There is very little public information on the inner-workings of USCIS and more specifically on USCIS’ EB-5 program adjudication process. Each time a prospective Regional Center submits an I-924 application it feels a bit like the application is going into a black box, where it could be adjudicated within a few months or it may not be looked at for nearly a year.
EB5AN has observed the application process from a unique angle – after submitting over a dozen regional center applications, all with a similar level of rigor in document preparation, we have been able to observe some of the various paths applications go through when being adjudicated by USCIS.
Earlier this year we submitted several I-924 applications within a few weeks of each other. From outside observation, we could tell each application went to a different “team” within USCIS. Each of these teams processed the applications very differently, with key differences including: time for initial review, length of review, focus of RFE’s, and the quantity and extensiveness of RFE’s.
Based on our extensive experience we have been able to gain some useful strategies to leverage when applying for new regional centers, even those with expansive geographic coverage. One of the things we have learned is that having substantial and in-depth evidence across the entire geographic area is a necessity for approval for the larger county group. The most critical additional analysis is related to the business plan / operations plan and the detailed job impact analysis. Multiple detailed local analyses are needed for larger geographic areas.
Due to our experience EB5AN has developed unique approaches to I-924 applications based on our extensive experience working with USCIS in the Regional Center application process. Going forward we will continue to monitor the processing times and tendencies based on our application volume and continue to gain insight from their operations.