USCIS Approves two Behring I-956F Projects in 1 day.

December 6th, 2023 Greg Sheehan

Both the debt and equity funds for 1900 Broadway are cleared for I-526E approvals. The continues Behring perfect approval history with USCIS.

What does an I-956F project approval mean?

  1. USCIS formally approved the post 2022 RIA business plan, TEA and job creation strategy. A full description of the 1900 Broadway project can be found on our website. Building multifamily real estate in the San Francisco Bay Area 100% focused on construction jobs is still a very successful strategy for EB-5 investment. 1900 Broadway specifically has already created over 2,700 jobs and counting. That update was provided to USCIS prior to this approval and was included in their consideration to issue approval. With less than 270 Investors subscribed to the 1900 Broadway project, we have successfully created over 100% of the requisite jobs for all investors subscribed.
  2. USCIS formally approved the post 2022 RIA Investment Offering terms and conditions. With this approval, we gain some critical insight and confirmation that USCIS is 100% onboard with all Behring strategies listed in the official offering documents. Those insights include but are not limited to the following:
  3. USCIS approved the ability to blend a single $800,000 investment across multiple share classes (Preferred Equity and Common Equity) in the same offering. Behring’s Legacy fund was the first of its kind for the EB-5 world. Many investors want to diversify their risk and with Behring they can choose between Common Equity (higher returns), Preferred Equity (Priority return of capital) or blend their investment across both options. The strategy was already originally approved Pre-RIA with a successful I-924 approval and multiple investor I-526 approvals.
  4. USCIS approved the use of multiple NCE’s to invest in multiple structures and share job creation credit from a single project.
  5. USCIS approved Behring’s strategy of utilizing bridge financing while EB-5 capital is placed. This preserves any job creation that occurred while using bridge financing prior to an investor being found.
  6. USCIS approved Behring’s template framework for investors investing over time with installments or partial capital contributions. Behring’s USCIS approved offering documents contemplate investors using partial capital contributions, describes the process and this was all included in the USCIS approval. Investors looking to financially plan their investment over time can feel confident that USCIS has issued yet another approval on the strategy directly to Behring.
  7. USCIS approved Behring’s open-end fund structure where Investors purchase individual units and the Redemption Plan allows the sale of some or all individual units after investors complete their initial investment commitment. Almost every EB-5 project is a closed-end debt focused fund and the old strategies were so pronounced that some investors thought that what we are doing was not part of the EB-5 rules. This USCIS I-956F approval should end all-doubt on the strategy.
  8. Investor I-526E’s for 1900 Broadway will start being approved. USCIS will now look to this I-956F approval with deference and it will pave the way for expedient I-526E investor approvals. USCIS is likely to only refer to the Investors personal information and source of funds report to issue approval.

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