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USCIS sees a lot of these projects, and I see them too.If I see a million building, and I go back to the people and say, "How could you possibly justify that this will be built in 2½ years when my other projects are being built in 16 months?
Phil: I assume you're talking about having proper assumptions in the business plan, which ultimately drive the numbers.
First of all, USCIS' directive is that inferences should not be conveyed as conclusive assumptions.
Do you find that this is a minor issue or is this something that USCIS takes very seriously? A key requirement is consistency between the business plan, which ultimately supports the assumptions that go into the pro forma, and the feasibility study.
At the very least, if there are differences between the feasibility study and the pro forma, especially if you are using revenues as an input into the economic model, the differences should be justifiable.
You don't even have that many people around." I thought there was a problem with the case because Carson City's not far from Reno, so maybe they would be commuting.
Also, I see a lot of developers try to get over the 2-year development period to get the boots on the ground construction jobs.
The ‘Matter of Ho’ is a precedent decision that just says that an extremely detailed business plan is needed in an EB5 undertaking, and it describes all the components.
If one is submitting a I-526 petition or an Exemplar I-924, a ‘Matter of Ho’ compliant business plan is required.
It can be quite a challenge; they may go through one reiteration of the documents after another to ensure that one particular number in one document is not inconsistent within another document.
It's also very important to read all the documents with common sense.