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Guidelines for EB-5 Investments

In A Regional Center
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Prepared for Internal Corporate Use Only

Effective Date of Analysis: January 15, 2012

California International Regional Center

9460 Balboa Boulevard
Northridge, California 91325
The Purpose of this Guideline Report
This report is being prepared to help guide a prospective investor through the requirements of becoming an
investor in a Regional Center under the United States Citizenship and Immigration Service pilot program for
investment based visas under the fifth preference for immigration commonly known as the EB-5.

The EB-5 program has become a popular tool for investors wishing to come to the United States and for
business in the Unites States seeking capital. The program has also become popular among brokers and
middlemen who are seeking the sale of EB-5 investments for profit and as a result there are many
programs, promises, and details that could confuse an investor. An investor must look at the facts and the
actual EB-5 requirements and follow the government guidelines in order to succeed in protecting his or her
money and getting a green-card.

The Facts:

The EB-5 program was implemented in 1993 and was not used very aggressively until 2009. Over
the past 20 years; by 2010, there were approximately 13,719 EB-5 visas petitioned and of those only
8,382 were approved for processing. From the petitions that were approved 5,748 have invested
long enough to seek permanent resident status (having made their investment more than two years
ago). From the qualifying petitions; only 3,127 petitioners have been approved and are now
permanent United States residents. 1,431 have left the investment program and another 1,190 had
their permanent designation denied. There are currently 2,634 approved petitions that are awaiting
maturity. In 2011, an additional 3,805 new petitions were submitted for processing.

The vast majority of investors into the EB-5 program came from Asia; where 80.2% of the petitions
originated, 13.5% originated from Europe, 3.1% came from North America, with the remaining 3.3%
coming from South America, Africa and the Pacific regions.

The number of Regional Centers also grew dramatically from 2007. There were 11 approved
Regional Centers in 2007; 72 approved Regional Centers by 2009; and 174 approved Regional
Centers by 2011. This growth in activity makes the choice of the right Regional Center and the right
business very important.

The numbers show that an investor should only invest where they have a personal knowledge of the
business and get to know the operators of a Regional Center. This familiarity is important because the
investment must be sustained for up to five years for the investor to get all of the benefits that are sought.
This includes the protection of the investor’s capital as well as the creation of jobs.

This report will explain some of the most important items in preparing the investment so that the investor
petition is accepted and the permanent visa is obtained.

The Contents of this Guideline Report

To help an investor make the right decision and properly document the investment the following items are
presented:

The Authority to Make an Investment and Obtain a Green-Card

How to Document the Investment Money to Meet USCIS Requirements

How to Transfer Money From China

The Process of Making an Investment

Issues for Chinese Investors to Consider

The Authority to Make an Investment and Obtain a Green-Card
The law is very specific for an investor wishing to invest in the United States in order to gain a United States
Immigrant Visa; known as a green-card. The process is not difficult but needs to be very well documented
and the procedures followed very closely. The law classifies the investor as an Alien Entrepreneur1.

An Alien Entrepreneur is an investor who invests at least $500,000.00 into a Regional Center in the United
States where the business results in the creation of ten (10) jobs. The technical language states that the
Alien Entrepreneur makes an Investment of Capital in a New Commercial Enterprise2.

The investment must actually be made and placed at-risk and the Alien Entrepreneur must show that it is
his or her actual money that is invested. The Alien Entrepreneur must provide evidence of an actual
investment and where the investment funds came from3.
___
1. When a petitioner seeks classification as an alien entrepreneur pursuant to §203(b)(5) of the Immigration and Nationality Act (the Act), 8
U.S.C. 1153(b)(5) based on an investment in a new commercial enterprise.

§ 203(b)(5)(A) of the Act provides classification to qualified immigrants seeking to enter the United States for the purpose of engaging in a
new commercial enterprise:
(i) in which such alien has invested (after the date of the enactment of the Immigration Act of 1990) or, is actively in the process of
investing, capital in an amount not less than the amount specified in subparagraph (C), and
(ii) which will benefit the United States economy and create full-time employment for not fewer than 10 United States citizens or
aliens lawfully admitted for permanent residence or other immigrants lawfully authorized to be employed in the United States
(other than the immigrant and the immigrant's spouse, sons, or daughters).

