On June 14, 2016, USCIS released a Policy Alert indicating that it is seeking input on revisions to the USCIS Policy Manual on job creation and capital at risk requirement for investors.
These revisions represent the next iteration of USCIS’s draft memorandum dated August 10 2015, Guidance on the Job Creation Requirement and Sustainment of the Investment for EB-5 Adjudication of Form I-526 and Form I-829 .
Coincidentally, the author had just argued that redeployment is not required under the EB-5 law of investment though it may be prudent under certain circumstances.
The revised USCIS Policy Manual appears to agree with this analysis in some respects and depart from it in others. The published highlights of the revised policy are:
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