EB-5 Report

Department of Homeland Security
United States Citizenship and Immigration Services

EmploymentBased Fifth Preference (EB5)
Regional Center Program
OIG-14-19 December 2013
OFFICE OF INSPECTOR GENERAL
Washington, DC 20528 I www.oig.dhs.gov
December 12, 2013
MEMORANDUM FOR: The Honorable Alejandro Mayorkas
Director
United States Citizenship and Immigration Services
FROM:
SUBJECT: United States Citizenship and Immigration Services'
Employment-Based Fifth Preference (EB-5) Regional Center
Program
Attached for your action is our final report, United States Citizenship and Immigration
Services' Employment-Based Fifth Preference {EB-5} Regional Center Program. We
incorporated the formal comments from the United States Citizenship and Immigration
Services in the final report.
The report contains four recommendations aimed at improving the EB-5 Regional Center
Program. Your office concurred with three of the recommendations. The OIG considers
recommendations 1, 2, and 3 open and unresolved. As prescribed by the Department of
Homeland Security Directive 077-01, Follow-Up and Resolutions for Office of Inspector
General Report Recommendations, within 90 days of the date of this memorandum, please
provide our office with a written response that includes your (1) agreement or
disagreement, (2) corrective action plan, and (3) target completion date for each
recommendation. Also, please include responsible parties and any other supporting
documentation necessary to inform us about the current status ofthe recommendation.
Based on information provided in your response to the draft report, we consider
recommendation 4 open and resolved. Once your office has fully implemented the
recommendations, please submit a formal closeout letter to us within 30 days so that we
may close the recommendation(s). The memorandum should be accompanied by evidence
of completion of agreed-upon corrective actions.
Please email a signed PDF copy of all responses and closeout requests to
OIGAuditsFollowup@oig.dhs.gov.

Consistent with our responsibility under the Inspector General Act, we will provide copies of
our report to appropriate congressional committees with oversight and appropriation
responsibility over the Department of Homeland Security. We will post the report on our
website for public dissemination.

Please call me with any questions, or your staff may contact Anne L. Richards, Assistant
Inspector General for Audits at (202) 254-4100.

Attachment

www.oig.dhs.gov 2 OIG-14-19

Table of Contents
Executive Summary ............................................................................................................. 1
Background ........................................................................................................................2
Results of Audit ...................................................................................................................5
The Laws and Regulations .......................................................................................5
USCIS Mission Limitations......................................................................................6
Foreign Investments and Job Creation ...................................................................7
Program Integrity....................................................................................................9
Conclusion.............................................................................................................13
Recommendations ...............................................................................................14
Management Comments and OIG Analysis .........................................................15
Appendixes
Appendix A: Objectives, Scope, and Methodology............................................19
Appendix B: Management Comments to the Draft Report...............................21
Appendix C: Major Contributors to This Report................................................34
Appendix D: Report Distribution ........................................................................35
Abbreviations
CFR Code of Federal Regulations
DHS Department of Homeland Security
EB-5 Employment-Based Fifth Preference
GAO Government Accountability Office
iCLAIMS Interim Linked Application Information Management System
INA Immigration and Nationality Act
OIG Office of Inspector General
U.S. United States
USCIS U.S. Citizenship and Immigration Services
www.oig.dhs.gov OIG-14-19

Executive Summary
In 1990, Congress created the United States Citizenship and Immigration Services
(USCIS) Immigrant Investor Program, also known as the Employment-Based Fifth
Preference Program. The programs intent was to stimulate the United States (U.S.)
economy through job creation and capital investment by foreign investors. Three years
later, the Departments of Commerce, Justice and State, the Judiciary, and Related
Agencies Appropriations Act, 1993 created the regional center pilot program for pooling
investor money in a defined industry and geographic area. Our audit objective was to
determine whether the USCIS Employment-Based Fifth Preference regional center
program is administered and managed effectively.
Several conditions prevent USCIS from administering and managing the Employment-
Based Fifth Preference regional center program effectively. Specifically
The laws and regulations governing the program do not give USCIS the authority
to deny or terminate a regional centers participation in the Employment-Based
Fifth Preference program based on fraud or national security concerns;
The program extends beyond current USCIS mission to secure Americas promise
as a nation of immigrants; and
USCIS is unable to demonstrate the benefits of foreign investment into the U.S.
economy.
Additionally, USCIS has difficulty ensuring the integrity of the Employment-Based Fifth
Preference regional center program. USCIS does not always ensure that regional centers
meet all program eligibility requirements, and USCIS officials differently interpret and
apply Code of Federal Regulations and policies. Furthermore, when external parties
inquired about program activities USCIS did not always document their decisions and
responses to these inquiries, making the Employment-Based Fifth Preference regional
center program appear vulnerable toperceptions of internal and external influences.
As a result, USCIS is limited in its ability to prevent fraud or national security threats that
could harm the U.S.; and it cannot demonstrate that the program is improving the U.S.
economy and creating jobs for U.S. citizens as intended by Congress.
Your office concurred with three of the four recommendations made to assist USCIS
management and administration of the Employment-Based Fifth Preference regional
center program. Our recommendations focused on strengthening regulations for
oversight authority and consistent program application; better coordination with other
Federal entities; comprehensive reviews of the program; and quality assurance
procedures for program integrity.

Background
USCIS mission is to secure Americas promise as a nation of immigrants by providing
accurate and useful information to its customers, granting immigration and citizenship
benefits, promoting an awareness and understanding of citizenship, and ensuring the
integrity of the immigration system. In 1990, Congress created the USCIS Immigrant
Investor Program, also known as the Employment-Based Fifth Preference (EB-5)
Program. The EB-5 Program was created under 203(b)(5) of the Immigration and
Nationality Act (INA) in 1990,Public Law 101-649, Section 121(a), to stimulate the U.S.
economy through job creation and capital investment by foreign investors.
Through the EB-5 Program, foreign investors have the opportunity to obtain lawful,
permanent residency in the U.S. for themselves, their spouses, and their minor
unmarried children by making a certain level of capital investment and associated job
creation or preservation. Three years later, the Departments of Commerce, Justice and
State, the Judiciary, and Related Agencies Appropriations Act, 1993 (The Appropriations
Act) created the concept of the regional center pilot program for pooling investor
money in a defined industry and geographic area to promote economic growth.
1
U.S.
citizens or foreign nationals can operate regional centers, which can be any economic
unit, public or private, engaged in the promotion of economic growth, improved
regional productivity, job creation, or increased domestic capital investment. As of
October 1, 2013, USCIS reports that there are 325 approved regional centers.
EB-5 Program Requirements
The EB-5 program requires that the foreign investor make a capital investment of either
$500,000 or$1 million, depending on whether or not the investment is in a high-
unemployment area. The foreign investors must invest the proper amount of capital in a
business, called a new commercial enterprise, which will create or preserve at least
10 full-time jobs, for qualifying U.S. workers, within 2 years of receiving conditional
permanent residency. Two distinct EB-5 pathways exist for a foreign investor to gain
lawful permanent residency; each pathway differs in job creation requirements:
1) The Basic Immigrant Investor Program requires the new commercial enterprise to
create or preserve only direct jobs that provide employment opportunities for
qualifying U.S. workers by the commercial enterprise in which capital has been
directly invested.
1
On August 3, 2012, Congress removed the word pilot from the regional center programs name;
however, the program expiration date is currently September 30, 2015.

2) The Regional Center Program, formerly known as the Regional Center Pilot
Program, allows the foreign investor to fulfill the job creation requirement through
direct jobs or projections of jobs created indirectly. Jobs created indirectly are the
job opportunities that are predicted to occur because of investments associated
with the regional center.
Application Process
Individuals or entities must file a Form I-924 with USCIS to become an approved regional
center or amend a previous approval.
2
Once the application is approved, USCIS requires
the regional center to report operational and financial data annually on Form I-924A.
The regional center can only operate within a self-defined geographic area and within a
self-designated industry. USCIS documents show that regional centers generally collect
unregulated management and administrative fees between $25,000 and $50,000 from
each foreign investor. These fees include travel and marketing expenses, legal fees, and
sales commissions.
Each foreign investor must file an individual Form I-526 petition to apply to the EB-5
program. If the Form I-526 petition is approved, the investor obtains conditional
permanent residency and has 2 years to fulfill the program requirements of job creation
and capital investment. At the end of the 2-year period, the investor must file a Form I-
829 petition to demonstrate that the investor has met all of the terms and conditions of
the program.When approved, the foreign investor becomes a legal permanent resident
of the U.S. and is no longer under the jurisdiction of the EB-5 program. Table 1 describes
the forms required for participating in the EB-5 program.
Table 1: EB-5 Forms
Forms User Purpose
I-924 An individual or entity
To request designation of theentity to be aregional
center under the Regional Center Program.
I-924A Approved regional center
To demonstrate continued eligibility for the regional
center designation.
I-526 A foreign investor
To petition for status as an immigrant tothe U.S.
under section INA 203(b)(5) as amended.
I-829
A conditional permanent resident
who obtained such status through
entrepreneurship
To request U.S. residency.
Source: DHS OIG generated based on USCIS documents.
2
Prior to 2010, narrative proposals were accepted as requests to bea regional center under the regional
center program.