2. 8 C.F.R. § 204.6(e) states, in pertinent part, that:

Capital means cash, equipment, inventory, other tangible property, cash equivalents, and indebtedness secured by assets
owned by the alien entrepreneur, provided the alien entrepreneur is personally and primarily liable and that the assets of the new
commercial enterprise upon which the petition is based are not used to secure any of the indebtedness. All capital shall be valued at fair
market value in United States dollars. Assets acquired, directly or indirectly, by unlawful means (such as criminal activities) shall not be
considered capital for the purposes of section 203(b)(5) of the Act.
Commercial enterprise means any for-profit activity formed for the ongoing conduct of lawful business including, but not limited
to, a sole proprietorship, partnership (whether limited or general), holding company, joint venture, corporation, business trust, or other
entity which may be publicly or privately owned. This definition includes a commercial enterprise consisting of a holding company and its
wholly-owned subsidiaries, provided that each such subsidiary is engaged in a for-profit activity formed for the ongoing conduct of a lawful
business. This definition shall not include a non-commercial activity such as owning and operating a personal residence.
Invest means to contribute capital. A contribution of capital in exchange for a note, bond, convertible debt, obligation, or any
other debt arrangement between the alien entrepreneur and the new commercial enterprise does not constitute a contribution of capital for
the purposes of this part.
New means established after November 29, 1990.

3. 8 C.F.R. § 204.6(j) states, in pertinent part that:

(2) To show that the petitioner has invested or is actively in the process of investing the required amount of capital, the petition must
be accompanied by evidence that the petitioner has placed the required amount of capital at risk for the purpose of generating a return on
the capital placed at risk. Evidence of mere intent to invest, or of prospective investment arrangements entailing no present commitment,
will not suffice to show that the petitioner is actively in the process of investing. The alien must show actual commitment of the required
amount of capital. Such evidence may include, but need not be limited to;
(i) Bank statement(s) showing amount(s) deposited in United States business account(s) for the enterprise:
(ii) Evidence of assets which have been purchased for use in the United States enterprise, including invoices: sales receipts; and
purchase contracts containing sufficient information to identify such assets, their purchase costs, date of purchase, and
purchasing entity;
(iii) Evidence of property transferred from abroad for use in the United States enterprise, including United States Customs Service
commercial entry documents, bills of lading and transit insurance policies containing ownership information and sufficient
information to identify the property and to indicate the fair market value of such property;
(iv) Evidence of monies transferred or committed to be transferred to the new commercial enterprise in exchange for shares of stock
(voting or nonvoting, common or preferred), Such stock may not include terms requiring the new commercial enterprise to
redeem it at the holder's request; or
(v) Evidence of any loan or mortgage agreement, promissory note, security agreement, or other evidence of borrowing which is
secured by assets of the petitioner, other than those of the new commercial enterprise, and for which the petitioner is personally
and primarily liable.
(3) To show that the petitioner has invested, or is actively in the process of investing, capital obtained through lawful means, the
petition must be accompanied, as applicable, by;
(i) Foreign business registration records;
(ii) Corporate, partnership (or any other entity in any form which has filed in any country or subdivision thereof any return described
in this subpart), and personal tax returns including income, franchise, property (whether real, personal, or intangible), or any
other tax returns of any kind filed within five years, with any taxing jurisdiction in or outside the United States by or on behalf of
the petitioner;
(iii) Evidence identifying any other source(s) of capital; or
(iv) Certified copies of any judgments or evidence of all pending governmental civil or criminal actions, governmental administrative
proceedings, and any private civil action; (pending or otherwise) involving monetary judgments against the petitioner from any
court in or outside the United States within the past fifteen years,
How to Document the Investment Money to Meet USCIS Requirements
For an investor making an investment into a Regional Center for purposes of gaining an EB-5 immigrant
visa, known as a Green-Card, there are two items that must be proven; (i) that the investor is a qualified
investor and meets the technical standards and the government definition of an investor, and (ii)
documenting the source of the investment funds.

The investor will not obtain the EB-5 visa if the USCIS is not satisfied that the source of funds is legitimate
and that the funds actually belong to the investor. The investor must prove with evidence that shows where
the money came from and how it belongs to the investor1.

The investor cannot simply provide a bank statement that shows the funds are in his or her account 2. The
investor must show the origin of the funds that are being presented.

