Comment: The EB5 Recession

The EB5 market has been plagued by irregularities. All markets have irregularities but the EB5 market may have more than its fair share. Even if the proportion of irregularities in EB5 is the same as other markets, the community which is affected by such irregularities is more vulnerable than typical American investors--due to poor language/cultural skills to assess risks.

Law enforcement is necessary but not sufficient in fixing of market irregularities. The major corrector of the market is the market itself as it matures over time. The market is cruel and it is already visiting its tender mercies on many players in the EB5 market, both in the USA and overseas.

Market forces have limitations, they are typically slow. That is not a criticism, but simply a recognition of a fact. Market forces and their impact dramatically accelerate during recessions--in that sense markets are shaped primarily by recessions. Especially important to market structures is the first recession that a new market faces because it flushes out a multitude of mistakes in one fell swoop. The modern EB5 market which took off in 2008 is nine years old and has not yet seen its first real recession (recessions prior to 2008 do not count for the modern EB5 market, due not just to the scale of the market today, but due also to the fact that its defining structures, such as reliance on China, did not exist in prior recessions).

When the first recession comes to EB5, it will expose massive structural flaws in the EB5 market. Unlike specific irregularities like Jay Peak or the Chicago Convention Center, some of the assumptions shared by a large number of players in the market will be sorely tested. For example:
  • Is mezzanine debt appropriate for EB5?
  • Is the loan model itself a viable one for EB5?
  • Is real estate the right asset class for EB5?
  • Is there a free lunch (China) in EB5?
Such fundamental shibboleths of the EB5 market will be tested. Some will pass with flying colors where as others will fail ignominiously. The greatest risk we see in the EB5 market is not fraud (which we are confident will be addressed by SEC and others) but instead structural corrections of its fundamental concepts by its first recessionary test. In other words, risks in EB5 are much higher than they appear, and are fundamental and widespread throughout the industry. The only force to reduce risk in the long term is a recession which will weed out weak ideas, and leave the remaining post-recession market players in a strong position. Recessions are both unavoidable and necessary for proper market functioning -- we cannot say exactly when the EB5 market will go through this ultimate test, but we can surely say that such test will one day arrive. In the meanwhile, Caveat Emptor.

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Focus: EB5 Quarterly Print Magazine - Chinese and English
ILW is pleased to announce the launch of Chinese and English print magazine.

  • The Chinese language magazine will have a print run of 3,000. It will be mailed out to Chinese agents and distributed to agents attending ILW China Expos and ILW Taiwan Expos.
  • The English language magazine will have a print run of approximately 1,000 and will be distributed to agents and investors in India and Middle East, agents in Korea and Vietnam.

We have kept the advertising rates for both the magazines low enough that they provide a cost-effective way of reaching agents in China and agents and investors throughout the EB-5 world. We offer combo discounts for advertisements in both the magazines and for multiple issues.

To find out more, please call (212)545-0818 or email or online.

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Help Wanted: Immigration Professional

Miami, FL - Visa Franchise ( is recruiting a full-time Client Services Manager at our headquarters in Miami, FL. The position entails acting as the main point of contact for Visa Franchise clients as well as business partners. The focus is on servicing clients through in-person, phone, and video conferencing meetings. Additionally, the Client Services Manager will be tasked with contacting and interacting with potential franchise partners as they are added to the Visa Franchise platform. As the company is still growing rapidly, the Client Services Manager will also assist with other aspects of the business such as event marketing, prospect outreach, and franchise analysis. Requirements: Bachelor's Degree, Fluent in English and second language required (Spanish, Portuguese, and/or French), Strong ability to work with and communicate with others including clients, prospects, and franchise partners, Ability to work in a fast-paced, flexible environment, and be able to work effectively autonomously when required, Ability for writing, facilitating, and presenting analyses, High level of intellectual curiosity about new industries and businesses and be must generate concrete results through that curiosity, 0-5 years of job experience, preferably in a client-facing role. If interested, send email to

Help Wanted: Immigration Attorney
New York, NY - Yarden Law Group has an opening for an immigration attorney with at least one year of business immigration experience to handle immigrant and non-immigrant cases including O-1, P-1, L-1, E-1, E-2, E-3, J-1, TN, EB-1,2,3 and naturalization cases. Good writing skills are necessary as well as ability to manage cases throughout their life cycle and effective communications with clients and team-members. Compensation depends on experience and skills. if interested, please submit your resume and cover letter by email to

Help Wanted: Immigration Attorney
New York, NY - Immigration lawyer (Midtown, Manhattan) - Boutique business immigration firm seeks Associate with 3+ years of experience & a demonstrated passion for the field. Must have extensive experience handling PERMs, full range of NIV (esp. H & L) and IV petitions. The successful candidate will demonstrate strong initiative, ability to handle a high volume and diverse case load, top-tier English writing and communication skills, and excellent organizational skills. Compensation package commensurate with experience and skills. Outstanding environment, team oriented. Please email cover letter, resume & 2 relevant writing samples to:

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