Comment: COVID-19 Crisis, ICE Detention Centers

  • To qualify as a TEA, an area needs to be a rural area or its unemployment rate needs to be 150% of national average. For the latter criteria, several different methodologies are in use for determining TEAs. Some of these methodologies use longer timeframes and others shorter timeframes in calculating unemployment rates.
  • With the national unemployment rate projected to shoot up from 3.5% to 10.5% due to coronavirus, even though the relative unemployment rate for TEAs remains 150% of the national average , the number for an area to qualify as a TEA jumps to a very high absolute number--so many TEAs that qualified easily before the coronavirus may no longer qualify as TEAs.
  • Further, the unemployment rate will change in a non-uniform fashion across the country. In densely populated areas the loss of employment may be higher than sparsely populated areas. If the coronavirus is affected by heat/humidity (and the jury is still out on this), then the Northern parts of the country will be hit harder on unemployment than the Southern parts of the country. So the TEA map may be scrambled further by density of population and perhaps by latitude as well.
  • On top of all that, unemployment numbers both national and local will gyrate dramatically so TEA calculations will fluctuate wildly with them.
  • The only safe harbor for TEA definition in the coronavirus age is in rural areas, that is areas outside of MSAs--whose TEA status is independent of any variation in unemployment numbers.
  • Many players who have exited the EB5 industry due to losing their TEA status under the new regulation may find it worthwhile to re-enter the EB5 market in the coronavirus age, due to the TEA scramble working in their favor.
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