The EB-5 Proposed Rule is Here

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This comment argues: Please see the attached comment letter submitted on behalf of regarding the EB-5 Reform and Integrity Act NPRM (DHS Docket No. As a sponsor developing a new post-RIA regional center offering, respectfully submits comments limited to two provisions of particular concern to sponsors financing ground-up development: (1) the elimination of job-creation credit for bridge-replaced financing under proposed 8 CFR § 204.407(e)(1); and (2) the petition-filing-date investment re...

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This comment argues: RIN 1615-AC94 I am an EB-5 investor in a rural project and submit the following comments. Bridge Financing (Proposed 8 CFR 204.407(e)(1)) I support USCIS’s goal of linking investor capital directly to job creation and preventing projects that rely solely on long-term bridge financing.

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This comment argues that the commenter submitted my Form I-526E in November 2025 as an Indian national investing in a rural project, and As a post-RIA applicant navigating long visa backlogs, having clear, reliable rules and consistent agency processing is essential for my family's future in the United States. Predictable Adjudications and Protecting Set-Aside Visas The current adjudication process for Form I-526E suffers from erratic processing order and escalating delays.

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This comment argues that the commenter chose this program in reliance on the clear statutory protections established by Congress in the EB-5 Reform and Integrity Act of 2022. I write in strong support of codifying a clear two-year minimum sustainment period under proposed 8 CFR 204.407(b) and 8 CFR 216.6.

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This comment argues: (“MRC”) its respectfully submit attached comments regarding DHS’s Notice of Proposed Rulemaking implementing EB-5 Reform Integrity Act of 2022. EB-5 Program provides substantial measurable benefits to United States by attracting private capital, creating American jobs, supporting economic development, particularly in rural underserved communities.

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This comment argues: On behalf of Holdings ., and its wholly owned subsidiaries, including NESF Fund Services Corp., and NESF Escrow Services Corp. (collectively “NES” and “”), thank you for the opportunity to comment on the Department’s Notice of Proposed Rulemaking (the “NPRM”) implementing the EB-5 Reform and Integrity Act of 2022.

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This comment argues that the commenter am writing to submit my public comments on the proposed rules for the EB-5 program under Docket No. As an Indian national who filed an I-526E petition in August 2026 for a rural project, my primary concern is my family's future, as my child will age out within the next five years.

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This comment argues: Consolidated comment of LLC and Capital LLC DHS Docket No. 2770-24 (91 FR 40676, July 2, 2026) We are submitting comments on four parts of the proposed rule.

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This comment argues: As an investor born in India, I am facing an impending multi-year visa backlog despite investing in the prioritized rural category. My perspective focuses on ensuring the final regulations align with the statutory intent of the EB-5 Reform and Integrity Act of 2022 (RIA) while reflecting practical commercial realities.

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This comment argues: For years, I have built my career and life in the United States on an H-1B visa, living under the constant, looming anxiety of the 60-day grace period. Watching talented colleagues face sudden layoffs and forced departures made it painfully clear that my entire life here rested on a fragile foundation.

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This comment argues: The EB5 program has been a great success for regions in the US where there is little direct funding from other sources. The EB5 program allows a legal pathway for these investors and their families for a US Green Card and at the same time greatly benefits the US economy by generating jobs and building infrastructure in places where there would otherwise be little development.

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This comment argues that the commenter am an American citizen submitting this comment in strong support of the Department’s effort to stop treating the EB-5 program as a green-card vending machine for foreign capital and start treating it as a program that must deliver new jobs for American workers with clean money. Developers start projects with ordinary American bank loans, later swap in foreign EB-5 money, and still claim every construction job as if the foreign investor created them.

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This comment argues that the commenter am an EB-5 investor in a 2025 Rural Montana project. My wife and I chose this pathway to build our long-term roots in the U.S.

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This comment argues: Public Comment Regarding the Proposed 90-Day Reinvestment Period I respectfully submit this comment to express my strong concern regarding the proposed requirement that EB-5 investors reinvest returned capital within 90 days in order to maintain their investment “at risk.” A 90-day reinvestment period is unreasonably short and does not reflect the practical realities of EB-5 investments. EB-5 investors generally do not have direct control over when investment c...

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This comment argues: In March 2024, I filed my Form I-526E under the post-RIA framework for a rural project, and my Form I-485 was approved in May 2025. My capital commitment and immigration filings were completed in direct reliance on the standards established following the 2022 statutory reforms, supported by an approved Form I-956F.

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This comment argues: Hello I am an individual EB-5 investor with a priority date of January 23, 2025. My capital is invested in a rural EB-5 project, so the question of when I get that capital back safely is not hypothetical for me.

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This comment argues: As a post-investor who filed my Form I-526E in January 2024 for a rural project under country chargeability for India, navigating the unpredictability of processing timelines while maintaining faith in the EB-5 program has been deeply stressful. The ongoing unreliability of processing orders means that wait times have grown, threatening to leave reserved rural visa numbers unused if too few petitions become visa-ready.

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This comment argues that the commenter am writing to submit comments on the Notice of Proposed Rulemaking (NPRM) regarding the implementation of the EB-5 Reform and Integrity Act (RIA) of 2022. While I strongly support the agency's goal of enhancing program integrity, mitigating fraud, and ensuring EB-5 capital flows to areas most in need of economic development, several provisions in the proposed rule risk stifling the program's viability and imposing unnecessary operational burdens on good-faith investors a...

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This comment argues that the commenter have lived in USA for 10+ years, always abided by laws, paid more a million dollars in taxes. In 2026, I invested approximately $800,000 in a rural EB-5 project using savings accumulated through years of employment and equity compensation.

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This comment argues that the commenter are legal resident in US since more than nearly 1.5 decade. I (and My family) has invested our lifelong earnings into a rural U.S.

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This comment argues: Here's the revised comment, incorporating your personal story and trimmed to fit within 250 words: I have filed my I-526E and am now living with the uncertainty that comes from rules that keep shifting under me. The unpredictability is exhausting and expensive, and it has taken a real toll on my quality of life and my peace of mind.

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This comment argues that the commenter filed my I-526E in February 2025 as a rural-project investor chargeable to India, and I now hold conditional permanent residence. Everything I planned - how long my money would stay tied up, when I could expect it back, what my family's finances would look like in the meantime - was built on the two-year sustainment period Congress set out in INA 203(b)(5)(A)(ii).

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This comment argues: My family is deeply grateful to the United States, and we wish to live here for the rest of our lives. To fulfill this dream, we dedicated most of our earnings from a decade of hard work to a rural EB-5 project, filing our I-526E petition in 2025.

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This comment argues that the commenter filed my Form I-526E in September 2025 as a post-RIA investor in a rural project, trusting that the framework established by Congress would be administered predictably. Delays and erratic adjudication sequences undermine this expectation.

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This comment argues: My project holds I-956F approval as both a rural project and a high-unemployment project, and my chargeability is India, so years will pass before a visa number reaches me. That wait is why these three parts of the rule matter most to me.

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This comment argues: Preserve Bridge Financing and Protect EB-5 Investors Who Invested Under Existing USCIS Policy Comment on Docket No. USCIS-2026-0100 I am an EB-5 investor and respectfully submit the following two requests for USCIS’s consideration: First, please continue to recognize reasonable bridge financing arrangements.

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This comment argues: Thank you for the opportunity to comment on these proposed changes. I am currently in the United States on an H-1B visa.

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This comment argues: The shift toward a defined two-year sustainment period, tied to INA 203(b)(5)(A)(ii) and proposed 8 CFR 216.6, is a change I support. Under the prior approach, investors in backlogged countries could face years of forced redeployment simply because a visa number was not yet current.

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This comment argues: When adjudicating Form I-829, USCIS should not re-examine the lawful source of the investment funds, because the source of funds was already reviewed and accepted during the adjudication of Form I-526E. Therefore, USCIS should not conduct a duplicative review of the source of funds at the I-829 stage.

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This comment argues: To the United States Citizenship and Immigration Services (USCIS): Thank you for the opportunity to submit feedback during this public comment period. As an H-1B visa holder navigating the uncertainty and instability of the current immigration system, I decided to pursue an EB-5 investment in early 2026.

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This comment argues that the commenter think i-829 shouldn't require disclosing the source of funding unless there are new related evidence of fraud for other i-829 case are found.

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This comment argues: Sustainment period 2 years - should be calculated from the day money is wired to NCE as there is not control over that money once it leaves from my account. establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months .

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This comment argues: The source of funds has been checked before. It shouldn't be checked again in the 829 phase because it is hard to find evidence of the source of funds from 15-20 years ago.

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This comment argues: Citizenship and Immigration Services: I am a prospective EB 5 investor considering a substantial investment through the Regional Center Program. I support strong integrity and anti fraud protections, but good faith investors should not bear immigration or financial consequences caused by parties they do not control.

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This comment argues that the commenter am writing to share my opinion and experience regarding the proposed rules. My EB-5 matter is chargeable to India, concerns a rural project, and falls under the post-RIA framework.

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This comment argues that the commenter am writing to support stronger protections for good-faith EB-5 investors in the proposed rule. First, I respectfully urge USCIS to reconsider the proposed three-month timeframe for redeployment of EB-5 capital.

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This comment argues that the commenter have lived in the United States for more than 15 years and have been waiting for my green card for many years. I took out multiple loans and combined them with my savings to make this EB-5 investment.

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This comment argues: My I-526E filing plan is for August 2026, and my investment is in a rural project. I need the final rule to give investors a clear and workable point at which the required investment period begins and ends, without extending that period because of circumstances outside the investor’s control.

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This comment argues: Considering the extraordinarily protracted priority‑date backlog for unreserved EB‑5 visas, we urge that Chart B be authorized for determining whether derivative children have aged‑out under the CSPA. This critical reform would keep families who have endured a decade‑long wait from being torn apart, and uphold fundamental humanitarian principles.

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This comment argues: Like many of the post-RIA investors, I am also left in limbo by unpredictable processing timelines. The uncertainty is worse when reserved rural, high-unemployment, and infrastructure visas go unused because too few petitions become visa-ready.

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This comment argues that the commenter have practiced immigration law for 53 years and handled my first investor visa case in 1974 when an alien could invest $10,000 in a business and file for a green card under the non-preference category of the quota system. i've followed the EB-5 system since the beginning and have handled every aspect of investor visas.

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This comment argues: Docket USCIS-2026-0100 will settle several questions that are still open in my own case. My chargeability is India, my capital sits in a rural project, and I filed under the post-RIA framework, so the sustainment, job counting, and termination provisions are not abstract to me.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter respectfully submit the attached detailed comments on the proposed EB-5 regulations. I have lived in the United States since 2016.

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This comment argues: submits this comment as an EB-5 market participant with practical experience in project development, project finance, capital deployment, and investment structures involving commercial and job-creating entities. supports DHS and USCIS efforts to strengthen integrity, transparency, and predictability in the EB-5 program.

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This comment argues that the commenter am an EB-5 investor who filed Form I-526E in April 2026 as a high-unemployment-area investor. I have lived in the United States for 14 years, where I have studied, worked, paid taxes, built my career, and raised U.S.-citizen children.

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This comment argues: Comment on DHS Docket No. USCIS-2026-0100

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This comment argues: Please find ' attached comments to the NPRM

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This comment argues: is a Dallas-based investment firm an EB-5 pioneer. For more than 15 years, has sponsored over 50 EB-5 transactions across multiple USCIS-designated regional centers, has served more than 1,700 individual investors, has deployed EB-5 into projects with total capitalization exceeding $3 billion.

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This comment argues that the commenter support meaningful audits, site visits, reporting requirements, and enforcement against fraud or serious noncompliance. Stronger oversight can protect investors by encouraging regional centers and project sponsors to maintain proper records, monitor project compliance, and identify problems before investors reach the removal-of-conditions stage.

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This comment argues that the commenter support clear and predictable EB-5 investment thresholds, but the applicable investment amount should be locked as of the investor's original filing date. This is especially important for good-faith investors who may later be required to reassociate with another regional center or make a replacement investment because of regional center, NCE, JCE, or project failure.

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This comment argues: USCIS-2026-0100-0001, because the outcome directly affects my investment and my family's future. Keeping your place in line when a regional center fails: I welcome the proposal to formalize a roughly 180-day window for investors to amend their petitions and re-associate with a new sponsor after a regional-center termination or debarment, as outlined under INA 203(b)(5)(M) and proposed 8 CFR 204.410.

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This comment argues: My family made our EB-5 investment relying on the rules governing the program when we committed our capital. We completed our investment with confidence in that legal framework.

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This comment argues that the commenter support the RIA's good-faith investor protections, but DHS should implement them broadly so an investor does not lose immigration eligibility because of conduct by a regional center, NCE, JCE, or project sponsor that the investor did not control. An individual investor cannot control the regional center's compliance, project management, financial condition, use of funds, or continued participation in the program.

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This comment argues that the commenter filed my I-526E in June 2026 for a rural project. What concerns me most about this rulemaking is the possibility that the rules, or the way they are interpreted, could change after someone has already invested and filed.

