Revised Draft Policy Memorandum Phone Call

It was interesting to note in the January 12 phone call with Director Mayorkas of USCIS, that some clarification was provided in relation to the revised draft policy memorandum relating to EB-5 policy.

While it is understood that it is still a draft in "Conversation with the Director" phone call the director appeared to indicate that in the case of a 'direct' EB5, money can be co-mingled from several EB-5 investors into a single holding company.  That holding company can then invest in three separate, wholly-owned, projects.  If 2 of those projects fail but the third project creates enough jobs for all three investors to qualify that all three investors can qualify for approval at the I-829 stage.
 

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USCIS EB-5 policy Direct multiple companies