First, U.S. Citizenship and Immigration Services has no economic development mission. USCIS has no economist with experience in working with the EB-5 Program and the job-creation / economic impact methodologies typically used by U.S. economists.
Second, when USCIS issues an official memo concerning the EB-5 Program, we in the EB-5 world know that we are going to get whacked over the head by a two by four. USCIS has no job-creation mission, even though it is the will of Congress that EB-5 be a job-creation program.
So it was no surprise to read the latest memo on the EB-5 Program to emanate from USCIS. The result of its orders to adjudicators in California will put brakes on the program, restrict job creation, and frustrate the intent of Congress once again, in a time of great economic crisis and loss of millions upon millions of jobs across the United States. It's a shame.