H. Ronald Klasko, Esq. Klasko, Rulon, Stock & Seltzer, LLP Philadelphia New York 1800 John F. Kennedy Boulevard., 17 th Floor317 Madison Ave., Suite 1518 Philadelphia, PA 19103, USA New York, NY 10017, USA A Legal Overview of the EB-5 Program October 2012

Klasko, Rulon, Stock & Seltzer, LLP H. Ronald Klasko, Esq. H. Ronald Klasko (Ron) is one of the country's leading lawyers representing investors in EB-5 cases. He was the Chair of the EB-5 Committee of the American Immigration Lawyers Association for the past 3 years. In that capacity, he has led the advocacy efforts of immigration attorneys around the world relating to improving EB-5 legislation, regulations and adjudications. Ron represents two of the three largest regional centers and is a designated preferred attorney for filing EB-5 petitions for many of the approved regional centers. He also regularly works with developers creating new regional centers and with investors investing in regional center or individual projects. Ron is a founding member of Klasko, Rulon, Stock & Seltzer, LLP and serves as its Managing Partner. He has practiced immigration law exclusively for over three decades. Under his leadership, the firm has been chosen with four other firms by Chambers Global as the top U.S. business immigration law firms. Ron, himself, was named as one of the top two most respected corporate immigration lawyers in the world for the last six years by the International Who's Who of Business Lawyers.

Klasko, Rulon, Stock & Seltzer, LLP Extension of EB-5 regional center pilot program Possible new EB-5 legislation Expected EB-5 quota backlog for China in 2013 October 16, 2012 EB-5 Stakeholders meeting Copyright © All rights reserved. For more information, visit

Year of the Dragon Project Specific Issues

Klasko, Rulon, Stock & Seltzer, LLP Job Projections Most important issue Construction jobs compared with operations jobs 2½ year rule Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Operations Jobs Visitor spending jobs challenged Tenant occupancy jobs being challenged Owner-operated jobs accepted What is required for I-829? Reliance on direct jobs requires proof of employees’ U.S. citizenship or permanent residence Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Construction Jobs How calculated? Direct construction jobs if construction lasts 2 years Indirect and induced jobs only if construction less than 24 months Only have to prove construction expenditures for I-829 Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Business Plan Compliance with EB-5 requirements Quarterly timelines Market analysis critical Consistent with economic report Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Bridge Financing Acceptable if EB-5 money anticipated from the beginning Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Other Issues Regional Center approved for geographical area and industry codes Unemployment over 150% of national average for TEA Investment at risk EB-5 capital used for job creation Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Investor Requirements Document lawful source of funds Document path of funds from investor to project Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Subjective Issues Job cushion Exit strategy Escrow Percentage of capital stack Reputation of developer Likelihood of project proceeding as planned Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Special Issues Travel  Must have residence in U.S.  If will be out of the U.S. 6 months or more, consider filing reentry permit Must file reentry permit if will be out of the U.S. 1 year or more Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP Special Issues Children  Only children under 21 at time of conditional permanent residence  Exception: if EB-5 petition (I-526) filed before age 21, and apply for permanent residence promptly, child can be included Copyright © All rights reserved. For more information, visit (cont’d)

Klasko, Rulon, Stock & Seltzer, LLP For more Information Copyright © All rights reserved. For more information, visit

Klasko, Rulon, Stock & Seltzer, LLP For Further Information H. Ronald Klasko, Esq. Klasko, Rulon, Stock & Seltzer, LLP Telephone: (Philadelphia, Pennsylvania, USA) (New York, New York, USA) Offices: Philadelphia, PANew York, NY 1800 John F. Kennedy Boulevard317 Madison Avenue Floor 17 Suite 1518 Philadelphia, PA 19103, USANew York, NY 10017, USA Copyright © All rights reserved.

Klasko, Rulon, Stock & Seltzer, LLP online Copyright © All rights reserved.

Klasko, Rulon, Stock & Seltzer, LLP COPYRIGHT NOTICE The materials contained in this PowerPoint does not constitute direct legal advice and is for informational purposes only. An attorney-client relationship is not presumed or intended by receipt or review of this presentation. The information provided should never replace informed counsel when specific immigration- related guidance is needed. Copyright © 2012 Klasko, Rulon, Stock & Seltzer, LLP. All rights reserved. Copyright © All rights reserved.