国土安全部EB-5新规提案的评议期将截止

一月时，美国国土安全部在《联邦公报》上公布了两个各自独立的EB-5新规提案，一个将重点放在EB-5项目的监管上，另一个将重点放在目标就业区TEA和投资额问题上。两个提案的评议期均为4月11日结束。

目前，鉴于特朗普总统暂时冻结了新规生效，而国土安全部并未对这些新规提案的状态给出更多信息，所以EB-5行业应当发表自己的意见和建议，表明这些新规提案可能会对EB-5项目造成怎样的负面影响，这非常关键。

如果您还没有为这两个新规提案向国土安全部递交意见的话，可以参考以下步骤。在截止期限前，能有尽可能多的EB-5利益相关者递交意见是非常必要的。

请参考以下步骤递交意见：

1、访问 https://www.regulations.gov/docket?D=USCIS-2016-0006 。这是其中一个新规提案的意见收集地址。

2、找到评论按钮，点击“Comment Now”。

3、然后在评论区输入评论。以下是一个简单的模板，供参考。（您可以直接复制黏贴这份评论）

As a stakeholder of the EB-5 Regional Center industry, I support the comments submitted by the industry trade association, Invest in the USA (IIUSA). I also respectfully submit the following comments:The Notice of Proposed Rule Making (NPRM) and Advanced Notice of Proposed Rule Making (ANPRM) published in the Federal Register by the Department of Homeland Security (DHS) in January 2017 pose many threats to the life and vitality of the EB-5 Regional Center Program and these measures must be carefully looked at as their repercussions would be at the detriment to thousands of American jobs and the families and communities that rely upon them all across our nation. I support reasonable and responsible reform of the Program to deter fraud and provide oversight while ensuring the Program is able to thrive for many years to come, providing capital to regional economic development projects.

Raising the minimum investment amount, as proposed in the NPRM, to $1.8 million for non-TEA investments and $1.3 million for TEA investments will destroy the program. It will reduce the number of investors down to levels not seen since the 1990s and would result in dramatically lower EB-5 investment and job creation in the U.S., hurting the very communities that rely upon it. Furthermore, as state in IIUSA’s comments, I believe that a dramatic 360% increase in investment amount will make the EB-5 program less competitive with other programs around the world which require little to no risk to the investor, unlike the U.S. program.

Given these points, it is important to keep the U.S. program competitive in the international market by not over-inflating the increased investment amount. It is also important to keep in mind that with any targeted employment area (TEA) reform, a majority of investors would likely be moving from TEA-qualified investment amounts (or the lower amount) to non-TEA-qualified amounts (or the higher amount). The proposed rule would result in a 360% increase for most investments. It is difficult to imagine a dramatic increase in the investment price would not result in a dramatic decrease in demand for the American EB-5 program, thus, cause a significantly negative impact on EB-5 jobs and investment in America.

TEA reform is needed in order to help enhance the Regional Center Program as an economic development tool and allow for a more even playing field that eliminates the “gerrymandering” criticism of the current statute. A TEA policy mapping tool is available that visualizes the impact of various TEA policy reforms that have been introduced over the course of reform discussions. It is available at iiusa.org/eb-5-tea-policy-proposals-analytic-mapping-tool/

I am supportive of measures that increase program integrity, deter fraud, and overall make the Program a stronger, more sustainable economic development tool and making these reforms through the legislative process. I encourage DHS to use the tools available to them, including working with industry stakeholders and Congress, to ensure a viable and sustainable future for the EB-5 Program.

4、如果想要添加附件，可以在“Choose files”处添加。

5、输入姓名（必须）。

6、如果愿意 ，可以填写联络信息（勾选后输入），或者表明代表第三方递交意见（勾选后输入）。

7、点击继续“Continue”。

8、网页将提供一个收件通知。可以留存作为存档，如果要修改评论的话，也可以借助这个通知。

至此，您已经完成了意见递交，官方记录中将有你的一份声音！

如果想为另一份新规提案递交意见的话，网址是https://www.regulations.gov/docket?D=USCIS-2016-0008 ，请重复以上步骤。