(a) General.
In 1990, Congress created the Employm ent Creation Immigrant Visa Category (EB-5). Section 121(a) of Public Law 101-649 (Nov. 29, 1990) . Section 203(b)(5) of the Immigration and Nationality Act, as amended, allows for admission to permanent residence on a two-year conditional basis to qualified aliens who will contribute to the economic growth of the United States by investing in U.S. businesses and creating needed employment opportunities. In 2002, Congress amended the EB-5 statute. Those amendments are discussed in paragraph (h), below.<br>
(1) Basic (Non-Pilot Program) Provisions .
Section 203(b)(5) of the Act authorizes up to 10,000 visas each fiscal year to alien entrepreneurs (along with their spouses and unmarried minor children) who have invested or are actively in the process of investing in a new commercial enterprise.
The new commercial enterprise may take any lawful business form, including a limited partnership, and must both benefit the U.S. economy and directly create full-time employment for not fewer than 10 “qualifying employees,” defined as U.S. citizens, lawful permanent residents, or certain other immigrants lawfully authorized to be employed. Noncommercial activities, including home ownership, do not qualify. In general, the Act established a threshold investment amount of one million U.S. dollars ($1,000,00 0.00). In order to encourage the investment in new enterprises located in areas that would most benefit from employment creation, section 203(b)(5)(B) of the Act sets aside on an annual basis 3,000 of the available 10,000 EB-5 visas for qualified aliens who have made investments in “targeted employment areas.” Such targeted employment areas are defined in the Act to include rural areas and areas which have experienced high unemployment. The investment amount for investing in a targeted employment area is currently set at five hundred thousand dollars ($500,000.00).
(2) Regional Center Pilot Program .
Under a Pilot Program first instituted in 1992, up to 3,000 visas (of the 10,000 total available EB-5 visas) are set aside for aliens who invest in a “regional center” (as designated by DHS) in the United States set up “for the promotion of economic growth, including improved regional productivity, job creation, and increased domestic capital investment. Section 610 of Pub. L. No. 102-395, as amended by section 116(a)(l) of Public Law 105-119 and section 402(a) of Pub. L. No. 106-396 . In addition, a regional center may, but need not, be set up for the purpose of increasing export sales.
Under the Pilot Program, aliens investing in new commercial enterprises located in regional centers are not required to demonstrate that the new commercial enterprise itself employs ten U.S. workers; a showing of indirect job creation and improved regional productivity will suffice. Implementing regulations for the Pilot Program are found at 8 CFR 204.6(m) .
Note: Other than the ability to demonstrate indirect creation of ten full-time jobs, all other requirements applicable to other EB-5 investors must be met.
(b) Governing Factors .
8 CFR 204.6(a) cites several governing factors which you must consider. They are:
• A visa petition must be filed;
• A fee for filing the petition is required;
• Before the petition is considered properly filed, the petition must be signed by the petitioner and the initial supporting documentation required by this section must be attached;
• The petition must be filed with the Service Center having jurisdiction over the area in which the new commercial enterprise is or will be principally doing business. For EB-5 petition filing purposes, the Texas Service Center has jurisdiction over its own territory and the territory of the Vermont Service Center; the California Service Center has jurisdiction over its own territory and the territory of the Nebraska Service Center;
• The appeal of a denial of this petition is to the Administrative Appeals Office; and
• The approval of the petition is valid indefinitely, provided that the investment remains qualifying.
(c) Preliminary Action . (after petition has been accepted and fee paid).
(1) When to Create a File . If the alien petitioner is in the United States, search for an existing "A" file. If none exists, create one. If the beneficiary is not in the United States, no file should be created, unless the petition is to be denied.
(2) Priority Date . The priority date of a petition for classification as an alien entrepreneur is the date the petition is properly filed with USCIS.
(3) General Review . Review the petition for completeness and signature of the petitioner.
• Verify that the name given in Part 1 (Information about you) is identical to the signature in Part 7 (Signature block).
• Remember that the petition can only be signed by the petitioner and not by his or her authorized representative.
