SEC fines for not registering as a registered investment advisor come in varying tiers, depending on how you're perceived as per EB5 Visa requirements
An investment advisor is required to supervise all persons acting on its behalf and the SEC can sanction an advisor if they fail to supervise them.
Project timing is very important to an EB-5 business plans because it affects the timing of job creation.
The role of EB5 broker-dealers is evolving as regional centers are required to certify securities compliance as stipulated in the draft Integrity Bill.
Some developers don't want to pay for a feasibility study, but it adds a great deal of credibility to the EB-5 business plan projections and marketing.
First, make sure your EB5 business plan is written to be I-526 compliant and ultimately approved by USCIS. Second, position EB5 offering for marketing.
Form ADV is the form that, to a large extent, represents what registration as an investment advisor looks like.
Registration as an investment advisor is complicated b/c you need to determine whether you should register with a single state, multiple states or the SEC.
Who is advising the investment vehicle entity in an EB-5 transaction and what exemptions to registering as an Investment Advisor are there?