Media Release: January 21st, 2015
Top 25 EB-5 Attorneys of 2015 by EB5Investors Magazine
Larry Behar has been an attorney since 1979, long before the establishment of the EB-5, and he has been following the program since its inception. He filed his first EB-5 case in 1995 for an individual applicant from China. He now runs Behar Law Group in Florida, which has established multiple regional centers since 2007. In addition to representing regional centers, Larry counsels individual investors and feels particularly capable of doing so due to his own immigrant background.
For the past decade, Larry’s practice has focused nearly entirely on EB-5 and he has organized two EB-5 teams—an in-house legal team and an outside “EB-5 dream team,” made up of other service providers. The multicultural and multilingual nature of his practice is a point of pride for Larry; he speaks three languages and his office boasts a total of seven languages spoken in-house.
Working within the EB-5 program rewards Larry in many ways. Most notably, he cites the personal stories of investors that he has worked with. Recently, he was able to secure permanent residence for a learning disabled woman who emigrated from Canada through the EB-5 program, and is now thriving in Florida. Additionally, he speaks of past clients that have come from security-challenged nations, such as Venezuela, and is proud that the EB-5 program can offer them a safe solution.
Since he began EB-5 work, the program has changed in many ways; Larry likens EB-5 to a growing child, and he has been there to witness all the growing pains. In the interest of encouraging program growth, Behar Law Group has been lobbying Congress for the past four years to increase the visa quota.
Larry is active in the EB-5 community and locally—he is the author of EB-5 United States Immigration Through Investment and How to Immigrate to the USA, and is a past chair of the Broward Alliance, Broward County’s economic development corporation. Larry is a long time member of AILA and IIUSA.
Media Release: November 16th, 2012
Larry J. Behar, Senior Attorney at the Behar Law Group announced today that the firm has been selected for two major innovative EB-5 projects in the U.S.
The first project will allow for the conversion of a half million square foot pinewood manufacturing facility to become a film and entertainment studio with six sound stages making it the largest of its kind on the eastern seaboard of the U.S.
Situated in the town of Seneca, South Carolina, the $168Million project will generate over 900 direct jobs in the first year of operation and 2,600 jobs thereafter. “With advanced lighting systems and over 100 terra bites of bandwidth, artists/producers will be able to communicate with media markets globally to provide entertainment content at a fraction of the price. The use of digital technology and value engineering provides a win win platform for producers from around the world who will benefit from this extraordinary facility” as stated by the Developer.
The Behar Law Group was also selected by the LDV Hospitality group, renowned for branding high end restaurants in New York City and Miami. With the added EB-5 capital, the company will be on a fast track to expand their operations in the U.S. and implement their business plan. “While we initially thought that we would self-fund our expansion, EB-5 low cost capital will provide additional valuable capital for further immediate growth in both our key markets and franchise expansions” said the CEO of Operations. The company boasts no less than three Iron Chefs on its teams.
The firm is pleased to announce the translation of its guidebook in both the Spanish and Portuguese languages, along with staff additions in both these languages and Russian.
The firm is also spearheading a Congressional initiative to double the EB-5 quota which is nearing its limiting this past fiscal year in anticipation of future growth of the program.
Mr. Behar has delivered three lectures in the past month to various business and academic organizations in South Florida.
Media Release: October 10th, 2012
Foreign funds back yachts’ construction in U.S.
By: Lucy Chabot Reed
Broward Superyachts laid the keels in late August of two vessels that just might become the first of their kind: funded mostly by investors seeking immigration status in the United States.
The yachts — hull No. 1201 M/Y Challenger and hull No. 1202 M/Y Voyager — are being built for WorldSea Yachting, a Belgian company who plans to merge yacht chartering with cruise ship operations and offer individual cabins on yachts for vacations.
Construction of the two Broward yachts is being funded, in part, by the EB-5 visa program, a job creation and foreign investment program created to encourage high net worth individuals from other countries to migrate to the United States and stimulate the U.S. economy through business and job growth.
In this scenario with Broward Shipyard, 12 foreign nationals will invest $1 million each to build these two 135-foot (41m) tri-deck motoryachts. Additional financing for the construction will come from personal investors, and bank financing.
The individual investors are not building the yachts; they are investing in Broward Super yacht 1201 and 1202, two companies created to build each yacht.