(4) Review of Supporting Documents . When reviewing the documentation submitted in support of the petition you should keep in mind the following factors:
(A) Investment in a New Commercial Enterprise .
• Whether the alien creates an original business, purchases an existing business, expands an existing business, or joins with a pool of investors who have already invested in an existing business, his or her action must be taken after November 29, 1990. The statute requires it, and the definition of the word "new" means created after November 29, 1990.
Note: [5 USC 552(b)(2) and 5 USC 552(b)(7)(E)]
If the petitioner submits evidence that the new commercial enterprise was a result of simultaneous or subsequent restructuring or reorganization of an existing business, the commercial enterprise that is the result of this action must be a new legal entity. Thus, there are three ways to invest in a new commercial enterprise: creation of brand new business, purchase of an existing business, or expansion of an existing business. You must keep in mind that in order for the business to qualify as a new commer cial enterprise, any of the above actions must have taken place after November 29, 1990.
• You must look at the evidence presented to demonstrate the date of creation of the business to determine whether it is a “new” commercial enterprise. In general, the business must have been created AFTER November 29, 1990. If the business was created BEFORE November 29, 1990, it cannot qualify, unless the petitioner can demonstrate expansion of the business after November 29, 1990. If the business was created prior to November 29, 1990, issue a RFE explaining this requirement, and requesting evidence rela ting to post-November 29, 1990, expansion.
• To qualify for creation based on expansion, the petitioner must invest the required capital in the existing business, and demonstrate that the investment has increased, by 40 percent, either the number of employees or the net worth of the business. The petitioner will still be required to employ ten additional employees before the conditional basis of his or her EB-5 permanent resident status may be removed.
(B) Investing the Required Amount of Capital . You should always be aware that the statutory requirements of investing the prescribed amount of capital and the creation of new jobs apply no matter how the alien seeks to demonstrate investment in a new commercial enterprise. These requirements apply even if the alien is investing in a new commercial enterprise that purchases an existing business. The alien is still obligated to show that he or she has invested the prescribed amount of capital (some of which would probably be the purchase price of the old company) and that 10 new jobs would be created in addition to the employees of the purchased company. A mere intent to invest does not suffice for EB-5 purposes. The petitioner must actually have committed the capital to the new commercial enterprise.
Note: “Capital” is defined to include cash, equipment, inventory, other tangible property, cash equivalents and indebtedness secured by assets owned by the alien provided that he or she is personally and primarily liable and the assets of the new commercial enterprise are not used to secure any of the indebtedness. If the alien uses a secured note, the alien must be able to show that this note has a real cash value, and that the total value of all capital invested, including the note, has a cash value equal to o r greater than the statutory minimum.
Note also: As discussed below, all of the requisite capital must go directly into the new commercial enterprise; amounts paid for “administrative fees, attorneys’ fees,” “finders’ fees” and other types of expenses not directly paid into the new commercial enterprise will not count towards the minimum investment amount.
Note further: The term “invest” is defined as a contribution of capital. In determining whether the full amount of capital has been invested, adjudicators should be aware that proceeds that are left (i.e., “reinvested”) in the business do not count toward meeting the minimum investment requirement. Further, adjudicators should be aware that an EB-5 petitioner must make an equity investment in the commercial enterprise; a mere loan from the alien shareholder or partner to the business does not qualify as an investment of capital for purposes of the EB-5 statute. Thus, contributions of funds to the commercial enterprise, in exchange for a note, bond, convertible debt, obligation, or any other debt arrangement, cannot be counted toward meeting the minimum capital requirement. Balance sheets, including those incorporated into tax returns, generally, but not necessarily, should reflect the amount of equity versus debt contributed to the commercial enterprise. The determination as to what constitutes debt or equity is, in the final analysis, a question of fact, and not simply a matter of what is reflected on a balance sheet.
(C) Investment of Capital Obtained Through Lawful Means . The regulation at 8 CFR 204.6(j)(3) indicates that the petitioner is to submit documentation "as applicable" that investment capital has been obtained through lawful means. Since it is often difficult to determine the source of the capital used for the investment, there is no clear-cut answer as to how far back the petitioner should go to establish that he or she has met this requirement. In making your determination, you should exercise sound judgment. Obviously, if you have reason to believe that more documentation is necessary, it shoul d be requested.
An individual who is operating as a sole proprietor cannot count his or her personal bank account as committed funds. The regulation refers specifically to funds in business bank accounts, not personal bank accounts. This applies to all cases, including sole proprietorships. Funds in a personal bank account are not necessarily committed to the new commercial enterprise.
(D) Job Creation . The petition must be supported with evidence the new commercial enterprise will create no fewer than 10 full-time positions (or the equivalent).
If the petitioner has invested in an existing enterprise, he or she must demonstrate how the investment will cause the creation of at least 10 additional full-time positions. Merely purchasing a share of a business from an existing shareholder, without more, will not qualify, since the payment goes to the former shareholder rather than towards the development of the enterprise.
If the employees have already been hired, the petitioner must submit copies of tax records, Forms I-9 , or similar documents relating to the ten qualifying employees. If the employees have not been hired, the petitioner must submit a comprehensive business plan demonstrating the need for ten new employees. If the petitioner purchases a troubled business, it must be demonstrated that the number of jobs at the pre-investment level will be maintained for at least two years. To qualify as a troubled business, it must have been in existence for at least two years and have incurred a net loss for accounting pu rposes of at least twenty percent of the troubled business's net worth prior to such loss. The loss must have been incurred during the twelve or twenty-four month period prior to the priority date on the I-526 .
If the investment is in a regional center under the Pilot Program, the petition must show, through the use of reasonable methodologies, the likelihood that the business will create ten jobs indirectly. See 8 CFR 204.6(m)(7)(ii) . Such methodologies may include multiplier tables, feasibility studies, and other economically or statistically valid forecasting devices indicating the likelihood that the business will result in increased employment.
Note: You must also keep in mind that full-time employment as defined in 8 CFR 204.6(e) means year-round employment and not seasonal full-time employment. Full-time employment consists of 35 hours a week. Regulations permit the combining of certain part-time positions to equal one full-time equivalent position for purposes of meeting the job creation requirement. Seasonal positions do not qualify for purposes of the full-time employment requirement.
(E) Alien Petitioner Engaged in the Management of the New Enterprise . The alien petitioner must be involved in the new enterprise by either exercising managerial control of the day-to-day operations or through policy formulation. The alien petitioner cannot just invest in the new enterprise; he or she must be involved in the new enterprise. An alien must be “actively involved in the business;” a purely passive investor may not qualify for the EB-5 classification. Se e 8 CFR 204.6(j)(5) . While an alien may seek EB-5 qualification on the basis of an investment in a limited partnership, under current regulations, even he or she, as a limited partner, must have a certain level of involvement in the running of the business. Under 8 CFR 204.6(j)(5)(iii) , if the alien is a limited partner, he or she must have been granted all (i.e., not simply some) of the rights, po wers, and duties granted to the other limited partners in the partnership in order to be considered sufficiently engaged in the business.
(F) New Commercial Enterprise in a Targeted Employment Area . As noted, a targeted area is either a rural area or an area experiencing a high unemployment rate at the time the qualifying EB-5 investment is made. If the petitioner shows that the area where he or she is investing is a rural area, the petitioner need not also establish that the area has high employment. Conversely, if the area is a high unemployment area, the petitioner need not also show that it is a rural area.
• A rural area means any area outside of a metropolitan statistical area (MSA) or an area outside of a city or town having a population of 20,000 or more. See section 203(b)(5)(B)(iii) of the Act. MSAs are designated by the Office of Management and Budget and can be found on the Internet at www.census.gov .
