EB 5 Visa for Investors – Ultimate Guide 2016

Author

Vivek Tandon

Table of Content

Introduction

What is EB-5 Visa?

What are the requirements of EB-5 Visa?

Direct EB-5 Investments

Regional Center Investment

At-Risk Investment

EB-5 Job Creation Requirements

The EB-5 Process and Timelines

Path to US Citizenship

Investor Visa Program Benefits

Disclaimer

Personal and Company Profile

Introduction

My name is Vivek Tandon, I am the founder and CEO of EB-5 BRICS, LLC. I’m a US

licensed lawyer and investment banker and I am here today to educate you about

EB-5 U.S. Investor Visa Program. We specialize in EB5 Visa program for Citizens of

India, Brazil, Mexico & Dubai.

What is EB-5 Visa?

The U.S. government administers this program called EB-5 Immigrant Investor

Visa Program which allows foreign investors to immigrate to the U.S through an

investment.

This program actually started back in 1990 and in recent years has been

immensely successful both for foreign investors as well as the U.S. economy.

Through this program the U.S. government makes available 10,000 Green Cards

every year for qualified immigrant investors.

The policy behind the investor visa program is really to create a “win-win”

situation for both the foreign investors as well as the U.S. economy. Through this

program, the U.S. economy gets the capital that some of its communities need to

really stimulate the local economies and the local employment and at the same

time, allows foreign investors to immigrate to the U.S. for a variety of reasons,

whether it’s for family, business, or otherwise.

What are the requirements of EB-5 Visa?

What are the requirements of EB-5 Visa? Now, three basic requirements must be

met: you must make an investment into a new business; and investment must be

at least $1 million, or in certain cases $500,000; and the investment must create

10 full-time U.S. jobs. Now if you look at the EB-5 Visa Program, generally

speaking, most investments are at the $500,000 mark and not the $1 million

mark. There are plenty of investment types available in the U.S. that qualify for

the $500,000 threshold. And shortly I’ll go into why, in certain cases, the

investment is $500,000 and not $1 million.

Direct EB-5 Investments

Now how does an investor really make an EB-5 investment? There are two

different options that are available to EB-5 applicants. One is called the Direct

Investment; the other is called the Regional Center Investment. So we will talk

about both today.

So let’s talk about option 1, the Direct EB-5 Investment. It’s really an investment

in a new business and creation of 10 full-time jobs. And when I say Direct EB-5

Investment, really, it pretty much means you’re directly investing into an actual,

real, operating business. And, remember when I talk about this earlier where I

said it could either be $1 million or $500,000? The reason the threshold is

lowered to $500,000 or a half-million dollars, is because if the business is situated

in a targeted employment area, then the investment amount is lowered to

$500,000. A targeted employment area really an area where the unemployment

rate is 150% of the national average rate, or it could also be a rural area.

Now if you look at most EB-5 investments, as I said previously, are actually at the

$500,000 level and quite a few areas throughout the U.S. qualify for the $500,000

investment whether it’s a Direct EB-5 or whether it’s a Regional Center

Investment.

In terms of the Direct EB-5 investments, generally speaking, most EB-5

investments are franchises, restaurants, you know, perhaps a small IT company,

perhaps a small retail chain of stores, perhaps it’s a trucking company, or a car

wash. But just keep in mind regardless of the type of Direct EB-5 investor makes,

you have to create those 10 full-time jobs. So, as a practical matter, if you say,

well I want to open up a gas station. Think about whether or you think that gas

station, or that one gas station can actually create, sustain and maintain 10 full-

time jobs or not. Most gas stations that I’ve actually personally seen, don’t tend

to create maybe 3-5 full-time jobs.

Now, if you have multiple locations and each of those locations are located in the

targeted employment areas, where the investment threshold is $500,000, then

yes, you know, you can actually those 10 jobs across multiple locations and that

would qualify for an EB-5.

Similarly, for restaurants, if one restaurant cannot maintain or sustain 10 full-time

jobs, then perhaps if you have multiple locations, and you get to 10 employees at

a minimum, then that would qualify for a Direct EB-5.

I meet a lot of people all over India and there are quite a few immigrant investors

that are interested in the Direct EB-5 investments. I always sort of tell them that

there are some major considerations that you should take into account. It’s

definitely doable, but it does come with its set of challenges.

