The new I-956K form raises questions as to who exactly must register. Immigration lawyer Robert Divine infers that all agents, sub-agents and employees interacting with prospective investors must register and that failure to do so can lead to termination of the regional center and debarment of the issuer and offending promoter. Promoter registration is not required until after the 60-day comment period ends and USCIS has published the final form.
See the Baker Donelson article.