Figure 1 describes the general adjudications process for EB-5 petitions and
applications.
Figure 1: EB-5Adjudications Process
Source: DHS OIG generated based on USCIS documents.
The EB-5 program has been the focus of several reviews and media reports highlighting
program concerns:
The Government Accountability Office (GAO) reported that there was a
significant lack of information maintained by USCIS about the EB-5 program,
including information onwhere immigrant investors established their business,
the extent to which the businesses remained in the original location, the types of
businesses established, the number of jobs created, or the number of immigrant
investors who applied for U.S. citizenship.
3
The USCIS Ombudsman reported the need to streamline USCIS policy and
strengthen the adjudication process for stabilizing the program and making it
more attractive to investors.
4
The media have reported concerns with the EB-5 programs operations.
Appendix A contains the objective, scope, and methodology of our audit.
3
Immigrant Investors: Small Number of Participants Attributed to Pending Regulations and Other Factors,
April 2005, GAO-05-256.
4
Employment Creation Immigrant Visa (EB-5) Program Recommendations, March 18, 2009.

Results of Audit
Several conditions prevent USCIS from administering and managing the EB-5 regional
center program effectively. Specifically:
The laws and regulations governing the program do not give USCIS the authority
to deny or terminate a regional centers participation in the EB-5 program based
on fraud or national security concerns;
The program extends beyond current USCIS mission to secure Americas promise
as a nation of immigrants; and
economy.
Additionally, USCIS has difficulty ensuring the integrity of the EB-5 regional center
program. Specifically, USCIS does not always ensure that regional centers meet all
program eligibility requirements, and USCIS officials interpret and apply the Code of
Federal Regulations (CFR) and policies differently. USCIS did not always document
decisions and responses to external parties who inquired about program activities
causing the EB-5 regional center program to appear vulnerable to perceptions of
internal and external influences.
As a result, USCIS is limited in its ability to prevent fraud or national security threats that
could harm the U.S., and it cannot demonstrate that the EB-5 program is improving the
U.S. economy and creating jobs for U.S. citizens as intended by Congress.
The Laws and Regulations
The laws that govern the EB-5 regional center program do not specifically allow
USCIS to deny or terminate regional centers based on fraud or national security
concerns identified during the adjudication process. The Appropriations Act, as
amended, onlydescribes the requirements to approve a regional center that
submits a general proposal for the promotion of economic growth. The INA gives
USCIS the authority to deny immigrants seeking a benefit or visa who are a
national security concern.

However, USCIS has interpreted that because regional centers are pooling funds
from investors and not seeking an immigrant benefit or visa, these sections of
the INA are not applicable.
5
USCIS has not developed regulations that apply to
the regional centers in respect to denying participation in the program when
regional center principals are connected with questionable activities that may
harm national security.
With stronger legal authority, USCIS would be in a better position to protect
national security and U.S. citizens from harmful types of economic activities.
USCIS Mission Limitations
The EB-5 program extends beyond USCIS mission to provide immigration and
citizenship services. When the EB-5 program was created, lawmakers
acknowledged that USCIS did not have all of the expertise needed to implement
the program and noted that USCIS should seek assistance from other agencies.
Three years later, the Appropriations Act gave USCIS the oversight of the
regional center concept, which further extended the EB-5 program from USCIS
mission. For instance, adjudications of regional centers involve different
complexities and expertise that align to missions of other departments and
agencies, such as the Securities and Exchange Commission and the Departments
of Commerce and Labor. Those adjudications involve responsibilities such as
reviewing investments, business and economic plans, job creation
methodologies, financial statements, funding, and legal agreements.
According to the USCIS Director, the component has coordinated with other
government agencies to assist with EB-5 program activities in the past, but
acknowledged that more collaboration would help.
Table 2 presents a comparison of the purpose of the EB-5 program to the
mission of four government departments or agencies. The underlined text shows
language that is applicable to the purpose of the EB-5 program. Because
agencies other than USCIS have missions that USCIS could leverage to its
advantage for the EB-5 program, USCIS needs to improve coordination and rely
on the expertise at these agencies during the adjudication process.
5
Senate bill S.744, section 4804 has provisions intended to prevent individuals with national security
concerns from participating in the EB-5 regional center program, aspart of a substantial overhaul ofthe
EB-5 program. S.744 would give the Secretary of Homeland Security the option to deny or terminate
participation in the regional center program based on national security concerns. The bill was proposed
on April, 2013, and passed by the Senate on June 27, 2013.

Table 2: Comparison of EB-5 Program Purpose and
Departmental MissionStatements
Department
and/or Agency
MissionStatement
United States
Citizenship and
Immigration
Services
To secure Americas promise as a nation of immigrants by
providing accurate and useful information to our customers,
granting immigration and citizenship benefits, promoting an
awareness and understanding of citizenship, and ensuring the
integrity of ourimmigration system.
Department of
Commerce
To promote job creation, economic growth, sustainable
development, and improved standards of living for all Americans
by working in partnership with business, universities, communities
and our nations workers.
Securities and
Exchange
Commission
To protect investors,maintain fair, orderly, and efficient markets,
and facilitate capital formation.
Department of
Labor, Bureau of
Labor Statistics
To measure labor market activity,working conditions, and price
changes in the economy. Its mission is to collect, analyze, and
disseminate essential economic information to support public and
private decision-making.
Source: DHS OIG created from information published on USCIS and U.S.
government websites.
In their application package, regional centers are supposed to provide USCIS with
predictions of economic growth. To evaluate economic growth predictions,
USCIS hired economists to participate in the adjudication process. However,
according to the economists, they do not have access to data and systems
needed to validate the support for these predictions.
Foreign Investments and Job Creation
economy. Although USCIS requires documentation that the foreign funds were
invested in the investment pool by the foreign investor, the CFR does not
provide USCIS the authority to verify that the foreign funds were invested in
companies creating U.S. jobs. Additionally, the CFR allows foreign investors to
take credit for jobs created by U.S. investors. As aresult, USCIS has limited
oversight of regional centers business structures and financial activities.
USCIS cannot demonstrate that foreign funds were invested in companies
creating U.S. jobs. Under the EB-5 Program, 8 CFR 204.6(j) requires a petition to
verify that the foreign investor is investing lawfully obtained funds in a new

commercial enterprise to create U.S. jobs.
6
Under the USCIS precedent decision,
7
Matter of Izummi, USCIS also allows the creation of jobs by other entities, but as
shown elsewhere, USCIS is not given the authority by the CFR to oversee these
other entities.
8
Therefore, USCIS cannot verify that the foreign investments lead
to the intended creation of jobs.
For example, we identified 12 of 15 regional center files in which USCIS allowed
the creation of new commercial enterprises that collected EB-5 capital to make
loans to other job-creating entities. USCIS adjudicators confirmed that because
the CFR does not give them the authority to oversee these additional job-
creating entities, they are unable to inquire or obtain detail that would verify
foreign funds are invested in the U.S. economy via a job-creating entity.
Additionally, 8 CFR 204.6(g) allows foreign investors to take credit for jobs
created with U.S. funds, making it impossible for USCIS to determine whether
the foreign funds actually created U.S. jobs. Consequently, the foreign investors
are able to gain eligibility for permanent resident status without proof of U.S. job
creation. In one case we reviewed, an EB-5 project received 82 percent of its
funding from U.S. investors through a regional center. The regional center was
able to claim 100 percent of the projected job growth from the project to apply
toward its foreign investors even though the foreign investment was limited to
18 percent of the total investment in the project. Every foreign investor was able
to fulfill the job creation requirement even though the project was primarily
funded with U.S. capital. When we questioned USCIS about this practice, the
officials explained that the EB-5 project would not exist if not for the foreign
investment.
We also identified two cases in which foreign investments were loans for
completed EB-5 projects. For example, in June 2010 a foreign national invested
$500,000 to pay off an existing loan for the construction and operation of a hotel
that had opened in December 2009. Total project costs for the hotel were about
$28 million, in which foreign investments totaled $4.5 million. Four million of the
foreign investments were used to pay off existing loans, and $500,000 was used
6
A new commercial enterprise is any public or private entity established for the purpose of promoting
economic growth through the investment of foreign funds established after November 29, 1990.
7
Precedent decisions are administrative decisions of the Administrative Appeals Office, the Board of
Immigration Appeals, and the Attorney General, which are selected and designated as precedent by the
Secretary of the Department of Homeland Security (DHS), the Board of Immigration Appeals, and the
Attorney General, respectively.
8
Matter of Izummi, 22 I&N Dec. 169 (Assoc. Commr 1998).

to purchase existing equity. Although 84 percent of the funds were contributed
by U.S. investors, the foreign investor was subsequently granted permanent U.S.
residency based upon an investment in a project that had already been
completed.
The flow ofEB-5 foreign investments is a complex process. It starts with the
foreign investor sending funds to the investment pool (i.e., the new commercial
enterprise). The foreign investor may be required to send administrativefees to
either the regional center or the new commercial enterprise for expenses related
to managing the investment. The new commercial enterprise then transfers the
funds to the job-creating entity for management of the project. At the job-
creating entity, the foreign investments are combined with investments from
other sources, such as U.S. domestic funds. The numbers of estimated jobs
created from that job-creating entity are not allocated among all investors based
upon investment percentage, but are only attributed to the foreign investor.
Additionally, current regulations do not require USCIS to track and verify that the
foreign investment was invested into the job-creating entity.
Recently, USCIS reported that since 1990, more than $6.8 billion has been
invested in the U.S. economy through the EB-5 program, and a minimum of
49,000 jobs have been created. We attempted to validate these statistics and
requested the supporting information. USCIS was not able to provide support for
the statistics reported. USCIS officials said that they had to estimate these
figures and assumed the minimum requirements of the program had been met.
As a result, USCIS was only able to speculate about how foreign investments are
affecting the U.S. economy and whether the program is creating U.S. jobs as
intended.
Program Integrity
USCIS has difficulty ensuring the integrity of the EB-5 regional center program.
Specifically, USCIS does not always ensure that regional centers meet all
eligibility requirements for the program. USCIS officials interpret the CFR and
USCIS policies differently. USCIS does not apply the regulations effectively to the
regional center program. Additionally, the EB-5 regional center program appears
to be vulnerable to perceptions of internal and external influences when there is
not adequate documentation that supports decisions made by USCIS.

