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 
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