alternative is not going to work for everyone. Investors
with relatively short redeployment terms (for example,
2 - 3 ye a r s) m ay n o t wa n t to s t ay i n a l o n g e r - te r m
redeployment investment suitable for investors subject
t o a l o n g e r t h a n 10 - y e a r v i s a
backlog. Also, he length of the
redeployment term will affect
each investor’s goals in terms of
expected returns, liquidity needs,
and risk tolerance. Finally, the
possibility of backlog relief that
shortens redeployment timeframes
c o u l d fa c to r i n to a n i nve s to r ’s
decision making when considering
redeployment alternatives.
eve n if th e o r i g i nal of fe r i n g g e n e r all y all owe d fo r
other investments to be made after the original EB-5
investment, the process of investors actually choosing a
subsequent investment may require investor consent for
any such subsequent investment.
Most investors who wish to
continue pursuing their EB-5 visa
would feel compelled to approve
a reasonable investment that
suits each inves tor ’s individual
circumstances. In such cases, it
would behoove a regional center to
engage an SEC-registered advisory
to provide consultation to ensure
that SEC and FINR A’s suitability
rules are being met.
"EB-5 investments are
regulated securities
subject to SEC oversight.
Redeployment
investments are no
different."
As with any investment decision,
it is critical that EB -5 investors
assess the suitability of a
particular redeployment investment. As such, regional
centers should of fer EB - 5 - compliant redeployment
investments suited to the needs and objectives of their
investors.
REDEPLOYMENT IS AN INVESTMENT,
SUBJECT TO INVESTMENT
OVERSIGHT
EB-5 investments are regulated securities subject to SEC
oversight. Redeployment investments are no different.
Most EB-5 investors subscribed for the original EB-5
investment based on an offering that described the
specific EB-5 project, but most likely did not contain
de tails regarding a re de ploy me nt inves tme nt. A nd
U nde r s tandably, U S CIS ’ p olicy
guidance on redeployment may
be outside the exper tise of most financial advisors
or wealth managers. With 792 USCIS -approved EB-5
re gio nal c e n te r s c u r re n tl y o p e r ating in th e U ni te d
S tates, it is clear that not all regional centers have
t h e e x p e r i e n c e , c a p a b i l i t i e s , a n d /o r r e s o u r c e s to
sufficiently accommodate all redeployment investment
options. In some instances, many regional centers only
have a handful of investors and providing a range of
redeployment solutions to its investors is simply not a
viable option.
There are other, less intensive ways that regional centers
can provide redeployment investment alternatives that
take into account an investor ’s individual situation
consistent with SEC and FINR A suitability rules. For
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