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This comment argues that the commenter am an EB-5 investor and filed Form I-526E in September 2025, placing our family's life savings at risk in full compliance with USCIS guidelines. We invested to support our children, who came to the US at age 6, grew up here, and are building their futures around contributing to American society.

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This comment argues that the commenter support the proposed EB-5 changes that provide greater certainty for investors, but I encourage DHS to make several points especially clear. Investment period: I support the two-year sustainment rule under INA 203(b)(5)(A)(ii), proposed 8 CFR 204.407(b), and proposed 8 CFR 216.6.

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This comment argues that the commenter have been living and working here for many years on H-1B status, and my EB-2 priority date is from the middle of 2019. Even so, the India employment-based backlog means my spouse and I still have no idea when our family will actually have permanent residency, and our two children are U.S.

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This comment argues: Applicants facing long Green Card backlogs already deal with a lot of uncertainty, and processing delays-especially around Advance Parole (AP) and Employment Authorization Documents (EAD)-create serious confusion for families trying to contribute to American culture and the economy. Most EB-5 investors bring strong talent and deep professional experience, but when EAD and AP approvals take far too long, we are forced to stick to safe, conventional career choices.

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This comment argues that the commenter am a post-RIA regional center investor, and I strongly oppose applying any new restriction, limitation, or elimination of bridge-financing job credit to projects or investors that filed under the rules and USCIS guidance in effect at the time. Bridge financing was recognized in USCIS policy when many post-RIA projects were structured, filed, and in some cases approved.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: In January 2026, I filed Form I-526E through a regional center for a project in a High-Unemployment Area (HUA), chargeable to a severely backlogged country. Erratic review sequences and growing backlogs hurt investors who committed capital in good faith.

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This comment argues that the commenter submit the attached comment as a business plan writer who has helped hundreds of businesses and investors navigate the standalone direct EB-5 program. My comment addresses key issues for direct EB-5: lawful source of funds for multiple investors (8 CFR § 204.407(c)(4)), the timing of job creation (8 CFR § 204.408(f)(1)(ii)), and amendments and material change (8 CFR § 204.410).

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter filed my I-526E petition in April 2026 in a rural project, committing capital irrevocably before having any reliable sense of how long adjudication would take. Two parts of this proposed rule will decide whether that commitment has a definite end point or an open-ended one.

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This comment argues that the commenter have lived in the United States for more than 11 years and have built my family here. In February 2026, I made a rural EB-5 investment with money I earned through hard work, hoping to create a more secure future for my family in this country.

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This comment argues: EB-5 should continue to be eligible for replacing genuine bridge financing of projects. USCIS does not have the legal authority to introduce a new category called "High Employment Area" with a higher investment amount.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: As an immigrant seeking to complete the EB-5 process, I am submitting these comments on the Department of Homeland Security's Notice of Proposed Rulemaking regarding docket number USCIS-2026-0100. Lengthy petition adjudication timelines and erratic processing orders cause immense hardship, leading to growing backlogs where reserved visa numbers in rural, high-unemployment, and infrastructure categories risk going unused while investors wait for approvals.

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This comment argues that the commenter submitted my I-526E petition in March 2026 as a post-RIA investor from India who selected a rural project. My decision to move forward with this step came after careful consideration of my family’s future, balancing the opportunity against significant financial sacrifice.

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This comment argues that the commenter am submitting these comments on Docket No. USCIS-2026-0100 to share feedback on the proposed EB-5 rules.

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This comment argues: Docket ID: USCIS-2026-0100 Re: Notice of Proposed Rulemaking for EB-5 Reform and Integrity Act of 2022 To Whom It May Concern: I am an EB-5 investor submitting this comment to address critical provisions in the recent Notice of Proposed Rulemaking (NPRM) that impact good-faith participants in the program. Support for Section IV.D.6: Duration of Investment I strongly support the proposal that capital only needs to remain invested for approximately two years after being made...

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This comment argues that the commenter filed my EB-5 I-526E application in December 2025 for a rural and infrastructure project, and as an investor chargeable to a backlogged country, I am deeply anxious about the current backlog and program mechanics. My biggest concerns are the very real possibilities of not getting a green card, losing my place in the immigration line, and facing total capital loss if my regional center fails.

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This comment argues: My journey in the United States began in 2013, when I came here to pursue a master’s degree. I began working in 2015, but I am still waiting in the green card queue.

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This comment argues: On behalf of (IIUSA), trade association of EB-5 Regional Center Program, please accept this letter/comment on Notice of Proposed Rulemaking (NPRM) published on July 2, 2026 (CIS No.

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This comment argues: In March 2024 I filed an I-526E as a post-RIA investor from India, putting my family's life savings into a high-unemployment TEA project in pursuit of permanent residency for us. I'm grateful for the chance this country has given me to build a livelihood and contribute to it, but the rules governing that investment need to be predictable enough for that trust to hold up over years of waiting.

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This comment argues: submits the attached comment on the proposed rule, EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Immigrant Classification, 91 Fed. operates eight designated regional centers and has filed twenty-three project applications since enactment of the RIA.

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This comment argues: Investing my child's future, and my own, in a program I trust to work is why I filed my I-526E in February 2025, and it is why the details of this rule matter so much to me now. **On the return of capital after the sustainment period** I support locking a defined, predictable sustainment period into regulation instead of leaving investors exposed to indefinite redeployment.

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This comment argues: On behalf of (IIUSA), trade association of EB-5 Regional Center Program, please accept this set of comments on Notice of Proposed Rulemaking (NPRM) published on July 2, 2026 (CIS No. We will be submitting an additional letter before commenting deadline.

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This comment argues that the commenter support codifying the current amounts and adding a published inflation schedule. Predictability here is valuable in itself; knowing the $800K TEA/infrastructure figure and the $1.05M standard figure are locked in, with a new higher-employment tier and a defined adjustment date of January 1, 2027, lets investors and their families plan years in advance instead of guessing.

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This comment argues: 40,676) I submit these comments as an attorney who has represented EB-5 investors for more than a decade. I support this rulemaking and the RIA's integrity architecture, and I identify provisions the final rule should retain.

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This comment argues: On behalf of (IIUSA), trade association of EB-5 Regional Center Program, please accept this set of comments on Notice of Proposed Rulemaking (NPRM) published on July 2, 2026 (CIS No. We will be submitting additional comments before commenting deadline.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: Citizenship and Immigration Services: I am an EB-5 investor whose underlying immigrant investor petition was filed before enactment of the EB-5 Reform and Integrity Act of 2022 (“RIA”). I submit this comment regarding DHS's proposed regulations concerning capital redeployment and the treatment of pre-RIA investors.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: PUBLIC COMMENT SUBMISSION Docket ID: DHS Docket No. 2770-24, RIN 1615-AC94) Title: EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Immigrant Classification Submitter: Edward S.

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This comment argues that the commenter am a post-RIA EB-5 investor who has lived and worked in the United States for many years and has already experienced a lengthy wait in another employment-based immigrant visa category. After years of uncertainty, I committed a substantial portion of my family's savings to an EB-5 investment as another path toward permanent residence.

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This comment argues that the commenter filed my I-526E in December 2025 and submitted my I-485 and I-765 at the same time, betting my family's future on this program. My work permit runs out in early 2027, and because I have no approved I-140, I cannot extend it.

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This comment argues that the commenter filed my Form I-526E in August 2026 for a rural project, entering the process under the India country chargeability pool. I have been working on H-1B visa in the USA for 10 years at a large tech company.

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This comment argues: Following a recent layoff and the 12 month delay in receiving my employment authorization, my household-which includes my U.S. citizen child-is enduring significant financial strain.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter invested $800,000 of my hard-earned money with the expectation that the EB-5 process would move forward under a clear and reliable framework. It has been 8 months since I invested, with no progress in terms of my immigration process.

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This comment argues that the commenter filed my I-526E petition in July 2026, investing in a project in a high-unemployment targeted employment area. Since my chargeability is India, the gap between filing and a visa number isn't a small detail for me.

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This comment concerns the proposed rule implementing the EB-5 Reform and Integrity Act of 2022 (DHS Docket No. I submit it in my personal capacity as an individual commenter on post-RIA regional center offerings.

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This comment argues that the commenter am a post-RIA investor and the trust in the modernized RIA framework made me invest and plan for a stable future. I am concerned about the proposed 8 CFR 204.407(b)(1)-(3), that specifies the sustainment period to only start when the capital is made available to the Job Creating Entity (JCE) and not when it is made available to the New Commercial Enterprise (NCE).

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This comment argues: My firm, , where is developing a 648‑bed purpose‑built student housing community serving Appalachian State University, in rural Watauga County, North Carolina. My attached comment addresses proposed 8 CFR 204.407(e)(1), which would bar jobs attributable to financing repaid with EB‑5 investment capital from being counted as jobs created by that capital.

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This comment argues that the commenter am chargeable to India and my EB-5 investment is in a rural project. Because no filing or plan date is provided here, I do not want to imply a personal processing timeline that I have not stated.

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This comment argues that the commenter am an Indian-chargeable investor in a rural project, and the uncertainty around EB-5 processing and visa availability has been very concerning for my family and me. I support the proposed two-year sustainment period under INA 203(b)(5)(A)(ii) and proposed 8 CFR 204.407(b).

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This comment argues that the commenter invested $800,000 of my life savings in the EB-5 program on March 31, 2026, after years of working and saving in the United States. This was one of the largest financial and personal commitments I have ever made, and the rules governing how long my money must remain invested were an important part of that decision.

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This comment argues that the commenter have lived in the United States for the last 10 years. My older child, who is 11, is an Indian citizen, while my younger child, who is 7, is a U.S.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter submitted my petition under the post-RIA framework for a project located in a rural area, with India as my country of chargeability. Because application adjudication has been irregular and queue movements remain unpredictable, reserved set-aside visas risk remaining unallocated if petitions fail to become documentarily qualified in time.

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This comment argues: Me and my family are living and working in the United States for over 13 years, law abiding people, paying our taxes on time and contributed to american economy by investing lifetime savings in EB5 investor program. I am filing my public comment as a post-RIA EB-5 investor facing a critical situation.

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This comment argues that the commenter respectfully request that DHS clarify proposed 8 CFR 216.6(b)(4) to expressly address derivative EB-5 family members whose principal investor becomes a United States citizen before filing a petition to remove conditions. This situation can arise lawfully under existing USCIS policy.

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This comment argues that the commenter submitted my Form I-526E in March 2025 for a rural development project as a family applicant subject to the India country limits. Because processing speeds remain erratic and unpredictable, many reserved visas risk remaining unissued while petitions wait for adjudication.

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This comment argues: Re: Proposed Rule - EB-5 Reform and Integrity Act of 2022 Implementation Issue: Currently, petitioners frequently receive Requests for Evidence (RFEs) or Notices of Intent to Deny (NOIDs) simply because their final funding source differed from the preliminary strategy outlined at initial filing. For example, a petitioner may initially indicate plans to source $400,000 via an approved loan, but later successfully secure personal capital to complete the remaining investment...

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This comment argues that the commenter am writing this as an EB5 Investor, invested via a Regional Center in 2025. When I made my investment, I relied on predictable sustainment period.

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This comment argues: My I-526E filing and investment plan date from November 2025, and my investment is in a rural project. I need the final rule to give investors clear, predictable rules after capital has already been committed.

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This comment argues: Please see the attached comments from the Assoc.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter intend to file Form I-526E this month, in a rural project. Two parts of this proposal bear directly on how that filing plays out over the next decade.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter am an EB-5 investor and appreciate DHS's efforts to implement the Reform and Integrity Act. My primary concern is the proposed treatment of bridge financing.

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This comment argues: My I-526E filing and plan date is September 2025. I am a post-RIA investor from India, and my investment is in a high-unemployment TEA project.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter filed my I-526E in January 2026 because my daughter will be aging out in about three years. Our EB-2 priority date is June 2026, and I am concerned that the wait for an Indian citizen may be longer.

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This comment argues that the commenter am writing as an individual EB-5 investor in support of the proposed two-year sustainment period measured from the deployment of capital. I ask that DHS adopt this provision without modification.

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This comment argues that the commenter am an India-chargeable, post-RIA investor. My primary concern with the proposed changes is predictability.

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This comment argues that the commenter submit this comment who invested $800,000 in a rural, targeted-employment-area project in early 2025, and I write in strong support of codifying the 2-year investment sustainment period. The EB-5 Reform and Integrity Act of 2022 provides that capital is expected to remain invested "for not less than 2 years," and USCIS's guidance rightly ties that period to the date capital is deployed into the job-creating enterprise.

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This comment argues that the commenter filed my I-526E in January 2026 for a rural investment, with India as my country of chargeability. I am a widowed single mother, and I have contributed to the U.S.

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This comment argues that the commenter am concerned that EB-5 investors with pending adjustment applications can face immigration-related timelines that are difficult to predict. In addition to the specific investment and program-integrity rules in this proposal, USCIS should establish a minimum five-year validity period for Employment Authorization Documents issued to EB-5 investors with pending I-485 applications, rather than 18 months.