For each $1 million investment, 10 U.S. citizens will be employed and the investor receives a two-year conditional U.S. visa translatable to permanent residency status once the investment proves successful, that is that 10 jobs have been created.
Ultimately, the construction of each vessel must employ 60 people, or 120 people total at Broward Shipyard.
“At the end of the day, you have to be creative, especially when financing from the bank is not coming,” said Larry Behar, a Ft. Lauderdale immigration attorney who wrote the legal documents for the foreign-national investment plan.
The plan falls under the U.S. Customs and Immigration Service program called EB-5. The EB-5 (employment-based fifth preference) Immigrant Investor structure was created in 1990, but it wasn’t fully explored until after 2001. It offers no more than 10,000 visas to foreign nationals who invest $1 million in either starting their own business or in an existing business looking to expand.
Behar, known in some circles as the godfather of EB-5, said this platform is different than any other he’s created before. He’s established the legal platforms for tourism resorts, shopping centers, gold mines, land development projects, a hospital and retail hotels across the United States.
To read the rest of the article, please visit: http://tritonpubs.com/edirectory/article/foreign-funds-back-yachts-construction.html
Media Release: September 6th, 2012
EB-5 Program win on the Hill
By now, I may be giving you ‘old’ news that Congress has passed the reauthorization of the Immigrant Investor program for regional centers by a whopping 412-3 vote in the House and a unanimous vote in the Senate. The President is scheduled to sign the Bill into law before the end of the month.
Why is this so important? First, it means that the EB-5 Bar as well as our lobbying organization, IIUSA, has done a masterful job in presenting our case to the members of Congress. We have it on good authority that an effort will immediately commence to make the program permanent. There is a broad support nationally. Logic and good sense have prevailed.
Second, the economy clearly has not allowed financial institutions to establish lending policies anywhere similar to pre-2008 levels. As such, it is our inclination that any significant commercial project funding will need to come from foreign sources through the EB-5 program.
In the last year, we had successively upgraded our prospects of the reauthorization of the bill. That is a reflection of the electorate for this job and capital generating program. However, USCIS continues to make life extremely difficult in the EB-5 unit. While the remainder of USCIS departments issue rational and logical decisions, the EB-5 unit, by and through its new economists, management and attorneys, seem to question some of the most logical and business sensed platforms above and beyond historical precedent and other USCIS procedures in other immigration procedures such as nonimmigrant investor visas and intra company transfers for multinational executives.
We have received clear direction from USCIS that any plan which is not accompanied by an impartial feasibility study will not pass muster. Further, all assumptions and conclusions must be independently supported. Many of the basic economic standards and formulae used in the past have been challenged. We hope that this will now level off as USCIS seems to have a reached a new high (or low, depending on your perspective) in expectations from EB 5 projects.
We are not sure whether these actions are intentional to discourage other applicants or just a super caution which is selfdefeating. Time will tell. In the mean time, we will continue to monitor and report to our clients and friends. As we have always stated, EB 5, with all its advantages, is not a linear or clear path and must be approached with skilled and steady hands.
Click here for more of the new legislation for your review.
Media Release: August 3rd, 2012
EB-5 Visa Program Development
It is with pleasure that we can advise you that the United States Senate has in principle agreed to a 3 year reauthorization of the EB-5 Regional Center Program (and other three programs included in S.3245). The Senate has already acted, passing the deal yesterday via unanimous consent. We understand that the House – which is already on recess – will take this up via suspension of the rules (i.e. no floor debate) in early September after recess is over.
While this measure is not a permanent or a five year reauthorization, it does afford a lengthy period of time to permit the EB-5 program to expand and stabilize. Please contact your House representatives to encourage passage in September.
Media Release: June 29th, 2012
USCIS Stakeholder Conference Call 06/22/12:
The Behar Law Group is pleased to send you further updates on the numerous changes in EB-5 laws. Our prediction of almost four years ago that traditional banking sources would not return to full scale commercial lending has been confirmed. As a result, the popularity of the Eb5 program has increased significantly and its notoriety nationally and internationally is also cresting.
Further, both the Canadian and Quebec investor programs have been suspended by their respective governments due to over demand. This bodes well for Eb5 which has had a slow start in structure and popularity. Statistics of the rise of the EB-5 program will be emailed to you under separate cover.
