New direct investors cannot join a post-RIA investment with other direct investors. But EB-5 law firm Saul Ewing says an “overlooked” statement in the Reform and Integrity Act (RIA) leaves open the question of whether a new direct investor can join a pre-RIA project with pre-RIA investors. The law firm says there is an argument that the intent of the RIA was to only apply to standalone projects structured after the new regulations. The firm has submitted the question to USCIS for clarification.
See the Saul Ewing release