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This comment argues: My I-526E filing plan is based on the EB-5 program as it applies to post-RIA investors, and I am pursuing a rural project from India. For that reason, I need clear and predictable rules about how long my capital must remain invested and when I can expect it to be returned.

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This comment argues that the commenter have three things I want to say about this rule, all tied to how my money is actually protected once it's committed. I'm glad to see it written into regulation, but the length isn't the part that worries me.

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This comment argues: As an applicant who filed Form I-526E in May 2026 under the post-RIA regulations, I am writing to share my feedback on docket USCIS-2026-0100-0001. My petition is subject to the India country chargeability and is tied to a rural development endeavor.

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This comment argues that the commenter invested my life savings-$800,000-into a rural EB-5 project in June 2025, filing my I-526E as a post-RIA investor after doing my own research and placing my trust in this program. The I-526E petition has since been approved, and two provisions in this proposed rule speak directly to what happens next for me.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter would like to share a few thoughts and as someone who believes in the original purpose of this program. EB-5 investors make a very significant commitment.

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This comment argues: Please see the attached comment letter regarding the proposed rule "EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Immigrant Classification," DHS Docket No. The attached comment is submitted by an individual immigrant investor in the EB-5 Regional Center Program and addresses five provisions: proposed 8 CFR 205.1(c) (revocation without process, and its interaction with proposed 8 CFR 204.410(a)); pro...

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This comment argues that the commenter am writing to share my perspective on the proposed changes, particularly regarding the I-829 process. Like many EB-5 investors, my family made a significant financial commitment to the United States through this program.

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This comment argues that the commenter am a current EB-5 investor who made my investment under the EB-5 Reform and Integrity Act of 2022 framework and filed my Form I-526E petition in November 2025. Because I relied on the post-RIA rules when making my investment, I am closely following this proposed rulemaking.

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This comment argues that the commenter am an EB-5 investor and respectfully submit this comment regarding the proposed regulations governing removal of conditions for EB-5 investors. EB-5 investors make substantial financial commitments to the United States.

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This comment argues that the commenter filed my I-526E petition in December 2025 as a post-RIA investor, chargeable to India, in a rural project. That combination, rural plus a country with a years-long backlog, means the details in this NPRM aren't abstract to me.

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This comment argues: develops market-rate apartment communities. Ground-up construction is funded with a construction loan retired at stabilization, so EB-5 capital can only ever enter behind interim financing, and the sentence in proposed 8 CFR 204.407(e)(1) barring job-creation credit for financing repaid with EB-5 capital should be struck from the final rule.

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This comment argues: is a vertically integrated affordable housing developer. Proposed 8 CFR 204.407(c)(4) would condition an investor's eligibility on proving the lawful derivation of capital belonging to state housing finance agencies, banks, and tax credit syndicators, which those parties will not provide and in some cases are not permitted to; DHS should limit the lawful-source inquiry to the investor's own EB-5 capital.

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This comment argues that the commenter filed my I-526E plan in December 2024 after putting almost a million dollars into this country through a TEA high-unemployment project. That was money I had earned legally and paid taxes on.

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This comment argues: Comment on the Start Date of the EB-5 Two-Year Sustainment Period Re: DHS Docket No. USCIS-2026-0100 I respectfully recommend that DHS and USCIS provide greater clarity in the final rule regarding the start date of the EB-5 two-year sustainment period, particularly for regional center projects involving multiple closings, phased fundraising, or subsequent EB-5 investors.

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This comment argues that the commenter filed my I-526E in November 2025, in the high-unemployment TEA category. These rules will determine how long my capital stays at risk and whether the program still works for investors currently in the queue.

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This comment argues: Specifically, I strongly advocate for two key regulatory policies: (1) maintaining a clear, practical two-year capital sustainment period, and (2) implementing rigorous, recurring third-party audits of Regional Center projects to safeguard job creation and protect investor capital. Reaffirming the 2-Year Capital Sustainment Period as Intended by Congress Under the RIA (INA § 203(b)(5)(A)(i)), Congress established that EB-5 capital is expected to remain invested for no...

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This comment argues that the commenter filed my I-526E petition in April 2026 as a post-RIA investor in a rural project. This EB-5 investment represents my family’s life savings; making the rules on investment sustainment, job creation and return of capital deeply important to me.

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This comment argues that the commenter filed my I-526E in October 2025 through a rural investment. This is an enormous financial commitment to make based on a particular immigration framework.

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This comment argues that the commenter planned my EB-5 filing for April 2026 under the post-RIA framework, with India as my country of chargeability and a rural investment. The rules governing how long my capital must remain invested, what happens if a regional center encounters problems, and which investment amount applies directly affect the certainty I need from this program.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: In February 2025 I filed my I-526E petition, seeking a stable and predictable path to permanent residence so I can provide for my family. As an investor charged under India's category in a rural project, I read this proposed rule closely, because timing and clarity are what determine whether the years ahead are manageable for us.

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This comment argues: My main concern is what happens to the jobs supported by my project during the temporary financing period - if these jobs no longer count, I could lose the ten I need without any decision on my part. Since an individual investor has no control over how a project arranges short-term funding or when it is repaid, this is a significant issue.

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This comment argues that the commenter filed my I-526E in November 2025 as a post-RIA investor from India, putting capital into a TEA high-unemployment project. I believe it is reasonable to expect an acceptance notice within a manageable timeframe-certainly not after a four-year wait.

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This comment argues that the commenter filed my I-526E petition in February 2026, and I am increasingly concerned about changes in rules or USCIS interpretations that may come after filing. Some of these issues did not exist when I submitted my petition, and I had no ability to anticipate or control how the requirements might later be interpreted.

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This comment argues: Revoke all EB5 visas, dissolve all cure periods and revoke the following visas as well due to fraud: F1, OPT, U and H1b.

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This comment argues: My I-526E plan dates to November 2017, and my experience has shown me how difficult it can be to plan around an immigration process that is extremely slow and inconsistent. For me, the uncertainty in I-526 processing is a much bigger issue that needs to be addressed.

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This comment argues that the commenter filed my I-526E petition in November 2025 in the rural category. I have lived in the United States for more than ten years, and I have not been able to travel to India in years to visit my aging parents.

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This comment argues that the commenter am an and father of two young children, ages 9 and 2. My family came to the United States with no financial resources, worked for approximately 13 years to build a stable life, and ultimately committed our life savings, while taking on significant financial debt, to pursue a secure future for our children through .

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This comment argues that the commenter respectfully recommend that DHS and USCIS further clarify in the final rule that when an EB-5 investor has fully contributed the required investment capital, but deployment is delayed because of the regional center, NCE, JCE, developer, or other project-side parties, the investor's statutory two-year sustainment period should not be postponed indefinitely merely because the project fails to deploy the capital within the timeframe contemplated by the business plan. Under...

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This comment argues: The 2 year sustainment period is a key feature that attracts investors. Also this period should start from when funds are available for NCE.

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This comment argues: Establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months .

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This comment argues that the commenter am a Canadian citizen who has had the privilege and honor of living in the United States for over 10 years, yet despite having had a pending 485 for over 8 hears, still to this date remain an outsider purely by virtue of my nationality of origin, and the happenstance of my mother being physically present in India when I was born. Since filing our I-526E in early 2025, the uncertainty has spilled into daily life.

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This comment argues: Please establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months .

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This comment argues: establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months .

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This comment argues: Please establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months.

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This comment argues that the commenter invested in EB-5 using all my savings. Having clear rules about when my capital can be returned is important to my family’s financial stability.

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This comment argues: U.S. Citizenship and Immigration Services

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This comment argues: As an active post-RIA EB-5 immigrant investor, I am submitting the following comments on this Notice of Proposed Rulemaking: SUSTAINMENT PERIOD: START TRIGGER AND CAPITAL RETURN (Section IV.D.6; 8 CFR 204.6, 216.6) Start Trigger (Escrow to NCE): The final rule should define the start of the 2-year sustainment clock as the date investor capital is released from escrow into the New Commercial Enterprise (NCE). Once funds reach the NCE, the investor has fully committed their...

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This comment argues that the commenter am waiting for clarity after a recent filing involving a rural project. Uncertain timelines make the process feel like an unpredictable challenge rather than a stable investment in rural infrastructure.

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This comment argues: Regarding docket USCIS-2026-0100-0001 (EB-5 Reform and Integrity Act NPRM, published July 2, 2026): My case is a rural-category, post-RIA filing, with India as my country of chargeability. Three parts of this proposed rule affect my situation directly, and I want to comment on each.

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This comment argues that the commenter filed Form I-526E in October 2025 as an investor in a rural project. The uncertainty about processing and the return of my capital makes long-term financial planning difficult for my family.

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This comment argues that the commenter am submitting this public comment to share how the proposed regulations impact immigrant investors like me who have committed significant personal capital to U.S. Because the agency has provided no clear queue or predictable processing order for I-526 and I-526E petitions, families face mounting wait times and uncertainty while our lives remain on hold.

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This comment argues: Public Comment Submission DHS Docket No.: USCIS-2026-0100 RIN: 1615-AC94 Subject: Public Comment Objecting to the Punitive Termination of Work Authorization Under Proposed 8 CFR § 216.3(a) and the compounding Risks of Retroactive Loan Scrutiny I. Introduction & Commenter Interest I am submitting this formal public comment as an active EB-5 immigrant investor and current Conditional Green Card (CGC) holder.

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This comment argues that the commenter am an EB-5 investor from India who made a significant financial commitment under the framework established by the EB-5 Reform and Integrity Act of 2022. I appreciate DHS’s efforts to provide greater clarity regarding the EB-5 program and respectfully offer the following comments regarding the proposed sustainment requirements.

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This comment argues that the commenter filed my I-526E in 2026 as a post-RIA investor from India backing a rural project, and like many people in the India line I am looking at a long wait before my visa becomes current. That reality shapes how I read this proposed rule, because the details that seem small on paper decide whether my capital is treated fairly during years of backlog.

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This comment argues: DHS Docket No.: USCIS-2026-0100 Regulation Identifier Number (RIN): 1615-AC94 Subject: Public Comment on Proposed Rules Affecting Form I-829 Adjudication for Existing Conditional Permanent Residents Sourced via Regional Center Loans I. Introduction & Commenter Interest I am submitting this formal public comment as an active EB-5 investor and current Conditional Green Card (CGC) holder.

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This comment argues that the commenter am writing to express strong concern regarding proposed restrictions on bridge loans in the EB-5 program. Bridge financing plays a critical role in allowing developers to start projects and generate jobs without waiting for full EB-5 capital stacks to mobilize.

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This comment argues: USCIS must provide unambiguous regulatory guidance regarding Regional Center (RC) loan structures in this document. Current definitions remain overly vague and subject to conflicting interpretations.

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This comment argues that the commenter came to the United States as a student and began working here in 2018. Once I had enough stability to travel, I spent my free time hiking and exploring the national parks, and that is what convinced me I wanted to make this country my permanent home.

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This comment argues that the commenter urge USCIS to adopt a clear, definitive rule that the EB-5 sustainment period ends two years after capital deployment. Forcing investors to keep their capital at risk indefinitely solely because of bureaucratic visa backlogs would be deeply inequitable, particularly for applicants from backlogged countries who face decades of limbo.

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This comment argues: # Comment on the Proposed Rule Eliminating Job Credit for EB-5-Repaid Bridge Financing ## Introduction Today, EB-5 capital serves as a cost-effective layer of the capital stack that frequently supports projects in underserved, rural, and high-unemployment communities. Under the proposed rule, new restrictions and delays risk making EB-5 financing less attractive to both developers and investors - undermining the program's core value proposition at a time when it is needed...

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This comment argues: My wife and I have lived in the United States legally for approximately 12-13 years. Throughout that time, we have worked hard to build our lives here, followed the laws and immigration requirements applicable to us, maintained our legal status, and met our tax obligations on time.

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This comment argues that the commenter am an EB-5 investor with an October 2026 priority date in the HUA category. I chose this program expecting predictable and timely processing under the post-RIA rules.

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This comment argues that the commenter filed my I-526E in December 2025 based on a high-unemployment TEA investment, and my country of chargeability is India. What concerns me most about these proposed changes is the possibility that an investor can follow the rules, invest lawful funds, and still face new requirements governing how long the money must remain invested or how the project may use it after the investment has already been made.

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This comment argues that the commenter am a post-RIA investor chargeable to India who chose a rural EB-5 investment. I am commenting because clear rules on investment duration, job creation, and protections when a regional center or project entity fails are important to investors who must make significant decisions before knowing how long immigration processing will take.

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This comment argues that the commenter filed I-526E especially for my son, who arrived in the United States at age three and has studied through his senior year of school here. He was raised with American standards, and we loved this country so much because it has given us everything from bread to a roof over our heads.

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This comment argues that the commenter did not make my investment expecting the rules or terms of the investment to change later. In any business, changing the terms after someone has already invested is concerning.

