There are many advantages to receiving your EB-5 Regional Center designation from the USCIS. But with this process comes a great deal of administration, documentation and paperwork. Every year, businesses that want to retain their EB-5 Regional Center designation must file a Form I-924A Annual Certification of Regional Centers with the USCIS before December 29th. Consequences for non-compliance can include penalties, time-consuming Requests for Evidence and, at worst, the loss of designation to participate as a regional center in the Immigrant Investor Program.
The Form I-924A has become a critical tool for USCIS to oversee the program and ensure the continuing eligibility of regional centers. It enables USCIS to understand exactly what types of projects and job creation activity are taking place under each designated regional center.
This year, USCIS introduced a new version of the Form I-924A and held a webinar on August 24, 2017, to review the updates. The new edition of Form I-924A is longer and requires more information and evidence from the regional centers. Regional centers must track and report both aggregate capital and EB-5 capital investments by NAICS industry code for each of their EB-5 projects or NCEs for the fiscal year.
In addition, job creation data must also be reported based on the fiscal year, and inputs should be prorated accordingly. The regional center must provide an analysis with an explanation of the methodology used, and many experts feel that engaging an economist to assist is a best practice.
Joseph Barnett, Associate Attorney at Wolfsdorf Rosenthal LLP, wrote in a recent article that “it’s critical to start the process of collecting relevant information and documents in the autumn months… Regional Centers that wait until December may very well end up being overwhelmed with the amount of information that needs to be included.”
The USCIS stressed that consistency between all other documents filed with the USCIS, such as I-526s and I-829s, is something that they are looking at closely. Regional centers with multiple projects may find it time-consuming to bring information from disparate sources into a consistent format.
Together with EB5 Affiliate Network, NES Financial is now offering customers a new service to streamline, automate, and bring consistency to completing the I-924A. Regional centers can now generate an accurate detailed Form I-924A and financial analysis in less time, for less cost — and maintain a consistent format for presenting complex information across multiple projects.
Allow us to address your EB-5 needs by contacting us. We look forward to hearing from you!