• A high unemployment area may include an MSA, a county, city, or town, or, other political or geographical subdivision designated by a State authority (appointed by the State’s governor) as having an unemployment rate of at least 150% of the national unemployment rate. For a political or geographical area other than an MSA, county, city, or town, the State authority must also certify, in writing, that such area is in fact a “high unemployment area” meeting the requisite 150% unemployment rate standard. If the State governor has n ot designated an official for this purpose, an alien petitioner must demonstrate that, at the time when the petition is filed, there has been an unemployment rate of at least 150% of the national unemployment rate within the MSA or other non-rural area in which the ten newly created positions is located (or in the case of a troubled business, the location of the ten saved positions). This should be based on the most recent information available from Federal or State governmental sources as of the time the p etition is submitted. An adjudicator, of course, must be satisfied of the veracity of any documentation as well as the substance of the information submitted by the petitioner. If the adjudicator has reason to believe that the information submitted by the petitioner fails to meet either of these criteria, he or she of course is not obligated to approve the petition.
(d) Approval of the Petition .
(1) Affix the approval stamp on the Form I-526 and sign.
(2) An approved visa petition should be sent to the specified embassy or consul or if petitioner is requesting adjustment, then the petition should be routed (with file) to the main file shelf waiting request by field office.
(3) Keep a record of statistics (approvals, denials, returned, etc.)
(4) Update CLAIMS with appropriate information. Do not place on clerical hold unless there is documentation to be sent back to the petitioner.
(e) Action to be Taken if the Petition is Denied .
Denial decisions will be prepared on Form I-292, usually with the reference "SEE ATTACHMENTS." The attached pages will cover the specific grounds for denial as determined from the evidence. Form M-188 (on appeals and motions) and Form I-290B will be attached to all visa petition denials. It is essential that any denial you prepare be premised solely on the evidence submitted. Refer in your denial to controlling statutes and regulations. Where the decision is motivated by or governed by any published decisions, reference to those decisions must be made in the approved format. Your decision should be written in direct and comprehensible language. All reasons for denial should be included. In all denial cases, an "A" file must be used to hous e the petition and supporting documents. Copies of the decision must be sent to the petitioner and any attorney of record. Once your supervisor has signed off your denial, CLAIMS should be updated to reflect that the case has been denied.
(f) Revocation of Petitions . Visa petitions approved under section 204 of the Act may be revoked under the provision s of section 203(e) or section 205 of the Act.
(g) Precedent Decisions . The following precedent decisions relate to employment creation petitions:
• In re Soffici, ID #3359 (Commr, 1998). (1) A petitioner under section 203(b)(5) of the Act cannot establish the requisite investment of capital if he lends the money to his new commercial enterprise. (2) Loans obtained by a corporation, secured by assets of the corporation, do not constitute capital invested by a petitioner. Not only is such a loan prohibited by 8 CFR 204.6(e) , but the petitioner and the corporation are not the same legal entity. (3) A petitioner's personal guarantee on a business's debt does not transform the business's debt into the petitioner's personal debt. (4) A petitioner must present clear documentary evidence of the source of the funds that he invests. He must show that the funds are his own and that they were obtained through lawful means. (5) A petitioner who acquires a pre-existing business must show that the investment has created, or at least has a reasonable prospect of creating, 10 full-time positions, in addition to those existing before acquisition. The petitioner must, therefore, present evidence concerning the pre-acquisition level of employment. Simply maintaining the pre-acquisition level of employment is not sufficient, unless the petitioner shows that the pre-existing business qualifies as a "troubled business."