The news for the reauthorization of the program from Washington,DC seems to be improving. We have now upgraded the extension of the EB-5 program from ‘probable’ to ‘likely’. This is based on the proposed Congressional Bill S-3245 which now has bipartisan support for a five year reauthorization. Both Senators Leahy(D) and Grassley(R) now support the bill and are seeking unanimous consent. There is virtually no opposition to the bill and even USCIS admits to having invested tremendous resources to make the program work. It is continuing its path of greater scrutiny by adding more professionals to its review staff. This is a double edged sword as there will be heightened review by new employees seeking to demonstrate their skills.
It has also been made abundantly clear further in the last Stakeholder call of July 26, 2012 that only undisputed sources of reference will be deemed sufficient for business, economic and other feasibility plans. For example, sources for Targeted Employment Areas (TEA) will be derived from the Bureau of Labor Satistics, not the Bureau of Economic Analysis. References must be derived from statutes, official regulations, case law, government sources and the like instead of expert witness or market-specific observations or opinions.
Additional layers of bureaucracy are being added in the form of the EB-5 Program Office and the Review Board. High volume regional centers will be assigned a case specific officer; this can be a double edged sword again. In person or telephonic reviews will be possible if needed in the event of I-924 denials. New FAQs will be issued ‘soon’. Business plans must adhere to outline in the precedent Matter of Ho. NAICS codes should extend to four digits. The boundaries of a regional center must clearly demonstrate the promotion of economic growth within an economic zone. There needs to be a clear contribution to the supply chain and/or labor pool in the area. The EB-5 program is a job creating engine, not simply a substitute for capital attraction.
Amendments to regional centers will take longer to review due to higher review of substance, juxtapositioned to economic growth and review of economists. The deference policy to previously adjudicated regional centers will be respected unless there is a material change, fraud, or that the previously adjudicated approval was legally deficient.
In conclusion, we are entering a new age of EB-5, one which will allow the program to exist and grow due to market demand but one which will be highly regulated and subject to high scrutiny until we reach a greater degree of reliance and predictability. Keep your seatbelts on, tight.
Media Release: June 29th, 2012
Positioning for October 1st 2012
As most stakeholders of the EB-5 program know, the Immigrant Investor pilot program is scheduled to sunset September 30, 2012. While any scheduled sunset is nothing to minimize, our firm has recently started to receive some signals that the statute may receive a permanent reauthorization before its deadline.
First and most important is Senate Bill 3245 while has been co-sponsored by Senator Patrick Leahy of Vermont and Senator Chuck Grassley of Iowa, a Democrat and Republican respectively. With mutual concessions in play, they have arrived at a consensus to present to Congress for review and ultimate vote.
As we had advised our clients back in 2008, the U.S. banking system has taken a dramatic shift to conservative lending which affected most developers across the United States. As such, particularly in the last two years, the notoriety of EB-5 in the capital stack as an alternate financing tool, as large or as small as it is structured, has presented a viable and popular tool.
In addition, CNN has recently confirmed that the United States lags significantly behind in the health of its immigration system compared to many other industrialized nations, particularly Canada and Australia whose programs have been so successful that they needed to be suspended.
Further, there appears to be little, if any opposition from the greater stakeholder community to the passage of this bill. The Administration, Congress, the Business community and even the agency in charge of the program are all committed to ensuring the continued viability of this job creating, capital attracting program, which, for the first time, has hit its quota of 10,000 in a fiscal year (which starts again October 1 every year).
You may have received a solicitation from our firm to contact your congressional connections to support this new legislation. To those who have done so, we thank you. To those who are getting ready to do so, the time is now! Do not believe that Congress closes for the summer. Representatives return to their districts and actually listen hard to their constituents when faced by them locally. Make your voice and pen heard!
Media Release: June 6th, 2012
The Behar Law Group is proud to announce that its EB-5 book, “EB-5 United States Immigration through Investment” is now available for download on the iPad for free.
- 50 Chapters easily explaining the EB-5 program and all that it entails for investors, developers, agents, officials, attorneys, and decision-makers;
- Important flow charts and checklist;
- Videos explaining the top 10 chapters, staring Larry J. Behar;
- FAQ’s ;
- Helpful websites and portals.
The “EB-5 United States Immigration through Investment”
book is also available for purchase on the Amazon kindle store
A Paperback version is also available if you prefer for purchase on Amazon
Like us on Facebook for current updates, news, and events.