I’ve sort of listed some of the challenges or some of the considerations that one

should think about when they’re considering a Direct EB-5. Generally speaking,

the successful Direct EB-5’s that I’ve seen or come across are where there’s a

good business opportunity and it’s a viable business opportunity and has the

potential to sustain and thrive and then also create and sustain 10 full-time jobs

over at least a 2-3-year period. I’m shortly going to be going to the timelines of

the EB-5 program, they’ll talk about why these need to be maintained over at

least a 2-3-year period.

The second consideration is, well, you know if you do open a business in the U.S.

and say, while your petition is pending for an EB-5, how do you run that business?

Say then if you have a B1/B2 visitors/`business visa, you can always come here

and visit your business, but you can’t work in that business, so there’s that

limitation or restriction. There are other avenues that might be available to

overcome that. So, there are other options that you can explore, but again, that is

something one should consider especially if they are fully occupied with either

their current job or business back in their home country.

Another consideration that you should think about, or an investor should think

about, is getting approval for the I-526, Immigrant Petition by Alien Entrepreneur.

That is the initial application that an investor files in order to get an EB-5. Now, if

you just file an EB-5 application, along with an EB-5 compliant business plan but

there are no real operations in place, the business hasn’t started, the employees

haven’t been hired, there are literally no operations whatsoever, would you get

approved for that I-526, or are the visa officers at USCIS, which is the U.S.

Citizenship and Immigration Services, the agency that is in charge of the EB-5

program that oversees the EB-5 program will they be satisfied with just a business

plan; an investment hasn’t been made, employees haven’t been hired, business

hasn’t been started? So that is a major consideration to take into account when

one is thinking about a Direct EB-5.

Now, there are ways around that, again, perhaps an investor can start that

business B1/B2 visitors/business visa prior to filing the I-526. But then, again, the

solution there would be perhaps the investor would find a local partner, perhaps

a confident and trustworthy manager or a CEO since the investor would be

waiting for that approval to take place in their home country. There are these

kinds of considerations when one takes into account when thinking about a Direct

EB-5.

Regional Center Investment

Let’s move on to option two, a regional center investment. What is a Regional

Center? A Regional Center is basically a private company. It’s involved in the

promotion of economic growth, job creation, and capital investment into the U.S.

economy. So, generally speaking, a Regional Center is usually a private company.

There’s a lot of information on the internet where it might indicate otherwise that

perhaps a Regional Center is perhaps a public/private company, public/private

partnership, but it is generally not owned by a public entity or a governmental

entity. So one has to be sort of cognizant of the fact that a Regional Center is an

economic entity which is a private company that is involved in raising capital for

EB-5 projects.

How does an entity become a Regional Center? It does have to apply to the USCIS

for Regional Center approval. It has to show the following things: how that

particular Regional Center plans to focus on that particular geographical region

within the United States and how are they going to go about promoting economic

growth in that region; and again, how, in verifiable details, meaning they might

have to submit business plans and economic reports and job creation models

showing how a particular type of investment or particular area will create and

stimulate the local economy and create jobs.

Regional Center Investments that I talked about earlier, either large mixed-use

development projects or commercial development projects, or residential

development projects. Those due tend to create full-time jobs.

Before we go into that, I do want to talk about one more point, which is actually a

key point when it comes to Regional Center Investments. Now, there are about

800 approved Regional Centers in the country and any given day, those 800

Regional Centers in the country will likely have, I would say about 600 odd EB-5

projects in the market, no two projects tend to be the same, each project carries

its own degree of risk: there are low risk projects, there are medium risk projects,

and there are high risk projects. How you classify them into one of the risk

categories really through taking into account a lot of factors that go into that

particular project and in terms of who the Regional Center is and whatnot. And I’ll

shortly go into those factors as well. Most Regional Center projects that you’ll see

in the market tend to be low - or no-return. When I say low - or no-return, I’m

really talking about perhaps a 1% return on investment, perhaps %0.5 return; I’ve

seen it up to 5-6% generally but there are projects in the market that might

promise or project 7-8% return. Just sort of remember the rule of thumb that I

like to follow is, the higher the risk, the higher the return may be. So you do have

to be careful about that. But it’s not say that just because a project has low

returns that it is low-risk, that’s not necessarily true. And, hence, you should think

about engaging professionals to help you make a fully informed decision when it

comes to Regional Center Investment.

