Gulf States Regional Center claims that USCIS unlawfully imposed the requirement on previously approved EB-5 regional centers to reapply for designation in order to sponsor new projects and investors. The regional center argues that the agency failed to issue a notice-and-comment period and ignored proper rule-making procedures. USCIS counters it was only implementing the new Reform and Integrity Act (RIA) and that the regional center “misunderstands” the RIA.