Comment: USCIS Guidance Needed

We urge USCIS to issue guidance on redeployment of EB5 funds for investors who are affected by retrogression, through a policy memorandum. We set forth below why is this guidance sorely needed:
  • Lack of guidance creates unnecessary uncertainty for investors as well as projects.
  • Projects need to plan long term to have viable redeployment strategies--this is impossible without clear guidance.
  • Lack of guidance provides no safe harbor for projects.
  • As retrogression already affects China, Vietnam and India, guidance for redeployment is essential for these high-volume EB5 countries.
  • All investments have risks involved--there is no need to add to the risk for investors and projects by adding uncertainty about redeployment of funds due to lack of guidance.
Issuance of guidance on redeployment from USCIS is long overdue, and is hurting investors, projects and consequently the EB5 program. We trust USCIS will remedy the situation by issuing a policy memorandum promptly.

Please let us know your thoughts by writing to editor@ilw.com.

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Focus: PERM For Beginners and Advanced Practitioners
Joel Stewart has done something remarkable in the new edition of THE PERM BOOK. He has taken the spaghetti of all the sources on PERM: legislations, rules, FAQs, cases etc. and reintegrated them into a simple and luminously logical progression of how to do PERM. In each of the chapters, he uses articles by notable practitioners and his own extensive commentary to provide deep insights on every aspect of PERM. If you are a seasoned PERM practitioner, you will appreciate the clarity of the organization seen in the table of contents below, and will discover many new insights in every chapter. For anyone relatively new to PERM, Joel Stewart serves as a trusted guide to your mastering the lay of the land of this complex area. This book belongs in the library shelf of every PERM practitioner.

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Help Wanted: Immigration Associate

NYC, Associate - Fragomen is seeking an Associate with 4+ years of business immigration experience to join one of its legal teams in NYC. PERM experience required. Please visit our careers page for additional information:https://bit.ly/2qrbUdH.

Help Wanted: Immigration Associate

Jersey City, Immigration Specialist - Fragomen is seeking an On-Site Immigration Specialist with 2+ years of business immigration experience to join a client site in Jersey City. Please visit our careers page for additional information:https://bit.ly/2D9fdcg.

Letters of the Week

ComingsNGoings: Immigration Event
Legalizing the Impossible Subject: The White Russian Refugees and the Development of American Immigration and Refugee Law during the Great Depression 12:00-1:30 p.m., Monday, February 24, 2020 Center for Comparative Immigration Studies University of California, San Diego Eleanor Roosevelt College Provost’s Building, Conference Room 115 9500 Gilman Drive La Jolla, CA 92093. For more information, Click Here.


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