When we look at a Regional Center Investment, what are the various factors that

one should take into account? Or how does one go about selecting a Regional

Center Investment? One, I said that you should definitely take advice from a

financial or investment advisor because you are putting at least $500,000 at risk

and perhaps if you’re taking the $1 million route than you’re putting $1 million at

risk for the next 5-6 years. So, I always suggest to people that, yes, you do need

an immigration lawyer to help you on the legal side but at the same time, you

should take help from a financial person to help you make that decision because

there’s a lot of things that they can look at in terms of the financial due-diligence,

the immigration due-diligence, and the regulatory due-diligence to help you make

a fully-informed decision. So, generally speaking, when one is looking at Regional

Center Investment, these are the sort of things that one should be looking at: The

Regional Center team and track record, say if it’s a long-established Regional

Center, then, you know how many projects have they done, how many I-526

approvals have they had, how many I-829 approvals have they had, how many

projects that they’ve actually overseen has actually returned capital back to the

investors?

Now, again, that’s not the only factor one should look in terms of deciding what

Regional Center Investment they’re going to put their $500,000 investment into

but it’s one of the factors because at the end of the day it’s really not the Regional

Center that’s returning the investors’ money, it’s the developer, who’s the

borrower of that $500,000 along with funds from other investors that is going to

be signing that loan agreement and saying, you know, he or she will return say

$10 million or $20 million from 40 EB-5 Investors in 5-6 years. Yes, one should

look at the Regional Center track record but at the same time it’s really the

developer or the borrower that one should be really, really, looking at and seeing

whether they have the capacity to return that capital and how they’re going to go

about returning that capital when it comes due and then what kinds of projects

has that developer run in the past, what kind of success rates have they had in the

past, have they done other projects through the EB-5 program before or not? So

those are some of the things one should look at.

Also, not to go too deep into this, but because you are a lender into that project,

you know, what is your position in relation to other lenders into that project? So

say it’s a $100 million, perhaps $20 million came from the developer themselves

and perhaps there’s a $50 million loan from the bank and the rest of the $30

million was raised through 60 EB-5 investors. Now, obviously, there’s a bank there

so the bank might have first position in that loan meaning if something were to go

wrong in that project, the bank would have the first right to foreclose into that

project, of course, it all depends on the terms of the loan but they would be the

ones who would be in a position to perhaps get some of their money back if

there’s enough collateral there. And if EB-5 investors are in the second position,

unless there’s something left over, they’re not going to get anything back. So,

that’s another thing that EB-5 investors should be looking at; and of course, the

financial viability of the project, do a fair bit of financial analysis, or have your

financial professional share with you the types of financial investments that

they’ve done and what kind of risks have they come across.

The next is regulatory compliance, so in the U.S., there’s two agencies that

oversee a lot of capital raising, one is the Securities and Exchange Commission

and one is the FINRA - Financial Industry Regulatory Authority. More and more,

these two agencies are taking a very close look at the EB-5 program, and there’s

quite a few Regional Centers in the country, now that are embracing the fact that

the SEC and FINRA are asking them to be compliant with securities laws of the

U.S. and hence, they are engaging securities broker dealers in the U.S. to help

them raise this kind of capital. And of course there are Regional Centers in the

country that don’t think that they need to comply with SEC and FINRA because

they are what you call exempt securities. Again, without going into too much

about the technicalities of what’s an exempt security and what’s not, because it

really depends on who you ask. But nonetheless, again, as an investor, you’re

risking $500,000 for the next 5-6 years, you want to make sure that the

developer, or the borrower, or the Regional Center is in full compliance of all U.S.

laws and not really operating in the grey areas of the law.

Another sort of big factor that one should be looking at is the Regional Center’s

relationship with the developer or the borrower. More and more developers are

looking to rush into becoming a Regional Center themselves, there is actually an

inherent conflict with that, there are good developers and there are not so good

developers in the market so, some investors are comfortable with that conflict,

some are not, but that is another factor that you should be looking at.

And of course, the Job Creation model for the project. At the end of the day, the

reason that investor is making that investment is so that they can get their

temporary Green Card and eventually get their permanent Green Card. That’s

completely contingent upon the project creating the required number of jobs. So

that Job Creation model, announcements of that model is definitely necessary.