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This comment argues: When I submitted my I-526E petition in June 2026 for a high-unemployment targeted employment area, I made a life-altering commitment based on the clear statutory frameworks enacted by Congress. Because my country of chargeability is India, unpredictable petition processing and shifting timelines directly affect my family's future and our ability to plan ahead.

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This comment argues that the commenter invested $800,000 into a rural targeted-employment-area project through a regional center in November 2025, and I write to strongly support the proposed rule's two-year sustainment period, measured from the deployment of capital. Investment duration and return of capital I support establishing a clear two-year sustainment period.

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This comment argues that the commenter filed my I-526E in 2026 for a high-unemployment area project and am chargeable to India, which means years of backlog before a visa number reaches me. Three aspects of this rulemaking matter most to my situation.

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This comment argues: Sustainment period be 2 years and not change. Establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months as processing times has slowed down.

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This comment argues: Job allocation within a project should be done in a first come first serve basis where the investor who receives their I-526E first is allocated jobs first. This should be enforced as any RCs using different allocation methods are unfair because post I-526E processing times are not in the control of investors

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This comment argues: Provide a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications instead of 18 months as 18 month EADs require frequent renewals which can take longer than 6 months. Causing lapses in work authorization and stress for individuals and their employers

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This comment argues: USCIS-2026-0100, EB-5 Reform and Integrity Act of 2022 Implementation NPRM As an India-chargeability investor who filed I-526E in August 2026 in a rural targeted employment area, I offer the following comments on the proposed rule. Delays and unpredictable processing order for I-526E petitions threaten to leave set-aside visa numbers unused; establishing predictable adjudication sequences will ensure reserved categories function as Congress intended.

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This comment argues that the commenter filed my I-526E in April 2026, and what troubles me most is not the project I chose but the risk that the rules underneath it keep shifting while my petition sits in a queue I cannot control. I am a person from India and invested in a rural project, so I am watching this rule making arrive in the middle of a commitment I already made and cannot easily unwind.

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This comment argues: As a post-RIA investor from China who filed an I-526E petition in 2026 for a rural project, I am submitting this public comment to share my perspective on the Department of Homeland Security's proposed regulations. Predictable Adjudications and Visa Allocations Unpredictable processing schedules and growing backlogs for I-526 and I-526E filings create immense uncertainty for applicants in high-demand countries like China.

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This comment argues: Hi Team, Firstly, I am grateful to DHS and USCIS for administering a program that gives investors like me the opportunity to invest in the United States and pursue permanent residence. This process deeply affects me and my family, and the opportunity to build our future in the United States is something I value greatly and take very seriously.

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This comment argues: Thank you for the opportunity to comment on the topics. I am a current EB-5 investor who invested my family's savings in a project after its Form I-956F had already been approved.

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This comment argues that the commenter am an investor and I submitted my I-526E for a rural project this year. Rural was a deliberate choice, not a coincidence of where the deal happened to be.

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This comment argues: The EB-5 process has important consequences for my investment, and I appreciate the work DHS and USCIS are doing to provide greater clarity and strengthen the integrity of the program. I hope the final rule will provide investors with more predictability while continuing to protect the goals of the EB-5 program.

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This comment argues: Having submitted my I-526E in August 2026 for a rural project, my primary concern is risking my $800,000 in savings that's built up since 2014, while facing long agency delays that threaten to age out my child. Current I-526E processing is unpredictable and causes reserved rural visas to go unused.

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This comment argues: My family moved from India to the United States more than a decade ago on an H-1B visa. For Indian nationals, the employment-based Green Card timeline has become entirely unworkable, with current adjudication rates suggesting a backlog of over 150 years for EB-2 visas.

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This comment argues that the commenter came to the United States in 2011 with my 6-month-old child, who was born in India. For the last 15 years, I have worked in the United States and supported the growth of this country.

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This comment argues that the commenter had to file my EB-5 petition twice, mainly because of a regional-center loan issue. USCIS had accepted this type of RC loan before, but later changed its position when I applied.

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This comment argues that the commenter filed my I-526E petition in December 2025 (post RIA) under the rural category. As one of roughly 80 investors participating near the end of my project's fundraising, I face a very real fear that my funds will sit in escrow or transfer to the new commercial enterprise long before reaching the job-creating entity.

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This comment argues: Kindly increase the EAD validity while waiting for i485 to 5years. Processing delays currently make the 18month validity EAD cards hard to use for eb5 investors like myself.

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This comment argues: EB-5 Investor Comment on I-829 Removal of Conditions and Good-Faith Investor Protections I am writing as an individual EB-5 investor regarding the proposed I-829 removal-of-conditions process. I have lived, worked, paid taxes and raised my family in the United States for many years.

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This comment argues: At the same time, I respectfully request that the final rule provide strong and practical protection to investors who have invested lawfully and acted in good faith. Two-year investment/sustainment period - Proposed §204.407 I generally support the proposed two-year minimum sustainment period for RIA investors.

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This comment argues: My investment is tied to the EB-5 process, and as an investor from India in a rural project, I need the final rules to provide clear and workable protections. I support changes that create greater certainty, while also asking DHS to protect investors who have relied on existing program guidance.

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This comment argues: My I-526E was filed in February 2026 under the post-RIA framework. I support the proposed rule in several important respects, but I urge DHS to provide clear, predictable rules for investors whose capital, immigration process, and eligibility depend on requirements outside their control.

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This comment argues: EB-5 Investor Comment Supporting the Two-Year Sustainment Period and Clear Start/End Rules I am writing in support of keeping the EB-5 minimum sustainment period at two years. I have lived, worked, paid taxes and raised my family in the United States for many years.

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This comment argues that the commenter invested in this program in good faith, relying on USCIS to process employment authorization, advance parole, and adjustment of status within reasonable timelines. Over the past year, processing times have increased significantly and have been inconsistent across service centers.

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This comment argues that the commenter filed my I-526E petition in December 2025 as a rural-project, post-RIA investor from India, so I sit behind one of the more crowded backlogs in the program, and the mechanics of the sustainment clock matter to me directly. I generally support codifying the two-year investment period that Congress set out at INA 203(b)(5)(A)(ii) through proposed 8 CFR 204.407(b), rather than leaving the sustainment period to shifting agency practice.

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This comment argues: Comment on USCIS-2026-0100 - DHS Proposed Rule Implementing the EB-5 Reform and Integrity Act We are an immigrant investor family in a rural EB-5 project, fully invested since 2025, writing in support of provisions that make this program predictable and fair - and to urge changes where the proposed rule falls short. Congress set fee levels in the RIA expressly calibrated to adjudicate I-526E petitions within 240 days, and 120 days for rural priority processing.

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This comment argues: 1.⁠ ⁠Sustainment period 2 years - should be calculated from the day money is wired to NCE as there is not control over that money once it leaves from my account. 2.⁠ ⁠Job creation allocation should be first come first basis .

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: As a post-Ria investor from India with an I-526E filing and rural project plan dated August 2025, navigating the current processing environment requires clear and predictable regulatory standards. Unreliable and unpredictable processing timelines mean that reserved rural visa numbers risk going unused simply because too few petitions reach visa-ready status in a timely manner.

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This comment argues: On behalf of in (IIUSA), trade association of EB-5 Regional Center Program, please accept this set of comments on Notice of Proposed Rulemaking (NPRM) published on July 2, 2026 (CIS No. We will be submitting additional comments before commenting deadline.

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This comment argues that the commenter filed my I-526E petition in May 2026, investing in a high-unemployment targeted employment area project. I have no published timeline telling me when my petition will be adjudicated - even though Congress set one.

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This comment argues: My investment represents a significant portion of my savings, and the rules governing the EB-5 program have a direct impact on my ability to plan for the future. The two-year sustainment period should be applied consistently.

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This comment argues: In 2026, I invested my hard-earned savings into a rural EB-5 project to secure a pathway for legal immigration to the United States. Coming from India, my primary apprehension is that linking the required sustainment period to the two years of conditional permanent residence will effectively tie up my capital for nearly ten years.

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This comment argues: My project brought in bridge financing first and raised EB-5 money shortly afterward, which is how my capital came to be at risk. It falls under the infrastructure category, so what it funds carries a public benefit well beyond my own petition.

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This comment argues: Planning our family's future around a February 2026 filing for a rural project in India's visa chargeability category carries immense financial and personal stakes. Unpredictable adjudications and expanding wait times for Form I-526E create severe uncertainty for applicants like us.

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This comment argues: Sustainment period 2 years - should be calculated from the day money is wired to NCE as there is not control over that money once it leaves from my account. Job creation allocation should be first come first basis .

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This comment argues: My biggest concern is what happens after filing when there is no clear and predictable path to getting my I-526E and I-485 decided. If USCIS processing continues to take 3 to 4 years while EAD and Advance Parole validity is reduced to only 18 months, investors like me could face repeated renewals and prolonged uncertainty through no fault of our own.

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This comment argues that the commenter am an existing EB-5 investor who invested in a rural targeted employment area project in 2025. I am submitting these comments from the perspective of an investor who has already committed substantial capital and a significant portion of my life savings, with the expectation of consistency and predictability in the treatment of my investment.

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This comment argues: Investment sustainment and return of capital I generally support a two-year investment period under INA 203(b)(5)(A)(ii), proposed 8 CFR 204.407(b), and proposed 8 CFR 216.6. The clock should begin when my capital is placed at risk, not when my visa becomes current.

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This comment argues: My I-526E was filed in early 2026, based on a rural project. Because my investment was made under the post-RIA framework, the rules that apply to projects and investors at the time of filing matter greatly to my expectations.

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This comment argues that the commenter-526 and I-526E processing has been unreliable and difficult to predict, while wait times have grown. That uncertainty makes the rules governing the period during which my investment must remain at risk especially important.

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This comment argues that the commenter am an active EB-5 investor with a priority date of March 2025. I respectfully request that USCIS codify that the minimum two-year sustainment period begins when the investor’s capital is made available to the JCE, independent of the investor’s timeline for obtaining conditional permanent residency and subsequently removing the conditions on residency.

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This comment argues: As an investor, I kindly request that the 2-year sustainment period be maintained and that investors be allowed to receive their investment funds back after the completion of the 2-year period. This would provide investors with greater financial flexibility and allow them to use the returned funds to support their family’s financial needs.

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This comment argues that the commenter filed my Form I-526E in January 2026 under the rural set-aside category as an applicant subject to the India visa backlog. As an immigrant who has placed capital fully at risk and fulfilled my obligation to create American jobs, my primary anxiety is being penalized at the Form I-829 stage if my regional center collapses or ceases to exist, leaving me unable to obtain necessary administrative records despite my full compliance.

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This comment argues that the commenter support the proposed two-year investment period because it provides a more defined endpoint for the required sustainment of capital. The rule should also make clear exactly when that period begins.

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This comment argues: My I-526E filing is planned for December 2025, and I am an investor from India in a rural project. Because EB-5 involves a significant investment and long-term immigration planning, the final rule should provide clear and predictable rules while protecting investors who rely on the rules in effect when they proceed.

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This comment argues: submits this comment on proposed 8 CFR 204.401 and 204.416: the definition of "involved person," the amendment and advance-notice requirements, and the adjudication holds. has operated USCIS-designated regional centers for more than fifteen years, sponsoring over fifty EB-5 transactions, serving more than 1,700 investors, and deploying over $3 billion in project capitalization.

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This comment argues: The EB-5 program was created to attract foreign capital and create jobs in the U.S. It should therefore balance the interests of the U.S.

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This comment argues: The uncertainty surrounding my EB-5 investment has made clear, predictable rules especially important to me. I support several parts of the proposed rule that would provide greater certainty and protect investors who have acted in good faith.

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This comment argues: To the Department of Homeland Security / U.S. Citizenship and Immigration Services: I appreciate DHS's effort to implement the EB-5 Reform and Integrity Act of 2022 (RIA) and to bring clearer, more predictable standards to the program.

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This comment argues: is a Dallas-based investment firm and an EB-5 pioneer. For more than fifteen years we have sponsored over 50 EB-5 transactions across multiple USCIS-designated regional centers, served more than 1,700 individual investors, and deployed EB-5 into projects with total capitalization exceeding $3 billion.

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This comment argues that the commenter chose to put money towards permanent residence rather than buying a house because I wanted to secure my child’s future. The delays at USCIS, together with uncertainty about how the EB-5 rules will ultimately operate, affect my entire family.

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This comment argues that the commenter respectfully urge USCIS to protect and grandfather bona fide EB-5 investors who have already filed their I-526E and I-485 applications in good faith. Investors who have complied with all applicable requirements should retain their eligibility, priority dates, and reserved-category benefits, and should not be negatively impacted by new regulations or processing delays beyond their control.

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This comment argues: In December 2025, I filed my I-526E petition for a rural EB-5 project as a post-RIA investor chargeable to India. After 14 years of building our lives here and investing a major portion of our savings, my family simply asks for a predictable process that honors these reserved rural visas, so we can finally put down permanent roots and contribute even more fully to the economy we already call home.