Media Release: April 27th, 2012
Mr. Larry J. Behar, senior attorney at the Behar Law Group, takes pleasure in announcing the appointment of Linda Liang to the firm, our fourth EB-5 attorney. Ms. Liang is a member of the California bar and focuses on U.S. immigration matters exclusively.
As a graduate of a Huazhong University of China, Ms. Liang, who is fully trilingual in English, Mandarin and Cantonese will assist the firm in transpacific immigration matters particularly EB-5 issues. A resident of Broward County, she has over a decade of legal experience and will join the firm effective immediately in an “Of Counsel” capacity, choosing to meet with clients and friends of the firm in the field. Ms. Liang will join paralegal Hailing Chen of BLG in assisting all Chinese investors and immigrants.
The firm is also pleased to announce the opening of its EB-5 franchising division to be headed by Mr. Behar and Ms. Liang. This section will allow foreign investors to benefit from the defined structures of U.S. franchises while immigrating to the U.S. and, conversely, assisting U.S. franchisors to become introduced to the China market which is heavily brand driven.
In addition the firm will also assist franchise designers to implement interior store modifications to render them wheelchair friendly allowing disabled persons to become gainfully employed. This novel design will be implemented both in China and the United States through the venerable Wheelchair Foundation which has offices currently in Shanghai and San Francisco.
As the firm defines its next twenty years of operations, we thank all our clients and supporters, friends and family who have been so generous with their time, expertise, and resources. We look forward to continued positive international growth and success.
Media Release: April 2nd, 2012
Mr. Larry Behar, Senior Attorney, Mrs. Lea Dimitri and Ms. Tania M. Sibonney, Associate Attorney’s of the Behar Law Group are pleased to announce the firm’s success of an approval of an EB-5 Investor in office record time.
The client, of Mexican origin, is currently in the United States on an E-2 investor visa and thus filed the I-526 application with our office. The Approval response was received from the United States Citizenship and Immigration Services (USCIS), within four (4) weeks of the date that the initial application was submitted to USCIS, with no Request for Further Evidence (RFE).
The basis for this quick turnaround was the familiarity of the USCIS with the established and proven Regional Center and the well prepared and documented application.
We wish to congratulate our attorneys Mrs. Lea Dimitri and Ms. Tania Sibonney, who worked hard to gain this wonderful result as well as the firm’s legal and administrative team who was also very prolific and meticulous in the preparation of the application.
We remain optimistic that USCIS will improve on its performance levels as time goes on and will ultimately implement premium processing which will greatly enhance the program.
For more information please feel free to contact our offices at 954 524 8888 or via email email@example.com
Media Release: March 14th, 2012
EB-5 – Getting Granular: The who, what, where, when, and how of mid-level financing ($5- $20million) using the EB-5 platform.
PRESENTERS: Larry J. Behar – EB-5 Immigration Attorney, Behar Law Group
Mathew “Matt” Johnston – 3K Strategies
Jenny Massey – Bingham Economics
DATE: Wednesday, March 21, 2012
VENUE: Maggiano’s Little Italy Restaurant
111 West Grand, Chicago, IL
TIME: 10.00am – 11.30am
Participation Fee: $25.00
RSVP : firstname.lastname@example.org
Media Release: March 2nd, 2012
Mr. Larry Behar, Senior Attorney of the Behar Law Group, has just returned from an EB-5 Convention in Shanghai, China. Organized by the Artisan Business Consultants Group and Wailian Overseas, the two day event which was hosted at the Portman Ritz-Carlton Hotel was extremely successful in terms of domestic EB-5 interest and attendance. Both days were heavily attended and numerous contacts were made with agents, investors, other regional centers and projects. The firm reserved a private suite for consultations.
In addition to BLG’s host the New Energy Horizons Regional Center, the group had no less than four other regional center success stories represented at the event. Extell New York Regional Center reported construction on its International Gem Tower is nearing the top at 33rd floor in Manhattan. Manhattan Regional Center has sold out its first project, a Marriott Hotel next to the Jacob Javits Convention Center in New York and is soliciting for an assisted living facility. Riviera Pointe Holdings Regional Center located in Florida also benefitted from the significant exposure, this regional center already has its first round of I-526 approvals. China City of America began its first soft marketing to a huge audience where Mr. Behar was guest speaker along with President Sherry Li. Finally, Mr. Behar welcomed a surprise visit from F & T Builders of Flushing, New York, builders of the 70 story World Trade Center in Nanjing, along with a representative of the Rockefeller Group.
