It’s that time of year again! As a reminder, all EB-5 Regional Centers must file form I-924A for each individual Regional Center designated during or before the fiscal year ending September 30, 2017. Regional Centers must file form I-924A with USCIS by December 29, 2017.
As a friendly reminder, the form was updated last year and the current edition is dated 12/23/16 and is the only version USCIS will accept. There is also now a filing fee of $3,035 for each Form I-924A filing.
For more information about the new form I-924A, you can read this article by IIUSA member Joseph Barnett from the most recent edition of the Regional Center Business Journal. An analysis of the changes by Peng & Weber PLLC is also available on our blog.
The Most Wonderful Time of the Year: I-924A Season
by Joseph M. Barnett, Esq. Associate Attorney, Wolfsdorf Rosenthal LLP
It’s that most wonderful time of the year again, when Regional Centers gather with their sponsored EB-5 projects and new commercial enterprises (“NCEs”) and reminisce over a warm beverage on the past fiscal year’s job creation. Yes, it’s the happiest season of all in the EB-5 industry. . . I-924A season! It is now time for Regional Centers to complete the Form I-924A, Annual Certificate of Regional Center (“Form I-924A”) for submission to USCIS, and to resolve to continue promoting economic growth so that USCIS does not issue a Notice of Intent to Terminate (“NOIT”).
In reality, the Form I-924A has become a time-consuming, agonizing requirement for Regional Centers that wish to maintain their designation. For new Regional Centers or Regional Centers with multiple projects, it’s critical to start the process of collecting relevant information and documents in the autumn months for submission of the Form I-924A to USCIS by December 29 each year. With USCIS’ emphasis on maintaining integrity within the EB-5 Program and the new focus of the Immigrant Investor Program Office (“IPO”) on terminating poorly-managed Regional Centers, the proper, timely submission of a Form I-924A is essential. Because the Form I-924A is concerned with each specific Federal fiscal year’s capital investment and job creation, it may be necessary to enlist an economist for assistance.