Kraig Schwigen simply didn't believe me when I told him that I had no idea that CMB's first batch of I-829s had been approved! "Pshaw!", I imagined him growling via his email, questioning my sincerity. Although the news of this milestone had been well-communicated within the immigration bar, I'd been a bit out of the loop for the past few months, for the reasons mentioned above. Kraig's disbelief that I could go from being one of CMB's biggest cheerleaders to apathetic about the full-circle conclusion of their first EB-5 investors' permanent residency was understandable!
I've written about CMB a number of times and expressed my opinion that its President, Pat Hogan, created the better EB-5 mousetrap when he designed the particulars which define each and every project CMB undertakes. I've also told you that when the day came when these folks were granted their first I-829 approvals, the distance between CMB and the other traditionally successful Regional Centers would begin to widen markedly. That's exactly what is happening.
CMB now has approved I-829s for their first three project, a rapid accomplishment explained by the success with which they have marketed their programs, completing tranche after tranche with Pat and Kraig's laser-beam precision. Despite the concerns of many who questioned USCIS' commitment to honor the "indirect job creation only" methodology invented by CMB -- remember, just because USCIS said something was acceptable at the RC formation and initial I-526 level doesn't mean they'll feel the same way two years down the road -- USCIS has delivered, and delivered well.
The key to CMB's success in I-829 is not about rocket science, bells, or whistles. It is simply about what I've been saying for the past two years on this blog and everywhere I speak: doing what you SAY you are going to do. The primary enemy of the EB-5 investor is the business plan of the project into which they invest, and therein lies the ironic conflict: in a turbulent economy, deft maneuvering and the ability to turn on a dime is the best way for a business to survive; it is also the fastest way to create a "material change" in an EB-5 structure and bring the whole house of green cards toppling down.
CMB knew this from the beginning, and each CMB project is cast from the same identical mold as the first. Think precision engineering applied to project structure; if you create no room for error, you don't need to be nimble. In the case of CMB, the complex project structure Hogan innovated marries conservative returns, a finite exit strategy, and formulaic indirect job creation to create what is, I believe, the most proven EB-5 program out there.
USCIS granted CMB statewide operational authority in California and Ohio last year, so expect more projects in the pipeline. In Kraig's words:
"We have sailed past the 400 investor mark. We are now on our ninth investor partnership...What has not changed though is we continue to have a 100% approval rate on I-526 and I-829 petitions"
Small wonder for the big numbers, eh?
Congrats to Team CMB from your old friend in Florida...(-: