Before you sign, verify.
A USCIS-designated regional center can lose its good standing overnight — for a missed annual filing, an unpaid integrity fee, a failed audit, or a fraud finding. Since the EB-5 Reform and Integrity Act of 2022 (RIA), USCIS has terminated over 750 regional centers, the majority for failing to pay fees or file required statements.
This checklist captures every document a center must produce, plus a step-by-step routine for confirming each one against USCIS's own public records. Tick each box, then run the cross-check procedure in Section 6.
Designation & Standing
Proof the entity is — and remains — an authorized regional center.
Original USCIS Designation / Approval Letter
The notice approving Form I-956 (or legacy Form I-924) that established the center, its approved geographic scope, and its unique 10-digit Regional Center ID (RCID) — required on every later project filing.
Current Designation Status Confirmation
Written confirmation the center is not suspended, terminated, or under a Notice of Intent to Terminate (NOIT). Ask for the most recent USCIS correspondence on its status.
Approved Geographic Scope Map & County List
The county map and list defining where the center may operate. Any project you partner on must sit inside this approved scope, or it falls outside the designation.
Organizational & Formation Documents
Articles of incorporation/organization, the operating plan, IRS FEIN letter, and the current ownership/management structure named in filings.
Annual Certification (I-956G)
The yearly statement that keeps designation alive under the RIA.
Most Recent Form I-956G — Annual Statement
The current annual certification (replacing legacy Form I-924A), filed for each fiscal year (Oct 1 – Sep 30) on or before December 29. Confirm the correct fiscal year and an attached filing receipt.
Part 4 — Three Qualified-Certifier Certifications
Signed certifications by a person of substantive authority attesting to: (1) bona fides & foreign-involvement compliance, (2) securities-laws compliance, and (3) compliance with INA §203(b)(5)(K)(iii).
Attachment 1 — Per-Project Capital Statement
A separate Attachment 1 for each project with active investors: capital invested, progress to completion, jobs created/preserved, and the dedicated NCE bank account.
Litigation, Bankruptcy & Prior-Year History
Disclosure of material litigation or bankruptcy involving the center, its NCEs or JCEs — plus 2–3 years of prior I-956G (and pre-2022 I-924A) receipts. A gap in any year is a termination trigger.
Project-Specific Approval
Evidence the specific project sits inside scope and is USCIS-recognized.
Form I-956F — Approved Project (Exemplar)
The project-level application that gets a specific NCE investment approved. Confirm the project you're partnering on has an approved I-956F (or at least a filed receipt) — not just a marketing claim.
Project-Within-Scope Confirmation
Map the project's location against the center's approved county list (Section 1). If it falls outside the geographic scope, the designation does not cover it.
Business Plan & Job-Creation Report
A USCIS-compliant (Matter of Ho) business plan plus the economic analysis showing ≥10 full-time jobs per investor within the approved area, with transparent methodology.
Securities, Offering & Escrow Documents
PPM, subscription agreement, NCE operating/LP agreement, SEC/state filings, plus the NCE–JCE loan/investment and escrow agreements showing how capital flows to the job-creating entity.
RIA Audit & Records Compliance
Proof the center can survive a mandatory five-year USCIS audit.
Most Recent USCIS Audit Result
Under INA §203(b)(5)(E)(vii), USCIS must audit every center at least once every five years. Request the audit outcome letter, or written confirmation of when the next audit is due.
Record-Retention Compliance (Post-May 14, 2022)
Confirmation that all operational and financial records created on/after the RIA enactment date of May 14, 2022 are preserved and audit-ready, tying back to annual statements and investor petitions.
Fund Administrator or Annual Audit Evidence
Under RIA Section Q each fund must either retain an EB-5 Fund Administrator or have an accountant audit its annual books. Request the fund-admin agreement or the independent audit report — plus evidence each disbursement was checked against the governing documents before release.
Consistency Across All RIA Forms
Cross-check that figures are internally consistent across I-956, I-956F, I-956G, I-956H (bona fides) and I-956K (promoters). Disparate numbers are a leading audit red flag.
Integrity Fund & Fee Compliance
Unpaid fees are the single most common termination cause — verify them.
EB-5 Integrity Fund Fee — Paid & Current
Proof the annual Integrity Fund fee is paid for every applicable fiscal year. USCIS has terminated centers specifically for non-payment — the January 2025 wave of 100+ terminations was largely fee-related.
I-956G Filing Fee Receipt ($3,035)
The separate $3,035 filing fee accompanying each annual I-956G — distinct from the Integrity Fund fee. Confirm the receipt exists for the latest filing.
Promoter / Agent Compliance (I-956K & I-956H)
If third-party promoters or agents are involved, request Form I-956K registrations and Form I-956H bona-fides documentation for persons in positions of substantive authority.
USCIS Public-Records Cross-Check
Never rely on the center's own documents alone — verify each against USCIS records.
Confirm the center is on the approved list
On the USCIS EB-5 Regional Centers page, match the exact legal entity name and RCID from the designation letter. Names alone are not enough.
Check the terminations list — separately
Open the regional center terminations page and search the entity name and any DBA/affiliate names. A terminated center may not lawfully solicit or promote investments.
Pull notices from the Electronic Reading Room
Search USCIS's Electronic Reading Room for published termination and NOIT notices. Confirm the center — and its principals' other entities — are absent.
Validate the geographic scope
Confirm the project's location falls inside the approved county list. A project outside it is not covered even if the center is in good standing.
Reconcile the I-956G against what you were told
Match fiscal year, RCID, capital totals, project list and job figures on the latest I-956G against the project documents and the center's marketing claims. Flag any mismatch.
Verify fee and filing currency
Cross-check Integrity Fund and I-956G fee receipts against the USCIS Form I-956G and Integrity Fund pages. Confirm no gaps in annual filings or payments.
Independent counsel + direct USCIS confirmation
Have qualified U.S. EB-5 immigration counsel review the file. For status questions, reach the USCIS EB-5 program at uscis.immigrantinvestorprogram@dhs.gov. Only after every box is ticked and every check clears should you sign.
Walk-Away Red Flags
Any single one of these should stop a partnership until fully resolved.
| Red Flag | Why It Matters |
|---|---|
| Appears on terminations list | Center cannot lawfully solicit, promote, or sponsor EB-5 investments. Investors get 180 days to reassociate. |
| No / late I-956G filing | Missing any fiscal-year annual statement is a direct termination trigger under the RIA. |
| Unpaid Integrity Fund fee | The leading cause of mass terminations (100+ centers in Jan 2025). Non-negotiable. |
| RCID mismatch | Entity name doesn't match the RCID on the official list — possible impersonation or stale paperwork. |
| Project outside geographic scope | The designation does not cover the project, regardless of the center's standing. |
| No I-956F for the project | The project isn't USCIS-recognized at the project level — only a marketing claim. |
| Disparate figures across forms | Inconsistent capital or job numbers across I-956 / I-956F / I-956G invite audit failure. |
| No fund admin or annual audit | Violates RIA Section Q; signals weak controls over investor capital. |
| Records gap before May 14, 2022 | Center cannot satisfy the mandatory five-year audit record-retention requirement. |
Educational reference on EB-5 due diligence. Confirm current requirements on USCIS.gov and engage qualified U.S. EB-5 counsel before signing.