The following examples will highlight the extent of the documentation that is required:

If a bank account shows the funds to be used for the investment:

The source of the funds must be shown; you must show all incremental deposits over a period of
time or the source of any wire or transfer used to move the money into the investment account from
the following sources:
a. If from earned income; you must show enough tax returns (at least five years) that prove you
had a level on income to provide for your family; your lifestyle and have enough left to
invest so that the investment amounts equal the amount in your bank.
b. If from the stock market you must show the growth in the account from stock buying and
selling as well as the source of the original money you put into the account to start the
investing account.
c. If from a business activity, you must show at least five years of business tax records;
licenses and permits and how you were paid from the business so that you earned enough
to provide for your family; your lifestyle and have enough left to invest so that the investment
amounts equal the amount in your bank.
d. If from the sale of assets; you must provide the documents that show how you acquired the
assets and documenting the sale of the assets.
e. If from the sale of real estate; you must show that you were the legitimate owner of the real
estate and the documents relating to the sale of the real estate (escrow documents and
closing statement with the tracing of the funds from the escrow to the bank account).
f. If from a loan; you must show the mortgage documents from real estate borrowing and if
a personal loan you must show where the lender obtained the funds to loan to you.
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1. In Matter of Soffici, the Service reversed the certified approval of an alien entrepreneur visa petition in part because the petitioner failed to
demonstrate that he had invested the requisite amount of capital obtained by lawful means. (See Matter of Soffici at page 6.) In Matter of
Ho, the Service found that the petitioner did not meet the burden of establishing the source of funds simply by submitting bank statements
showing deposits, a letter indicating the number and value of shares of capital stock held by the petitioner in a foreign business, or
documents which show someone else as the legal owner of capital. (See Matter of Ho.) Additionally, in Matter of Izumii, the Service found
that the petitioner did not meet the burden of establishing the source of funds by simply submitting a bank letter stating that the funds had
been deposited: "As the petitioner has not documented the path of the funds ... the petitioner has failed to meet his burden of establishing
that the [funds] were his own funds." (See Matter of Izumii at page 26.) Simply going on record without supporting documentary evidence
is not sufficient for purposes of meeting the burden of proof in these proceedings. See Matter of Treasure Craft of California 14 I&N Dec.
190 (Reg. Comm. 1972):
(2) The petitioner must establish that he has placed his own capital at risk, that is to say, he must show that he was the legal owner
of the invested capital. Bank statements and other financial documents do not meet this requirement if the documents show
someone else as the joint owner of the capital.
(3) The petitioner must also establish that he acquired the legal ownership of the invested capital through lawful means. Mere
assertions about the petitioner's financial situation or work history, without supporting documentary evidence, are not sufficient
to meet this requirement.

2. A petitioner cannot establish the lawful source of funds merely by submitting bank letters or statements documenting the deposit of funds.
Matter of Ho, 22 I&N Dec. at 210·211; Matter of Izummi, 22 I&N Dec. at.. 195. Without documentation of the path of the funds, the
petitioner cannot meet his burden of establishing that the funds are his own funds. Id. Simply going on record without supporting
documentary evidence is not sufficient for the purpose of meeting the burden of proof in these proceedings. Matter of Treasure Craft of
California, 14 I&N Dec. 190 (Reg. Comm. 1972). These "hyper-technical" requirements serve a valid government interest: confirming that
the funds utilized are not of suspect origin. Spencer Enterprises. Inc. v. United States, 229 F. Supp. 2d (affirming a finding that a petitioner
had failed to establish the lawful source of her funds due to her failure to designate the nature of all of her employment or submit five
years of tax returns).
How to transfer money from China
For an investor who wants to make an investment into the United States using a Regional Center and
getting the benefit of a green-card there is an issue with how to make the investment from China into the
United States. There are government restrictions on the amount of US dollars or foreign currencies that a
Chinese citizen can transfer overseas each year (this is limited to $50,000.00 per person). In response, the
Chinese investment community has developed several ways to make investments out of China.

