CMB & Investment Related Issues Questionnaire:
Please note, these FAQ’s are for informational purposes only and they are not meant to be a substitute for professional legal and financial advice. Please consult an attorney and/or qualified financial expert before choosing any EB-5 investment.
1. Where is the investment situated?
The investments will be situated in San Bernardino, Riverside and Sacramento Counties in California, USA they and are associated with the former military bases located in these counties. This is the geographic scope of the CMB federally designated Regional Center. CMB’s first rounds of investments were focused on the former Norton Air Force in San Bernardino County. Improvements at the former Norton Air Force Base in, San Bernardino County and the former McClellan AFB in Sacramento County. The other bases that comprise our Regional Center are the former George Air Force Base in San Bernardino County, the former March AFB in Riverside County, and the former Mather AFB and Sacramento Army Depot in Sacramento County. CMB will coordinate any future military investments with the redevelopment agencies associated with each of these former bases.
2. How is the investment structured?
The Limited Partnership is managed by the General Partner of the Limited Partnership, CMB Export LLC. The General Partner is responsible for initiating and managing the investments of the partnership. The General Partner is also responsible for the day to day business operations of the partnership as well as working to ensure that the Regional Center meets all laws and regulations pertaining to the EB-5 program. The Limited Partners who are the Foreign National EB-5 Investors and the General Partner share in the profit from the Partnership’s business activities on a pro-rata basis as set out in the Limited Partnership Agreement.
3. What is a Limited Partnership?
The limited partnership is formed by filing a charter with a state government and consists of a general partner and one or more limited partners. The charter details the rights and powers of the limited and general partners, percentages of ownership, and distributions of profits. The general partner manages the business. The limited partners are passive investors liable only for the amount of their investment.
This is best explained through an overview of the various entities available to investors.
A corporation, formed by filing a charter with a state government, is owned by shareholders. The corporation is taxed on its income. The shareholders are only taxed on dividends paid to them by the corporation. Shareholders do not pay tax on the corporation's income. The shareholders only risk the cost of their investment in the corporation; they bare no responsibility for the general affairs of the corporation.
A partnership is comprised of two or more people or entities coming together for an enterprise, without any particular state charter. The partnership does not pay tax, but passes through all items of income and loss to the partners. The partners pay tax on partnership earnings. Each partner, unlike a corporate shareholder, undertakes responsibility for the entire operations of the partnership. If the partnership were to be sued and judged liable, each partner bares full responsibility for the damages. A corporate shareholder has no such direct liability.
A limited partnership combines corporate limited liability with partnership taxation. The limited partnership, formed by filing a charter with a state government, consists of a general partner and one or more limited partners. The charter and the Limited Partnership Agreement detail the rights and powers of the limited and general partners, percentages of ownership, and distributions of profits. The general partner manages the business. As in a corporation, the limited partners are passive investors liable only for the value of their investment. As in a general partnership, limited partnership income is taxed at the partner level, not at the entity level.
A limited liability company is a corporation that passes through income and loss to the shareholders but offers shareholders the same limited liability as a limited partner or corporate shareholder. You could say a limited liability company is a corporate version of a limited partnership.
4. What are my risks?
As in any investment there is a risk of total loss. However, CMB works hard at its mission to invest our clients’ funds in manner that minimizes the risk to the client while still meeting the EB-5 law’s “at risk” requirement as well as the shared goal of achieving an EB-5 Visa. CMB requires its borrowers to identify sources of revenue for the repayment of the loan and to make annual appropriations of interest and principle. The borrowers are to provide CMB with recent audited financial reports and other references such as a Standard & Poors or a Moody’s rating. For example, the IVDA had reported a AAA rating from Standard & Poors. There remain matters much beyond the Regional Centers control such acts of god, war, and market fluctuations in income and or real estate values. All investors are provided the opportunity to visit the project sites, meet with management, be provided with documents as needed to enable review of the investment, and are provided with references to permit independent verification of the information contained in the investment prospectus.
5. Must I invest the full $500,000 before you will apply for my green card?
YES: Although the regulations permit escrow arrangements, other EB-5 investment companies place EB-5 investors’ funds directly into the project; however for investor protection, with CMB Investor’s funds are placed into a secure CMB authorized escrow account pending petition approval. In this case the funds may only be released to the project upon approval of EB-5 Investor immigration petition.
