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Form I-924A
Best Practices
(Post-RIA aware)
Quick context: Historically, Form I-924A was the USCIS Annual Certification of Regional Center. The EB-5 Reform and Integrity Act of 2022 (RIA) introduced Form I-956G as the current annual statement. Many operational disciplines from I-924A still apply one-for-one under I-956G. The guidance below focuses on annual reporting best practices that satisfy the spirit and detail of I-924A—and map cleanly to post-RIA obligations. In practitioner shorthand you’ll sometimes see it written as I-924a; always follow the latest instructions for the form currently required, and the conventions in USCIS I-924A guidance where applicable.
1) Treat The Annual Filing As A Year-End Audit, Not A Form
Whether you’re finalizing I-924A (legacy) or I-956G (current), run a formal year-end close before you open the form:
- Freeze dates: lock the reporting period and list all NCEs/JCEs within the center’s geographic and industry scope as of the close.
- Data owners: designate a single point of contact for each data domain—investor ledger, bank/custody, jobs/economist, construction/operations, immigration counsel.
- Evidence index: maintain a master index mapping each form field to the underlying artifact (bank statements, fund-admin reports, economist updates, USCIS notices).
- Variance log: document changes from last year’s filing (scope, methodology, project status, promoter rosters), with a short “why/how resolved” note.
2) Build Investor And Capital Ledgers That Reconcile Forward And Backward
USCIS expects totals that foot cleanly across investors, dollars, and projects.
- Investor ledger: show per-investor amounts subscribed, escrow release dates, redeployments, refunds, and current status (active, withdrawn, denied, transferred).
- Capital flow: reconcile sources & uses from NCE to JCE with bank proofs or fund-administrator certifications—each draw tied to a budget line.
- Timing sensitivity: align the ledger’s as-of date with the reporting period; avoid mixing subsequent-year disbursements into a single figure.
- Triangulation: investor headcount ↔ total capital ↔ job creation basis must cross-check. Update all three if one leg changes, and annotate.
3) Job Creation: Align Model, Spend, Schedule—Then Show Your Buffer
Annual reports live or die on job evidence discipline.
01
Methodology
state the model (RIMS II, IMPLAN) and the exact version/vintage used; note changes and their impact.
02
Qualifying spend
tie hard/soft costs used for multipliers to draw approvals and invoices; exclude non-qualifying categories and document why.
03
Schedule
include a Gantt or milestone table showing when spend occurs and when jobs accrue inside the eligibility window.
04
Buffer
publish jobs per investor under base case and stress (e.g., 10–15% overrun or quarter-length delay).
4) Geographic And Industry Scope: Prove You Stayed Inside The Fence
I-924A asked whether activity occurred within the approved geography and NAICS scope.
- Project roster: list each active project with NAICS codes, address, county/MSA, and in-scope status.
- Maps/certifications: add a simple boundary map; affix TEA/rural certifications with effective dates.
- Material change log: if the center expanded scope (or a project changed), identify the filing vehicle and receipt numbers.
5) Immigration Metrics: Count Exactly What USCIS Counts
Report petition activity by form type and by project for the period and cumulatively:
- I-526 / I-526E: filed, approved, denied, withdrawn; RFEs/NOIDs issued/resolved.
- I-829: filed, approved, terminated/denied, pending; track per cohort.
- Derivatives: reflect household effects as requested while keeping investor headcounts precise.
6) Third-Party Fund Administration And Promoter Controls
Post-RIA integrity rules expect clear controls; legacy I-924A filers benefit from the same rigor.
- Fund-admin attestations: obtain a year-end letter describing mandate scope (dual-signature, invoice matching, KYC) and any exceptions.
- Bank letters: confirm account titles, authorized signers, and month-end balances for NCE/JCE accounts.
- Promoter registry: maintain a current list of compensated third parties with agreements and disclosures; certify marketing consistency with filed facts.