These include the following:

1. A Chinese investor may go through the Chinese government; outbound investment petitions have to
be approved by the local Administration of Foreign Exchange. This applies to outbound
commercial investments such as setting-up factories, offices, enterprises, and mergers, among
others. Most people choose not to deal with the government agencies because of the length and
complexity of getting approved and the danger of corruption or red-tape involved in the process.
2. A Chinese investor may set up an offshore bank account in Hong Kong or Macau. Investment
funds are transferred out of Hong Kong for purposes of EB-5 investments. Setting up an account is
relatively easy for a Chinese investor who can open an account with a Hong Kong based bank.
3. A Chinese investor may use the services of a money exchange broker or migration agency.
Some migration agencies work closely with local Bank of China branches to assist clients in
transferring funds overseas. However, many Chinese citizens choose to do it privately by
themselves. Opening a bank account in Hong Kong is the most popular and practical way for
Chinese investors who want to transfer money for the purpose of EB-5 investment.
4. A Chinese investor may transfer the investment to someone in Hong Kong who will then transfer the
funds to make the investment in the EB-5 or the investor may give the maximum amount
($50,000.00) to several people who then transfer the money directly out of China to make the
investment in the EB-5.
5. A Chinese investor may use an Informal Money Transfer System (“IMTS”). This is a well
established undocumented deposit, withdrawal and transfer system in China that is used as an
alternative to the banking system. It is a trust-based ancient system with no paper trail that operates
outside of the government’s control. It is known as fie ch’ien (“flying money” or “coin”) in China and
hui kuan in Hong Kong. In addition to the fie ch’ien method of transfer, there is the chit and chop
methods where a “receipt” is given in the location of sending the money transfer and it is redeemed
at the location of receiving the money transfer.
6. A Chinese investor may use an Informal Value Transfer System (“IVTS”). This is similar to the
informal money transfer system but instead of money, the investor acquires and sends products
such as inventory, prepaid calling, debit, credit cards or other items of value or barter.

A diagram of the various systems

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How the fei ch’ien system works:

The fei ch’ien (means “flying money or coin”) system of money remittance evolved during the latter half of the T’ang Dynasty (618-907 AD) as a
result of the growing commodity trade within China. During that period, merchants from the southern part of China sold their tea and other goods at
the Capital and transferred their revenues from the sales to “memorial offering courts” (liaison offices or agencies of provincial governments located
at the Imperial Capital) where these revenues were used to pay taxes due from these provinces to the central government. These “courts” issued
certificates indicating amount paid by the merchants who, upon their return, would present them to the provincial governments for payment of an
equivalent sum of money. The fei ch’ien system was thus a convenient means of exchange, sparing the merchants and couriers of the provincial
governments the inconvenience and risk involved in transporting money physically over long distances. This system enabled money to “move“
instantaneously from the capital to the provinces. In addition, as the Chinese began to migrate to many parts of the world, a split family system
developed, featuring one part that stayed back home and another that took up residency abroad. This split family system was held together by a
strong bond, which was characterized by the continued flow of remittances from the expatriate unit in support of the family that stayed in China. The
expatriate families with stores (like gold shops) soon dominated the business of transferring money from abroad to China. The remittance system
that developed as a result of the demand to send money back home was the precursor to the early banking services in China. For instance, in the
Shansi Province during the Ch’ing Dynasty (1644-1911), banks were originally a system to transfer money safely between locations. These
operations, initially run by families, soon expanded outside provincial borders to cover the whole country. Branches were opened in cities where the
families had business interests and issued drafts, similar to present-day travelers checks. Later, other forerunners of the modern bank, such as silver
shops, clearinghouses, and money exchangers sprouted and competed with the Shansi “banks”. With the advent of Chinese emigration in the
nineteenth century, the fei ch’ien system became “internationalized”. The “within-the-family” structure of the remittance process offered the added
advantage of privacy in the transactions and many clients would use the system to shield their income from the heavy tax burdens imposed by some
governments on the ethnic Chinese.

