example, for investors whose regional centers do not
offer any redeployment solutions, or the options offered
are not appealing to investors, regional centers
could consider allowing investors to vote to redeploy
their capital into redeployment investments structured
by another regional center, provided that the governing
documents allow for it.
THE BOTTOM LINE
Per USCIS policy, investors need to sustain their capital
“at risk” through the reinvestment of capital following
the realization of the original EB-5 investment for at least
the duration of their sustainment period. As with any
investment, when redeploying EB-5 capital, investors are
"All redeployment
offerings should
undergo detailed project
screening and proper
due diligence performed
by all regional centers."
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exposed to market risks. However, that does not mean
that redeployment is or should be a risky investment, nor
should the only “safe” option be another EB-5 project.
In fac t, all redeployment of ferings should undergo
detailed project screening and proper due diligence
performed by all regional centers. Well-rounded projects
with sound financials will generally come with sufficient
documentation to explain and evidence the capital
stack, the investment strategy, and any exit strategies.
Those are the qualities that regional center operators
should look for in evaluating a possible redeployment
Christine Chen Since joining CanAm
in 2002, Christine Chen has been shaping
CanAm Enterprises’ strategic initiatives
and operational efficiencies. As the chief
operating officer, Chen oversees several
distinct EB-5 business functions and
manages a global staff of more than
40 members. Chen has led a variety of
initiatives to support CanAm’s operations.
S h e h a s s p o ke n a t i n d u s t r y e v e n t s ,
discussing EB-5 program issues and
providing insight based on her executive management experience.
Chen earned a bachelor’s from the University of Chicago and a
master’s from Columbia University.
112 EB5 INVESTORS M AGAZINE
investment.
E n g a g i n g a r e g i s te r e d i nve s t m e n t a d v i s o r i s a l s o
advisable. With proper due diligence, redeployment
investments can fulfill investors’ immigration
requirements while producing solid returns.
Walter S. Gindin
is a director and
in-house immigration counsel at CanAm
Enterprises, which operates seven USCIS-
designated regional centers throughout
the U.S. Gindin develops and oversees all
aspects of the preparation of Forms I-924,
I-526 and I-829 for CanAm’s projects. He
also provides guidance on compliance
with EB-5 regulations. Gindin received a
bachelor’s in economics and master’s in
political science from New York University.
He holds a Juris Doctor from the University of Iowa. Gindin is
an active member of the New York State Bar and the American
Immigration Lawyers Association.