Earlier this week, Invest in the USA (IIUSA) submitted comments to the U.S. Citizenship & Immigration Services (USCIS) in response to the USCIS Policy Alert on “Immigrant Investors and Debt Arrangements” released on October 30, 2018.
The comments reflect the diligent, and quick, work of the IIUSA member lead Public Policy Committee and we thank them for the efforts. While we appreciate the opportunity to have our comments considered by USCIS we believe that the process for the release of this Policy Update needs improvement to ensure indsutry stakeholders are given sufficient time to comment on substantive policy changes. We are confident that by engaging the industry in a more interactive process will help USCIS its goals of meaningful policy and enable the EB-5 Program to run with integrity.
We continue to urge the Agency to use the APA process to make significant changes to EB-5 policy. We share the Agency’s goal of protecting innocent investors, who have gone through our legal immigration process with significant diligence, from unintended consequences of changes to policy during their path to residency. We look forward to continuing IIUSA’s engagement with USCIS and IPO in the months and years ahead.