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This comment argues: is a Dallas-based EB-5 investment firm that has sponsored over 50 transactions across multiple USCIS-designated regional centers and served more than 1,700 investors. We comment on proposed 8 CFR 204.407(c)(3), 204.407(c)(4), and 204.408(c), which would condition EB-5 eligibility on the lawful derivation of that no EB-5 party owns, controls, or can obtain records about.

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This comment argues: Due to the uncertainty surrounding EB-2 priorities, I decided to invest in EB-5 project under the rules in effect when I made that decision. I have worked hard, paid taxes, and invested my hard-earned money in EB-5 project.

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This comment argues that the commenter am the first person in my immediate family to take such an extraordinary leap. Committing over $800,000 in personal capital to the U.S.

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This comment argues: To Whom It May Concern, I am writing to submit formal comments regarding the Department of Homeland Security’s (DHS) Notice of Proposed Rulemaking (NPRM) published on July 2, 2026, under Docket No. Specifically, this comment addresses two major proposed changes: the elimination of bridge financing as a basis for job creation, and the updated rules governing the investment sustainment period.

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This comment argues: Please define SLA to act on the petition instead of variable processing timeline. This would build trust on the system and have transparency.

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This comment argues: USCIS-2026-0100** **EB-5 Sustainment Period - Two Years From Investor's Transfer of Capital to the NCE** I am an active EB-5 investor, and I respectfully request that DHS establish a clear rule that the EB-5 sustainment period is **two years beginning on the date the investor transfers the required investment capital from the investor's account to the New Commercial Enterprise (NCE), provided the capital is committed to the qualifying EB-5 investment and placed at risk.**...

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This comment argues that the commenter respectfully urge DHS to establish a minimum Employment Authorization Document (EAD) validity period of 5 years for EB-5 investors with pending I-485 applications. The current 18-month EAD validity period creates an unreasonable burden on EB-5 investors for the following reasons: 1.

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This comment argues: My father's medical emergency and the extended delays I have experienced with my travel documents demonstrate why the final rule must establish dependable, fixed timelines rather than compounding uncertainty with administrative hurdles. This isnore about when the capital is at risk and when it should be returned and also the policu change impact for existing vs net new projects.

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This comment argues: As someone who filed my Form I-526E recently in August 2026, my life savings of $800,000 are currently locked in escrow with zero control over when those funds transfer to the job-creating entity. Leaving behind everything with nothing left makes the regulatory stability of this program a matter of urgent personal survival rather than abstract policy.

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This comment argues that the commenter filed my I-526E in October 2025 under the rural category and am still waiting for adjudication. This uncertainty goes beyond immigration processing.

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This comment argues: In early 2026, I submitted my I-526E petition as an Indian national backing a mixed project under the post-RIA framework. Like many applicants, I committed a major share of my life savings into this process based on the established rules of the road.

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This comment argues that the commenter respectfully submit this comment regarding the proposed regulations, particularly the proposed two-year investment period and its interaction with visa availability and redeployment. I understand that the immigration process involves several separate stages and that the timing of petition adjudication and visa availability can vary for reasons outside the control of an individual investor.

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This comment argues that the commenter made my EB-5 investment in Q2 2025, and I have since received my immigrant visa. At this point, one of the most important questions for me is very practical: when has an investor actually completed the required sustainment period, and when can the investment be repaid without creating a problem later during removal of conditions?

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This comment argues: My priority date is April 2025, and I have already received my immigrant visa. My main concern with this rule is how the two-year sustainment period will be applied when I become eligible for repayment and later when I file to remove conditions on my permanent residence.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter generally support the formal codification of a two-year sustainment period pursuant to INA 203(b)(5)(A)(ii) and proposed 8 CFR 204.407(b) and 8 CFR 216.6. Measuring this timeframe from the point at which capital is placed at risk, rather than delaying until visa becomes current, represents a necessary regulatory improvement.

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This comment argues that the commenter sold our home in April 2025 to fund my EB-5 investment in a rural project, at the exact moment my son was starting college - the two biggest financial commitments of my life landing at once. That timing is why the details of this rule matter so much to me, not as an abstraction but as something that will decide whether my family's sacrifice pays off as promised.

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This comment argues that the commenter am chargeable to India, and my investment is in a rural project under the post-RIA program. I made this investment under rules that are supposed to provide a defined path, so it is important that the final regulations give investors clear rules they can rely on when making long-term financial decisions.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter filed my I-526E in January 2026 through a rural project, and my country of chargeability is in the rest-of-world category. I entered the EB-5 process under the post-RIA framework with the expectation that the rules would be clear, predictable, and applied fairly.

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This comment argues: Three years from petition to conditional green card is now typical for EB-5 investors: roughly twelve months for I-526E processing on rural projects, then another two to three years for adjustment of status. During that entire stretch, capital sits at risk with no clear end date.

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This comment argues that the commenter respectfully ask DHS to grandfather projects for which an I-956F was filed before the final rule takes effect. Investors and project sponsors who have already made significant financial commitments and proceeded in reliance on the rules in effect at the time of filing should not be subjected retroactively to new requirements.

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This comment argues: Based on the processing center I have dealt with, the timeline for immigration benefits has been unpredictable. EAD and advance parole approvals are taking more than a year, and the lack of automatic renewal has created significant inconvenience for investors who are committing up to a million dollars to projects that are creating actual jobs.

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This comment argues that the commenter filed my I-526E petition for a rural project in April 2025, committing my family's entire life savings based on agency guidance that my funds could be returned once at risk for two years and jobs were created. Because I lack visibility into the I-485 backlog and processing timelines, my greatest fear is that visa retrogression will trap our money in years of forced, unwanted redeployment, causing severe financial hardship.

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This comment argues: The proposed rule addresses two issues that deserve especially clear treatment: when the required investment period begins and how job creation is credited when bridge financing is involved. Predictable rules on both points are important because investors must make financial decisions based on requirements they can understand in advance.

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This comment argues: For close to two decades I have lived and worked in the United States on an H-1B visa, keeping my status in order and following every step of the legal process. My EB-2 priority date has been pending since 2016, and after nearly ten years without a clear path forward, I turned to EB-5 as another route to permanent residency.

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This comment argues that the commenter support the proposed two-year sustainment period, but the clock should begin when the investment funds are released from escrow to the NCE, since the timing of JCE draws is outside the investor’s control. I am concerned about the proposed bridge-financing change.

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This comment argues: USCIS-2026-0100 I respectfully submit this comment regarding implementation of the EB-5 Reform and Integrity Act of 2022, particularly the interaction among rural priority processing, reserved visas, adjustment of status, removal of conditions, and continuity of employment authorization. Congress created meaningful incentives for rural investment.

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This comment argues that the commenter invested through a TEA high-unemployment project and, as an investor from India, I am particularly concerned about rules that could add uncertainty or delay to an already unpredictable immigration process. I support clear rules that provide certainty while protecting the reliance interests of investors who made decisions under the existing framework.

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This comment argues: In February 2026, I filed my Form I-526E petition tied to an investment in a rural development initiative, with chargeability to India. Having lived in the United States for more than 15 years, paying taxes and supporting my local community throughout that time, I write to share feedback on the proposed regulations concerning adjudications and overall program administration.

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This comment argues: It is good to know that some parts of the proposal gives investors clearer rules, but I am concerned about changes that could disrupt investments and petitions that were structured in reliance on the rules already in place. My case is a post-RIA rural investment from India.

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This comment argues that the commenter filed my I-526E petition in March 2026 after investing in a rural project. I am from India, where visa backlogs and processing delays can keep an investor’s money inaccessible for additional years.

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This comment argues: First, I support a clear two-year investment sustainment period beginning when the investor’s full qualifying investment has been contributed and placed at risk. Investors who satisfy this requirement should not be required to keep their capital invested indefinitely because of visa backlogs, USCIS processing delays, adjudication delays, or other circumstances beyond their control.

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This comment argues: In 2025, I invested $800,000 into a rural targeted-employment-area project - EB5 Capital Aspen Mountain Hotel (JF43) in Aspen, Colorado - through a regional center, and I strongly support the proposed rule’s two-year sustainment period, measured from the deployment of capital. I respectfully urge DHS to retain this provision as proposed.

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This comment argues: My I-526E petition (filed October 2025, post-RIA, India, rural project) will be directly shaped by this rule, so I'm submitting two focused points. On the two-year sustainment period: I support codifying it under INA 203(b)(5)(A)(ii) and proposed 8 CFR 204.407(b)/216.6, but the clock should start at escrow release to the new commercial enterprise, not when funds reach the job-creating entity - JCE draw timing is outside investor control and could quietly extend the at-risk...

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This comment argues that the commenter am worried that adjudication delays for rural projects have now extended beyond nine months, even though the RIA initially set a 120-day target. Given the high USCIS fees paid for an I-526E petition, USCIS should bring average processing times closer to 120 days, including by adding workforce if necessary.

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This comment argues: Supplemental comment on proposed 8 CFR 204.407(e)(1) (bridge financing and job-creation credit), 91 Fed. This comment supplements the comment previously submitted in this docket by , comment ID USCIS-2026-0100-0112, tracking number msr-pe3t-xmrw.

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This comment argues that the commenter put my money into a rural project, and my petition is charged to India, so the queue rather than the business plan will decide how long that capital sits where it is. That gap between the commercial life of a project and the immigration timeline is why the sustainment provisions matter to me more than anything else in this proposal.

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This comment argues: The wait times for I-526E processing are too long and unpredictable. Because of these delays, reserved visas for rural, high-unemployment, and infrastructure projects are going unused.

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This comment argues: Thank you for the opportunity to provide feedback. I want to help make the final EB-5 rules clearer and more predictable for investors making significant long-term financial decisions.

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This comment argues that the commenter have been living in the United States on an H-1B visa for more than 17 years. My employment-based green card priority date is in 2017, and because of the large backlog for India, I do not know when I will receive my green card.

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This comment argues: My family and I chose to seek EB-5 investment after a lot of consideration and due diligence. Investing $800,000 of our hard-earned savings is a big personal risk and we decided to take that leap because of key statutory assurances like a fixed term of 2 years from the day of investment for return of capital eligibility, priority processing of 526E for rural petitions and concurrent filing to obtain travel and work authorization.

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This comment argues: Need effective regulation on when the Sustainment Period starts and avoid exploitation of the investment funds by regional centers, especially the vertically integrated regional centers where the regional center, the NCE, and the JCE (Job Creation Entity) are under the same entity. Today, when the investor funds the investment to the regional center there is no clear timeline on when the investment is moved to JCE for the sustainment period to start.

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This comment argues: In August 2026, I committed $800,000-my entire life savings, leaving me with nothing left-into a rural EB-5 project and filed my Form I-526E. My principal currently sits in an escrow account where I have zero authority over when it gets transferred to the job-creating enterprise.

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This comment argues that the commenter put all of my savings into the EB-5 program after spending around five months choosing a project. My biggest concern is that, even after making such a significant commitment, both my capital and my immigration situation can remain uncertain while investors have limited control over regional centers after investing.

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This comment argues: My I-526E filing plan is from October 2025, and I am an investor from India in a rural project. One of my biggest concerns is having a predictable path to adjustment of status.

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This comment argues that the commenter submitted my Form I-526E in April 2026 under the rural targeted employment area category, with my petition chargeable to India. Facing significant backlogs and unpredictable processing, I rely heavily on clear, fair regulations to protect my investment and immigration path.

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This comment argues: My husband and I have our application for rural EB-5 project submitted in June 2026. We went all in with our savings to make this investment happen and navigating the changing landscape around the regulations and timelines rhymes a constant source of stress in our lives.

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This comment argues: In February 2025, I filed my Form I-526E as a post-RIA investor from India in a rural project. Because visa availability and petition processing can directly affect how long an investor remains tied to an investment, I support clear rules that provide predictability and protect good-faith investors who have complied with program requirements.

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This comment argues that the commenter planned my I-526E filing for November 2025 as a post-RIA investor from India in a rural project. The rules governing how qualifying jobs are counted matter directly to investors like me because investment decisions and project financing structures are established before the immigration process is complete.

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This comment argues: Comment on the Start Date of the EB-5 Two-Year Sustainment Period Re: DHS Docket No. USCIS-2026-0100 I respectfully recommend that DHS and USCIS provide greater clarity in the final rule regarding the start date of the EB-5 two-year sustainment period, particularly for regional center projects involving multiple closings, phased fundraising, or subsequent EB-5 investors.

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This comment argues that the commenter chose a HUA TEA project and invested my life savings only after doing my own thorough research, so that I could trust where that money was going. I filed my I-526E in 2025 as a post-RIA investor in a TEA high-unemployment project, and these two issues affect me directly.

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This comment argues: As an investor who filed my Form I-526E in August 2025 for a rural project, navigating the processing timeline while planning my family's future brings constant uncertainty. Unpredictable wait times for petitions like mine mean that reserved visa categories run the risk of going unused simply because too few files reach adjudication in time.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: Comment on Late-Stage EB-5 Fundraising and Redeployment Re: DHS Docket No. USCIS-2026-0100 I respectfully recommend that DHS and USCIS strengthen safeguards governing late-stage EB-5 fundraising and capital redeployment (Redeployment), so that investors who select Project A do not ultimately bear most of their investment risk in Project B.

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This comment argues: Comment on Delayed Deployment of EB-5 Capital and Investor Protection Re: DHS Docket No. USCIS-2026-0100 I respectfully recommend that DHS and USCIS clarify in the final rule that when an investor has fully contributed the required capital, but deployment is delayed due to the regional center, NCE, JCE, or project, clear time limits, disclosure requirements, and investor protections should apply.

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This comment argues that the commenter support the two-year sustainment period under INA 203(b)(5)(A)(ii), proposed 8 CFR 204.407(b), and proposed 8 CFR 216.6. The clock should run from the moment capital is at risk, not from the date a visa becomes current.

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This comment argues: thanks Agency for this opportunity to submit attached comment regarding definition of "Infrastructure Project" as provided by EB-5 Reform and Integrity Act of 2022.

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This comment argues that the commenter am a post-RIA EB-5 investor, and the uncertainty around the process has made it difficult for my family to travel to India. We have not traveled there in about four years.

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This comment is submitted in response to the U.S. Citizenship and Immigration Services (“USCIS”) Notice of Proposed Rulemaking, EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Classification, 91 Fed.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: The EB-5 process requires investors to make significant financial commitments while depending on immigration timelines they cannot control. I-526 and I-526E processing has become difficult to predict, including the order in which cases are decided.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: When I submitted my Form I-526E in December 2025 for an EB-5 rural project, my family and I took a major step toward building our future in the United States. Even with an approved Form I-956F already in place for the project, my single greatest fear remains the dark box of adjudication timelines for both my initial petition and the subsequent Form I-485 adjustment of status.

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This comment argues that the commenter support the proposed two-year sustainment period and the 180-day good-faith re-association period in the NPRM. I do, however, have concerns about when the two-year sustainment period should begin and would appreciate clarification on reinvestment requirements.

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This comment argues: In June 2026, I filed my Form I-526E for a rural project. I am an Indian-born investor, and I made my decision based heavily on the post-RIA rules.

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This comment argues: My I-526E & I-485 file dates to July 2025, and my investment is in a rural project. 2026, I still await an adjudication of my form I-485 with no end in sight.

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This comment argues that the commenter invested in January 2026 in a rural project, and I am concerned about both my capital and when it can be returned. I am also chargeable to India, so uncertainty in petition and visa processing directly affects how long my money may remain tied up.

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This comment argues that the commenter filed my I-526E in August 2026 for a rural project, and my country of chargeability is India. My concern is being forced into redeployment after I have already completed the required two-year investment period.

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This comment argues: The delays and uncertainty in processing my I-526E and adjustment of status application have made employment authorization and advance parole especially important to me and my family. With processing timelines already difficult to predict, reducing EAD and AP validity from five years to 18 months would add another layer of uncertainty and repeated renewals while I wait for my case to be adjudicated.

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This comment argues that the commenter invested in a rural EB-5 project and filed my I-526E in February 2026. I made this investment with the understanding that my capital could be returned after the loan term and would not remain tied indefinitely to when a green card or visa becomes available.

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This comment argues that the commenter am writing to express my concern regarding the proposed changes to the new interpretation of bridge financing and associated job creation credit in the EB-5 program. Based on existing standard practices, numerous projects obtained Form I-956F approvals where the bridge loan was supposed to be replaced by EB-5 capital.

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This comment argues: Please see the attached full comment regarding DHS Docket No. The principal recommendations are summarized below.

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This comment argues: Thank you for the opportunity to provide feedback. I filed my I-526E for a rural project in June 2026.

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This comment argues: Having committed my family's capital to a rural EB-5 development through Form I-526E in August 2026 under the post-RIA framework, with India chargeability, I submit these comments to ensure the regulations provide workable certainty. Delays and unpredictable order in petition adjudications already risk leaving reserved visa numbers unallocated, making clear, predictable guidelines essential.

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This comment argues: On behalf of in (IIUSA), trade association of EB-5 Regional Center Program, please accept this set of comments on Notice of Proposed Rulemaking (NPRM) published on July 2, 2026 (CIS No. We will be submitting additional comments before commenting deadline.

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This comment argues: In May 2026, I filed a Form I-526E petition alongside a concurrent adjustment of status application for an investment in a high-unemployment targeted employment area, under Indian country chargeability. Having maintained lawful nonimmigrant status in the United States since 2018, my decision to commit capital was guided by the two-year sustainment framework established under the EB-5 Reform and Integrity Act of 2022.

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This comment argues: Eight years ago, my wife and I moved to the United States, taking on substantial education loans that we worked tirelessly to pay off. Seeking long-term stability in this country amidst the constant uncertainty of temporary employment visas, we decided to file our I-526E in April 2026 under the post-RIA high-unemployment Targeted Employment Area category, committing virtually all our life savings into this process.

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This comment argues that the commenter filed my I-526E in September 2025 under the post-RIA EB-5 framework, for a rural project, with India as my country of chargeability. I am submitting these comments because the rules adopted now will directly affect the predictability of my investment, the treatment of my project, and my ability to rely on the rules that applied when I invested.

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This comment argues: Gives the RC and developers a strict timeline to complete the project which is otherwise abused heavily by developers and rcs at expense of tax paying individuals life savings at risk

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This comment argues that the commenter support the proposed two-year sustainment period because it would give investors a much clearer point at which their investment obligation can end. At the same time, the rule should be very clear about when the two years begin and what an investor can do once that period is complete.

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This comment argues that the commenter am an EB-5 immigrant investor with a petition based on an investment in a post-RIA regional center project.

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This comment argues: As a rural TEA I-526E investor (Docket No. USCIS-2026-0100), I submit comments on three related provisions of this proposed rule: (1) the two-year sustainment/duration-of-investment requirement, where I ask DHS to clarify that the clock starts when capital reaches the New Commercial Enterprise rather than the Job-Creating Entity draw, confirm capital return is not contingent on I-829 approval, and oppose forced redeployment without investor consent; (2) the 120-day rural I...

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This comment argues: Codifying a minimum two-year sustainment period under proposed 8 CFR 204.407(b), proposed 8 CFR 216.6, and INA 203(b)(5)(A)(ii) provides helpful regulatory structure. Yet, measuring that timeline from the moment capital reaches the job-creating entity creates an unfair burden.

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This comment argues that the commenter have already put my family's savings at risk in a rural project as a post-RIA investor from India, and I am writing because I am afraid that new interpretations will change the rules after I committed. That uncertainty weighs heavily on my family.

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This comment argues: In 2026 I invested $800,000 into a high unemployment area targeted-employment-area project - Homefed Cota Vera 3 - through a regional center, and I write to strongly support the proposed rule's two-year sustainment period, measured from the deployment of capital. I urge DHS to keep this provision exactly as proposed.

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This comment argues: My EB-5 filing has left me concerned about redeployment and the sustainment period. I support the effort to make the EB-5 rules more predictable, especially where the proposed rule can reduce uncertainty for investors who have already committed their capital and are waiting for their cases to move forward.

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This comment argues that the commenter am the spouse and derivative beneficiary of an EB-5 investor with a pending Form I-526E. Our family's $800,000 investment in a regional center project in a USCIS-designated high unemployment area (HUA) was funded in substantial part by my own lawful employment earnings, which I gifted to my husband for this investment.

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This comment argues that the commenter am an EB-5 investor who, with my spouse, invested the full $800,000 in a regional center project in a USCIS-designated high unemployment area (HUA), in reliance on an approved Form I-956F, and whose Form I-526E is pending. I write on the Department's requested topic C (HUA designation and renewal) and the bridge-financing alternatives (Section IV.D.7).

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This comment argues: Hello, I am a current investor in EB5 program. When my family decided to pursue permanent residency through a rural EB-5 project in April 2025, the statutory changes introduced by the Reform and Integrity Act of 2022 (RIA) were the single most important factor in our decision.

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This comment argues that the commenter filed my I-526E in January 2026, racing a clock that has nothing to do with the merits of my case: my teenage daughter is close to aging out. She has lived in this country since first grade and is now in college, and this petition is the difference between keeping my family together and stable, both financially and emotionally, or watching years of our lives unravel.

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This comment argues that the commenter filed my I-526E in March 2026 as an India-chargeable, post-RIA investor in a rural project. I support the proposed rule in these areas, but request the following clarifications.

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This comment argues: Citizenship and Immigration Services Department of Homeland Security Docket ID: USCIS-2026-0100 I am writing chargeable to India who has invested under the post-Reform and Integrity Act (RIA) framework in a rural project. Because applicants from India face significant visa backlogs, predictable petition adjudication and clear guidance on capital sustainment directly impact my family's future and financial security.

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This comment argues: Having placed my life savings at risk by filing my Form I-526E in January 2026 for a rural project, my foremost personal worry is navigating prolonged and unpredictable wait times. Between slower Form I-485 processing and narrower advance parole travel windows, it is increasingly difficult to visit my aging parents in India while remaining confident about returning to the United States.

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This comment argues: My I-526E petition is filed in March 2026, as a post-RIA investor from India investing in a rural project, and the details of this proposed rule will directly shape how long my capital stays at risk and how predictable my path forward will be. I support writing the two-year sustainment expectation into regulation under INA 203(b)(5)(A)(ii) and proposed 8 CFR 204.407(b), but the start-date language deserves close attention.

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This comment argues: My EB-5 investment is in a high-unemployment TEA project, and my country of chargeability is India. Because I am a post-RIA investor, clear rules about the investment period, job creation, and protections if my regional center fails are especially important to me.

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This comment argues that the commenter am an EB-5 investor with a Priority Date of July 2023. I am Indian born national, and I selected an investment under the post-RIA framework in a high-unemployment TEA.

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This comment argues: My family and I have filed an I-526E for a rural project in Aug 2026, charged to India. Visa availability for overseas appointments remains severely limited, which keeps processing unpredictable and has lengthened overall waits.

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This comment argues that the commenter filed my I-526e petition as a rural investor participating in a hotel development. My immigration journey depends on a well-functioning program, yet current administrative hurdles are deeply concerning.

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This comment argues: am an EB-5 investor in the Yellowstone Club Phase II rural project in Big Sky, Montana. I made my qualifying EB-5 investment in March 2025 in reliance on the EB-5 Reform and Integrity Act of 2022 and the applicable USCIS rules and policies in effect at that time.

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This comment argues: Having waited in the EB-2 line for more than a decade with an Indian chargeability date, I committed my family's life savings in April 2025 to file an EB-5 petition for a rural project. My daughter wants to pursue a career in medicine, and without a viable path to permanent residency, she faces the immediate threat of aging out of her legal status.

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This comment argues that the commenter filed my I-526E in February 2026, after months of researching projects and options since July 2026. In that short window alone, EAD/AP validity dropped from five years to eighteen months, and processing times for I-526Es, EADs, APs, and I-485s doubled or tripled.

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This comment argues that the commenter am an Indian born national, and my investment was structured after the Reform and Integrity Act for a project in a high-unemployment targeted employment area. Because I must rely on my regional center and the project throughout the immigration process, effective oversight directly affects my interests.

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This comment argues that the commenter am writing to provide feedback on the proposed EB-5 rules. Processing for Form I-526E is slow and unpredictable, which risks leaving reserved visa numbers completely unused.

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This comment argues: When I submitted my I-526E petition in March 2026 for a targeted employment area project in a high-unemployment location, I placed my confidence in the integrity and predictability of this path. Charged under India's visa allocation, I am deeply concerned about the expanding adjudication delays affecting every stage of the EB-5 process.

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This comment argues: The benefits/risks of the EB-5 program need to be codified and deterministic. Multiple investors including me who invested in 2025 with the hopes of attaining the concurrent petition filing benefits (526E + 485) of employment authorization and travel document of five years validity had to see this cut short to 18 months alongside steadily lengthening form I-485 processing queues after making the full 800K investment, because of delays from USCIS in adjudicating these petit...

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This comment argues that the commenter filed my petition in September 2025, under the post-RIA rules, in a rural project, with my chargeability to India. What has weighed on me since is not the amount I committed but how little of the road ahead I can predict: the adjustment application, the work permit, and the travel document all sit on timelines no one can forecast.

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This comment argues that the commenter filed my I-526E and I-485 concurrently in May 2025 under the rural EB-5 category. My I-526E has been approved, but my I-485 is still pending.

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This comment argues that the commenter filed my I-526E petition for a rural project in December 2025, and I am still waiting for approval even after 8 months. As an Indian investor, my family and I are deeply concerned that USCIS keeps stretching its processing timeframes without any clear accountability on how long these windows can expand.

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This comment argues that the commenter applied for my I-526E in March 2026, and my biggest concern is that new policies or rule changes could later be applied to investors who already made their decisions and investments, rather than only to future filings. I believe that would be unfair to investors who relied on the rules in place when they invested.

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This comment argues that the commenter am an EB-5 investor from India with an investment in a TEA high-unemployment project. I support several parts of this proposed rule, but I urge DHS to make the final regulations clear, predictable, and protective of investors who have relied on the existing framework.

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This comment argues that the commenter respectfully submit this comment who filed a Form I-526E under the EB-5 Reform and Integrity Act of 2022 (RIA). I support DHS’s efforts to strengthen the integrity, transparency, and accountability of the EB-5 program and to take appropriate action against fraud, intentional misrepresentation, criminal conduct, and other misconduct.

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This comment argues: Background: When I filed my EB-5 case in Nov 2025, I relied on the rules and processing framework in effect at that time. Since then, I have seen how quickly those expectations can change even after an investor has filed.

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This comment argues: My biggest fear is simple: years of immigration delay, followed by uncertainty about my capital. My I-526E file/plan date is May 2025, my chargeability is India, and the project is rural.

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This comment argues: When I submitted my Form I-526E in April 2025 for a rural EB-5 project, I did so relying on the governing framework and established operational records at that time. As an applicant born in India facing significant visa queue delays, I am deeply concerned that shifting regulatory requirements mid-stream will retroactively alter the ground rules of my pending petition and destabilize my family's future.

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This comment argues: As a rural EB-5 investor with a pending Adjustment of Status, I urge USCIS to establish 5-year validity periods and automatic extensions for EADs (Form I-765) and Advance Parole (Form I-131). The EB-5 Reform and Integrity Act of 2022 mandated priority adjudication for rural investments to drive growth in underserved communities.

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This comment argues that the commenter support several parts of the proposed EB-5 rule, but I believe the final rule should provide clearer and more workable protections for investors. My main concerns are the beginning and end of the two-year investment period, the amount of time available after a regional-center failure, and the treatment of investment amounts and future inflation adjustments.

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This comment argues that the commenter submit this comment who made the required investment and filed an immigrant petition and adjustment of status application in reliance on the EB-5 statutory and regulatory framework. I support DHS's effort to implement the EB-5 Reform and Integrity Act (RIA) through clear regulations.

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This comment argues: Title: Public Comment on EB-5 Reform and Integrity Act of 2022 Proposed Rule My EB-5 investment was made under the post-RIA framework, with my project located in a rural area. I am concerned that changes made after investors have already committed capital could alter the rules that those investors relied upon when making their investment decisions.

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This comment argues: After eleven years of working in the United States, I have saved a modest nest egg and am now putting about 75% of it into a rural EB-5 project scheduled for a September 2026 filing. I am taking this step to keep working and eventually retire here, which makes fair rules and honest regional center oversight deeply personal to me.

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This comment argues: The $800,000 I invested is almost all of my life savings. Choosing EB-5 was a very difficult decision because I had to choose between immigration and keeping my life savings due to the immigration problems I was facing.

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This comment argues: Public Comment I made my EB-5 investment with the expectation that I could understand the requirements I needed to meet and plan accordingly. Because the timing of important investment requirements can depend on events controlled by the project rather than by me, I believe the final rule should provide investors with clear and predictable standards.

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This comment argues: The proposed change to bridge financing raises a significant concern for investors whose projects were structured in reliance on the current Policy Manual guidance. Because I have not provided personal timeline or project details, I am focusing this comment on the reliance interests that arise when a project was structured under the existing rules.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: Tighter restrictions would diminish that ability.

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This comment argues: USCIS-2026-0100 EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program Dear U.S. Citizenship and Immigration Services, I am an EB-5 investor who recently filed an I-526E petition with a concurrent I-485 application.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: Protect Existing EB-5 Investors and Preserve Job Credit for Previously Approved Bridge-Financing Structures I am an individual EB-5 investor in a project whose Form I-956F was approved in January 2026. Relying on that approval, the project’s disclosed financing structure, and existing USCIS policy norms, I filed my Form I-526E in February 2026.

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This comment argues: In February 2026, I committed my family's hard-earned savings to an I-956F approved rural project in India's chargeability queue, placing full trust in the rules published by USCIS at that time. Pulling the rug out from under families who thoroughly reviewed active agency guidance and invested in good faith severely undermines the credibility of the entire EB-5 program.

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This comment argues: When I planned my EB-5 investment this year, I understood that my capital could remain committed for a substantial period because of visa availability. What concerns me is the possibility that, even after the required sustainment period has been completed, I could remain unable to recover my investment because capital is redeployed into a project I did not choose.

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This comment argues: U.S. respectfully submits the attached comments concerning DHS Docket No. USCIS-2026-0100 and RIN 1615-AC94.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter am writing to submit a formal comment as an active EB5 investor, regarding the Notice of Proposed Rulemaking (NPRM) published in the Federal Register on July 2, 2026 (Vol. Specifically, my comment addresses the proposed regulations in § 204.426, titled "Redeployment of alien investor capital".

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This comment argues that the commenter am writing to submit a formal comment as an active EB5 investor, regarding the Notice of Proposed Rulemaking (NPRM) published in the Federal Register on July 2, 2026 (Vol. Specifically, my comment addresses the proposed regulations in § 204.426, titled "Redeployment of alien investor capital".

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This comment argues that the commenter filed my I-526E in April 2026 for a rural project. My biggest concern is that rules governing my investment could change after I invested, in ways that negatively affect my eligibility or the job creation of the project I selected under the rules that applied at the time.

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This comment argues: Having spent a decade stuck in the backlogged EB-2 queue, I submitted my Form I-526E in July 2026 under the high-unemployment TEA category for India chargeability. My primary anxiety is that administrative delays in the EB-5 program will stretched into another decade of uncertainty, turning a massive capital commitment into a frustrating waste of time and money while I remain on temporary visas without basic stability or international travel freedom.

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This comment argues: As a prospective EB-5 investor from India intending to invest in a rural project, I am closely following the Department of Homeland Security’s proposed updates to the program. The choices made in this rulemaking will directly impact my financial security and my family’s future path to U.S.

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This comment argues: My investment is tied to a December 2025 I-526E date, and the project already has an approved Form I-956F. I acted based on the requirements that USCIS had established at that time.

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This comment argues: In February 2026, after about 15 years of building our net worth, my wife and I planned to invest $800,000, a significant portion of what we had built, into a rural EB-5 project. We moved forward because the post-RIA framework gave us a reasonable degree of predictability: the required investment period would be a minimum of two years and would not depend on when a visa became available.

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This comment argues that the commenter am an investor from India with a rural EB-5 project. The proposed rule addresses several issues that directly affect how long my capital remains exposed, how job creation is treated, and what happens if my regional center fails.

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This comment argues: My suggestions below: Protect reliance on approved projects. If an I-956F was filed or approved before the final rule, a later amendment should not subject unchanged portions of the project to new substantive standards.

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This comment argues that the commenter planned my I-526E filing for December 2025 after spending years navigating the uncertainty of the U.S. With India as my country of chargeability, timing and visa availability are not abstract issues for me.

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This comment argues: Comment on proposed 8 CFR 204.407(e)(1) (bridge financing and job-creation credit), 91 Fed. , a Dallas-based investment firm and EB-5 pioneer, has for more than 15 years sponsored over 50 EB-5 transactions across multiple USCIS-designated regional centers, served more than 1,700 investors, and deployed EB-5 into projects with total capitalization exceeding $3 billion.

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This comment argues: USCIS should set a definitive two-year sustainment deadline starting from capital deployment. This creates clear expectations, treats applicants from all nations equitably despite visa backlogs, and maintains investor interest while fully protecting U.S.

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This comment argues that the commenter have been legally living and working in this country with my family since 2012. With an EB-2 priority date of 2015 and my elder son having grown up here since he was three and now approaching college, I made a major financial decision in October 2025.

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This comment argues that the commenter am planning to file my I-526E in August 2026 for an investment in a rural EB-5 project. Because my investment is being made under the current rules, clear transition rules and predictable handling of my case are very important to me.

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This comment argues that the commenter filed my I-526E petition in July 2026 for a rural project, and my family has put absolutely everything we have into this process. Because we are subject to the visa backlog for India, my biggest fear is the severe delays and apparent inefficiency at USCIS.

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This comment argues that the commenter invested through the post-RIA EB-5 program in a rural project, and I currently have an I-829 petition pending that I filed in May 2026. The proposed rule addresses important integrity concerns, but it also raises a serious issue for investors and projects that relied on the rules and agency guidance in place when their transactions were structured.

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This comment argues that the commenter have already invested into a project which got initial support from bridge loan and got clear post receiving EB5 investor. I feel that having bridge loan supports project development and reduce risk of project timeline and possible going into default.

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This comment argues: To USCIS, Preparing to file my I-526E petition for a high-unemployment targeted employment area project in the second quarter of 2026 has demanded immense planning. I appreciate the opportunity to provide feedback on this proposed rule.

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This comment argues that the commenter filed my I-526E petition in March 2024 based on a rural project, and my I-485 was approved in May 2025. Because my application was approved under an already approved I-956F, my investment should be governed by the laws in place at that time.

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This comment argues: On bridge financing, I am concerned about the proposed change and how it would reach projects already underway. Bridge financing is standard in real estate and infrastructure - a large share of projects rely on temporary capital that EB-5 funds later replace - so a rule that stops counting jobs tied to repaid bridge loans would unsettle deals structured in good faith under current guidance.

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This comment argues that the commenter filed my I-526E for a rural EB-5 project in September 2026, and I am concerned about how the proposed changes could affect investors who have already made decisions based on the rules and guidance in place when their projects were structured. I appreciate DHS’s effort to provide clearer rules, but the final rule should protect reasonable reliance by investors in pending cases.

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This comment argues: Bridge loans Allow bridge financing but impose restrictions, such as: * maximum bridge-loan maturity; * limiting the percentage of project costs funded through bridge financing; * requiring a stronger connection between the bridge financing and the EB-5 capital.

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This comment argues: My capital sits in a high-unemployment targeted employment area project, my petition falls on the post-RIA side of the line, and my country of chargeability is India. That combination means the rules this proposal settles will govern my case for years, and the details of the drafting matter more to me than the general direction.

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This comment argues that the commenter am planning to become an EB-5 investor as a future filer from India. Before making such a major financial commitment, two points are especially important to me: how long my capital will remain invested and how much I will be required to invest.

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This comment argues: In April 2026, I filed my Form I-526E petition for a rural project. Facing India chargeability, my main anxiety stems from the potential for endless capital redeployment, where investors are routinely left with unsatisfactory choices.

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This comment argues that the commenter filed my I-526E in November 2025, and I am now about one year into the process. I am a post-RIA investor from India in a rural project.

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This comment argues that the commenter have been in this country since 2012, legally working and maintaining the required paperwork. After waiting since 2015 for an employment-based green card through EB-2 for India, my family and I relied on the EB-5 process created by Congress.

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This comment argues that the commenter value the United States deeply and want to continue building my life here. I invested $800,000 in EB-5, putting almost all of my retirement savings into the program, and that capital has already been invested and at risk for about a year.

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This comment argues that the commenter filed our EB-5 application in June 2026. Before our investment, we were told that the maximum time for funds to be deployed to the JCE would be 90 days, but afterward that estimate changed to three to six months.

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This comment argues: To the Department of Homeland Security and U.S. Citizenship and Immigration Services: USCIS-2026-0100).

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This comment argues that the commenter filed my I-526E in November 2025 as a post-RIA investor from India in a rural project. I made my investment and filing decisions under the EB-5 rules and agency guidance then in place.

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This comment argues that the commenter assume you mean 5,000 characters (the regulations.gov comment field limit), not 5,000 words. Here’s a tighter version that preserves all your required points.

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This comment argues that the commenter am writing on DHS Docket USCIS-2026-0100-0001. I filed my Form I-526E in January 2026 as a post-RIA investor.

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This comment argues: My I-526E petition has now been pending for one year after we applied in September 2025 as a post-arrival investor from India. Because my daughter came to the United States at the age of one and is starting college this year, we are facing the reality that she will age out in about three years and is currently missing vital internship opportunities to learn and build her future.

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This comment argues that the commenter am a post-RIA investor in a rural EB-5 project. I appreciate the opportunity to comment on this proposed rule because clear and predictable rules are important to investors who rely on the EB-5 program.

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This comment argues that the commenter am a post-RIA investor in a rural EB-5 project. I appreciate the opportunity to comment on this proposed rule because clear and predictable rules are important to investors who rely on the EB-5 program.

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This comment argues that the commenter am a post-RIA investor from India in a high-unemployment TEA project. I have already committed my capital to the EB-5 process, and my investment was made based on the rules and USCIS guidance applicable to the project at that time.

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This comment argues that the commenter plan to file my I-526E petition in July 2026 as an investor chargeable to India in a high-unemployment TEA project. Because this proposed rule could affect projects that are already being structured under existing guidance, I appreciate the opportunity to submit these comments.