There are what are called pre-approved projects in the market and these are

projects where the developer, or the borrower, or the Regional Center have

submitted the documents, the business plan, the economic report to the U.S.

government even before the investors have filed their I-526 on that project and

the U.S. government has approved those projects and in approving those

projects, agreed that yes, the business plan makes sense, yes, the Job Creation

model makes sense. Again, they are not endorsing the projects or anything like

that, they are just saying, yes, if all these things were to happen in this particular

geographic area, and you were to spend this amount of money, we think that yes,

these amount of jobs will be created.

And the next is again, the economist report, is related to the Job Creation model;

the immigration compliant business plan is closely tied to the Job Creation model.

So, all of these things are things one should be looking at when making a decision

as to which particular Regional Center they should be investing in.

At-Risk Investment

I mentioned you’re risking a $500,000 for the next 5-6 years if you were to pick a

Regional Center Investment that follows the loan model. A lot of time, there’s a

lot of confusion about what is an “At-Risk” investment. There must be a risk of

loss or a chance of gain, simply put. I always tell people that “At-Risk” does not

necessarily mean risky, unless you want it to be. There are plenty of projects in

the market which, because of one factor, or several factors, may be perceived as

high-risk and perhaps to compensate for that, they may be offering a higher

return, but at the end of the day, it’s a call that the investor needs to make in

terms of the amount of risk the investor is willing to take. EB-5 law requires that

your investment be “At-Risk.” So, if anyone ever tells you that this is a risk-free

investment, or a risk-free project, or that we’ve eliminated 100% of the risk, they

are just misrepresenting the facts to you. There is no such thing as a no-risk

investment because EB-5 projects, or EB-5 investments need to be “At-Risk”

investments for them to qualify under the EB-5 program.

EB-5 Job Creation Requirements

Just going a little beet deeper into the Job Creation piece. Now, as I mentioned

earlier, that each and every EB-5 applicant is required to create at least 10 full-

time jobs. If you the Direct Investment route, you have an obligation to create

and maintain at least 10 full-time jobs until you get your permanent Green Card

and if you do a Regional Center Investment, then the Regional Center and

developer have the burden but you still have to show the proof that those jobs

are indeed created through your $500,000 investment. And again, in the Regional

Center framework, the Regional Centers and developers will provide you with

those types of documentation.

And you might notice in the first bullet point there that every EB-5 applicant shall

be required to preserve at least 10 full-time jobs. The preserve piece comes in

when say an investor does not necessarily invest into a new business, perhaps

they invest into an existing business. Now, an existing business may qualify for an

EB-5 given that it is a troubled business. So, say that if you rescue a business

that’s in the danger of closing or that’s been in losses for a number of years, and

it’s in danger of losing jobs. And perhaps say it’s a hotel in Southern California

where I live, in fact, I’m actually talking from a real world example where, there

was an Egyptian client who identified a property in California that was in losses

and in danger of shutting down and they were going to lose about 10 or 12 full-

time jobs because of that. So, they came in an actually rescued that property and

put in new management and did some other things that turned the whole

business around. Instead of creating 10 new jobs, they actually saved 10 or 12

existing jobs, and that helped them qualify for an EB-5.

Now, they did that through a Direct EB-5 and there’s obviously a level of risk that

they took on when they rescued a troubled business. They actually ended up

putting in more than $500,000 and you know, they did have about 25-plus years

of experience back in their home country in running hotels and motels and they

had a very strong support system in place here in California. I think that

contributed immensely to their success. Again, going back to my initial thought

about direct investments, they’re doable, but they’re challenging, but with the

right solutions and strategies in place it can definitely work.

The EB-5 Process and Timelines

Now, moving on to the EB-5 Process and Timelines, again, I can’t stress enough

that an Eb-5 application should be handled by a team of professionals.

Professionals who know legal, who know financial, who know investment. There

are various stages in this process and there are various, various, things that one

needs to take into account when doing an Eb-5. Now, simply put, there’s two

sides to an EB-5.

There’s an investment side and there’s an immigration side and both of those

sides need to come together to make sure that you have an air-tight application.

Generally speaking, those two things can take 1 to 2, sometimes 2 to three

months to get together. Once you have those two things together, meaning you

have an invest identified and you’ve got the immigration side taken care of in

terms of taking care of making sure that the EB-5 investment meets all of the

immigration law requirements, making sure the source of funds for that $500,000

has been properly and thoroughly documented, and of course you’ve done all the

due-diligence that you needed to do on that investment.