• In re Izumii, ID #3360 (Assoc. Commr, 1998). (1) Regardless of its location, a new commercial enterprise that is engaged directly or indirectly in lending money to job creating businesses may only lend money to businesses located within targeted areas in order for a petitioner to be eligible for the reduced minimum capital requirement. (2) Under the Immigrant Investor Pilot Program, if a new commercial enterprise is engaged directly or indirectly in lending money to job-creating businesses, such job-creatin g businesses must all be located within the geographic limits of the regional center. The location of the new commercial enterprise is not controlling. (3) A petitioner may not make material changes to his petition in an effort to make a deficient petition conform to USCIS requirements. (4) If the new commercial enterprise is a holding company, the full requisite amount of capital must be made available to the business(es) most closely responsible for creating the employment on which the petition is based. (5) An alien may not receive guaranteed payments from a new commercial enterprise while he owes money to the new commercial enterprise. (6) An alien may not enter into a redemption agreement with the new commercial enterprise at any time prior to completing all of his cash payments under a promissory note. In no event may the alien enter into a redemption agreement prior to the end of the two-year period of conditional residence. (7) A redemption agreement between an alien investor and the new commercial en terprise constitutes a debt arrangement and is prohibited under 8 CFR 204.6(e). (8) Reserve funds that are not made available for purposes of job creation cannot be considered capital placed at risk for the purpose of generating a return on the capital being placed at risk. (9) USCIS does not pre-adjudicate immigrant investor petitions; each petition must be adjudicated on its own merits. (10) Under 8 CFR 204.6(e), all capital must be valued at fair market value in United States dollars, including promissory notes used as capital. In determining the fair market value of a promissory note, it is necessary to consider, among other things, present value. (11) Under certain circumstances, a promissory note that does not itself constitute capital may constitute evidence that the alien is "in the process of investing" other capital, such as cash. In such a case, the petitioner must substantially complete payments on the promissory note prior to the end of the two-year conditional period. (12) Whether the promissory note constitutes capital or is simply evidence that the alien is in the process of investing other capital, nearly all of the money due under the promissory note must be payable within two years, without provisions for extensions.
Note: In 2002, Congress eliminated the requirement set forth in Izumii that, in order for a petitioner to be considered to have “created” an original business, he or she must have had a hand in its actual creation. Under the new law, an alien may invest in an existing business at any time following its creation, provided he or she meets all other requirements of the regulations.
• In re Hsiung, ID #3361 (Assoc. Commr, 1998). (1) A promissory note secured by assets owned by a petitioner can constitute capital under 8 CFR 204.6(e) if: the assets are specifically identified as securing the note; the security interests in the note are perfected in the jurisdiction in which the assets are located; and the assets are fully amenable to seizure by a U.S. note holder. (2) When determining the fair market value of a promissory note being used as capital under 8 CFR 204.6(e) , factors such as the fair market value of the assets securing the note, the extent to which the assets are amenable to seizure, and the present value of the note should be considered. (3) Whether a petitioner uses a promissory note as capital under 8 CFR 204.6(e) or as evidence of a commitment to invest cash, he must show that he has placed his assets at risk. In establishing that a sufficient amount of his assets are at risk, a petitioner must demonstrate, among other things, that the assets securing the note are his, that the security interests are perfected, that the assets are amenable to seizure, and that the assets have an adequate fair market value. (4) A petitioner engaging in the reorganization or restructuring of a preexisting business may not cause a net loss of employment.
• In re Ho, ID #3362 (Assoc. Commr, 1998). (1) Merely creating and capitalizing a new commercial enterprise and signing a commercial lease are not sufficient to show that an immigrant investor petitioner has placed his capital at risk. The petitioner must present, instead, evidence that he has actually undertaken meaningful concrete business activity. (2) The petitioner must establish that he has placed his own capital at risk; that is to say, he must show that he was the legal owner of the invested capital. Bank statements and other financial documents do not meet this requirement if the documents show someone else as the legal owner of the capital. (3) The petitioner must also establish that he acquired the legal ownership of the invested capital through lawful means. Mere assertions about the petitioner's financial situation or work history, without supporting documentary evidence, are not sufficient to meet this requirement. (4) To establish that qualifying employment positions have been created, Forms I-9 presented by a petitioner must be accompanied by other evidence to show that these employees have commenced work activities and have been hired in permanent, full-time positions. (5) In order to demonstrate that the new commercial enterprise will create not fewer than 10 full-time positions, the petitioner must either provide evidence that the new commercial enterprise has created such positions or furnish a comprehensive, detailed, and credible business plan demonstrating the need for the positions and the schedule for hiring the employees.
Note: There are also a number of precedent decisions that pertain to old (pre-1978) immigrant investor provisions under the former non-preference immigrant visa category. While some of these decisions may be interesting from a historical perspective, they have little or no relevance to the "employment creation" investor category created by IMMACT 90 and should not be relied upon when adjudicating post IMMACT 90 cases.
(h) November 2, 2002 Amendments to EB-5 .
