IIUSA’s NPRM Comment Submission: A Herculean Group Effort

IIUSA’s NPRM Comment Submission: A Herculean Group Effort

Earlier this week, IIUSA submitted its final tranche of comments to the Notice of Proposed Rulemaking (NPRM) ahead of the August 31 deadline. The submission of the over 150 pages of thoughtful, comprehensive comments, grounded in empirical knowledge and fact-based data was no small feat.

To read more about the process to collect, hone, and disseminate our official comments, read the press release.

Read IIUSA’s full comment submission to the 2026 NPRM

IIUSA’s board, membership, and staff extend a special thanks to Lulu Gordon and her team at EB5 Capital. From the outset, Lulu became the association’s chief strategist not only in coordinating the effort to include as many perspectives, members, and experts as possible, but also in coordinating the association’s comments themselves; making sure none conflicted and that IIUSA’s priorities were eloquently reflected across all the working groups’ text.  IIUSA is grateful for her time, her acumen, and her tireless efforts on behalf of the association and the entire EB5 industry.

IIUSA would also like to thank all 45+ members of the Public Policy subcommittee, including the Working Group leaders, that mobilized almost immediately after the NPRM was published, in large thanks to Lulu. Without the tireless dedication of these members, this effort would not have been possible.

2026 IIUSA NPRM Subcommittee

*Indicates Working Group leader