So those two things come together and the investor submits an I-526 application,

and these funds that are part of the application can be the investor’s own money

and right now, as the law stands, it does allow for a loan or gift funds, the loan

has to be a secure loan, it cannot be secured against that EB-5 investment, or it

can be a gift, it could be a parent giving gifts to a son or daughter, quite few of our

clients are parents in their own country whose children are attending college or

universities in the U.S. and they are either graduating soon from their Bachelor’s

degree program, or their Master’s degree programs, or they’ve already graduated

and are on some sort of temporary work visa and they don’t necessarily wish to

go back to their own country, and they want to settle permanently in the U.S., so

we’ve got quite a few parents who are basically funding an EB-5 application for

their U.S.-based son or daughter.

Now, as I’ve said, once you complete your due diligence with the help of an

experienced U.S. based and U.S. licensed, I would highly recommend, financial

and investment advisors and lawyers, then the investment is made, the I-526

petition is filed, and on average an I-526 petition takes about 12-14 months

currently. That time period can change, it can go up, it can go down, but it really

depends on the number of resources the USCIS has in place, and obviously, the

number of applicants that are filing through the EB-5 program.

So, say once the I-526 is approved in say approximately 12-14 months, then the

investor is issued a conditional Green Card. A conditional Green Card is pretty

much the same thing as a permanent Green Card, it gives you the same rights and

privileges, you can work anywhere in the country, you can travel, you can travel

back and forth from your home country. So there’s no restrictions per-say, it’s just

that the conditional Green card, you know the validity of that conditional Green

Card is about 2-2.5 years. And also, it’s also conditional upon your investment

upon creating those 10 full-time jobs.

So say you get your conditional green card status, what happens next? Once the

conditional green card is issued, then you know, you can enjoy the United States

and once you enter the United States you are here for about two years or so

because that’s what the conditional green card is valid for and then in those two

years you’ve got to get documentation.

Say you’ve made a Regional Center Investment; you’ve got to get documentation

from the Regional Center showing how your investment created those 10 full-

time jobs. You would file what is called an I-829 application and once you file that

application then you’re basically waiting for that application to be decided upon

by the USCIS and once it’s approved you will be given your permanent Green

Card. Now, in terms of processing time, the I-829 is taking up to 12-14 months or

even more in fact that I’ve noticed recently. The good thing is, while your I-829 is

pending, your conditional Green Card status gets automatically extended. So, the

processing times affects you, it doesn’t necessarily affect your legal status in the

country.

But say your I-829 is processed, and it’s decided upon and it’s approved, then you

get your permanent Green Card. Now, the entire time period, you can really think

about it in terms of a total time period would be 3.5-4 years before you have your

permanent Green Card. Because, remember what I said, it could take two or

three months to get the investment and the immigration site together and file the

I-526 application which could take 12 to 14 months to adjudicate so we’re already

at a year and a half and then you’re in conditional Green Card status which could

take an additional two years and that’s already three and a half years and when

you file your I-829 application, say this only takes six months. So you’re already at

the four-year mark in terms of before you get your permanent Green Card,

moving over to the investment side, you know you make that investment at the

time of the I-526 application.

In fact, you can’t file that I-526 application unless you’ve made that investment

especially if you’re going the Regional Center route because the Regional Center

will then issue you a participation certificate which becomes a part of your I-526

application and once the application is filed your investment is made the

investment term can be five or six years. Once you get your permanent Green

Card, you’re essentially waiting about 1-2 years to really get your money back.

Path to US Citizenship

In five to six years you get your money back. Once you’ve been a U.S. resident,

meaning in Green Card status both conditional and permanent, for at least five

years you can actually qualify for a US citizenship; and there are some residency

requirements and there are some physical presence requirements before you can

qualify yourself for U.S. citizenship.

But generally speaking, once you’ve been living in the U.S. for approximately five

years, on Green Card status, you can apply for U.S. citizenship. And, of course,

there’s a lot of questions I get in terms of well, great, I get my permanent Green

Card and I’m just waiting for my money to be returned to me in five to six years,

how do I actually get that money back? Well, it goes back to that Regional Center

Investment, and again, I focus on that Regional Center Investment part because a

majority, or more than a majority, as I said 95% of all EB-5 applicants usually

choose the Regional Center route. Every Regional Center project isn’t going to

have an exit strategy, meaning, how are they going to return the money back to

the EB-5 investors?