Regional Center Accountability
Although USCIS adopted 8 CFR 204.6(m) in 1994 to assist its efforts in
implementing the Appropriations Act, as amended, it has not always held
regional centers accountable to the CFR requirements. Specifically, 204.6(m)
requires regional centers to submit business plans with verifiable detail on how
jobs will be created, yet regional centers continue to provide general concepts
with some applications. After 8 CFR 204.6(m) was created, Congress amended
the Appropriations Act in 2002 to allow regional centers to submit a general
proposal. In 2013, 20 years after the creation of the regional center concept,
USCIS officials have indicated that there is obvious tension evident in the
regulatory language requiring verifiable detail and the statutory language
which allows for the proposal to be based on general predictions. Because of
this language difference, it appears that USCIS may not always apply its CFR
requirements to the regional centers.
For example, the USCIS California Service Center asked regional center officials
to provide additional information related to one proposed business plan. Center
officials responded that they did not need to submit a detailed business plan
according to the Appropriations Act. Subsequently, the USCIS California Service
Center approved the regional centers application without obtaining verifiable
detail that complies with the CFR. As a result, there is no assurance that regional
centers meet the qualifications to participate in the program.
USCIS Regulations and Policy
USCIS officials interpret the CFR and USCIS policies differently, which prevents
adjudicators from evaluating regional center applications and related petitions
effectively. For example, an adjudicator requested additional evidence from a
regional center applicant. According to 8 CFR 103.2(b)(8), the regional center
application should have been denied for not responding in the mandated
12 weeks. However, the denial letter was refused by the USCIS legal department,
stating that there is no language that provides the ability to go straight to denial.
In another example, to generate a favorable decision, USCIS requested a regional
center applicant to omit information from its application because the language
was not in compliance with a USCIS precedent decision. By advising applicants to
remove information because it may delay or prevent approval, USCIS may be
circumventing measures in place to ensure applicant eligibility. An adjudicator
must deny an application if the evidence establishes ineligibility.

Another example is the designation of high-unemployment areas by state
governments. The regulations provide for state governments to designate high-
unemployment areas for determining whether the EB-5 regional center project
qualifies for the lower foreign investment of $500,000. However, the regulations
do not instruct the states on how to make the designation. Because of how the
regulations are written, USCIS adjudicators said that they must accept what the
state designates as a high-unemployment area without validation even when it
appears as if these designations are areas of low unemployment. For example, a
regional center provided USCIS a letter from its state agency designating that
one EB-5 project being built in a prosperous area qualified as being in a high-
unemployment area. The letter explained that employment data for the
requested combination of areas did not qualify for the designation but provided
an alternative combination of areas for the project to qualify. The area where
the project was being built is included in both combinations. This places doubts
on whether program requirements are met, and it allows the foreign investors to
invest only $500,000 instead of $1 million to qualify for permanent residency.
As a result of USCIS unclear regulations and policy, USCIS is unable to hold
regional centers and foreign investors to a consistent standard, and adjudicators
may approve applicants and petitioners that do not meet eligibility
requirements.
Internal and External Influence
USCIS did not always document decision making and responses to external
parties who inquired about EB-5 activities. Outside influence may require USCIS
senior leadership to become involved in the EB-5 adjudication process, thereby
creating the perception of special treatment and internal influence by senior
managers. While the files we reviewed were not well organized and
comprehensive, they appeared to contain sufficient evidence to support the final
adjudication decision. However, USCIS employees provided supplemental emails
that suggest internal and external parties may have influenced the adjudication
of EB-5 regional center applications and petitions. Some parties may have
compelling reasons for influencing decisions made regarding EB-5 participation.
For example
The estimated job creation and economic improvements to local economies
are convincing and important reasons for lawmakers and citizens to have an
interest in advocating the EB-5 program.
USCIS documents show that regional centers generally obtain between
$25,000 and $50,000 in unregulated fees from foreign investors, and as such,

we believe that may contribute to them losing sight of the integrity of the EB-
5 program in the interest of making money.
USCIS did not have protocols to document all inquiries and decisions made
during the adjudication process. During the course of the audit, we obtained
records showing email communications from external parties who were
contacting USCIS senior leaders with inquiries pertaining to specific EB-5
adjudications. The emails requested private discussions about regional center
applications or expressed dissatisfaction with the time USCIS was taking for
adjudication decisions. Based solely on the correspondence, we were unable to
determine whether USCIS honored the requests. These emails referenced 3 of
the 15 regional centers in our case file review along with other regional centers
not covered in the scope of our review. The case files we reviewed did not
contain evidence of the external or internal inquiries, whether the inquiries were
addressed, or if anyone from USCIS ever met with or responded to the external
parties.
One set of emails contained inquiries about unwarranted delays and denials in
processing applications. The regional center was amending its application to
increase its area of operations. This amendment was denied by the USCIS
California Service Center. The emails also discuss I-526 petitions that had been
held awaiting the outcome of the Administrative Appeals Office. The emails
discuss scheduling a meeting with a senior official and others at USCIS to discuss
the inquiries and the decision of the Administrative Appeals Office. The emails
do not discuss the outcome of this issue.
In another email, a Congressman attached a letter asking a USCIS senior official
to withdraw a request for evidence that USCIS sent to a regional center. In the
same letter, the Congressman thanked the senior USCIS official for discussing the
request for evidence with him. In the draft letter, the senior official responded to
the Congressman saying that some items in the request for evidence were
appropriate and some were not, and promises to clarify some of the issues in
forthcoming EB-5 policy guidance. The emails do not discuss the outcome of this
issue.
One set of documents showed a president of a regional center emailed a senior
USCIS official threatening a Federal lawsuit because a previously approved
regional center project was in the process of being terminated by USCIS. The
president of the regional center thenasked to speak to the senior USCIS official
personally. The emails do not discuss the outcome of this issue.

In another example, there is indication of USCIS senior leadership with no direct
involvement overturning an adjudicators decision to deny a foreign investors
petition associated with a regional center. Senior management stated that the
adjudicator did not give proper consideration to previous decisions made on
other investor petitions associated with the same regional center. Consequently,
the petition was approved even though the adjudicator had concerns that the
proposed project would not meet the requirements of the EB-5 regional center
program. USCIS senior managers reported that they were not making an
adjudicative decision legally; however, they noted that functionally, the
adjudicator must make decisions based on senior managements guidance.
Other examples of regional center advocates that may attempt to influence the
adjudication process to benefit their own interest included a newspaper article,
which reported that a lawmaker pushed for an adjudicativeapproval to be made
within 15 days, while the regional center was approaching bankruptcy. We
provided that information to our Office of Investigations for further review.
As a result, USCIS decisions regarding the EB-5 regional center program may be
questioned due to the perception of internal and external influences. USCIS
needs to establish protocols to ensure all correspondence and discussions
between external interested parties and USCIS leadership are documented and
shared for transparency and accountability.
Conclusion
Currently, USCIS cannot administer and manage the EB-5 regional center
program effectively. The legislation establishing the regional center program did
not give USCIS the necessary authority to prevent fraud and national security
threats that could harm the U.S., and it assigned responsibility to USCIS for a
program with mission areas outside USCIS immigration mission. Also,
regulations were not always enforced, and USCIS did not always enforce its own
regulations and procedures established to assist with managing the regional
center program. To improve upon the administration and management of the
program, USCIS needs to revise the regulations governing the EB-5 regional
center program. USCIS also needs to execute memoranda of understanding with
other agencies.

Until improvements are made, USCIS is unable to prevent fraud and national
security threats, and it cannot report the results of the program accurately or
ensure the EB-5 program is benefiting the U.S. economy and creating jobs for
U.S. citizens as intended by Congress.
Recommendations
We recommend that the Director of the U.S. Citizenship and Immigration
Services:
Recommendation #1:
Update and clarify the Federal regulations to
provide the U.S. Citizenship and Immigration Services with the authority
to deny or terminate EB-5 regional center participants at any phase of the
process when identifying known connections to national security and/or
fraud risks without compromising any ongoing or potential investigation;
make explicit that fraud and national security concerns can constitute
cause for revocation ofregional center status under 8 CFR 205.2;
give the U.S. Citizenship and Immigration Services the authority to verify
that the foreign funds were invested in companies creating U.S. jobs; and
ensure requirements for the EB-5 regional center program are applied
consistently to all participants.
Recommendation #2:
Develop memoranda of understanding with the Departments of Commerce and
Labor and the Securities and Exchange Commission to provide expertise and
involvement in the adjudication of applications and petitions for the EB-5
regional center program.
Recommendation #3:
Conduct comprehensive reviews to determine how EB-5 funds have actually
stimulated growth in the U.S. economy in accordance with the intent of the
program. If necessary, employ other specialists or work with other Federal
agencies to assist and confirm the results.

