EB5 Investors Magazine English Edition, Volume 4, Issue 2 | Page 80

Regional Center-Based EB-5 Project Setup Costs: Notes regarding costs presented: seek equity stakes in the projects themselves. This may Regional center-based projects commonly involve additional components and service providers. A few additional items should be considered when eval- not be welcomed by all project developers but it does, uating the costs presented above. at times, incentivize the migration broker to advocate IMMIGRATION LAWYER LOW HIGH NOTES $ 25,000 $ 50,000 Can be higher for complex cases, or larger firms S ECURITIES LAWYER $ 20,000 $ 100,000 CORPORATE AND LOAN DOCUMENT COUNSEL $ 20,000 $ 60,000 BUSINESS PLAN $ 7,500 $ 15,000 Filing Fees May Change Right around the time this article was going to press, May vary considerably depending of the amount of corporate legal advices that may be required High cost includes project plan & regional center operations plan $ 20,000 ESCROW SETUP* $ 2,000 $ 5,000 are currently proposed as follows: PROJECT MANAGEMENT* $0 $ 25,000 FUND ADMINISTRATION DATA TRACKING SERVICE SETUP* $0 FORM I-924 FILING FEES $ 6,230 $ 6,230 TOTAL $ 98,730 $ 333,230 $ 2,000 Commonly a function of RC manager, developer or 3rd party. some sophisticated immigration attorneys will manage coordi nation of proffessionals as part of their services This refers to managing the development of the EB-5 application and team members; comonly handled by the immigration attorney Depending on the service, this cost can be borne by investors, while others charge the RC $129-$495/ month case-by-case basis. changes have not yet been approved, $ 8,000 $ 50,000 igence reports, which should be evaluated on a CIS with respect to filing fees. While the ECONOMIC IMPACT REPORT $ 10,000 some U.S.-based broker-dealers recommend due dil- some proposed changes were made by US- it is worth keeping in mind that they FEASABILITY STUDY* more strongly on behalf of the project. Additionally, That being said, due to the international nature of EB-5 marketing, and separately from the pertinent and • Form I-924 application for region- very important securities law con- al center designation or amend- siderations, it is prudent for newer ment: a fee increase has been pro- EB-5 participants to anticipate the posed that would raise the cost from possible need for working with ex- $6,230 to $17,795. perienced migration brokers in rele- • Form I-924A (to be titled “Annual vant EB-5 markets such as China. This Certification of Regional Center”): a new $3,035 fee has been proposed. * Denotes items that are not technically required, but are commonly used or strongly recommended for most part Marketing Costs does not necessarily mean, however, that the developer would necessarily be paying the highest cost range provided in the tables above. Marketing costs (i.e. the cost of marketing a project to Insurance potential investors and/or their respective migration Many different insurance options are available for EB-5 brokers) can easily be the highest cost in the whole projects. While insurance, generally speaking, can add Ongoing Costs: EB-5 process. The costs presented above represent the a significant benefit to projects, the EB-5 industry uses The ongoing costs of an EB-5 capital raise are presented separately in the following table. outside extremes for most projects. By way of exam- these products to varying degrees. Including all possi- ple, agents in China, the biggest EB-5 investor market, ble insurance options in the costing table would have a NOTES might command anywhere from just the administra- potentially distorting weighting effect on the high-end tion fee on the lower end, up to the administration fee scenario, so it was excluded from the costing model. plus 4-5 percent annually of the funds raised on the Insurance options include I-526 (investor) insurance, high end. Commonly, agents that charge fees at the errors and omissions insurance and construction in- lower end of the range may work with only the most surance to name a few. Insurance options should be experienced EB-5 project teams, and thus are comfort- evaluated on a case-by-case basis and explored with able with lower fees because there is a trust built-in professionals. LOW HIGH REGIONAL CENTER COSTS (if 3rd party) 0.25% $ 15,000 per investor This cost can be less, depending on the number of investors RETURNS TO INVESTORS 0.5% 2.5% Annually. This fee can vary but 0,5% is very common in the marketplace today MARKETING COSTS (marketing to EB-5 investors) 0 6% Annually. Costs shown there are over and above the “administration fee” commonly charged to investors in addition to their core investment, so it is not shown here as a cost, because it is a pass trough cost (i.e. typically charged to investors and paid to agents) ESCROW ANNUAL RENEWAL FEE 0 ESCROW FEE PER INVESTOR 0 FUND ADMINISTRATION DATA TRACKING SERVICES $ 2,000 May apply in circumstances where an account remains open and unfunded from years of interaction, or otherwise, may be smaller agents who may not be able to fully subscribe the units 0.10% $ 1,500 0.50% This fee may apply with some providers in some cases where aggressive escrow terms exists in a deal entirely on their own, and so there may be an Annually. There is a wide and growing range of options (e.g. loan servicing, loan enforcement, fund accounting and 3rd party co-manager. Costs shown range from traditional services, to EB-5 specialized services and are annual fees, based on EB-5 funds under management) to complete the subscription process. More recently, added cost associated with finding other small agents some agents are even commanding large one-time fees upfront, in addition to the other compensation outlined above, prior to completing their marketing obligations. Many potential ways exist to go about marketing a project and the costs can vary considerably, depending on the approach taken. Another trend in the market has arisen in situations where the migration brokers even 79 EB5 INVESTORS MAGAZINE WWW.EB5INVESTORS.COM 80