The Proposed USCIS Regulations Do Not Address Fraud in EB-5 Program
Any and all federal programs are subject to fraudulent actions by small groups of bad actors. It is for this reason that each and every major federal program is accompanied by the delegation of enforcement authorities to the relevant regulator.
USCIS has spent considerable time on restructuring the USCIS program through a series of proposed rulemakings instead of focusing on enforcement. Even if the totality of the USCIS proposed structural changes were to become law they would have virtually no impact on eliminating fraud in the USCIS program. What is the rationale for making structural changes through new regulations a higher priority than enforcing existing regulations?
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If CRE receives a threshold level of comments it will use them in developing a White Paper which will be sent to USCIS.