Recommendation #4:
Establish quality assurance steps to promote program integrity and ensure that
regional centers comply with the Code of Federal Regulations requirements.
Management Comments and OIG Analysis
USCIS agreed with three of the four recommendations. USCIS acknowledged that
additional statutory authorities would strengthen the program. USCIS also
acknowledged concerns with the consistency in EB-5 adjudications, the lack of
clarity regarding program rules and serious fraud and national security issues
within the program. In USCIS management response, the Component indicated
that it recently completed a transformation of how they administer the EB-5
Program. Our audit focus was limited to regional center applications as of
November 29, 2012, which was before details of the transformation were
announced. We will evaluate managements reported changes as part of the
audit recommendation follow-up process.
USCIS noted that they previously had no meaningful economic expertise to
conduct independent and thorough reviews of economic models, but had hired
economists and corporate attorneys to support the EB-5 program. Our report
recognizes that USCIS hired economists to participate in the adjudication
process. At the beginning of our fieldwork, USCIS provided an organizational
chart that showed the EB-5 program had seven economists. During our audit, we
validated that two additional economists were hired. We did not audit program
changes completed after our audit fieldwork. During fieldwork, five USCIS
economists expressed concern that their expertise was not being used in the
adjudication process because they did not perform any substantive analysis of
economic plans or predictions. Instead they prepared checklist summaries of
answers to a series of canned questions.
USCIS response indicated that it reviewed each of the 22 regional center cases
mentioned in our report and believed that all were adjudicated properly. Our
conclusions are based on our analysis of documentary and physical evidence
supported by corroborating testimonial evidence that showed limitations of the
legislation for denying applications and consistency in EB-5 adjudications, which
USCIS has also acknowledged. We did not make recommendations specific to the
regional center cases identified. Our report does not make conclusions on
whether cases had been decided properly or whether we concur with the
statute, regulations, or policy.

In its response, USCIS stated that the report suggests Component officials
improperly urged an applicant to omit information from an application in
contravention of the regulations and is incorrect. We provided the facts based
on our review of documentation which showed that USCIS specifically requested
removal of language to ensure that the regional center would meet eligibility
requirements.
USCIS responded that they are not in a position to quantify the impact of the EB-
5 Program on the U.S. economy. They also believe they are not charged with
conducting a broader assessment of the programs impact, something which has
been the subject of both congressional hearings and private studies over the
years. We disagree with USCIS position that it should not attempt to monitor or
measure the performance of the EB-5 program. One of USCIS strategic
objectives is to ensure the integrity, effectiveness, and responsiveness of its
programs. The USCIS Strategic Plan provides integrated planning context for
other USCIS initiatives, such as the business transformation plan, human capital
strategy, management improvement plans, and the development of new
immigration programs.
USCIS defended its policy of deferring to prior agency decisions involving the
same investment project, and believed our criticism was misplaced. USCIS
indicated that an important element of consistency is that the agency must not
upend settled and responsible business expectations by issuing contradictory
decisions relating to the same investment projects. It disserves the public,
undermines program integrity, and is fundamentally unfair to USCIS to approve a
project, have developers and investors act in reliance on the approval, and then
subsequently reverse course by determining that the agencys initial approval
was in error.
USCIS provided technical comments to the draft report. When appropriate, we
incorporated those changes into the report. A summary and analysis of the
Components response to each recommendation follows.
USCIS Response to Recommendation #1: USCIS concurred with the
recommendation. USCIS will update regulations to provide greater clarity
regarding the requirements for establishing eligibility under the program. In
particular, revised regulations will more clearly delineate the evidentiary
requirements applicable to stand-alone EB-5 petitions versus regional center-
based applications and petitions. A revised rule will be drafted for interagency
clearance within 9 months of the report.

OIG Analysis: Although USCIS concurred with the recommendation, the planned
corrective action does not fully address the recommendation. This
recommendation will remain open and unresolved until USCIS provides specific
corrective actions and milestones to address the recommendation in its entirety.
We need to review and analyze the corrective actions plans and evidence of
their implementation. We need USCIS to provide actions taken to proactively
address fraud or national security concerns by participants; verify funding and
job-creation results; and ensure consistent application of the program.
recommendation. Within 6 months of the report, USCIS will develop and
implement an interagency collaboration plan outlining liaison and collaboration
roles and responsibilities among key Federal partners. This will include
collaboration with the Department of Commerce and the Securities and
Exchange Commission.
OIG Analysis: USCIS corrective action plan should resolve this recommendation.
However, more details of the memoranda of understanding are necessary. This
recommendation will remain open and unresolved until we have more
information on the memoranda of understanding and have reviewed
documentation of the interagency collaboration plan.
USCIS Response to Recommendation #3: USCIS did not concur with the
recommendation. USCIS stated that its mandate is to adjudicate EB-5 cases
according to the eligibility criteria, including the statutory job creation
requirements. USCIS responded that the Component is not charged with
conducting a broader assessment of the programs impact. While the
Component agreed that an assessment may be beneficial, it did not believe
USCIS, as the administering benefits agency, is best positioned to conduct a
study.
OIG Analysis: This recommendation will remain open and unresolved until
USCIS provides an action plan and evidence of comprehensive reviews scheduled
to validate how EB-5 funds have actually stimulated growth in the U.S. economy.
Because program results and integrity assurance may be compromised and we
identified concerns within the program, our recommendation included the
option for USCIS to employ specialists or other Federal agencies to confirm the
results of the EB-5 Program. We realize USCIS is facing challenges to ensure the
program is meeting its goals and needs assistance and an assessment by internal
groups or external specialists.

recommendation. Within 6 months, USCIS will establish quality assurance steps
to promote program integrity and ensure regulatory compliance.
OIG Analysis: USCIS corrective action plan should resolve this recommendation.
This recommendation is resolved, but will remain open until we have reviewed
documentation of the implemented quality assurance steps.

Appendix A
Objectives, Scope, and Methodology
The Department of Homeland Security (DHS) Office of Inspector General (OIG) was
established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment
to the Inspector General Act of 1978. This is one of a series of audit, inspection, and
special reports prepared as part of our oversight responsibilities to promote economy,
efficiency, and effectiveness within the Department.
This report provides the results of our work to determine whether USCIS administered
and managed the EB-5 Regional Center Program (regional center program) effectively.
We reviewed the INA; the Departments of Commerce, Justice and State, the Judiciary,
and Related Agencies Appropriations Act, 1993; and other legislation to renew the pilot
program. We also reviewed USCIS regulations, management policies, procedures, and
other memoranda related to the EB-5 program and Fraud Detection and Nationality
Security.
We interviewed USCIS management and staff responsible for the administration ofthe
EB-5 program at both USCIS Headquarters and the California Service Center. Our
interviews included representatives from the Branches of Service Center Operations;
Fraud Detection and National Security; Policy and Strategy; and the Office of Chief
Counsel.
We identified 336 I-924 regional centers with applications or amendments submitted
during fiscal years 2010, 2011, and 2012. Our selection of regional center application
files to review was based on the most foreign investor petitions filed as reported in the
Interim Linked Application Information Management System (iCLAIMS) as of November
29, 2012. USCIS began using iCLAIMS in fiscal year2010 as a database to store
information related to EB-5 Regional Centers. The iCLAIMS database is updated
manually when regional center applications, amendments, or annual updates are
received on forms I-924 or I-924A bythe California Service Center. The immigrant
investor applications and petitions for permanent residency, forms I-526 and I-829, are
maintained in other USCIS systems and transferred to iCLAIMS. We did not verify the
reliability of the iCLAIMS system and do not draw any conclusions from its data. We
used the National File Transfer System to identify the location of immigrant investor
files related to the regional centers.
We visited the California Service Center and reviewed 15 Regional Center application
files and 6 immigrant files, either form I-526 or I-829, associated with the regional
centers. Our selection was based on the location of the files and the timeframes needed

