Traditionally, USCIS has treated unsecured loans as unviable sources of EB-5 funds. The U.S. Court of Appeals for the D.C. Circuit, however, changed the landscape of the EB-5 program in 2020 when it concluded in Zhang v. USCIS, 978 F. 3d 1314, 1319-22 (D.C. Cir. 2020) that loan proceeds invested into an NCE are indeed…
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