There’s usually two different strategies that they’ll have; when I say different,

they could have option one and option two, and option one could be that they

sell the project entirely and whatever proceeds they get from selling that project,

they use those proceeds to pay off those EB-5 loans. Again, we’re assuming that

the proceeds of the sale exceed the amount they owe, say to a bank, or to an EB-

5 investor. So, assuming that everything went well in the project, and the

economy is doing well, and a project was $100 million when it was built and now

it’s a $125 million and then the project is sold for $125 million then there should

be sufficient funds to pay back the EB-5 investors as well as any other lenders to

that project. So, that’s one option.

Second option, in terms of an exit, is generally refinancing the EB-5 loan. So,

again, same scenario, say it’s a $100 million investment, and at that time, there’s

$20 million from the developer, $50 million from a bank, and $30 million from EB-

investors; now, in 5 to 6 years, say that project is worth, again, $125 million, now

it might be much easier for that project, or that developer, to get a second loan

from a second bank because now the value has gone up quite a bit for that

particular project in which case, there’s a less amount of risk the second bank is

taking because there’s more equity in that particular project, hence, you know,

the second loan from the second bank can then pay off the loan the EB-5

investors made. I’m talking in very general terms here, there’s a lot more detail to

this, there’s a lot of other things one needs to be looking at, but for today’s

purposes I just wanted to at least give you some of the common points, some of

the commonly asked questions and information and education about the EB-5

program and about the kinds of things an investor should be thinking about when

they’re considering an EB-5 application.

Please don’t take anything I say today to be set in stone, there are a lot of

variables that come into play, but again, I just wanted to give you some general

information about the EB-5 program.

Investor Visa Program Benefits

The EB-5 Investor Program allows a direct route to permanent residency in the

U.S. for the investor, his or her spouse, any children under the age of 21. The

investor can live anywhere in the country, work anywhere in the country, retire

anywhere in the country. The investor and their spouse and their children can

attend college or university at U.S. resident cost instead of a foreign student cost.

Again, there are certain rules and conditions that need to be met, those are

benefits that are derived directly from having a Green Card through an EB-5

program.

And of course, the freedom to travel, to and from the U.S. without a visa, and as I

said, after 5 years of permanent residency, if the investor meets or the resident

meets certain conditions, they can apply for U.S. citizenship. Quite a few investors

actually, that I deal with will do this, where they invest $500,000 through a

Regional Center to take care of the immigration piece and then to really make

money in the U.S. they might get an additional business, from other funds that

they might have. So again, if you have a Green Card holder in the U.S., you can go

work for someone else or you can work for yourself, you can start a business, and

there’s no compulsion for you there to create or sustain 10 full-time jobs because

that is not related to your EB-5 application. Eventually, if an investor holds a

Green Card, they can apply for their family members as well. The wait there is

quite a wait, it’s about 10-15 years generally speaking for most of the countries

out there because of visa availability issues. If one does become a U.S. citizen,

general, immediate family members, so parents, can be brought over from the

U.S. in Green Card status, in usually 6-12 months. So, there are other kinds of

benefits as well.

Disclaimer

You know, I do want to sort of emphasize that anything you heard, or read today

should not be construed as legal advice. Again, I’m just here today to educate you

and inform you. I don’t know what your personal goals are, what your personal

situations are, so I’m not giving any legal advice to anybody here. And of course,

there is no attorney-client relationship that was established between you and I,

Vivek Tandon, or EB-5 BRICS LLC by downloading, reading or listening to this

presentation. Again, this presentation is strictly for information purposes only.

And of course, there is no offer to sale any security or investment, made through

this presentation, or anything that I’ve said today.

Personal and Company Profile

And again, going back to my point about today’s presentation being very general

in nature, if anybody here wants to know more about or learn more about an EB-

5 program, I’m happy to educate them more. My phone number is on the screen;

my email address is on the screen. Again, I sort of just want to give you an idea of

my background, it’s right there on the screen, but again I’m a U.S. licensed lawyer

and banker, actually licensed through FINRA and Securities and Exchange

Commission. And I’m associated with a registered broker-dealer called NMS

Capital Advisors. It’s a Beverly Hills based bank and that’s the bank that

represents the investors that we place into various projects. Thank you, and I’ll

look forward to talking to you more if anyone needs more information.