As anticipated, the Canadian Immigration Investor Program (CIIP) has imploded. As such, aside from Quebec, there is no more migration to Canada under this vehicle. The Australian program has also ceased and the UK alternative is complex, making the US EB-5 program extremely desirable with a perpetual well of investors. Agents continue to play a primary marketing role with a local presence useful in key cities. As the EB-5 program matures, confidence in the ability of the US government to harness the high degree of capital and job creation through EB-5 will be a boon to the US economy.
Amongst added value contacts made, BLG has established protocols with the following: one of China’s major law firms with 1700 lawyers; a Canadian law firm with reach throughout China and Vietnam; developed a relationship with Citibank; the World Trade Council in Shanghai, and a highly reputable French law firm with a strong Chinese domestic client base. Mr. Behar was also able to negotiate use agreements for new projects within existing regional centers and continue on the path of certification of the firm by the Chinese government. Accounting firm Marcum Rachlin, LLP also had a strong presence at the seminar, and has developed an alliance with NEH for source of funds analysis for their investors, through its four offices in China. NEH obtained its first round of qualified investors.
Finally, BLG Express partner, Matt Johnston and his associate Jeff Whipple, were present for the entire weekend to assess transactions in the standalone direct employment context, of which there were many. Through the use of an EB-5 vertical integration design and Mr. Johnston’s 20 year relations in China, the firm will be able to introduce investors to smaller projects below $20Mln and to client regional centers.
Mr. Behar leaves for Hawaii March 6 to confer with government and business leaders on solar energy projects throughout the islands. In conjunction with new solar panel manufacturers and expert advisory support, BLG has begun to harness energy sources globally utilizing new technologies for its clients. In addition, through its capital markets connections, the firm has organized a $100Mln commitment for an EB-5 project utilizing a self supporting 25 year bond coupled with a 20% EB-5 component, all favorable terms meeting the strictest requirements of agents and investors.
The firm also began preliminary investor reconnaissance for new clients in the resort industry in New Jersey and the manufacturing industry in Ohio where the BLG team will travel to attend the opening of a future EB-5 facility. The firm continues its commitment to formation of regional centers within 90 days as ably supported by the home team of attorneys Mrs. Lea Dimitri and Ms. Tania Sibonney.
Thank you to our clients who make all of these exciting and productive events happen. Should you have any specific questions please contact us at: email@example.com.
Media Release: February 6th, 2012
The Behar Law Group is pleased to announce New Energy Horizons(“NEH”) Regional Center’s participation at the upcoming “Invest in America 2012 Summit and Exhibition”. The Summit and Exhibition is being held from February 25-26, 2012 at the Portman-Ritz Carlton Hotel, in Shanghai, China. NEH will be present at the Exhibition and can be found at Booth A-14, please feel free to visit their booth for more information.
Members of New Energy Horizons’ Senior Management will be available to meet with you: Mr. Thomas Yee, Chairman/CEO; Mr. Chih Ming “Jimmy” Chuang, President/CIO; Mr. Larry J. Behar, Behar Law Group & Chief Legal Counsel to New Energy Horizons’, along with Mr. Jeffrey B. Carr, President & Economist, Economic & Policy Resources, Inc.; Mr. Ronald Fieldstone, Attorney & Partner, Arnstein & Lehr LLP; and Mr. David Appel, CPA & Senior Partner, Marcum LLP. The latter three will be Key Speakers at the Summit and will be available to meet and discuss investment options in NEH Regional Center. A private Executive Meeting room at the Portman-Ritz Carlton Hotel has been reserved beginning on Friday, February 24th thru Sunday, February 26th, 2012.
Media Release: January 23, 2012
Mr. Larry J. Behar, Senior Attorney of the Behar Law Group, takes pleasure in announcing a strategic alliance with two new value added partners, Ms. Jenny Massey, Director of Operations of Bingham Economic, and Mr. Mathew ‘Matt’ Johnston, Principal of 3K Strategies, both of Indianapolis, Indiana.