Other remittance systems

A variant of the fei ch’ien systems is the chit system. Chit is a diminutive of the Hindi word, chitti, and means a note, pass or certificate given to a
servant. In the chit system, the salaries of British workers were deposited to an escrow account managed by a Chinese comprador. These foreign
workers would write chits to pay for food and other essentials that they purchased from local merchants. In turn, the merchants would present these
chits for payment to the comprador, who would then deduct the amounts from the accounts of the foreign workers. The chit system offered safety
and convenience since foreign workers did not have to carry around cash, silver ingots or commodities, to use as payment for their purchases. The
chop system works the same way as the hawala system and is still in use today. A client in Country A wishing to remit money to a recipient in
Country B would come to a “broker” at a store or outlet who will take the cash, make an entry into a ledger book for the amount received and
communicate the relevant information about the transaction (amount to be remitted, name and location of recipient, etc). The “broker” will also create
a chop (in this situation, possibly a train ticket or play card), tear it into two pieces, give one piece to the client and send the other piece to his
counterpart broker in Country B. The client sends his half of the chop to the recipient. A match of the two halves will be made before the broker
releases the money to the recipient. Transactions involving the transfer of goods usually entail the use of seals (which would be broken in two
pieces) and generally follow the procedures described above in the remittance of money. A commission fee is charged the client for the service. The
hawala system makes comparatively less use of negotiable instruments since the components that drive its operations are the element of trust and
use of ethnic or family connections. Some remittance systems, like those operating in Hong Kong, and the Chinese and Vietnamese systems in
Australia, require that the entire sum to be remitted be given before the transaction takes place. Also, Chinese IMTS is mostly one directional (to
China), while the South Asian systems are bi-directional. To restore balance in the books of the Chinese remittance systems, it is thought that
conventional banks and wire transfers are used to send money back to China.
The Process of Making an Investment
In order to accommodate the appropriate number of investors and to ensure that each investor is
appropriate for an investment in the Regional Center, the following process must be followed prior to the
acceptance of an investor by the Regional Center and the submission of an immigrant alien petition for the
issuance of an EB-5 based visa.

To properly evaluate the investors who will work with the Regional Center and prepare adequate petitions;
four items will need to be obtained; (i) a letter of intent to invest, (ii) evidence of the money, (iii) the source of
the money, and (iv) the investment or indication of the intent to invest.

Specifically:

1. An investor must review the Regional Center investment and indicate an interest in pursuing
an investment by signing the one page EB-5 Investment Letter of Intent;

a. This is a short letter that states the investor desires to pursue an investment so that
the Regional Center will reserve an investment position and set aside the appropriate
number of jobs for the investment.

2. The prospective investor must fill out the Investor Questionnaire to prove that the individual is
qualified under the United States SEC rules for private investing;

a. The Investor Questionnaire gathers specific information on the investors level of

earnings and types of investment experience;

b. The Investor Questionnaire will set out the required statements that the investor has
the required knowledge to evaluate investments and provides evidence of the
material that the investor has reviewed to evaluate the Regional Center investment.

3. The prospective investor must provide evidence of the capital available for investing;

a. A current account statement showing that at least $500,000.00 is available in the

investor’s name; if the funds are not in U.S. Dollars an attached exchange rate
calculation must be provided (showing an exchange source accepted by USCIS).

4. The prospective investor must trace the funds from their source to the availability for
investing and must properly document the path;

a. All documents showing where the funds originated and how they are attributed to the
investor; if the documents are in a language other than English they must be
accompanied by a certified translation.

Once the investor has been qualified and the funds adequately documented the investor may proceed with
the petition and the submission.

5. The prospective investor must sign the Regional Center subscription agreement;

6. The prospective investor must pay the investment commitment fee to the Regional Center;

7. The prospective investor must fill out the I-526 petition;

8. The prospective investor must move funds into the Escrow Bank or the Holding Institution
(Law Firm or other entity).
Issues for Chinese Investors to Consider
For an investor who wants to make an investment into the United States using a Regional Center and
getting the benefit of a green-card there are many factors that must be considered. For each investor there
are two main decision points; the amount of the investment is never insignificant and the protection of the
investment is a major decision point; additionally, obtaining a green-card is the primary reason for making
the investment and obtaining the ultimate permanent residency is a major decision point.

I. Some of the general issues in EB-5 investing include:

Investing outside of China is considered a safety tool for many wealthy Chinese. The Bank of
China and Hurun Rich List estimated that there were 960,000 people with "personal assets" of at
least 10 million yuan, and 60,000 people with 100 million yuan or more. Their survey, conducted in
May to September of 2011, covered 18 major cities including Beijing, Shanghai, Wuhan, Nanjing,
Dalian and Suzhou, and interviewed respondents with an average age of 42 and average personal
assets of 60 million yuan. The survey showed that 46% of respondents were considering
emigrating, while an additional 14% had either already emigrated or filed immigration applications.
Respondents with assets of 100 million yuan or more were even more inclined to emigrate, with 55%
considering leaving China, and 21% already living overseas or having filed applications. Another
survey published in April by China Merchants Bank and Bain & Co. showed that almost 60% of high-
net-worth individuals in China had either arranged for, or were considering emigration. Of those,
more than 20% had already completed their immigration applications, or made the decision to apply,
according to that survey, which covered 2,600 high-net-worth individuals. The U.S. was the most
popular destination for their investments, accounting for 42%, and property was the most popular
type of investment, accounting for 51%, according to the survey. Regardless of emigration desires
many wealthy Chinese maintain investments internationally; the report estimates that rich Chinese –
those with assets of more than 10 million yuan – have about 3.6 trillion yuan invested overseas.