for review. We evaluated internal controls to the extent necessary to address the audit
objective.
We conducted this performance audit between September 2012 and June 2013
pursuant to the Inspector General Act of 1978, as amended, and according to generally
accepted government auditing standards. Those standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based upon our audit objective. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions
based upon our audit objective.
OFFI CE OF I NSPECTOR GENERAL
Appendix B
Management Comments to the Draft Report
U.S. DeJlartment of Homeland Security
L.S. Citi:r.ensh..ip and Immigralion Services
Office of the Din>ctnr (MS 2000)
Wasllmgton, DC 20529-20<XJ
U.S. Citizenship
and Immigration
Services
NOV 4 2013
Memorandum
TO:
Charles K. Edwards
Deputy Inspector Genera Y:!J
J::
FROM: Alejandro N. Mayorkas
Director, U.S. Citizcnshi an Immigrati n Services
SUBJECT:
Official Comments to the Draft Report Recommendations on U. S. Citizenship and
Immigration Services ' Employment-Based Fifth Preference (EB-5) Regional Center
Program- For Official Use Only (010- 12- 166)
U.S. Citizenship and Immigration Services (USCIS) thanks the Office of the Inspector General
(OIG) for the opportunity to review and comment on its draft report on the EB-5 program.
The draft report cites regarding USCIS ' s administration of the program, and other
concerns best directed at Congress given its sole authority over the program's statutory
framework_ \Vhether the EB-5 statutes vest CSCIS with sufficient authority t o ensure the
program's integrity is an important queslilln, and one which we have worked closely with
Congress in recent years to address. We agree with the 010 that additional statutory authorities
would strengthen the program.
The EB-5 caseload is, by far, the most complex that USCIS oversees, and involves decisions on
issues- such as the evaluation of business plans and econometric employment modeling - more
typically associated with other U.S. government agencies than with USCIS. We appreciate that
the OTG shares our concerns regarding consistency in EB-5 adjudications, the lack of clarity
regarding program rules, and serious fraud and national security issues in the program. It is
precisely these concerns that have driven users over the past several years tu undertake a
complete transformation of how we administer the EB-5 program.
This work is progressing rapidly; indeed, JUSt as the OIG was wrapping up its work on this audit
in June 2013, USCIS was implementing several fundamental, long-planned steps to improve the
EB-5 process. We have strong confidence that our overhaul of the program, already well
underway, will translate to improved consistency, integrity, timeliness, and adherence to law_
We arc, in other words, already in the of addressing the issues raised in the OIG' s audit
that are within the agency' s power to resolve.
Oil! cia] Comments to the Drafi Report Recommendations on U.S. Cilizenship and Jmmzgralwn
Services ' Employment-Based F1.fth Preference (EB-5) Regional Center Program- For Otlicial
Cse Only (OIG-12-166)
Page 2
In particular, we have taken the following cm1crete steps to improve ow administration of this
progrmn:
lJSCJS announced its plans to reali!!n the FR-5 into a new office in
Decem her of 2012, to he stafted the expertise needed to efth.-tively the
progn1m in-houst. In .\'lay 2013, LISCIS stood up tht' mw progmm otlk.t- tht'
Immignmt Innstor Program Office- in Headquarters. Previously, and essentially
through the end of the OIG's audit work. the EB-5 program was based at the CSCIS
Califomia Service Ccntcr, in the same facility as more traditional immigration casework
involving, for ex<mlple, family-based immigration petitions, and handled by generalists
who did not necessarily have the needed national security, economic, business, and legal
expertise. The needs of the EB-5 program arc unique. from an eligibility perspective as
well as a security perspective, and the program warrants dedicated and
leadership. 'l11e new program ollice opened in May 2013 just before the OlG audit
work was completed in June 2013.
The new program office is led by a sit1gularly-focused SF.S-Ievel Chief atld consists of
prolessional economists with prior lederal and commercial experience, COflJOrate and
immigration attorneys, and experienced adjudicators. For the firsttimc in the agency's
history, the office is also staffed full time by :fiaud and national security specialists :fiom
the headquarters staff of the Fraud Detection and National Security (FDNS) directorate.
By locating the otllce in \'>.i ashington, DC, we have ensured that FDNS will be better
situated to coordinate directly with critical enforcement and intelligence partners at other
agcncics in the adjudication of EB-5 applications.
Within the nell:t six months, all ED-5 work will transition away from the Califomia
Service Center structure reviewed by the OIG and to the new structure at Headquarters.
On May 30, 2013, USC IS issued a comprehensi\'e EB-5 memorandum thr the
first. tirm in the progmm's history. Previously, there were several separate policy
documents that applied to EB-5 adjudications and these doclmlents failed to address a
wide range of critical issues that typically arise in EB-5 cases, leaving adjudicators
without rom1al guidance on an array or complex questim1s. 'lltis was una..:ceptahle and,
predid.ably, it undennined ..:onsisl.ency, timeliness or adjudications, and adllerence to law.
The comprehensive policy memorandum was subject to several rmmds of public
comment before it \Vas finalized, and it now gives agency officials as well as the public
the prediclahiliLy and gLtidam;e they need.
LISCIS has fortified the program with adYanccd expertise. EU-5 cases involve
evaluation of business plans, econometric job creation models, and international financial
nows. For too long, users failed its adjudicators by not Sllpporting them with the
expertise needed to contend properly with these issues. 'l11at now changed. In 2011,
users began hiring full time federal economists and transactional attomeys to work the
Page 3
F.R-5 case load. Tn the new program office, we \vill for the first time have economists
who actually serve as adjudicators (as opposed to simply consulting with adjudicators).
lJSCJS. in close consultation with other enforcement and intelli::ence a::encies. has
bolstered fraud and national secmity safeguards in the pl'Ogram. Historically,
lJSCTS treated ER-5 like its other immigration programs when it came to fraud and
national security. Tite consequence was a security infrastructure that was not properly
tailored tor the unique needs of this program. In recent years. US CIS has implemented
i.mpottant and substantial EB-5 integtity enhancements. For the fnst time, the agency
now secutity o.:hecks on regional center businesses :md certain exe<.:utives
(instead of only potential investors). collaborates closely with partner agencies on
program-level issues. conducts enhanced security checks leveraging a range of holdings
rrom across Lhe l J.S. govemmenl lellllinates regional centers where rrand is detected, and
refers wbslantialmmtbers or EU-5 lo OLLr interagency partners. Also
tor the tlrst time, beginning in 2010. the agency began requiring use of a standard tonn
by all regional center applicants, and in 2011 began requiring all regional centers to file
an annual disclosme npdate to USCTS detailing regional center activities on a contitming
basis. All or these are new developments. We are rnlly leveraging the range or statutory
authorities we have at our disposal. TI1c progress on the fraud and security front has been
substantial. The program is, unquestionably, more secure now than it has ever been.
As we have before, we invite the OIG to review our new operations. We believe our new model
addresses the deficiencies in the legacy program that the OIG reviewed, and would welcome an
audit ofthc new structure. Unfmtunatcly, because of the ongoing changes, the present audit docs
not ao.:o.:uratdy describe the current stale or the program.
W c remain disappointed that the OIG did not interact more tl!lly with the senior career leaders
who manage the ER-5 program and are responsible ror its integrity. Over the course or its ten
month audit period, the OIU interviewed the Chief of Ute EU-5 Program lor jttst one honr, and
only upon our express request that it do so after the OIG had already conveyed to us its initial
audit findings. TI1e OIG interviewed the Associate Director for Fraud Detection and
Secnrity jusl once, and only at the heginnittg or the audit process. We do not believe the andit or
such a program should o.:ondude on these knns.
We respond to the draft repott' s findings and recommendations bdow. While we believe the
draft rep01t a number of ittaccuracies and mischaractetizations as to how the program
operates, we have focused our response on the high-level points that we believe are most critical
from the perspectives of progran1 integrity, efficiency, and effectiveness.
Th<' Laws and Rcgulrltions
\Ve agree in significant part with the OTG's con cent that the "laws and regulations goveming the
program do noL give LSCIS the authority to deny or temtinate a regional cenler's participaLimt itt
the EB-5 program based on fraud or national security conccms," which is why last year, CSCIS
Services' Employment-Based F1_fth Preference (EB-5) Regional Center Program- For Otlicial
Page 4
offered e:>.'tensive legislative proposals to Congress to close these gaps, and to equip CSCIS with
important authorities to enhance ED-5 program integrity. CSCIS already authority to deny
or terminate a regional center based on fraud or misrepresentation,
1
but the statutory framework
leaves other significant gaps in users authorities. especially with regard to national security.
In anticipation of the regional center program's reauthorization, in June of2012 USCIS proposed
to the Chairman and Ranking Member of the Senate Judiciary Committee specific statutory
language that would, for example: ( 1) grant USCTS authority to deny or tenninate F.R-5 cm;es on
a discretionary (2) require regional centers to certily their compliance with lhe lJ.S.
securities laws; (3) penuit USClS to run security checks on a broader range of regional center
patiicipants thatl is eunently authorized tmdcr existing statutes; ( 4) pcnnit USC IS to exclude
from regional center participation individuals with prior of crime or fraud; and,
(5) broaden lJSCIS authorities to condud oversight over job-creating associated with
regional centers.
2
The draft report recommends that CSCIS pnmmlgate regulations that would allow the agency
"to deny or tenninate ED-5 regional center participru1ts at ru1y phase ofthe process when
