After analyzing the SEC rules a lot of regional centers recognize that their activities could result in them being deemed a broker-dealer. And so, the quick answer is, 'We'll just get licensed as a broker-dealer', easy enough.
The Disadvantages of Hiring a Broker-Dealer in the EB 5 Visa program
The PPM investment documents need to be modified for every 'material change' in the offering, so do all existing members need to sign-off?
An issuer can be held accountable for failure to disclose material changes since the PPM was finalized, even if it was correct when it was first released.
The PPM is among the most significant documents for a project. It must convey the good and bad, but how it's disclosed ends up having a marketing impact.
Sources of Guidance re: Disclosures
The definition of 'material information' is what info a reasonable investor would consider important. So what defines a 'reasonable investor?'
Who controls the translation of the EB-5 documents?
The role broker dealers play in EB-5 is substantially different from their traditional role in private placement offerings. Listen to our expert panelists discuss