Comment: Where Are The 900K Wires

Many banks which have handled the bulk of EB5 wire transfers and escrows in pre 2020 EB5 market are reporting that there are no wires at the $900K level. Issuers who are in touch with these banks have concluded from that there is no EB5 market at the $900K level. This is a mistaken conclusion because it is based on incomplete information.

More than half dozen of our clients have reported that:

  • They have had a number of investors sign subscription agreements at $900K level
  • Many investors have engaged immigration attorneys to work on the source of the $900K
  • Some investors have paid all or part of the admin fee
  • One investor has transferred $100K+ of the total investment amount
  • It appears that doing source of funds for $900K takes longer than $500K
  • In the absence of a deadline, investors are taking their time to wrap up the investment process

What explains these two conflicting pieces of information - the bankers' report that there is no $900K market, and reports from our clients confirming that the $900K market does exist? The fact is that the networks in EB5 industry have changed. Everyone tightly connected to the giant real estate projects of the pre-11/21 EB5 world were the primary sources of information on the EB5 industry--whether they were banks, business plan writers, securities attorneys, economists, immigration attorneys or developers themselves. In the new EB5 market the same players who had all the information, suddenly have no information, since they are no longer in a TEA. The EB5 market has shifted to small projects--projects with as few as 5-10 investors. These players because of their small scale cannot see the whole picture, and furthermore they do not use the EB5 professionals that were used by the giant developers of the past. Everyone seems to be still relying on the past trustworthy sources for information, but those same sources do not have information any more because EB5 investments are taking place with a large number of smaller, newer players that are not connected to them. With 50% of the top highly connected nodes gone from the past EB5 network, 100% of the old network is defunct. Everyone is flying blind and will stay blind. It will take months to years for any patterns to emerge from this new highly fragmented new network.

As direct reliable information is no longer possible, the giant developers that are used to a high degree of certainty will find the EB5 market increasingly unsettling, and not worth the uncertainty, since they have capital available through much easier channels than EB5. The new smaller EB5 players often run operating companies that are used to a higher degree of uncertainty in their businesses and uncertainty in their capital raises as well--so for them EB5 remains a good option. EB5 industry seems to be shifting from almost exclusively real estate projects to a greater proportion of manufacturing projects (real estate will continue to dominate, but its market share may well shrink from 95% to 65%). Information is in Networks. Past players who were connected to giant real estate projects, will continue to have incomplete and therefore misleading information about the EB5 market going forward--because the giant projects that were once the central hubs of the EB5 information network are gone. That old network is now replaced by new widely distributed and disconnected networks where information is smaller in quantity and much greater in uncertainty. ILW will continue to bring you such information as we have as we go forward into this brave new world.

ILW estimates the 2020 EB5 market to be more than $1 billion. If you are raising EB5 capital in 2020, we have identified a very small number of specific opportunities in the new EB5 market. Contact us for a conversation on what we can do for you in this brave new EB5 world by emailing us at, calling us at 212-545-0818 or online.

Article: USCIS Re-Prioritizes the EB-5 Adjudication Process: An Analysis! By Mona Shah, Esq & Rebecca S. Singh, Esq.

Blogging: The All-or-Nothing Problem By Jason Dzubow

Blogging: House Democrats' immigration bill would use tax dollars to import crime to America By Nolan Rappaport

Blogging: Trump asks for $8.6 billion dollars more for Border Wall while slashing spending needed to protect America against Coronavirus By Roger Algase

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.

Get your copy Now, Here:

Headline: The immigration showdown between President Trump and Andrew Cuomo, explained Click here
Headline: Scandinavian Airlines removes ad after online criticism, particularly from anti-immigration parties Click here
Headline: This Lawmaker Wants to Remove the Words ‘Illegal Alien’ From the Law Click here
Headline: Bernie Sanders camp blasted AOC’s Iowa rally performance last month, report says Click here
Headline: New York Governor Signals Possible Compromise With Trump in Immigration Spat Click here

Kaufman; Kahn, LLP
Real Estate Practice: Landlord/Tenant and Real Estate Litigation; Cooperative and Condominium Disputes; Collection Actions; Enforcement of Judgments; Arbitration; Residential Real Estate Transactions; Commercial Real Estate Transactions; Business and Commercial Litigation in State and Federal Court; Business Transactions (Contracts, Promissory Notes, Mortgages, Security Agreements, Operating Agreements, Shareholder Agreements, Partnerships, License Agreements); and Commercial Leasing and Lending. Intellectual Property Practice: Copyright Law and Trademark Law: filing and prosecuting applications in the Copyright Register, the USPTO and TTAB; litigating to enforce registrations against infringers (and defending against alleged infringers) in federal courts; defending against Americans with Disability Act (ADA) claims; Intra-Corporate Business Litigation ("Business Divorces"); Drafting and Negotiating Transactions: Licensing Agreements and other Intellectual Property Contracts. Contact:Robert L. Kahn, Esq.; Kaufman; Kahn, LLP - 10 Grand Central, 155 East 44th Street, 19th, Floor, NY, NY 10017, (212) 293-5556,

Help Wanted
Bilingual legal secretary/paralegal (Spanish-English) needed for small Nassau County, Long Island immigration law office. Must have excellent attention to detail and organizational skills. Job includes preparing benefit applications and court papers for filing, answering phones, general office work and heavy client contact. We are an older firm with a good reputation concentrating in family and employment-based cases. Send resume and cover letter to:

Help Wanted
Law Firm for Sale. Central L.A. 1.3 million dollar practice with a focus on family immigration and deportation/removal. The firm also has steady TPS revenue from El Salvadoran immigrants. Owner retiring and available to help transition. For more information, contact Roy Ginsburg, who is acting on behalf of seller/owner, at 612-812-4500 or

Letters of the Week: Harry DeMell

ComingsNGoings: Immigration Event
Southeastern Immigration Studies Association Conference Current Trends in Immigration Research and Activism Thursday-Saturday, February 20-22, 2020 The Citadel Charleston, SC. comingsNgoings announcements is a free service.

An Important disclaimer! The information provided on this page is not legal advice. Transmission of this information is not intended to create, and receipt by you does not constitute, an attorney-client relationship. Readers must not act upon any information without first seeking advice from a qualified attorney. Copyright 1995-2017 American Immigration LLC, ILW.COM. Send correspondence and articles to Letters and articles may be edited and may be published and otherwise used in any medium. The views expressed in letters and articles do not necessarily represent the views of ILW.COM.
Publisher: Sam Udani ISSN: 1930-062X
Advisory Board: Jason Dzubow, Rami Fakhoury, Matthew Kolken, Chris Musillo, Lory Rosenberg, Greg Siskind, Joel Stewart, Margaret Wong