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This comment argues that the commenter am filing this public comment as an individual EB-5 investor. In 2025, I committed $800,000 to a rural Targeted Employment Area (TEA) initiative-specifically the Yellowstone Club Phase II project in Big Sky, Montana, facilitated through an approved regional center.

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This comment argues that the commenter am writing to share my comments on the proposed rules for the EB-5 program (USCIS-2026-0100). Having filed my I-526E in March 2025 for a rural project under India country chargeability, I have a direct interest in how these regulations are finalized.

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This comment argues that the commenter commend the Department for proposing a definition of "infrastructure project" and for inviting comment on that definition and the documentation needed to establish eligibility. This comment focuses on a single issue the commenter believes is critical to ensuring the set-aside functions as Congress intended: expanding the range of qualified entities that may participate in EB-5 financing while preserving the governmental role in administering public infrastructure projects.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues that the commenter support aligning the sustainment period to long-term job creation. Two years is insufficent for meaningful investment.

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This comment argues that the commenter support strengthening EB-5 integrity, but I urge DHS to add an explicit, lifecycle-wide grandfather clause. As drafted, the rule would apply new substantive standards to investors who committed capital and filed before this rule was proposed, and who will first encounter those standards at the Form I-829 stage, when nothing can be restructured.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: 2770-24; RIN 1615-AC94 - "EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Immigrant Classification," 91 Fed. The full comment is attached as a PDF; this field summarizes it.

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This comment argues: Defining qualifying infrastructure projects generically leaves decision-making too arbitrary. Providing more specific examples, or at least providing a more detailed definition of categories, would reduce confusion and increase the probability of approval.

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This comment argues: In 2025, I invested $800,000 into a rural Targeted Employment Area (TEA) project through a regional center. I am writing to strongly support the proposed rule's two-year sustainment period, measured from the deployment of capital, and I urge the Department of Homeland Security (DHS) to adopt this provision exactly as proposed.

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This comment argues that the commenter submit this as a good-faith EB-5 investor who invested in reliance on a project application (Form I-956F) and petition (Form I-526E) that USCIS approved under the rules then in effect, and who has not yet filed to remove conditions (Form I-829). I support program integrity, but three provisions, if applied to investors already in the program, would break faith with those who followed the rules as they existed.

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This comment argues: DHS should expressly confirm that the new job-creation standards in proposed 8 CFR 204.407(e) - particularly the elimination of bridge financing and the "but-for" nexus requirement - will not be applied at the removal-of-conditions (Form I-829) stage to investors whose project applications (Form I-956F) and petitions were approved before the effective date. Applying these standards to such investors would give the rule an impermissible retroactive effect on completed trans...

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This comment argues: As a good-faith EB-5 investor whose project application and petition were approved by USCIS under the rules in effect at the time of my investment, I respectfully urge DHS to apply the substantive job-creation changes in this rule particularly the elimination of bridge financing (proposed 8 CFR 204.407(e)(1)), the "but-for" job-creation nexus, and the prohibition on visitor-spending methodologies (proposed 8 CFR 204.407(e)(3)(iv)) prospectively to new investors only, and n...

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This comment argues that the commenter am a conditional permanent resident who invested in the EB-5 program in good faith and whose project application and petition were approved by USCIS under the rules in effect at the time. I have not yet filed to remove conditions.

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This comment argues: 2770-24; RIN 1615-AC94 - "EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program; Automatic Revocation of Petitions for Immigrant Classification," 91 Fed. The complete comment, with full analysis and proposed regulatory text, is attached as a PDF; this field summarizes it.

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This comment addresses proposed 8 CFR 204.407(c) and 204.401, which appear to require EB-5 petitioners to document the lawful source of ALL capital in the NCE - including funds from non-petitioner co-investors not seeking EB-5 classification. I respectfully submit this requirement is inconsistent with the existing regulatory framework, practically unworkable, and has already been rejected by a federal court.

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This comment argues: COMMENT SUMMARY - Docket USCIS-2026-0100 This comment addresses two interconnected concerns with the proposed rule implementing the EB-5 Reform and Integrity Act of 2022: COMMENT ONE - Sustainment Standard (Proposed 8 CFR 216.6(d)(1), 91 FR at 40770-72): The proposed rule creates a two-tier sustainment system that subjects pre-RIA investors to an open-ended sustainment obligation lasting fourteen to sixteen years due to visa retrogression, while post-RIA investors satisfy...

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This comment argues: Elimination of Repaid Bridge Financing as Qualifying Capital Prohibiting the use of EB-5 capital to repay bridge financing severely prejudices existing EB-5 applicants and Regional Centers (RCs) that structured their financial and job creation plans around established USCIS policies. Regional Centers routinely rely on bridge loans to advance critical funds to Job-Creating Entities (JCEs) while I-956F applications remain pending.

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This comment argues: USCIS-2026-0100) that seeks to eliminate the use of bridge financing for job creation in the EB-5 program. While I fully support USCIS’s overarching goal of ensuring program integrity under the EB-5 Reform and Integrity Act of 2022 (RIA), a blanket ban on bridge financing is a fundamentally flawed approach that will severely undermine the legislative intent of the EB-5 program: economic growth and job creation.

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This comment argues: As an existing investor in EB5, I find the clause about prohibiting the use of EB5 capital as a bridge loan concerning. Applying such a new enforcement for existing investors may jeopardize their immigration plans and may cause financial loss as well.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: On behalf of , please find attached This comment on the proposed rule, EB-5 Reform and Integrity Act of 2022; Ensuring the Integrity of the EB-5 Program (DHS Docket No. This comment addresses the proposed definition of "Infrastructure Project" at proposed 8 CFR 204.401 and the scope of "public works project," and responds to the Department's specific request for comment on the types of projects that may meet the definition of an infrastructure project (Public Participation,...

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This comment includes an attachment on regulations.gov. Open the filing to read the full text; no separate body text was posted in the API.

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This comment argues: USCIS-2026-0100 Comment on proposed 8 C.F.R. § 204.410(b)(1) - material changes; source of capital I am an immigration attorney with more than 15 years of EB-5 experience representing hundreds of investors worldwide, especially H-1B professionals who have spent years contributing to the U.S.

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This comment argues: Comment on Proposed Rule Regarding Full-Time Employment I respectfully urge DHS to retain the current allowance for job-sharing arrangements within the definition of full-time employment. While job-sharing may have been used infrequently in prior EB-5 petitions, it remains critically important for many direct EB-5 businesses, particularly in the food and beverage (F&B), hospitality, retail, and franchise industries.

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This comment argues that the commenter am writing to submit a formal comment regarding the proposed rule implementing the EB-5 Reform and Integrity Act of 2022 (RIA), specifically concerning the definition and commencement trigger of the 2-year sustainment period for post-RIA Regional Center investors. While the proposed rule helpfully codifies the transition to an investment-based timeline rather than a residency-based timeline, the current language regarding when capital is considered "placed at risk" and "...

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This comment argues: In 2025 I invested $800,000 into a rural targeted-employment-area project - Yellowstone Club Phase II in Big Sky, Montana - through a regional center, and I write to strongly support the proposed rule's two-year sustainment period, measured from the deployment of capital. I urge DHS to keep this provision exactly as proposed.

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This comment argues: This proposed change is going to hurt the US economy more than help since it will prevent from a lot of potential investors to invest capital in US markets and eventually hurt economic development and local economy in general.

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This comment argues: The proposed rule grants DHS broad authority to impose monetary penalties, suspensions, debarments, and terminations on regional centers, but it does not clearly specify evidentiary standards, appeal timelines, or proportionality guidelines for these sanctions. Without more precise procedural limits, this creates a real risk of arbitrary or inconsistent enforcement, and could expose good-faith investors to loss of status or capital based on a regional center’s miscon...

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This comment argues: Thank you for the opportunity to comment on this proposed rule implementing the EB-5 Reform and Integrity Act of 2022. I appreciate USCIS’s efforts to strengthen program integrity, improve transparency, and protect good-faith investors.

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This comment argues that the commenter strongly support extending the EB-5 investment sustainment period beyond two years. The primary purpose of the EB-5 program is to promote long-term investment, sustained economic growth, and job creation in our country.

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This comment argues that the commenter strongly support the proposal to eliminate the use of repaid bridge financing as a basis for demonstrating EB-5 job creation. In EB-5 practice, it creates significant abuse.

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This comment argues: While supporting the goal of protecting genuine good-faith investors when a Regional Center is terminated or an NCE/JCE is debarred through no fault of the investor, I believe the proposed regulation may generate potential collusion and moral hazard. Specific Recommendations: Expand the circumstances where priority date retention should be denied to include situations involving the investor’s own fault or lack of due diligence, not only proven fraud.

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This comment argues: Comment 1 - 8 CFR 204.425(a)(2): Define how the fund administrator's "cosignature" is executed. The rule requires the fund administrator to "serve as a cosignatory on all separate accounts" and to approve transfers "with a written or electronic signature," but does not say how - bank signature card, dual-authorization on each wire, or platform-based electronic approval.

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This comment argues that the commenter invested $800,000 through a USCIS-designated regional center after the EB-5 Reform and Integrity Act. My family has already received our conditional permanent residence, and one of the reasons I was comfortable making this investment was USCIS's guidance that the required sustainment period is generally two years from deployment of the capital.

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This comment argues: Re: Proposed 8 CFR 204.401, Definition of "Capital" - Treatment of Trust Structures and Retirement-Account-Sourced Funds; Request for Transition Clarity Given the September 30, 2026 Grandfathering Deadline I. Introduction This comment addresses the proposed definition of "capital" at 8 CFR 204.401, limiting trust-held capital to assets "held in a revocable living trust of which the investor is the settlor and beneficiary and to which the investor has unrestricted access."...

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This comment argues: Supplemental Comment Regarding the Meaning of “Qualifying Investment” Under INA Section 203(b)(5)(M) I respectfully submit this supplemental comment regarding DHS’s proposed implementation of INA section 203(b)(5)(M), specifically the meaning of “qualifying investment” when a good-faith investor seeks to preserve eligibility after regional center termination or NCE/JCE debarment. The proposed rule should clarify how USCIS will interpret &ldquo...

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This comment argues: INTRODUCTION This comment is submitted in strong SUPPORT of the Notice of Proposed Rulemaking (NPRM) regarding the EB-5 Regional Center Program (91 FR 40676). The commenter is an advocate for working-class economic integrity.

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This comment argues: As an individual EB-5 investor, I strongly support the proposed rule’s codification of the two-year sustainment period measured from the date capital is fully deployed and made available to the job-creating entity. I made my investment under the post-RIA framework with the understanding that my capital would need to remain at risk for at least two years, not for an open-ended period tied to unpredictable visa backlogs or processing delays.

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This comment argues: Please release my investment in 2 years. I trust Reform Integrity Act & am awaiting my funds for leading a better life in USA.

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This comment argues: EB5 United/RC gave me confidence that my capital wouldn't be trapped indefinitely, and it was mentioned in the PP that the investment’s sustainment period is 2 years from the date deployment in the project. Extending this period would have made me reconsider the investment entirely.

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This comment argues: USCIS should adopt a clear rule that the EB-5 sustainment period ends two years after capital deployment. This approach provides certainty, treats investors from all countries fairly regardless of visa backlogs, and encourages continued participation in the EB-5 program while fully preserving the program’s job creation objectives.

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This comment argues: Reform Integrity Act is a soule of EB5 program. That 800k repayment help me for start ups and Make America Great Again.

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This comment argues that the commenter chose to invest $800,000 in an EB-5 project in Montana because the two-year sustainment period provided clarity and confidence that my investment would not remain tied up indefinitely. If the rules had allowed for an open-ended investment period, I likely would not have moved forward with the investment.

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This comment argues: The 2 year sustainment period makes sense, since that is a realistic time frame for creating jobs. We invested the amount keeping this timeline in mind and the rule gives us peace of my mind in case there's a backlog for my country.

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This comment argues that the commenter am writing to express my strong opposition to any extension of the EB-5 sustainment period.As an immigrant investor, I committed $800,000 of my personal capital into a project in YellowStone Big Sky.My decision to invest was heavily based on the clear, structured rules in place-specifically, the two-year sustainment period. Extending this period retroactively or changing the expectations mid-stream undermines investor trust and creates severe financial unpredictability f...

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This comment argues: Eliminating the use of repaid bridge financing as a basis to demonstrate - This elimination will create tremendous problem for the existing EB5 visa applicants who has filed petition based on regional center operation where investment are made based on I-956F filing and RC has already structured the project financials and job creation planning based on existing USCIS policies. Bridge finance is a widely used strategy for Regional Centers when they accept EB5 applicants bas...

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This comment argues that the commenter respectfully submit this comment regarding the proposed implementation of protections for good-faith EB-5 investors, including the provisions related to INA section 203(b)(5)(M), amendments, subsequent investments, and removal of conditions. DHS should clarify in the final rule that, for a good-faith investor who previously invested the full required amount of capital and whose capital was sustained at risk but later lost due to business failure, fraud, receivership, reg...