idcntif)'ing known connections to national security and/or tfaud risks without compromising any
ongoing or potential investigation." and to "[m]akc explicit that fraud and national security
concems can constitute cause for revocation of regional center status tmder 8 CFR 205.2.''
3
1n
principle users agrees that explicit authority to tenninate a regional center based upon fraud
and national security concerns is needed, but USCIS lacks authority to promulgate such
regulations uttder current law. Statutory change is required, which is why l JSCIS over a year
ago proactively proposed legislative language to Congress t.o secure these authorities and oU1er.;.
CSCIS appreciates OIG's support tor this etlort.
However, USC IS has taken substantial administr-ative measures to ensure ER-5 program security
to the fullest extent permitted tmder existing law. The drart report roc uses on legal attthorities,
and docs not address many of the operational steps- some transfonnativc -that USCIS has
taken in recent years to counter fraud and national security risks in the EB-5 program with the
limited authority that USC IS already possesses. \Ve are concerned that this omission may leave
readers with the misimpression that users has done little to leverage the tools it already has.
when in tact quite the opposite is true:
users has expanded its background vetting to include regional center entities and key
executives, for the first time itt the program's history.
1
Soi!e Matter ofCTTAIY471TF:, 2'i 1 &N Dec. 169, .176 (AAO 201 0).
., USCJS notes, as Joes the Jrart repurt, that the Senate earlier tills year passed (S. 744) that woulJ
significHntly improve ER-'i Huthorities in line with the recommendations that users offered
3
S C-..F .R 205.2 0st.1.blishcs for the s authority pursuant to s-.,ction 205 of th0
Immigration and )Jationahty Act (1:\fA) to revoke approval of any petition approved under INA 204. Speciftcally,
C'.F K 205 2(a) states "ra lny Service offrcer m1thorized t.o approve a petition under section 21.14 oftli< Ad. may
revoke the approval of that petit1on .. " CSCJS designates rogronal centers the Appropnatroru; Act, as
HJ11 ended. and 11 Dt under section 204 of the TNA.
Page 5
users has required all regional centers to file annual disclosures on their business
ac--tivities and and management changes, for the first time in the program's
histor:v.
USClS has dramatiL:ally enh;mL:ed collaboration with key government partners, induding
ICE, CDP, the fDI, the Securities and Exchange Commission (SEC), the Treasury
Department, and the intelligence community, on specific EB-5 cas.:s as well as
pr-ogrammatic issues.
users has created a new EB-5 progrmn office at lwadquartcrs with embedded FD:-JS
officers, who have the authority to liaise directly with other l .S. govennnent agencies,
tor the tlrst time in the program's history.
Where lJSCIS develops <Xllll:ems in Fll-5 it leverages its regulatory authority to
withhold adjudication of those cases until it has ti.llly coordinated its approach with
enforcement and intelligence pmincrs. See 8 C.F.R. 103.2(b)(l8).
A titHer stunmary of steps US CIS taken to ensure ED-5 program integrity is attached as
Exhibit A, which is marked For Official Use Only- Law Enforcement Sensitive.
Finally, we note the drail report's reference to a. specific Ll3-5 involving national se..:urity
concems. TI1e OIG's conclusion is premature and inaccurate. TI1e OIG's conclusion that the
referenced regional center poses a national security threat, m1d that the primary reason the
regional center has not been terminated is a legal belief held by USC IS, is simply not supported
by the record. 'l11e mallerremains under law enforcement investigation and USClS continues to
closely coordinate with the lead law enforcement agency, m1d will coordinate any adjudicative
action, as appropriate. TI1e OIG bases its case assessment on input tfom "one CSCIS otlicial''
despite PSCIS's detailed comments to the OIG delineating where OIG's case record
lacking. ' llte OICJ has not smtght to discuss the matter wilh key LSCIS national security oiTicers
responsible for handling the matter, despite USC IS's notice to the OIG that these ofilcials have
relevant information. Further. to the best of US CIS's knowledge, the OIG did not seck input
from the law enforcement agency involved in investigating the matte.-. Our detailed summary of
C(mcems on this issue is heing tnmsmitted llltder separate cover given the law enf'or<.:emenl
sensitivities.
Tht> J.l:ll-5 Progr:tm :tntl thl' LSCIS .Vlission
We note the draft rep01t's conclusion that the EB-5 program "ell.1cnds beyond CSCIS' s mission
to provide immigration and citizenship services," at1d its observation that other agencies have
mission closely aligned will1 ll1e program's goals. LSCIS (and its predecessor, the
Immigration and Naturalization Service (Il\S) 1mdcr the Department of Justice,) has been
charged by Congress with administering the EB-5 program since the program's inception in
1990. l:SCIS operates and will cm1tinue to operate the program as it is required to do by law
unless Congress changes this mandate.
Services' Employment-Based F1.fth Preference (EB-5) Regional Center Program- For Otlicial
Page 6
We agree with the draft repmt that USCIS can benefit from collaboration with other CS.
government agencies in administering the ED-5 program. A tew years ago, the CSCIS Director
proposed to the Department of Commerce that the agencies explore possibilities for Commerce
to take on a significant role in EB-5 adjudications. Since that time, US CIS and Commerce have
partnered successfttlly on a munber of discrete issues in the EU-5 program, and we continue to
the optimal level of collaboration in the program.
In support of its goal to reduce fraud, CSCIS has also forged a highly successful partnership with
the SEC in recent years. The agencies have cm1ducted a joint public engagernent,jointly issued
an Fll-5 investor alert to the investing public, and collaborated on investigation and enl(lrcement
action in particular EU-5 cases. USClS has also collaborated with SLC staff in the development
ofteclmical assistance to Congress that would enhance securities law compliance and investor
protection within the ER-5 prog.-am.
W c believe the OIG should have assessed the wide range of initiatives on which we arc currently
engaged with the Department of Commerce and the SEC. We appreciate the OIG's general
recommendatim1 that PSCTS execute memoranda of understanding with these agencies, but a
memorandum is simply a procedural vehicle and not a substantive strategy for how to enhance
collaboration. We welcome specific suggcstioll.S, as we arc focused on this goal.
We ultin1ately defer to Congress as to wheti1er the program is properly housed aJ LSCIS or
another agency. \Ve have tal,en tremendous strides to develop in-house expertise and to ensure
that the program has all necessary resources to properly and effectively handle EB-5 cases.
Historically, CSCIS had 110 significant economic or corporate tra11sadional expertise 011 hand to
manage this complex casework. Culminating in U1e creal ion and ongoing sta111ng of the new
progrmn otlice, we now have 22 economists
4
on stntr as well as business analysts and corporate
artomeys to review the business and economic questions that EB-5 cases typically present. We
continue to build up these resources i11 the new ER-5 pmgram office and are committed to
providing our team wilh all the resources and expertise they need lo administer lhe program.
Measurement of Overall Program Impact
\Ve note the draft report's finding that USClS is not in a position to quantity the impact of the
EB-5 program on the U.S. economy. We agree. CSCIS administers a number of business visa
programs that were designed by Congress to foster economic pmsperity, hut we do not attempt to
measLtre the broader economic impact of' any of' those programs, inciLtding EH-5. LSCIS"s
mandate is to adjudicate EB-5 cases according to the eligibility criteria, including the statutory
job creation requirements. USC IS is not charged with conducting a broader assessment of the
program's impact, something which has been the subject of both congressional hemings and
private studies over the years.
4
The draft report criticizes CSCIS for not providing its economists with access to needed systems and data. We
h ave \Vorkc>d dosdy with our economists to ensure they ru-e equipped to hruKJle the workload and we-re stlrprised by
this Imding. Our economists have received access tu the IMPLA'.' econumelnc phmnmg tool nd other resources.
Tfthe om helieves tooh are needed, it would he helpful to specify which ones.
Page 7
CSCIS therefore agrees with the OIG's recommendation to the ex-tent that fmther study of the
EI3-5 program's impact may be warranted, but we do not believe users, as the administering
agency, is to conduct those studies. W c stand ready to provide any
appropriate assistance to Congress and to U.S. govemment agencies that specialize in
measurement of economic impacts in this regard.
Velification of Job Creation
'11te draft report observes, correctly, that it is often impossible for US CIS to conclusively verity
job creation in EB-5 cases. Titis is a direct result of the statutory design of the EB-5 program,
which pcm1its in1migrant investors to usc economic modeling to predict "indirect" job creation
that will likely result rrom lhe regional center's economi<: adivily. The legislation creating lhe
regional center program provides that L SCIS shall penuit immigrant investors to rely upon
"reasonable methodologies tor determining the number ofjobs created ... including such jobs
which are estimated to have been created Ry definition, these indirect jobs cam10t
each he verified, they are or an economic model. hroadly accept the use
(some of which are developed by U1e Department of Commerce), <md Congress
has mandated that cscrs accept them as evidence. !d. Jvlorcovcr, because the statute pennits
regional centel' applications (Form T-924) and initial investor petitions (Fol'm T-526) to be filed
hef(Jre the economic adivity ha-; heetl underlaketl and the jobs have been created, these
processes involve estinzatesoflikdy job creation. and not a backward-looking
counting of jobs already in existence.
We emphasize that cscrs is rigorous in its review of each case before it, applying economic
expertise to determine whether each economic model presented to the agency is a reasonable
approxin1ation of how many jobs arc likely to be created. cscrs conducts independent and
thorough reviews or the suhmitted economi<: models bel(>re concluding they are in
their assumptions and predictions. Where the agency previously had no meaningt1tl economic
<)Xpertise on hand to conduct this work, we have in recent years hired and continu<) to hire