6. How safe is my investment?
CMB believes it is a safe as possible given the legal requirement that the investments are truly “at-risk”. This is why CMB structures loans to government agencies or master base developers where in either case there is a pledge of public monies as part of its investment portfolio.
7. Why is a promoter used for this EB-5 program?
CMB uses promoters or finders from time to time to assist it in locating prospective EB-5 investors.
8. If I wish to visit the military bases/CMB investment project sites, is this possible?
Yes, CMB can arrange such visits on a case by case basis provided enough notice is given to schedule a visit.
9. Is the EB-5 Green Card 'guaranteed' by participating in this investment program?
A Green Card cannot be "guaranteed" however your $500,000 is held in a "Bank Escrow Account" and refunded in full in the unlikely event of a denial of your I-526 petition. No one can ever guarantee the outcome of a visa application or petition; it is solely up to USCIS to adjudicate. The key is to have a well prepared petition by competent, legal counsel experienced in EB-5 visa matters, to create the best opportunity for success. No money is released from the bank escrow account to the project until your I-526 Petition is approved.
10. If my I-526 petition for my 'Green Card' is denied, do I get my $500,000 back?
Yes, in the unlikely event of an I-526 denial you would be refunded your entire subscription amount ($530,000) and any interest that would accrue while the funds were held in escrow.
11. Does the Administration fee include unbiased legal counsel to represent me for my application to USCIS?
No, CMB believes that it is important for you to have independent legal counsel representing your interests. As a result while we are able to recommend a lawyer who can competently handle EB-5 applications, you will ultimately choose the attorney who will represent you.
12. How extensive is the paperwork/application process, will I receive help?
You will be provided with a detailed schedule of requirements and a list of documents from your immigration attorney. You will also be assisted by the CMB team throughout the entire application process.
13. Am I still required to hire an immigration attorney?
Yes - it is important for you to have independent legal counsel representing your interests. The EB-5 application process is complicated and many technical requirements must be met.
14. What are the fees if any?
CMB requires an $30,000 syndication fee at the time the subscription is entered into.
15. US Tax Matters and Considerations
The United States charges income tax on all US Citizens and Permanent Residents alike, and based upon worldwide income. Foreign Investors should consider the tax implications and review matters with their professional advisors regarding becoming a US Permanent Resident before making any investment.
16. Pre-immigration Tax Planning
Before you become a resident of the United States you may wish to consider reducing or eliminating some of the United States income, gift and estate tax consequences which would be applicable to you once you become a United States taxpayer. These objectives may be accomplished through utilizing some common planning techniques such as:
• making gifts
• accelerating income and gains
• deferring deductions and losses
• creating, amending and/or revoking wills and trusts
• creating and/or reorganizing entities
17. Who should invest?
EB-5 investors include people from all walks of life; professionals, business people, persons wanting to facilitate a child's education, and retirees. Because the EB-5 visa permits employment in the US, many EB-5 investors become involved in charity or part time work. Simply put, the EB-5 visa gives you the flexibility to do what you want in the USA. If you don't want to actively manage your business, you should consider EB-5.
18. How is my limited partner interest protected?
The Certificate of Limited Partnership must be recorded with the State of California as a public record. The Certificate refers to a Schedule A of the limited partnership agreement, which lists the names and percentage interests of the limited partners. Investors are protected by California Revised Limited Partnership Act and the Uniform Commercial Code, and other California laws as well as Federal and State Courts in California. Funds are typically invested with governmental agencies and thus part of the public record and collateralized in the case of investments in private agencies.
19. Is my investment guaranteed?
No. The law requires an "at risk" investment without guarantees or redemption rights. CMB goes to great lengths to minimize or mitigate risk but the investment is required to be “at risk”. Prospective EB-5 investors should be extremely cautious of any Regional Center or their representative that indicates their EB-5 investment is guaranteed.
20. What are my risks?
As in any investment there is a risk of total loss. Like everybody we risk the deleterious effects of acts of god, war, financial distress of state and local governments and market fluctuations. We urge all investors to visit us, check our references and to independently verify the information contained in our prospectus otherwise known as the PPM. (Private Placement Memorandum).
21. How does the bank "escrow" account protect me against the risk of losing my money?
The initial cash deposit from the investor is placed in a legal, interest-bearing escrow bank account. When an escrow bank account is established, the funds continue to belong to the investor; however, they are committed to be placed into the investment upon petition approval. The CMB Escrow Agreement with the investor that requires the funds to be released from the account only when the petition is approved by the USCIS.
