EB5 Investors Magazine (English Edition) Volume 5, Issue 1 - Page 60

KEEP IT IN THE FAMILY An investor might be resistant if the NCE redeploys the funds into another project related to the original borrower. Such new ventures may be illiquid unless, there is a short time horizon associated with each new project. For example, the JCE requires the initial EB-5 project to work on phase 1 of a project. Phase 1 gets completed in record time and all required jobs are created. JCE, following the terms of the offering project and appropriate consent, as may be required under the offering, from the NCE and investors, utilizes the proceeds for phase 2 and then phase 3 and so on. If an EB-5 issuer is able to contemplate a multi-phase project with short life spans allocated to each phase, this could allow the funds to remain within the NCE/JCE family. PURCHASE OF EQUITY INVESTMENTS Some have interpreted the draft policy rules to permit the purchase of equities as a feasible alternative