then perhaps up to ~750 might
have to be evaluated for viability on an annual basis. What a waste of resources! Is it any
wonder why processing times stretch out so long? While it is true that the proposed new
and increased fees may allow IPO to increase human and technological resources, that
takes time to put in place. So, considering the battle for resources and effects on
processing times across the board, does it not make sense to cut the dead weight of non-
viable and/or inactive Regional Centers in addition to the technical violators, ordinary
failures, and those found to have engaged in fraud? While some stakeholders advocate for
“leniency” so that various Economic Development Agencies can have the lure of EB-5 “in
reserve” “just in case” a suitable project comes along; this same leeway would have to be
given to everybody (without a statutory change which would differentiate state and local
“agencies” from private sector actors). The annual burden and drain on resources for IPO
is likely to be an untenable situation. Processing times will not improve without change!
I have urged those Regional Centers in danger of Termination to simply Withdraw
from participation in the EB-5 Regional Center Program in lieu of Termination or to try to
negotiate a withdrawal and that USCIS accept it. I recognize that it might be necessary for
a lawsuit to be filed if a situation required an exercise of equitable estoppel in order to
protect the immigration processes of limited numbers of EB-5 investors affiliated with a
particular Regional Center. Whether it is styled as a Stipulation or as a Settlement is
irrelevant if what is required is an exercise of authority beyond the powers of USCIS.
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 14 OF 15
Bottom-line: It is simply too damned expensive to continue with the status quo!
The EB-5 Program and the EB-5 Industry must be streamlined or there will likely be
dark days ahead.
Dated this 29th of July, 2016
Joseph P. Whalen
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CONSIDERATIONS FOR TERMINATION OF REGIONAL CENTER DESIGNATION PAGE 15 OF 15
FOR EASY REFERENCE
AAO AFFIRMANCES OF REGIONAL CENTER TERMINATIONS
__________________________________________________________________________
USCIS’ POSTED NON-PRECEDENT TERMINATION APPEAL DISMISSALS
HYPERLINK CITATION STRING (IF ANY) NAME OF REGIONAL CENTER
JUN222016_01K2610.pdf Matter of P-C-F-R-C- LLC, ID# 14717 (AAO June 22, 2016)
Palm Coast Florida Regional Center
JUN202016_01K2610.pdf Matter of A-L-V- LLC, ID# 15160 (AAO June 20, 2016)
American Life Ventures Everett, LLC
NOV172015_01K2610.pdf Matter of K-R-C-, LLC, ID# 14127 (AAO Nov. 17, 2015)
Kentucky Regional Center
Jul232012_01K2610.pdf El Monte Regional Center
Dec212011_01K2610.pdf Regional Center of Victorville Development, Inc.