Consider the Adjudicator
The adjudicator’s function is to ensure that all of the necessary
requirements are being met in any given EB-5 application. It
stands to reason, given the current volume of EB-5 applications,
that an adjudicator will not necessarily study every business plan
in great detail. Rather, it is likely that they will review an entire
plan to get an initial feel for the business before taking a deeper
look at the parts which address the specific requirements they are
looking for, to ensure that those requirements are being properly
met. Because most adjudicators are not experts in any given
business, applicants should seek to strike a balance between
providing sufficient detail and explanation on the one hand, and
making it easy for an adjudicator to quickly and simply grasp the
key concepts and find key information on the other.
Striking this balance can be done in several ways:
Present both Summary and Detailed Information
One should not compromise on detail in an EB-5 business
plan. While there are some in the industry who believe that a
shorter plan is best, experience dictates that providing as much
relevant detail as possible ensures that any questions that adjudicators may have can be minimized --or eliminated entirely-- if
the detail they seek is already in the plan. One should not fear
submitting a longer business plan to USCIS, as long as the adjudicator can quickly and simply find the summary information
needed and it is clear that additional detail is available should
the adjudicator wish to take a ‘deep dive’ into the details. One
of the best ways to make it easy for adjudicators is to properly
organize the plan from the adjudicator’s perspective and make
good use of headings and subheadings, so ѡ