22. What are CMB Export’s fees?
CMB, as the General Partner receives a percentage of the interest of the total interest that is charged to our target investments (Borrowers). It should be noted that all routine day to day expenses are covered in the interest that is paid to the General Partner. The General Partner is also entitled to 20% of the profits derived by the Partnership while 80% of said profits and/or gain are distributed to the Limited Partners on a pro-rata basis.
23. Is CMB Export LLC currently a qualified Regional Center; and if so, what are the advantages of investing with a federally designated regional center like CMB Export LLC?
Yes, CMB was designated as a Regional Center by the Federal Government in 1997. The advantages of investing with a regional center are:
• Facilitates the pooling of capital of multiple EB-5 investors
• Investors can take credit for jobs created directly as well as indirectly from their investment in the Regional Center. Indirect job creation may be demonstrated using any reasonable approved methodology.
• Congress gave the USCIS discretion to give priority to EB-5 applications filed in conjunction with a Regional Center.
• CMB has a track record of success with several projects underway.
• The regional center handles the day to day management of the investments.
24. What is meant by qualifying investment "capital?"
The regulations define capital as cash, equipment, inventory, other tangible property, cash equivalents and indebtedness secured by assets owned by the alien entrepreneur. A debt will qualify as capital only when the alien entrepreneur is primarily and personally liable for the indebtedness. An investor may also acquire the required amount of capital via a gift.
25. When may the investor exit the investment?
The anticipated duration of the Limited Partnership is 6 (six) years. However, depending on the operations of the Partnership, it could be shorter or longer. CMB investments are loan based versus equity based. By this we mean there is nothing that has to be sold by the Limited Partners in order to exit the partnership. We believe structure provides a greater assurance when determining the point at which the limited partners will be able to exit the investment. Remember, in an equity based investment all of the EB-5 investors will be exiting the investment at or about the same time. This mass exodus can dramatically affect not only the ability to sell the equity interest be it ownership in a hotel, resort, far, commercial building etc. But the value of the equity shares because all of the limited partners will be selling identical ownership interest. A loan based investment avoids these pitfalls because there is nothing to sell in order to exit the partnership. Once all the investments are repaid the respective capital accounts and shared retained earnings and capital gain will be distributed to each limited partner.
26. What investment enterprises qualify under the regulation?
Under the regulations, there are three types of qualifying investments for investor visa purposes: the new commercial enterprise, the expansion of an existing business, or the rehabilitation of a troubled business. They are defined as follows:
• The "new commercial enterprise" is either the creation of an original business, or the subsequent or simultaneous restructuring of an existing business such that a new commercial enterprise results;
• The "expansion of an existing business" may qualify through the investment of the requisite dollar amount such that a 40% increase in either net worth or the number of employees results; or
• The "troubled business" investment requires the requisite dollar amount in a business which has been in existence for at least two years, and for a period of 12 to 24 months prior to the filing of the petition, has demonstrated at least a loss of profit equal to 20% of the business net worth.
A qualifying investment may utilize any one of these three types of business enterprises. However, most recently, investors have successfully utilized either the "new business" or "troubled business" situation, which qualifies for special, advantageous treatment by the regulations in terms of the job creation requirements. CMB’s investments target the development of “back-bone” infrastructure at former U.S. Military Bases in California and take the form of 6 year investment loans to the respective base reuse agencies.
27. What are the obligations of the investor to participate in the investment?
Under the regulations, the investor must be "active" in the management of the investment. The investor must engage in the management of the new commercial enterprise, either through day-to-day managerial control or through policy formulation. However, the regulations do specifically allow that an investor will qualify as a "limited partner" as defined in the Revised Uniform Limited Partnership Act. The Investment Visa Program meets all the regulatory requirements by enrolling the investor in the investment as a limited partner. This passive role allows the investor to continue to engage in his or her own business without needing to participate in the investment operations. Additionally, this allows the investor to live where he or she pleases, and gives him or her the option to enter and exit the United States without any obligation to manage the investment. Most importantly, the limited partner, like the corporate shareholder is only liable to the enterprise to the extent of the agreed-upon investment. This business structure protects the investor.
28. What is an "escrow" account, and when does the investor transfer the money to this account?
An Escrow Bank Account is a legal, interest-bearing account established in a bank to hold the initial deposit in trust until the completion of visa processing. This type of account is commonly used in the sales of real estate, businesses and personal property. The CMB Export, LLC Investment Visa Program has established an Escrow Bank Account for the purpose of safely holding an investor's funds until such time as the I-526 petition has been approved by the USCIS. Escrow accounts have been established at several leading banks both in the United States and overseas. Under the agreements entered into with the servicing affiliate, the investor's money is not authorized to be released from the Escrow Bank Account by the bank until the I-526 petition has been approved. This process was created to protect the investor.
29. What is meant by "net assets"?
An investor's net assets, or net worth, can be determined from a simple calculation: the combined value of all things owned, minus the combined value of all liabilities (debts). The assets may be from any legal source, anywhere in the world:
• cash;
• gifts and inheritances;
• the net cash value of life insurance;
• the value of personal property such as jewelry, art and antiques;
• the proceeds from the sale of a business or real property (real estate);
• the value of real property, including the family home and any additional homes;
• the value of securities such as stocks and bonds, including stock in a family business.
(Naturally, funds that come from such sources as smuggling, the sale of illegal drugs or any illegal activity are not allowable.)
Verification of assets and the sources of those assets will be required. It will not be necessary to document or reveal all assets, but only enough to meet the requirements of the USCIS and the Program -- an absolute minimum of US $530,000. The easiest proof of net worth, of course, is a bank account with actual cash.
30. Why are the loans to the government agencies at a low interest rate?
CMB’s goals on behalf of the EB-5 investor are threefold. Our primary focus is upon achieving the green card and preserving the initial capital contribution of our investors. The rate of return on the investment is third but the first two are our primary focus. We feel that investing with government agencies or master base developers is the best strategy in order to achieve these goals.
In effect we are working to minimize risk. No Regional Center investment is allowed to eliminate risk but we do not feel that you, as the investor, have to invest you r fund foolishly. The projected rate of return on any investment is normally associated with the amount of risk associated with that investment. The Government entities we invest with have access to low cost capital. They can issue bonds, receive grants, and have other avenues for low cost funding. We must be competitive with our rates.
31. Once I put my money in CMB what do I receive for my investment?
Each investor who is admitted to the CMB Limited Partnership is given a certificate of Limited Partnership Ownership. They become a limited partner with all the rights granted by the Limited Partnership Agreement and Subscription Agreement and are protected by the California Uniform Commercial Code and other relevant California Laws. Additionally, each Limited Partner is granted access to the secure portion of our website where they can monitor the activities of the partnership and their own individual capital account. You also get the hard work, experience and dedication of the entire CMB team. Remember we are only a phone call or an email away for any questions you may have.
32. When I send my funds to CMB and I am waiting for my I-526 Petition, how do I know my funds are safe?
The funds are put into an escrow account whereby neither the Partnership nor the investor has access to them. The funds cannot be released unless one of the provisions of the escrow agreement are met. The terms specifically state that the I-526 Petition must be approved or both parties must sign off on disbursement; otherwise, the funds cannot be released. Additionally, escrow funds are held through the Trust Department of the bank in the name of the investor. The bank never takes title to the funds.
33. Will CMB help me with filing my immigration petition?
CMB Export, LLC will work hand in hand with your immigration attorney but CMB requires all investors to secure their own legal counsel to file the paperwork and complete the applications for an EB-5 investor visa. CMB is the business side of this complex process. CMB will provide documents in support of the investor’s I-526 and I-829 Petitions to the attorney of the investor’s choice. An EB-5 investor must retain his or her own immigration counsel to assist in the initial I-526 petition or application. However, CMB will assist your counsel in providing information on the investment and the regional center. CMB will provide supporting documentation including a comprehensive business plan.
34. Why do you believe CMB is a superior program to other Regional Centers?
Because CMB has three clearly established goals that are designed around the needs of the EB-5 investors. Most equity investments add in a project that the General Partner has an ownership interest in. In those cases the prospective investor has to look very closely at the equity portion of the investment as well as how the investment is structured to meet the immigration needs of the investor. Our three primary goals are:
Qualify the investor for a permanent visa under the EB-5 investment program.
Secure a return of the original capital investment to the investor.
Secure some sort of return on the investment if at all possible.
Each one of the above is discussed throughout our website and in other frequently asked questions. In addition the following strengths are a part of every CMB investment.
• Proof of Jobs. Investors should be very interested in the details of any EB-5 program and paramount to understanding EB-5 is proving new jobs. CMB combines investor capital with Government funds and private capital to multiply the effects its investment capital has on job creation, thus creating many more new jobs than required.
