Form I-956G
Best Practices
for EB-5 Investors (Post-RIA)
Form I-956G is the annual report that EB-5 regional centers must file with USCIS to keep their designation. It replaced Form I-924A under the EB-5 Reform and Integrity Act (RIA).
RIA stands for the EB-5 Reform and Integrity Act of 2022, a federal law that reauthorized and comprehensively overhauled the EB-5 Immigrant Investor Program. It introduced strict oversight measures, increased investment minimums, and created reserved visa categories for projects in rural or high-unemployment areas. The law also grants unique benefits to investors, such as the ability to concurrently file for adjustment of status while inside the United States.
For potential EB-5 investors, this filing can provide valuable insight into how organized, transparent, and compliant a regional center may be. Regional centers that approach this filing with strong internal review and compliance procedures may demonstrate a higher level of organization and attention to EB-5 program requirements.
What a Regional Center Should Do First
Reliable EB-5 regional centers complete a formal year-end review before filing Form I-956G:
- List all active NCEs and JCEs within their approved scope.
- Assign data owners for investor records, bank statements, job reports, and immigration filings.
- Create an evidence index linking each form answer to supporting documents like bank statements and economist reports.
Clean Investor and Capital Records
USCIS expects numbers that match perfectly across investors, capital, and jobs. Look for regional centers that:
Track each investor’s subscription, escrow release, capital redeployments, refunds, and status.
Reconcile capital flow from NCE to JCE with bank statements
Cross-check investor count, total EB-5 capital, and job creation numbers.
Job Creation Evidence
Job creation numbers are one of the most important parts of the filing. Regional centers should:
- State the exact economic model used (RIMS II RIMS II (Regional Input-Output Modeling System) is an economic model developed by the U.S. Bureau of Economic Analysis. It measures how money spent on a project creates extra jobs in a local area. In EB-5 investments, regional centers use this model to count “indirect jobs” (like builders or suppliers) and “induced jobs” (when workers spend their paychecks nearby) that come from the investor’s capital – not just the direct employees. The model helps prove the 10 jobs per investor needed for the green card. or IMPLAN IMPLAN is considered slightly more modern and flexible as an economic model than RIMS II, as it uses current, proprietary regional data (updated annually) to estimate indirect and induced jobs from a project’s spending. Regional centers enter the project’s construction budget and operating costs, and IMPLAN calculates additional jobs – like suppliers delivering materials or local spending by those workers. )
Link qualifying costs to invoices and draw approvals.
Show a project schedule with spending and job creation timing.
Report jobs per EB-5 investor under normal conditions and stress tests (like 10-15% cost increase).
Proof of Staying Within Scope
Regional centers must show all activity fits their approved geography and industry. They should provide:
A list of each project with NAICS codes, address, and scope status.
Maps and TEA/rural certifications.
Documentation of any scope changes with USCIS filing details.
Accurate Immigration Tracking
Regional centers report EB-5 petitions by type and project:
I-526E: filed, approved, denied, withdrawn; RFEs/NOIDs issued and resolved.
I-829: filed, approved, denied, pending — tracked by investor group.
Third-Party Oversight Proof
Post-RIA rules require strong controls. Regional centers should provide:
Year-end letters from fund administrators describing their role and any issues.
Bank letters showing NCE/JCE account details and balances.
Current promoter list with agreements and marketing approvals.
Clear Redeployment Records
If EB-5 capital was redeployed, regional centers should show:
Written capital redeployment policy covering triggers, allowed assets, and investor notice.
Transaction records proving capital stayed “at risk.”
Alignment with offering documents.
Governance Documentation
Regional centers close with compliance proof:
Annual memo from counsel covering scope, records, promoters, and marketing.
Records retention policy and access controls.
Log of issues and how they were fixed.
Easy-to-Review Organization
The Form I-956G filing should have three clear parts:
Summary: Dates and totals on page one.
Tables: EB-5 investors, EB-5 capital, jobs, petitions.
- Evidence index: File names for every data point.
Filing Details Handled Properly
Regional centers must confirm:
Current form edition, signature rules, fee, and filing address.
Internal deadline set two weeks before the due date (typically December 29).
What EB-5 Investors Should Verify
Before investing, check that the regional center:
- Matches EB-5 investor, EB-5 capital, and job totals perfectly.
- Lists projects with proper NAICS codes and locations.
- Shows job model details and stress buffers.
- Provides bank proofs for every draw.
- Has current petition numbers from legal counsel.
- Documents promoters and any capital redeployment fully.
Mistakes Regional Centers Should Avoid
Watch for EB-5 regional centers that have:
- Mismatched totals across EB-5 investors, dollars, and jobs.
- Job model changes without explanation.
- Scope issues without maps or amendment proof.
- Weak bank records without project-level detail.
- Outdated immigration data.
Key Takeaway for EB-5 Investors
A well-prepared Form I-956G shows an EB-5 regional center is organized, compliant, and tracking requirements properly. Look for clean numbers, strong job evidence, verified EB-5 capital flows, and precise immigration metrics. This filing discipline supports investor confidence and a smoother visa process.
While these best practices may complement counsel’s advice on strategy and procedure, it is not a substitute for legal counsel—contact us to be connected with a seasoned immigration attorney who can help assess your specific situation.
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