Suppose you want a formal license from the U.S. government that allows you to raise tens of millions of dollars in investments through a government-promoted program that makes aliens into green card holders, a program in which you, the middleman, can levy fees on the aliens without limit?
Suppose, on the other hand, you want a credit card?
Which application do you suppose asks more personal questions of the applicant, the one for the fraud-plagued EB-5 immigrant investor program or for the credit card? Here is the full list of all the personal questions asked in these two programs:
| Application to handle millions in investments and green cards for aliens (DHS Form I-924) | Application for a simple credit card (Amex Every Day credit card) |
| Name | Name |
| Postal address | Postal address |
| Date of birth | Date of birth |
| Telephone number | Mobile phone number |
| Fax number | Email address |
| Website address | |
| Social Security number | |
| Total annual income | |
| Income source | |
Similarly, if you want to register to vote you have to tell the registrar your Social Security number and citizenship status. (If you are not one, you do not get to vote.)
DHS does not burden the would-be middlemen — applicants to operate EB-5 regional centers — with those basic questions, but, to be fair, does ask some questions about the types of investment programs they are proposing, and where the investments (in broad terms) will be.
The casualness that characterizes the administration of the EB-5 program and the number of frauds perpetuated by some of the regional center operators have been reported frequently in the national media and discussed at congressional hearings, but I did not recognize until now that DHS doesn't even bother to ask about the citizenship of the regional center operators, but, in a 1980's sort of way, it does inquire about fax numbers.
The Amex credit card, incidentally, is typical of the genre and was simply the first one I encountered; for more on that see here.
This unthinking, total lack of curiosity on the part of DHS emerged in the March 1 Federal Register, in which the agency announced, in a routine way, that it plans to keep on using the same limited sets of questions for regional center operators that it has used in the past.
If a reader thinks that these would-be-handlers of tens of millions of dollars in a government-promoted program should be asked to provide their citizenship status and their Social Security number, and maybe — gasp — a bank reference, they should convey those thoughts to the government before March 31 following these instructions:
Written comments and/or suggestions regarding the item(s) contained in this notice, especially regarding the estimated public burden and associated response time, must be directed to the OMB USCIS Desk Officer via email. Comments may also be submitted via fax at (202) 395-5806 (This is not a toll-free number). All submissions received must include the agency name and the OMB Control Number [1615-0061].
Note that you no longer can use the government's own postal system to communicate with this part of the government, but you are welcome to dust off the old fax to do so. I also wonder why the word "received" is in the instructions, it is totally extraneous, but then those OMB writers are not seeking Pulitzers.