Comment: Value Proposition of old RCs

Value Proposition of old RCs

RIA is the first statute change to EB5 in about 30 years. It has caused a Magnitude 9 Earthquake that has scrambled the EB5 ecosystem. In this email we explore the impact of RIA on old RCs. We look at the value old RCs offered to both agents and developers respectively and what has happened to those value propositions due to the enactment of RIA.

  1. Marketing & USCIS docs
  • Agents need excellent marketing materials; many old RCs have years of experience doing this well
  • Old RCs also have years of experience in preparing project documents acceptable to USCIS to ensure investor petitions get approved for green cards.
  1. Relationships with urban developers
  • An important value old RCs brought to agents were their relationships with large urban developers. RIA has banished large urban developers from EB5. Therefore this value is gone, and consequently what old RCs now offer to agents is lessened thereby.
  1. Agent network
  • Over the years, old RCs built a large agent network spanning multiple countries. This network is half gone due to the 3 year hiatus in EB5 program caused by covid and Congress - half the agents formerly in EB5 have exited the industry. Because the agent network is half gone, this value old RCs offer developers is reduced by half.
  1. Know-how selling glitzy large brands
  • The old RCs knew very well how to sell glitzy large branded properties in NYC/Miami/LA. RIA has made these glitzy projects impossible. Old RCs do not know how to sell rural securities that have neither glitz, nor large size nor an internationally recognized brand.
  1. New RC players 
  • Congress wants new players in EB5–it banished large urban EB5 players and forced a move towards rural area players (and chronically high unemployment urban area players)
  • Only half of the top 25 RC players of 2019 will remain in the top 25 in 2023, 2024 and beyond under the fundamental changes in their value proposition to agents and developers alike due to RIA.
  • USCIS site visits and audits as enforcement of Congress’ intent will hit old RC players much harder than new players since the old RCs long histories provide richer hunting grounds to a USCIS armed with RIA-turbo-charged enforcement powers 
Please let us know your thoughts by writing to us at

Article: Trends for Immigration Lawyers in the Second Half of 2023 by Marina Shepelsky, Esq.

Blogging: Does Biden Know He Is a President, Not a King, When It Comes To Enforcing Border Law? by Nolan Rappaport

Blogging: Rep. Thomas Massie Introduces Bill to End COVID-19 Vaccine Mandate for People Seeking to Become U.S. Citizens by Matthew Kolken

Blogging: CA2 Finds BIA Applied Wrong Legal Standard in Evaluating Ineffective Assistance Claim by Matthew Kolken

News: USCIS Updates Policy Manual to Make It Easier to Identify Who Is Subject to the Public Charge Ground of Inadmissibility

Focus: Silicon Valley EB5 Event

The new EB5 Reform Act allows for concurrent filing of Adjustment of Status with I-526 applications, which gives investors residing in USA most of the benefits of a Green Card within a few months of investing. So Indian H1Bs in the US may be the single largest piece of the EB5 global market in 2023. ILW has conducted 175+ in person EB5 events in 30+ cities across USA To find out more click Here 

Headline: 'It's a ghost town': Florida's new immigration law impacts businesses in NCFL Click here
Headline: Mass. rolls out new program to help immigrants with legal services Click here
Headline: At the Breaking Point: Rethinking the U.S. Immigration Court System Click here
Headline: On immigration, terrorists, and fentanyl, DHS Sec. Alejandro Mayorkas has something to say Click here
Headline: Canadian Immigration Work Initiative Reaches Cap in Two Days Click here

Letters of the Week:

ComingsNGoings: NPZ Law Group Announces its Ft. Lauderdale, Florida Office
The Nachman Phulwani Zimovcak (NPZ) Law Group continues to build its presence throughout Florida. Located at Crown Center, 1451 W. Cypress Creek Road, Suite 300, Ft. Lauderdale, Florida 33309, NPZ Law Group, also known as VISASERVE continues to expand our U.S. and Canadian Immigration Law services both regionally and nationally.  NPZ Law Group, headquartered in Ridgewood, NJ, (with offices in Raritan, NJ, a presence in Indiana and an office in Toronto, Canada, and multiple “on the ground” relational offices throughout in India), continues to be committed to delivering top-notch US and Canadian immigration and nationality law services. Our Florida office is part of our continuing efforts to reach and serve our South Florida clients in a more personal and efficient manner. For more information, please e-mail us at info@visaserve.comor call us at (201) 670-0006.

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