Expert Insight Series: Key Points from Immigration Investor Program Office Acting Chief Julia Harrison

Over the next few weeks we will be providing some insight into key immigration news directly from the source, Immigration Investor Program Office (IPO) Acting Chief Julia Harrison. This information comes from the EB-5 National Stakeholder Engagement conversations held in November. This series will aim to report back to our readers the most important information we have received and to explain how this will affect EB-5 Visas in the near to medium term.

Mark Ivener, A Law Corporation, is focused primarily on aiding our clients in efficiently and effectively working through the EB-5 Visa process, so we are committed to maintaining thought leadership so that our clients and stakeholders can understand EB-5 as well as possible.

Key Meeting Attendees:

Julia Harrison, IPO Acting Chief

• Acting Chief as current Chief, Nick Colucci, is on detail as Deputy Director to the Refugee Asylum and International Operations Division

Ricky Murray, IPO Division Chief of Adjudications

• A key player in the development of EB-5 policy and procedures
• Now serves as Division Chief for Operations, but continues to provide guidance and support to the Policy team

Jan Lyons, IPO Senior Adviser for Economics

• Has been with IPO since its inception
• Is a leading expert providing knowledge and guidance to IPO

Alissa Emmel, IPO Head of Compliance Team

Adam Hermansen, IPO Branch Chief for Compliance Division

Rebecca Galindo, IPO Acting Division Chief for the Fraud Detection and National Security Division

Larry O’Connell, IPO Branch Chief for FDNS

IPO Year In Review

EB-5 Regional Center Compliance Review Program

• IPO conducted a regional center review in 2017 with the goal of verifying the information provided by designated Regional Centers (RCs) in applications and annual certifications, and verifying compliance with applicable laws and authorities to ensure continued eligibility for the RC designation
• The RC Compliance Review is in its initial phase, but aims to review 5-10 percent of RCs per year once it reaches its full capacity
• Coordination and collaboration from both the RC and United States Citizenship and Immigration Services (USCIS) is critical to successful reviews
• Regional Centers that consent to data requests and onsite visits as part of the review process should have all required documentation on hand and readily available for review during the onsite assessment
• In order to most effectively comply, Regional Centers should appoint an EB-5 point person who coordinates and manages interaction with the review team and will ensure that any documentation required for EB-5 compliance can be readily accessed

Transparency and Customer Service

Published Filing Tips on USCIS.gov

• Helpful filing tips have been posted to USCIS.gov
• Thus far stakeholder feedback has been largely positive, so these tips are worth reviewing

Published Regional Center Terminations in the Reading Room

• Redacted versions of Regional Center termination notices have been posted to the reading room
• This information can be helpful if you are looking to understand what can cause a RCs termination

I-924A Form Amendments

• We are working to amend instructions on this form, based on stakeholder feedback, to make some necessary corrections

I-924 Cover Letters

• During FY2017, IPO asked stakeholders to include cover letters with their Form I-924 exemplar filing
• Many stakeholders have included these cover letters, and IPO has seen significant value from these
• IPO has asked that stakeholders continue to include cover letters with their I-924

For more Expert Insights, read our Second and Third instalments.