Green and Spiegel Submits Comment on the Proposed EB-5 "Modernization Rule"

The Green and Spiegel Investor Team submitted its comment on the proposed EB-5 Modernization Rule. For background, see our analysis of the proposed Rule here.  Fellow stakeholders interested in providing comment to USCIS may do so online before April 11 at 11:59 pm ET, when the comment period closes and the agency must review comments in its efforts to move forward with regulatory reform.

Our comment on the Rule focuses on the following main points:

• As drafted, the Rule is too narrow to truly "modernize" EB-5. There remain many other facets of the program that need improvement through regulatory reform, such as allowing concurrent filings, being able to incorporate voluminous filings by reference, overhauling the post-decision I-829 review process, and allowing for a Condition Removal Exemplar;