First, you should start by consulting with an experienced SEC attorney in respect to the EB-5 program. Second, there are current SEC concerns with overseas brokers having a U.S. relationship eg.office, and marketing the EB-5 project either overseas or in the U.S. In this case it would be advisable for the Broker to have an Investment Advisor and/or Broker / Dealer license especially if the broker desires to accept finders fees from the EB-5 project.