economists a11d corpol'ate attomeys to ensure the work is done properly and consistent with
widely accepted standaJ'ds in the fidd. \.ISCIS regLtlal'ly denies cases rm lailul'e to meelthejoh
creation requirements. ln FY 2012, for example, USClS denied 63 regional center applications
for failure to satisfy the job creation or other eligibility requirements and approved 35 regional
center applications.
CSCrS agrees with the draft report's finding that users would bcndit hom additional
authorities to oversee job creation in cntctpriscs associated with a regional center. USC IS has
provided legislative proposals to Congress to expand those authorities.
' ScctJOn 610 of th<' Dq:>.'Utmonts of Commorco, Jtistlcc, and State, the JudJcJary, and Rotated Agcnc1os
,\ppropriations Act, 1993, Pub. L :-Jo. 102-395, 106 Stat. 1828 (1992), as amended by section 116 of Pub. L. No.
liJ5-ll D, Ill Stat 244.1 (l'i'!'l); ""ction 402 of Pub L No lll(>-3%, 114 Stat. 1(>3 7 (2000), section 11037 of Pub
L. 1\o. I 07-273, 116 Slat. 1758 (20:)2); sect10n 4 of Pub. L. Nu I 08-156, 117 Slat. 1944 (2003): and seclton 1 uf
Puh. !.. \o. I 12-176, 126 Stat (2012).
PageS
The draft report references instarrces in which CSCIS has granted ER-5 benefits to investors
whose capital was used to pay off construction loans or other bridge financing t:rom projects that
had already begun. W c note that EB-5 !rogram rules do allow EB-5 capital to replace bridge
fmancing under certain circumstances. For example. a bank may approve a temporary
construdion loan on the condition thallhe loaned funds will be replaced once a developer is able
to secure EI3-5 timding. TI1ese types oftinancing arrangements pemtit shovel-ready projects to
begin (and jobs to be created) right away. Of course, users has denied and will continue to
deny ca<;es where a project is already completed and circumstarrces do not wanant attribution of
jobs to a proposed late-stage investment.
Program Integrity
'11troughout the draft report, the OIU has included references to casework that may leave the
reader with the impression that these cases were adjudicated in error, even though the draft report
states, with respect to at lea<;t a number of these cases, that there is evidence to support the
adj udicalive decisions reached. ;\sa result ol'the ()[(f's willingness to a list ol'the
actual reH:reno.:ed, USC IS been able to look. inlo each of these further to
detennine whether a case had been adjudicated properly. A total of twenty-two (22) regional
center applications were identified by the OKr. CSCIS detennined that in each of the
applio.:alions o.:ited in Lhe reporl in whidr a lirral deo.:ision has been made, that deo.;ision irr
accordance with the law, regulations, and policy. users thanks the OrG tor the opportunity to
clarify this issue.
Inasmuch as the review fomtd that each case cited by the OIG had been decided properly,
cscrs must conclude that the orG's concern is not that cases arc being adjudicated improperly,
but rather the OIG docs not concur with the statute, regulations or policy, as written. In the
section below, LSCIS will directly address ea(;h Lo provide clarirication orthe
relevant law, regulation or policy.
A, Re::ional CenteJ' Accountability
We disagree with the draft report's finding that users does not require regional centers to meet
all regulatory requirements, and in particular the requirement on which the draft report focuses:
6
See ED-5 Policy MomordndLun Cv!ay 30, 2013) at 15-16 ("Since tt is tho commercial cnterpmo that creates the
johs, the developer m the principn1 of the nevt' commercial enterprise, either directly or through a. joh-
croatmg entity. m"y utiltze mtenm, tempomry or bmlge financing- m the form ui etthor debt or equity- pnor to
receipt ofF.R-5 capital. Tfthe project commences hased on the interim or bridge financing prior to the receipt of the
RR-5 cflpiml m'd ;rul"equently replAces it wit], FR-5 capital, the new commercial emerpri'e may 'till receive credit
for the JOb creation LLJJ.Llcr the rcgulalivn>. Generally, the replacement of bndgc iinancing with EB-5 investor ""pital
should hnve 11een contemplated r1rim !.t..l acqulrlng the original nonER-5 financing_ HC'J\\'ever, even if the F.R-5
flllancing was not prior to acqujrjng the temporary fm .. wcmg.. as long as th .. --; fin .. 'lliC.ing to be r0placcd
was contemplated as short-term tempomry financing which would be subsequently replaced, the infusion of ED-5
financing could still result in the creatjon of, and credit for, tk'W _jobs_ For example, the> non HB-5 financing
ongin"lly contemplated lu replace the temporary tinancmg may nu longer be av"tlablc tu the commerctal enterprise
as fl result of changes in availability oftmd1ti0.nal financing.")
Page 9
that an application for a ne\V regional center must pm'>ide "in verifiable detail how jobs will he
created indirectly." 8 C.F.R. 204.6(mX3)(ii). The draft report suggests that US CIS should
its regulation to require that all regional center applications a fully
developed business plan. but that view is contrary to the statute, which permits creation of a
regional center on "general proposals'' 'l11e regioruil center legislation sfl{t.es !hat the
progrmn "shall involve a regional center in the Cnited States, designated by the Secretary of
Homeland Security on the basis of a general proposal, tor the promotion of economic grow1h,
including export sales, improved regional productivity, job creation, or
domestic capihtl im:estmenl" and that "l tjhe establishment or a regi(mal center may be based on
general predictions. "
7
ln light of the controlling statute, US CIS has interpreted the regulation's
reference to "verifiable detail" as requiring substantial evidence of how jobs will likely be
created, but not necessarily a ii.tlly developed business plan, which is not a requirement
authorized by the statLtte.
It is i.mpottant to note that no alien is properly admitted as an immigrant to the C.S. under the
ER-5 program if he or she cannot show a fully developed husiness plan and finn commitment of
the required investment amomtt. At the stage at which an individual investor seeks approval to
invest in an already-approved regional center, a fully developed business plan must be presented.
Afatter ofHo, 22 !&1\ Dec. 206, 213 (Assoc. Comm'r 1998). The statute, however, docs clearly
permit regional<.:ent.ers lobe approved at the oulsel, before any individual investors have been
approved, on a lesser showing. Again, if Congress modified the statute to require a more
detailed showing by the regional center, CSCIS would adhere to that new standard.
In another example cited in the dra1l report, !he OIG suggests !hal USCIS improperly urged an
applicant to omit intonnation from an application in contravention of the regulations. TI1e OIG
is inconcct; in the case discussed, users followed ordinary evidentiary procedures in a manner
consistent with law. users adjudicates every regional center application to ensure thatthe
docLtments submitted establish eligibility l'or the designation as a regional center as ol'the date of
tiling. In addition to establishing eligibility tor designation as a regional center, Fonn I-924
applications arc sometimes accompanied by a Form I-526 Exemplar along with draft documents
describing the proposed investment oppmnmity. The I-526 Exemplar is an avenue available to
the regional center applicant to obtain a determination from users. in advmtce of the tiling of
actual investor petitions, that the draft documents do not contain provisions that violate program
requirements. Ifthe draft investment documents contain impennissiblc provisions. USCIS
provides the applicant t.he opporhmit y to ;unend !he dra.fi in vestment. through a
Request for Evidence (RfE). This process is pennissible tmder both the statutes and the
regulations. Moreover, the exemplar process is an intportant tool to ensure predictability and
eiTiciem:y in the processing ol'investorpetitions under the regional center proje..:t. We therel'ore
believe the OIG 's criticism of this established and well-designed process is Lmwarrant.ed.
7
ScctJOn 610 of th<' Dq:>.'lrtmonts of Commorco, Jtistlcc, and State, the JudJcJary, and Rotated Agcnc1os
,\ppropriatiollS Act, 1993, Pub. L :-Jo. 102-395, 106 Stat. 1828 (1992), as amended by section 116 of Pub. L. No.
liJ5-ll D, Ill Stat 244.1 (1
1
i'!7); ""ction 402 of Pub L No lll(>-3%, 114 Stat. 1(>3 7 (2000), section llll37 of Ptrb
L. 1\o. 107-273, 116 Slat. 1758 (20:)2); sect10n 4 of Pub. L. Nu 108-156, 117 Slat. 1944 (2003): and soclton 1 uf
Puh. T.. \-o. I 12-176, 126 Stat (2012).
Services ' Employment-Based F1_fth Preference (EB-5) Regional Center Program- For Otlicial
Page 10
The OTG also concludes that USCTS's regulations and policies pertaining to the designation of
Targeted Employment Areas (TEA) are tmclear. Specifically, the OIG appears to take issue with
an adjudicator's ability to challenge the designated boundaries of a TEA. CSCrS believes the
recent policy memorandum removes any ambiguity. As noted in the May 30, 2013 EB- 5 Policy
l'vlemorandtun, "US CiS defers to stale detenninations ofthe appropriate boundaries of a
geographic or political subdivision that constitutes the targeted employment area. However, tor
all TEA designations, USCrS must still ensure compliance with the statutory requirement that the
proposed area designated by the state in fact ha-; arr unemployment r-ate of at lea-;t 1 50 percent of
the national average rate. This policy pronouncement adheres lo lhe legal framework !'or TF.:\
designation.
R. lJSCJS and Policy
We agree with the OrG's concern that users has historically applied laws and policies
inconsistently in the ER-5 program. This ha-; been arr ongoing source of criticism for the agency,
and one lhat has been warranted. The program's eligibility involving complex issues or
job creation proje<.:Lion, economic modeling, business plan evaluation, <md review of
transactional documents, complicate eff01ts to devise simple rules that arc readily applied to
actual The problem was long exacerbated by three key deficiencies that users now
made sigrril1canl headway in resolving: (1) lJSCIS had no fomral policies addressing many of
the critical issues that frequently arise in EB-5 cases; (2) users did not inject meaningful
economic or corporate legal expcttise into the program: and, (3) users did not require regional
center applicants to suhmit standardized and information to gain approval, or to update
csers regularly on their status once approved.
On 30, 2013, cscrs issued a 27-pagc EB-5 policy memorandum that. for the first time in
the program's history, addresses comprehensively the range or eligibility issues in a single
doctmtent. '11te issuance of the new policy memorandmn was a seminal event for the program,