On November 2, 2002, the President signed into law certain amendments to the EB-5 program. Title I, subtitle B of Division C of the Twenty-First Century Department of Justice Appropriations Authorization Act (the “2002 DOJ Appropriations Act),” sections 11031-37 of Public Law 107-273.
On June 10, 2003, USCIS issued interim policy guidance regarding changes effected by the new law. Memorandum from William R. Yates, HQ40/6.1.3, entitled “Amendments Affecting Adjudication for Alien Entrepreneur (EB-5)” (the “Yates Memorandum”). The Yates Memorandum provides that:
• As before, the com mercial enterprise must be “new,” that is, have been created after November 29, 1990. See 8 CFR 204.6(e) . Section 11036 of the law does, however, eliminate the previous requirement that an alien personally have “established,” that is, have had a personal hand in, the creation of the new commercial enterprise. Under the 2002 DOJ Appropriations Act, the alien need only “sustain” his or her investment in a pre-existing commercial enterprise. This effectively allows multiple investments in the same commercial enterprise at any time, provided that the alien still creates ten new positions for qualifying U.S. workers jobs and meet s all other EB-5 requirements are complied with. The law applies to both pending I-526 and I-829 petitions filed on that date or thereafter. This provision modifies 8 CFR 204.6(h)(1) , regarding the creation of an original business.
Note: The 2002 DOJ Appropriations Act does not change the requirement that the commercial enterprise create 10 new jobs. In order to determine whether the commercial enterprise actually has created ten new positions, adjudicators must first determine whether the petitioner personally created the commercial enterprise and, if the petitioner did not create the business, the number of jobs there were in the existing business at the time the petitioner acquired the business.
Note Also: The 2002 DOJ Appropriations Act supercedes, in part, 8 CFR 204.6(h)(3), which describes “the establishment of a new commercial enterprise,” due to the removal of the requirement that the alien entrepreneur establish the new commercial enterprise. Section 204.6(h)(3) of the Act continues, however, to be relevant in that it describes the circumstances under which a commercial enterprise in existence prior to November 29, 1990 will be considered “new” for purposes of the law. Enterprises that have been expan ded or substantially reorganized, as described above, will continue to meet the definition of “new” regardless of when the commercial enterprise was actually created.
• As was the case by regulation before November 2, 2002, a new commercial enterprise may include a limited partnership.
• Full-time employment is defined as employment that requires at least 35 hours of service per week “at any time,” regardless of who fills the position. This provision does not change the requirement that, in order to be “full-time,” the job created may not be seasonal. If the enterprise employs individual workers on a temporary basis, it can meet the “full-time” requirement only if the job itself is permanent in nature and will be staffed year-round by qualified U.S. workers for the requisite 35 hours per w eek. For example, an enterprise which is staffed by qualifying workers on one-year contracts would qualify only if, upon expiration of a particular contract, the enterprise, without break, continues to employ the same or another U.S. worker in that same position.
• With the limited exception of certain persons eligible for a “second opportunity” to make a qualifying investment (discussed below) under the 2002 DOJ Appropriations Act, as before, a petitioner may invest capital, for purposes of EB-5, in only one commercial enterprise. A petitioner who filed a Form I-526 petition after August 31, 1998 therefore may not qualify for removal of conditions if he or she has invested in multiple commercial enterprises.
• The 2002 DOJ Appropriations Act does not change the definition of “qualifying employee.”
The 2002 DOJ Appropriations Act also provides a second opportunity for certain aliens whom USCIS believes failed to make a qualifying investment, now to satisfy USCIS that they have done so, provided certain conditions are met. Persons specifically covered by this provision of the 2002 law may invest in the same or a new commercial enterprise, or even a combination of the two. This second opportunity is limited, however, to cases where the alien’s EB-5 petition does not contain any material misrepresentati on. Persons eligible for this “second chance” to comply with the statute and regulations are those whose Form I-526 petitions were approved between January 1, 1995 and August 31, 1998. The 2002 DOJ Appropriations Act also contains provisions with respect to certain aliens who applied for immigrant visas or adjustment of status prior to November 2, 2002, but did not obtain or were not granted conditional resident status.
