EB-5 Policy Development Strategy Explained

The Stated EB-5 Policy Development Strategy

The introductory material to the Draft EB-5 Policy Guidance Document of 11-09-2011, acknowledges that EB-5 involves:

• A significant number of complex issues;
• That USCIS has learned lessons over time;
• The guidance needs to be consolidated in one place; and
• Stakeholders do contribute constructive input.

Lastly, it can be safely inferred that USCIS is acknowledging that EB-5 issues are dynamic and fluid as opposed to static and therefore, its interpretations and processes need to reflect that dynamism.

Specifically, the Draft states:

“Additional reforms are planned. Importantly, USCIS also has reviewed its various EB-5 policy memoranda and determined that they should be consolidated into a single overarching agency policy memorandum. This memorandum will incorporate constructive stakeholder input and reflect the lessons learned since the various memoranda were initially promulgated. Given the number and complexity of issues involved, USCIS will develop this single EB-5 policy memorandum in iterative fashion, seeking public comment as the draft policy memorandum progresses.”

Iterative Development (as often used in software development)

A discipline for developing systems based on producing deliverables often. Each iteration, consisting of requirements, analysis & design, implementation and testing, results in the release of an executable subset of the final product, which grows incrementally from iteration to iteration to become the final system....1

The intended back-and-forth exchange won’t happen if the masses of EB-5 stakeholders leave it to just a few bigmouths. Speak up NOW, while they are listening. That’s my two-cents!

December 3, 2011

1 http://encyclopedia2.thefreedictionary.com/iterative+development

 

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EB-5 Policy