In response to market demand, Mr. Behar has created EB 5 Express which will allow U.S. developers with requirements in the $5Mln – $15Mln range to utilize a direct non regional center standalone structure for foreign investors seeking U.S. residency and a greater participation in the investment project.
Investors and Project can expect:
- fast turnaround legal structuring;
- no need for creation of regional center;
- application of direct jobs only;
- faster filing time of I-526 application;
- limited number of investors;
- same family benefits.
Ms. Massey, an expert in federal, state, county and local incentives will provide valued capital to developers seeking to diversify their capital stack. Mr. Johnston, an expert in global marketing of U.S. products, will provide a valuable bridge for foreign investors and the U.S. EB-5 market.
As U.S. banks are not expected to be able to service the needs of the market for capital in the foreseeable future, this strategic relationship has been welcomed across the U.S. and Asia as a triple win scenario.
Media Release: January 20, 2012
Mr Larry J. Behar, Senior Attorney of the Behar Law Group takes pleasure in announcing TODAY the online launch of its new up to date state of the art website.
This new and dynamic site contains information that will assist Developers, Investors, Agents, and other interested parties in learning about the EB-5 program and the many benefits it provides. The site will reflect the most up to date news in the EB-5 realm.
We also take this opportunity to introduce a special section called the EB-5 Express which specifically applies to Project Developers of any size who are interested in developing small to medium sized transactions.
While the site is now only available in English, we are currently working on versions of Mandarin, Spanish and Russian that will also be available in the near future.
Please visit us on Facebook and Twitter and leave us your comments.
Media Release: January 13, 2012
Mr. Larry Behar, Senior Attorney of the Behar Law Group, will be attending the Wailian Conference in collaboration with the Artisan Business Group at the Ritz Carlton Hotel, Shanghai, China from February 22-28, 2012. He will also be introducing his new book in the mandarin language: “Eb-5 United States Immigration through Investment“, the English version is already well received by all in the EB-5 community.
This is a unique opportunity for investors, developers, qualified agents and professionals to meet with Mr. Behar, a leading advocate of the U.S. Eb-5 program, both regional center and standalone projects.
Mr. Behar will be accompanied by New Energy Horizons (NEH) principal Mr. Thomas Yee. NEH was recently approved by USCIS as a Regional Center and is ready to accept investors.
Kindly schedule your appointment by contacting : Hailing Chen firstname.lastname@example.org or Nikki Sankar at email@example.com
Media Release: January 12, 2012
Regional Center Update
On the heels of seven previously approved EB 5 regional centers, the Behar Law Group has once again successfully had approved the Extell New York Regional Center in New York, New York and New Energy Horizons Regional Center in Santa Clarita, California.
“The EB 5 program is a congressionally mandated job creation platform which affords high net worth foreign nationals the opportunity to immigrate to the United States by creating ten jobs per investor family while stimulating the economy. With hundreds of millions of dollars and thousands of US jobs at stake, this program is a natural win/win proposition benefitting the US economy.” Behar said.
The firm has already attained considerable notoriety in the EB 5 marketplace, a concentration of US immigration law. With three precedent decisions at the Lake Buena Vista Resort Village & Spa Regional Center in Orlando, the firm has already received numerous investors at the $500,000 level in five months which includes the investor, spouse and minor children under the age of 21.
“The investors need to be accredited first, have no criminal record and have a net worth of no less than one million dollars” added Hailing Chen, a Chinese born EB5 Specialist and member of the Behar Law Group. “With these qualifications, investors can aspire to receive their conditional green cards within eight months.”
“Developers will do what they do best with either equity or loan structures” stated Ronald Fieldstone, a corporate and securities lawyer who is a pivotal member of the EB 5 Dream Team. “The infusion of capital puts construction workers back on the job and US workers back into full time employment”.
The EB 5 program has been designed to help rural areas or high unemployment areas of the US. However, some experienced economists have identified pockets of high unemployment in virtually every part of the country thus allowing the program to flourish. The Behar Law Group has also been instrumental in the actualization of the Idaho State Regional Center in gold mining and resort development, and Gold Coast Regional Center in south Florida in a mixed use hotel and retail development, the projects requiring $60 million and $140 million respectively.
“We are entering an era where the world today is flat”, Behar said. “There are no more barriers to communication or information. The United States, long sheltered and competing for foreign capital attraction, has come of age with the long awaited maturity of the EB 5 program.”