• I-526 Approval or the Client receives their money back including all interest accrued while the funds are in escrow.
• A well defined and simple exit Strategy. The investment is structured as a six year infrastructure investment loan. This structure provides for a very simple exit strategy exit strategy. When the loan is paid back and no other public sector investment remain the partners vote to liquidate the partnership and the original investment is returned. There is nothing to sell. The investors do not have to worry about real estate markets going up and down or their investment being tied to any other segment of the economy such as travel and entertainment, farming, bio fuels and electricity or the whims of any other segment of the economy.
• Low Risk Investment. The investment is placed with a government agency who has the power to raise funds through several sources such as Tax Revenues, Bonds and State or Federal Grants. Additionally each agency has oversight by various joint powers authorities.
• Transparency in the financial transaction. Investors in CMB have a Right of Access to the partnership records. The government entities’ financial records are also available. Thus our investors can see all the financial records of all parties.
• California Location. Our California location is a major strength. California has a vibrant economy and it would have the world’s seventh largest economy if it were its own country.
• The greatest strength of CMB is the Simplicity of the Program. Invest funds
through a government agency. There is nothing to sell, rent or actively manage
day-today. The return and the costs are fixed. CMB Infrastructure Investment
Group II, LP is a continuation of two previously approved projects, CMB Investment
Groups A and I. The exit strategy is simple and straight forward.
And, further, much of our competition is dependant on a particular investment project, be it rehabilitation of warehouses, growing almond trees and grapes, the operation of dairy farms, loans to a particular business, etc. Potential investors have to ask what if that business fails? What are the methodologies for proving that new jobs will be created? Are jobs that are moved into existing businesses considered new? Are the workers harvesting grapes and other agricultural products going to be able to meet the strict requirements for proof of direct job creation? CMB invests into multiple projects with a primary focus on infrastructure improvements. These infrastructure improvements have always been proven to produce jobs both in the past and by the using economic methodologies such as RIMS II, REDYN and IMPLAN. In summary, CMB has simple proven methods to prove job creation. CMB Limited Partnership fund infrastructure improvements in a variety of individual projects. Additionally, CMB funds are no more that 25% of the overall investment. This means that each investor has at least three outside dollars that are working to create new jobs for every dollar they are investing. CMB investors are afforded “peace of mind” that is unparallel in any other Regional Center investment when consider job creation and when or if it will take place. CMB investments rely solely upon indirect job creation and CMB investment show exactly how and when the indirect jobs will be created as a part of each investor’s I-526 petition. Investments that rely upon direct jobs subject each investor to wondering when and if those direct jobs will be created. Some of the most noted EB-5 immigration attorneys have described direct jobs as “messy” and something to be avoided.
35. What are the risks associated with the business investment regarding the removal of the conditions from the conditional visa (the I-829 Petition) twenty months after the I-526 Petition approval?
The risks associated with the business investment and the removal of conditions are depend on the individual investment a potential investors chooses. Each Regional Center is different and they structure their investments differently.
The prospective investor needs to see how well the investment they are considering meets the requirements for I-829 approval.
The I-829 is primarily an anti-fraud measure. The USCIS has two primary concerns when determining if they are approving the I-829 petition of an investor. (1. Have the jobs been created? 2. Is the investor still active?) The following (LINK) is directly to the USCIS where they discuss approval of for I-829 by the District Director. You will see that “A-C” deal with being fully invested and maintaining the investment during the conditional residency period and “D” addresses job creation. Simply put, the investor must be able to show that the fully amount of their capital contribution was at risk and the required jobs were created. The ability to prove up these requirements will vary from Regional Centers to Regional Centers. CMB is able to show how jobs are created at the time the I-526 is being adjudicated. Any Regional Center that uses Direct Jobs as a portion of the jobs being claimed will not be able to show that the jobs were created until the I-829 stage. CMB investors know that as soon as monies are spent, jobs are created. This eliminates the uncertainty that goes along with using direct job creation.
CMB investments use Indirect Job creation only and CMB requires at least three outside dollars for each CMB dollar that is being invested. What is not being asked in this questions is addressed in Question 39. Every prospective investor needs to consider a “worst case scenario” of every investment they are considering. Every Regional Center should have an answer to this hard hitting question. The attached list is a series of questions that should be presented to every Regional Center.
