Current Policy
The standard minimum investment amount has been $1 million since 1990 and has not kept pace with inflation. (Why is this a concern for immigration? They have been raising their fees and the visas are now being used in greater numbers than before)
Further, the statute authorizes a reduction in the minimum investment amount when such investment is made in a TEA by up to 50 percent of the standard minimum investment amount. Since 1991, DHS regulations have set the TEA investment threshold at 50 percent of the minimum investment amount. Similarly, DHS has not proposed to increase the minimum investment amount for investments made in a high employment area beyond the standard amount. (This sounds like a thinly veiled threat)
Proposed Policy
DHS proposes to account for inflation in the investment amount since the inception of the program. DHS proposes to raise the minimum investment amount to $1.8 million. DHS also proposes to include a mechanism to automatically adjust the minimum investment amount based on the unadjusted CPI–U every 5 years. (Taking a under utilized visa and benefit to economic growth, because it was historically to expensive, and raise the cost so it continues to be to expensive now and in the future)
DHS proposes to decrease the reduction for TEA investment thresholds, and set the TEA minimum investment at 75 percent of the standard amount. Assuming the standard investment amount is $1.8 million, investment in a TEA would initially increase to $1.35 million. (Again making the investment to expensive)
DHS is not proposing to change the equivalency between the standard minimum investment amount and those made in high employment areas. As such, DHS proposes that the minimum investment amounts in high employment areas would be $1.8 million, and follow the same mechanism for future inflationary adjustments.
Suggested Results
Benefits:
• Increases in investment amounts are necessary to keep pace with inflation and real value of investments; (Why, it is finally at a workable price)
• Raising the investment amounts increases the amount invested by each investor and potentially increases the total amount invested under this program. (It also decreases the pool of investors significantly. It is much more likely the amount invested will go down significantly.)
• For regional centers, the higher investment amounts per investor would mean that fewer investors would have to be recruited to pool the requisite amount of capital for the project, so that searching and matching of investors to projects could be less costly. (While there would be fewer investors needed, the pool of available investors goes down potentially raising the cost of attracting investors.)
Costs:
• Some investors may be unable or unwilling to invest at the higher proposed levels of investment. (Yes you are doubling the costs)
• There may be fewer jobs created if fewer investors invest at the proposed higher investment amounts. (Less available investors and less money to invest)
• For regional centers, the higher amounts could reduce the number of investors in the global pool and result in fewer investors and thus make search and matching of
investors to projects more costly. (Yes!)
• Potential reduced numbers of EB–5 investors could prevent projects from moving forward due to lack of requisite capital. (Stalled projects and a decreased need for employees, not what the visa creation visa was intended for)
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