Masami Hibino

Our clients are asking if we could summarize and clarify the newly announced redeployment rules for them.

Our clients are asking if we could summarize and clarify the newly announced redeployment rules for them. Many have funds with regional centers that have completed the original projects. The JCE has already paid back the NCE. The NCE has redeployed the EB5 capital to other projects. They are anxious to know if the redeployment of their funds is within the newly announced guidelines and policy of USCIS.


Marko Issever
August 10, 2020 10:53 PM  Marko Issever

Although the newly announced policy of USCIS clarifies many of the open issues, it still leaves quite a few very important items open to discussion. In no order of importance, the newly announced policy states that further redeployment:
• must be through the same NCE and be consistent with the original purpose of the NCE

• must be within the geographic area of the same regional center, including any amendments to the regional center’s geographic area approved before the further deployment

• must be made within a commercially reasonable period whereby USCIS generally considers 12 months

• cannot be made into financial instruments, including municipal bonds or securities


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