36. What is the likelihood of the investor getting the basic return of his/her original investment?
CMB investments are made with government entities or master base developers that have identified a number of sources of revenue as ways to repay our investors. EB-5 investments are required to be “at risk” investments. No Regional Center is allowed to guarantee the return of an investors funds. The USCIS has been very clear on this issue, the funds must be at risk. On the other hand there is no requirement that the funds be invested foolishly. CMB structures investments that are compliant with the rules and guidelines of the USCIS that also afford the investor the greatest likelihood of a full return of their capital contribution. CMB investments are loan based infrastructure investments that have a pledge of public monies even if the investment is made with a private entity. In a loan based investment the Limited Partners have nothing that needs to be sold. Equity investment have to worry about market trends and have certainly segments of the economy can impact the “Fair Market Value” of their ownership interest in any equity based investment.
We cannot guarantee that an investors funds are 100% safe but we can tell you that we believe that CMB investment structure has the lowest rick and the greatest likelihood of achieving the investor’s Green Car, preserving the original capital contribution and achieving some sort of a rate of return to the investor.
37. What is the likelihood of the investor realizing a profit in this investment?
The day to day expenses of our Group II investment are capped such that the interest rates charged to the investment targets are at least one percentage point higher than the cap on day to day expenses thus the projected rate of return is approximately 1% per year to the investor.
The investments are with government entities or master base developers. Each borrower makes quarterly interest payment to the partnership. Remember, the investment is loan based and the day to day expenses are capped so we feel that this structure affords the investor the greatest likelihood of realizing a profit on their investment.
38. What if the investment is lost? Will the investor also lose his/her visa?
This is one of many questions that should be asked of all Regional Centers any prospective investor is considering. Every Regional Center should be able to respond to this questions because this is something they should have considered already. What is a “worst case scenario” and what will happen to the investment and the hopes of immigration if a “worst case scenario” becomes a reality.
There are two concerns being discussed here, investment and immigration. Most if not all other Regional Center investments are structured differently from CMB investment. To answer the questions we are going to look at the absolute worst case where the investment no longer exists and neither does the Regional Center.
Non-CMB (investment): If the target investment no longer exists and the Regional Center no longer exists it is highly unlikely there is any chance the investor is going to be able to recover any of the monies they have invested. If the target investment ceases to operate there will probably be no sources of income to look to for repayment. The target investment may have some fixed assets to look to for repayment but it will have to be determined where the EB-5 investors stand in line among all of the other creditors when or if there are any monies that can be divided.
Non-CMB (immigration): Job creation methodologies are vitally important now. Remember there are direct and indirect jobs that are being claimed in the various Regional Center investments. If direct jobs are being claimed they are probably all lost in a worst case scenario. If the target investment and the Regional Center no longer exist where would the investor find proof of jobs whether they are direct or indirect. In this worst case the investor stands to lose all their money and the hopes and dreams of coming to the United States.
CMB (investment): CMB infrastructure investments are made with government entities or master base developers and in both cases there are pledges of public monies as a source of repayment. In the scenario CMB no longer exists and the target investment no longer exists. First we will consider the government entity. I am not sure how the government entity will cease to function but if it were to do so another entity would step in to serve that region. The country or the state would step in because individual home owners and businesses would still be required to pay taxes on their property. These streams of revenue would not cease. Additionally the assets of the government entity would still exist including any leased property that provides a source of income. The loan agreements in place with our borrowers identify a variety of sources of repayment beyond just fixed assets so our investors have a number of directions to look for repayment.
In order to make things fair, even through CMB investments are structured differently than any other Regional Center investment we are aware of, let’s say all the money is lost. Now we have to look at the immigration. In the case of a master base developer CMB investments fund infrastructure improvements including improvements to public roadways and right of ways. In California public funds can be pledged for improvements by a private entity in a Communities Facilities District. In our investment with McClellan Park there is a pledge of Mello-Roos bonds as a source of repayment. This pledge of repayment comes from the County level which would be Sacramento County.
CMB (immigration): CMB investments rely only upon indirect jobs and indirect jobs are proven through reasonable methodologies unlike direct jobs that require W-2’s, I-9’s and citizenship papers. Additionally CMB investments are able to show at the time of an investors I-526 petition adjudication that the indirect jobs are created when the monies are spent. This way if the target investment no longer exists and CMB no longer exists the investor and their attorney has there report detail how and when indirect jobs are created. Additionally, government, no matter who they are, would have public records indicating when monies are spent and what they were spent on. The indirect jobs needed by CMB investors can be proven in the very worst of a “worst case scenario”.