and though it was finalized only toward the end of the orG' s audit period, we are confident that
it will result in more consistent decision-making that faithfully applies the statutory and
regulatory requirements. \Ve regret that the OICI not addressed the policy memorandum.
Fmthennorc, users has made great strides in resourci.ng the EB-5 program with the types of
expertise necessary to conduct these complex adjudications. In 2009, USeTS had just nine
employees to the program, none or whom were economists or corporate
With the creation and ongoing stafiing of the new program otlice, there arc currently more than
80 employees assigned to the EB-5 program. including economists and corporate attomcys
whose expertise will pay enonnous dividends in ternrs of improving the agency's consistency
and adherence to law in its adjudications. The pro grant chief is also now designated. tor the first
time in program history, as an SES-Icvd position.
LSCIS has also sought to bring order and consistency to the regional center approval illld
monitoring process, which until recently was extraordinarily under-developed and ad hoc.
Historically, and as recently as 2009, a regional center applicant could apply to csers through
Page 11
an infomral letter-writing process. There was no regular security vetting and no standardized
collection of basic information. users in 2010 introduced a new fonn, fonn r-924, that collects
this intonnation and that all new regional center applicants (or regional centers tiling to amend
their designation) arc required to usc. CSCIS also began. for the first time, charging a fcc for
regional center applications. Previously, regional center applicants paid no fee at all, me:ming
that the work lmdertaken to adjudicate cases filed by sophisticated business interests was
dfcctivdy subsidized by the rest ofCSCrS's customers. That inequity no longer persists.
:Moreover, as of2011, appmved regional center-,.; are required to submit infonnation to
LSCIS on an annual basis through 1:omr 1-924.:\, updating the agency orr the status oftlreir
investment projects and management or ownership changes, and pennitting LSClS to conduct
heightened oversight and vetting of regional centers on a continuing basis.
:\11 of these changes have contrihuted to enhanced consistency and integrity in \.ISCIS's
administration of the program.
J .astly, the dr-aft report implicitly criticizes CSCJS 's policy of defening to prior agency decisions
involving the same investment project, but we believe the criticism is misplaced. A . .n important
dement of consistency is that users must not settled and reasonable business
expectations by issuing contradictory decisions relating to the same investment projects. It
dis serves the public, Lmdem1ines progr:un integrity, am! is ftmdament.ally unfair for lJSClS to
approve a project, have the developers and investors act in reliance on the approval, and tben
subsequently reverse course by determining that the agency's initial approval was in error. To
that end, CSCIS has long followed a policy that it will defer to its own prior det:isions unless
there is evidence of fraud, material change in f:td.s, or legal deilt:iency in the prior decision.
Some of the sharpest criticism cscrs has historically received from Congress and stakeholders
relates to perceived failures to follow this deference policy, precisely because of the huge
reliance U.S. project developers and investors justifiably place on CSCJS 's decisions. Where a
prior approval issued in ohjedive contravention of law, 1 !SCIS will not accord deference to
that approval (and indeed has rdi.Jsed to deter in such cases in recent years). But where an
adjudicator simply would have decided a close case differently, it lmdermines the program's
effectiveness, predictability, and consistency for the agency to abmptly rever-,.;e course.
8
C. Internal and External htfluence
LSCIS agrees with the OIO's observation llrat EH-5 cases attract signil1cant interest from a
range of stakeholders, including members of Congress, state and local otlicials, the
'The draft report cites an of USGS deference policy in tenm thflt we believe ze our
processes Before 1 ISCTS detennines that one of its prior decisions was incnrrect and that the agency should reverse
a prior <1pprvval, a ''DdCri..:ncc Bmmr or users o(Ticiab: indw..ling Cl:onomists, to ri..:vicv ..' the t:asc and
R determinntlon a::. to tl1e way forwArd The Defere11Ce Ronrd process includes op].')t.:1rhmity to
discuss and clanfy Js""" m tho case w1th the appliCant. ln the case cited at page 13 of the dra!lrq:>ort, the
Deference Board determined that the agency's initial decision was not in error and should not be disrurbed,
notwithstanding the contnuyview of a USCJS adjudJC'lltor We believe the process worked m this case, and that the
010. S lS liilWarmnlel\; we are concerned lhallhe draft report does not even acknowledge lhallhe
ultimate decision in this cnse wHs mHde tn thi::. carefu1].1TV...:ess.
Page 12
community, and the applicants themselves. On average, USCTS receives hundreds (and in recent
years thousands) ofED-5 case inquiries from members of Congress per year.
As a threshold matter. \Ye note the draft report's finding that the case files "appeared to contain
sufficient evidence to support the adjudicalim1 decision'' in ea.ch oflhe cases that the OIU
reviewed involving ell.'temal inquiries. cscrs 's core fimction is, in a manner consistent with
ensuring national security, to approve cases that arc eligible, and to deny cases that arc not. \\' e
decide based mr the facts and the law and nothing else. CSCTS management officials
have in many instances received case inquiries lr-om memhers of Congress or applicants and
declined to take action because they assessed that the agency had reached the right result. In
other instances. CSCIS officials have become more involved where they believe the agency had
eTTed. That is as it should be.
\V c agree \vith the draft report that it is important to have processes in place to manage external
inquiries about EB-5 cases, to pcnnit appropriate responsiveness to those inquiries, and to avoid
perceptions that anything other than the facts and the law drives agency decisimrs. ;\t the same
time, we must be accountable and responsive to legitimate criticism. In the ED-5 program in
particular, our agency has historically struggled with issuing timely decisions that arc consistent
with the law given the enonnously complex economic and legal issues that these cases can raise.
If our agency has decided a. case incorred.ly, in U1e EU-5 program or any other visa progrmn, we
cannot allow that error to go uncorrected when it is brougl1t to our attention. Senior agency
managers must be empowered to supervise and to correct course when they believe difficult
issues are not heing handled coTTeclly in cases. Thal is the responsibility or the chain or
cmnmand.
We would welcome suggestions from the OIG for processes that Users could implement to
accommodate all of these legitimate concems. \lie would particular-ly welcome suggestions from
the 01(1 as to protocols it would recommend l(rr documenting the agency's response Lo Lhe
thousands of inquiries received every year regarding EB-5 cases. It is important that the public,
Congress. and USCIS staff all have confidence in the integrity of the EB-5 process and our
adherence to the la\'li. \Ve are committed to taking any steps that can help accomplish this.
Conclusion and Recommendations
We concur with three or the rour 010 recommendations, allhmtgh as noted a/rove we have
refined some of the action items to comport with USCIS's authorities and structure. We
respectfully request that the recommendations be amended to reflect these refinements:
1. users will update regulations to provide greater clarity regarding the requirements tor
establishing eligibility under the program, in particular by more clearly delineating the
evidentiary requirements applicable to stand-alone EB-5 petitions versus Regional
Center-based applications and petitions. A revised rule will be drafted for interagency
clearance within nine months of this report.
Page B
2. users will develop and implement an interagency collaboration plan outlinirrg liaison
and collaboration roles and responsibilities among key federal partners, to include the
Department of Commerce and the Securities and Exchange Commission. within six
months of this rcpott.
3. USCIS's mandate is to adjudicate ED-5 cases according to the eligibility criteria,
including the statutory job creation requirements. US CIS is not charged with conducting
a broader assessment of the pmgram's impact. And while we agree that an assessment
may he hend'i(;iaL we do not believe lJSCIS, the administering henel'its agen<:y, is best
positioned to conduct that study. LSCIS therefore disagrees with the OlU's
recommendation that such a study be undctiaken by US CIS.
4. \.ISCIS will establish within six months quality assuran<:e steps to promote program
integrity and ensure regulatory compliance.
We appreciate the OIG's review of the legacy F.R-5 program and we cmrcur in the OIG's
assessment that improvements to the legacy program will enhance CSCIS's ability to ensure the
program is administered dlicicntly and consistently, with due focus on preventing fraud and
threats to national security. Tite OIG's assessment echoes concems we developed independently
which spurred us t.o transfonn the wa.y the EU-5 program is administered. Some of those
steps have come online over the past several years, but other critical and transformative changes
have become a reality only in the months since the OIG finished its audit \York. \Vc th.:rcfore
renew our invitation for the OIG to t:ondnct andit work on the rrew F.R-5 program oiTi<:e that we
latm<:hed in May orthis year, lhe new EU-5 poli<:y memorandtml that we published in 'lhy of
this year, and the many anti-fraud and nntional security we have recently implemented.
We and the public would benefit from the OIG's independent analysis of these measures, which
are not cuTTently reflected in the dmft report.

Appendix C
Major Contributors to This Report
Patrick OMalley, Director
Cheryl Jones, Audit Manager
Keith Nackerud, Analyst-in-Charge
Jeanette Hyatt, Auditor
Rebecca Mogg, Program Analyst
Audrey Van, Auditor
Katrina Bynes, Auditor
Marisa Coccaro, Program Analyst
Kevin Dolloson, Communications Analyst
Patricia Benson, Referencer

Appendix D
Report Distribution
Acting Secretary
Deputy Secretary
Chief of Staff
Deputy Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
USCIS Audit Liaison
Acting Chief Privacy Officer
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees, as appropriate

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