Holding a United States visa is viewed as social insurance for many wealthy Chinese. As China
becomes more prosperous there is also a yawning gap between rich and poor in China, which feeds
a resentment that makes some of the wealthy uncomfortable. The country's uneven jump to
capitalism over the last three decades has created dozens of billionaires, but China barely ranks in
the top 100 on a World Bank list of countries by income per person. Getting a foreign passport is
like "taking out an insurance policy," said Rupert Hoogewerf, who compiles the Hurun Rich List,
China's version of the Forbes list. "If there is political unrest or suddenly things change in China -
because it's a big country, something could go wrong - they already have a passport to go overseas.
It's an additional safety net."

The United States has superior legal protections for investors when compared to China: (for an
investor, entrepreneurship in the United States is like a zoo and entrepreneurship in China is like a
jungle. In the United States, while there is always a lion next to you with sharp claws, driven by self-
interest, there is a cage between you and the lion to keep you safe. You can count on the cage to
protect you from unreasonable or illegal behavior. In China there is no cage between you and the
lion – if you don’t take great pains to protect yourself from the self-interested behavior of the lion you
are going to get bitten).

The United States has an attractive investment environment because is at the bottom of its
economic cycle and China is at the top of its economic cycle; (an investment in the United States at
this time will control assets that are at a low valuation point and this will result in the investment
growing rapidly when the United States economy begins to grow again). While growth has slowed
somewhat in China during 2011 the countries economic performance is still the envy of the Western
world (China registered annual gross domestic product growth of 9.1% in the third quarter, and the
International Monetary Fund has forecast growth of 9.5% for all of 2011). Concerns are mounting,
however, that China's growth could be derailed by a raft of problems, including high inflation, a
bubbly real-estate sector and a sharp slowdown in external demand. Many Chinese who have
profited most from the country's growth also express increasing concerns in private about social
 issues such as China's one-child policy, food safety, pollution, corruption, poor schooling, and a
weak legal system. A research report from Bank of America Merrill Lynch's strategy team in Hong
Kong in October, 2011, cited "hot-money outflows" as one of four systemic risks that could lead to a
hard landing for China's economy. It said that a sign of such outflows were record gambling revenue
in the gambling enclave of Macau, a former Portuguese colony near Hong Kong, where many
mainland Chinese go to gamble (an indication of money moving out of the system).

Owning a home (or any other real estate) in the United States can be forever and you keep it in
your family for as long as you like; while owning a home (or any other real estate) in China is only for
70 years and then it goes back to the government.

There are no restrictions on the size of a family (how many children an investor has) and there
are no restrictions on travel inside the United States or out of the United States. Under Chinas one
child policy – in place for the last three decades – to control population growth, couples can be
penalized for having more than one child. In Beijing, the penalty is a one-off fee that is 3 to 10 times
the city’s average income, a maximum of 250,000 yuan.

Regular transfers of money out of China become easier as a U.S. resident investor (doing
business as either a Permanent Establishment [PE] or non-Permanent Establishment) than for a
Chinese national: (as a United States resident you can do business in China and benefit from the
foreign expatriation laws without the limit on the amount of money you can take out of China each
year [Chinese nationals cannot take out more than $50,000.00]; you only need to pay the taxes on
the earnings and follow the State Administration of Foreign Exchange rules and pay the taxes to
take the money out).

II. Some of the specific issues in California International Regional Center (“CIRC”) investing include:

The primary owner of CIRC is a successful Chinese businessman who has strong ties to mainland
China and a personal relationship with many of the investors.

CIRC owns the business and the real estate of the project without any debt – so the investment is
considered safe from an equity perspective and investors can be on title to protect their
investment.

The business of the CIRC investment is in senior housing, medical services, and food-services.
These are necessary and core businesses that are considered very important to the United
States and internationally.

The business of CIRC creates many more jobs than are required by USCIS for approval of the
investors visa so the investment is safe from the perspective of jobs creation (one of the most
important review items the government considers when granting a permanent visa).
[end of document]