7) Redeployment Policy: Write It Down, Follow It, Evidence It
If redeployment occurred or may occur:
- Policy summary: include the written policy (triggers, asset criteria, risk limits, decision rights, investor notice, reporting cadence).
- Transactions: show proceeds flow, custodian records, and confirmations; explain how each redeployment maintains “capital at risk.”
- Alignment: confirm consistency with offering documents and consents.
8) Internal Controls And Compliance Attestations
Close the loop with governance artifacts:
- Annual compliance memo (counsel/compliance lead): scope adherence, records retention, promoter disclosures, marketing review.
- Records policy: retention periods, file taxonomy, access controls.
- Incident log: data discrepancies, late filings, complaints—plus corrective actions.
9) Presentation: Make It Easy To Read And Verify
- One document, three parts: (A) executive summary (dates and totals); (B) data tables (investors, capital, jobs, petitions); (C) evidence index with filenames.
- Consistent totals: page-1 numbers equal the sums in tables and attachments.
- File hygiene: stable PDF naming, internal bookmarks, legible scans.
10) Deadlines, Editions, Signatures, Fees, Addresses
These change. Avoid unforced errors:
- Edition/date: confirm the current form edition before drafting.
- Signature: verify the proper signatory and ink/e-signature rules.
- Fee & address: check fee schedule and lockbox/online pathway the day you file.
- Cut-off: calendar the statutory deadline and an internal QC deadline two weeks earlier.
If you still maintain legacy processes, ensure your internal checklists work equally well if your team refers to them as I-924a procedures.
11) QC Checklist (use before you hit submit)
- Investor counts reconcile to capital and job totals.
- Each project lists NAICS, location, status; scope documented.
- Job model vintage/inputs identified; buffer shown under stress.
- Bank/fund-admin proofs match draw schedule and uses of proceeds.
- Petition tallies match counsel’s receipts/approvals at the reporting cut-off.
- Promoter roster current; disclosures/agreements on file.
- Redeployment policy and transactions (if any) fully evidenced.
- Editions, fee, signature, and address confirmed same-day.
- Evidence index cross-references every datapoint in the form.
Have a reviewer who did not prepare the figures run this checklist before you finalize your I-924a packet.
Common Pitfalls—And How To Preempt Them
- Mismatched totals (investors vs. dollars vs. jobs).
- Fix: maintain a single reconciliation workbook and lock it after sign-off.
- Job modeling drift (silent multiplier changes).
- Fix: log model vintage; annotate year-over-year effects.
- Scope ambiguities (county line/NAICS reclassification).
- Fix: provide maps, code rationales, and—if needed—filed amendment evidence.
- Bank evidence gaps (pooled statements, no project-level proof).
- Fix: obtain sub-account statements or fund-admin confirmations per project/draw.
- Immigration metrics lag (CRM snapshot vs. counsel records).
Fix: reconcile to counsel’s receipts/approvals list as of the cut-off.
A One-Page Executive Snapshot You Can Copy
Executive Snapshot (FY ____)
- RC ID / EIN / Reporting period: ________
- Projects active (period):________
- Investors (period / cumulative): ________ / ________
- Capital deployed (period / cumulative): $____ / $____
- Jobs credited (model + vintage): __ (RIMS II 20xx); buffer: __ jobs/investor base; __ under stress
- Petitions (period / cumulative): I-526E filed /, approved /, denied/withdrawn / ; I-829 filed / , approved /
- Scope adherence: in-scope counties/NAICS; changes filed: Y/N (details attached)
- Fund-admin/controls: provider, mandate summary, exceptions: none/minor (attached)
Bottom Line
If you approach I-924A (and today’s I-956G) as an audit-ready annual report—tight ledgers, documented job math, scope discipline, verified capital flows, and clean petition metrics—your submission will read as credible, consistent, and complete. That, more than anything, shortens review cycles and reduces avoidable follow-up—regardless of whether your internal playbooks still refer to the legacy I-924a label or the current form naming.
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