Note: The 2002 Appropriations Act is NOT an amnesty program; the statute merely provides certain aliens with a second chance to establish that they have made a qualifying investment. Conditions may not be removed with respect to any of these persons unless they can establish, at the end of their two-year period of conditional residence, that they meet all applicable requirements for removal of conditions.
1. World Trade
Center/Greenville-Spartenburg Inc.
315 Old Boiling Springs Road
Greer, SC 29650
2. Beacon U.S. Studios Inc.
5610 Sanderling Way
Blaine, WA 98230
3. City of New Orleans Office of Planning and Development
40 Poldras Street, Suite 1000
New Orleans, LA 70112
www.nobleoutreach.com
4. North Country Alliance
One Lincoln Boulevard
Rouses Point, NY 12979
5. Aero-Space Port International Group
512 Strander Boulevard
Tukwila, WA 98188
www.aspigroup.com/
6. North Texas Commission
P.O. Box 610246
DFW Airport, TX 75261
7. Legacy Project
1100 Spring Street, Suite 600
Atlanta, GA 30309
8. Abacus, LLC
740 6thh St., NW, Suite 302
Washington, DC 20001-3798
www.eb-5investors.com
9. American Export Partners
180 East Bay Street, Suite 300
Charleston, SC 29401-2123
E-mail: info@tenstate.com
10. Danou Enterprises
World Trade Center Detroit/Windsor
1251 Fort Street
Trenton, MI 48183
11. Pueblo Economic Development Corporation
P.O. Box 5807
Pueblo, CO 81002
12. GV Development
7525 W. Highway 68
P.O. Box 10430
Golden Valley, AZ 86413-2430
13. Unibex Global Corporation
1201 Eleanor Avenue
Las Vegas, NV 89106
14. State of Hawaii, Department of Business,
Economic Development & Tourism
P.O. Box 2359
Honolulu, HI 96804
15. Atlanta International Center for Academic and Athletics
1131 Alpharetta Street
Roswell, GA 30075
16. The Gateway Freedom Fund
American Life Inc, 3223 3rd Ave South
Seattle, WA 98134
www.amlife.us/visa.html
17. West Rand Gold Trust
P.O. Box 2222
Ridgecrest, CA 93556
18. Miami Chinese Community Center, Ltd.
331 NE 18th Street
Miami, FL 33132
19. CKS Western Inc. World Trade Center
620 W. Graham Drive
Lake Elsinore, CA 92530
20. Empirical Entertainment
6255 Sunset Boulevard, Suite 2000
Hollywood, CA 90028
21. Vermont Agency of Commerce and Community Development
National Life Building
Montpellier, VT 05620-0501
www.eb5greencard.com/
22. Trading Partners International of California LLC
2677 N. Main Street, Suite 930
Santa Ana, CA 92705
23. CMB Export LLC
Corona Professional Center
400 S. Ramona Avenue, Suite 212AA
Corona, CA 91719
www.cmbeb5visa.com/
24. Alameda Trade Center
c/o Lowe Enterprises Commercial Group
1818 East 7th Street, Suite 200
Los Angeles, CA 90021
25. Matrix International, LLC
P.O. Box 22891
Seattle, WA 98122
26. California Consortium for Agricultural Export
700 South Flower Stree, Suite 1100
Los Angeles, CA 90017
www.ccax.com/
27. Philadelphia Industrial Development Corporation
2600 Centre Square West
1500 Market Street
Philadelphia, PA 19102-2126
www.canamenterprises.com
28. South Dakota International Business Institute
711 East Wells Avenue
Pierre, SD 57501-3369
www.sd-exports.org/dairy2002/regional.htm
29. Iowa Department of Economic Development
200 East Grand Avenue
Des Moines, IA 50309
www.extension.iastate.edu/ag/staff/info/
ianewfarmfamily.pdf
30. Capitol Area Regional Center
1801 K Street, NW, Suite 201-L
Washington, DC 20006
31. Redevelopment Agency of the City of Vernon
4305 Santa Fe Avenue
Vernon, CA 90058
32. Whatcom Opportunities Regional Center
1305 11th Street, Suite 304
Bellingham, WA 98825
www.worc.biz/