Comment: USCIS Rudderless

Given massive EB5 retrogression in China and rising EB5 retrogression in Vietnam and India, guidance from USCIS on redeployment of EB5 capital is long overdue (See: USCIS Guidance Needed). If USCIS applies the same standards at redeployment time that are then current for new EB5 investments, it would lead to massive investments of redeployed EB5 capital in rural areas, and high unemployment urban areas right away (as in immediately - these investments would be from existing EB5 projects that raised capital in China 5 or more years ago - these old Chinese monies would be recycled, reinvested in the now narrowly defined TEAs - usually in EB5 projects that have thus far languished for lack of capital). We would have expected that when Mr. Cucinelli was at the helm of USCIS, he would have seen it as a golden opportunity of adding rural jobs to the tune of 10,000+ jobs per month (since all existing rural projects are shovel ready), and thus helping President Trump's re-election efforts. We do not know if after Mr. Cucinelli's departure USCIS is rudderless, uninterested in implementing the President's priorities or merely swamped--time will tell.

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Focus: PERM For Beginners and Advanced Practitioners
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