Suggestions
Jeremy Shackle
EB-5 Industry Expert • Financial Modeler
Jeremy Shackle is the Principal at Consultancy 619, LLC, and his LinkedIn profile provides insights into his professional background and interests.1
Professional Background
Jeremy's vocation is finance, with a background in real estate development.1 He has experience in the EB-5 industry, where he has held various positions and witnessed rapid changes in the field.2 His career progression in this industry includes advancing from associate to senior associate, and eventually becoming the head of the consulting and affiliation business.2
Expertise and Interests
Jeremy describes himself as an EB-5 Industry Expert and Financial Modeler.4 His professional interests extend beyond finance and real estate:
- Geopolitics: One of his stated passions1
- International Commerce: Another area of passion1
- Financial Modeling: His self-described "nerd obsession"1
Recent Activities
In 2024, Jeremy has been active on LinkedIn, sharing updates about his career and industry insights:
- On April 1, 2024, he announced launching the "Campaign for the Defense of the Pronoun," possibly a tongue-in-cheek reference to language and communication issues.3
- On April 12, 2024, he reflected on his career progression in the EB-5 industry.2
- On September 17, 2024, he made a post related to EB-5, regional centers, and compliance.4
Jeremy Shackle appears to be a finance professional with a diverse range of interests and expertise, particularly focused on the EB-5 industry and financial modeling, while also engaging with broader topics such as geopolitics and international commerce.
Highlights
#EB5 regional centers need to be preparing now for their first quinquennial audit by USCIS, as mandated by the EB-5 Reform and Integrity Act of 2022 (#RIA). Everyone I’ve talked with who has already been through it has had a similar experience: IPO gives a long list with a short time to get ready. Records must be complete and organized, because auditors could ask for anything before or during the site visit. This presents a particular challenge to RCs operating under an affiliation (a/k/a "rent a center") model. Compliance managers should have a plan in place which covers not only records but all aspects of participating in the audit. Invest In the USA (IIUSA) is on top of this issue and has been disseminating helpful information to its members. Regional centers that are not IIUSA members should join today.
As USCIS continues to work its way through an eternally large pile of #I526 petitions, many for pre-pandemic investments, I am seeing more NOIDs than RFEs.
If agency staff cannot see in publicly available information sources that a project or business actually happened, the officer may jump straight to a denial. With only 30 days to respond, #EB5 investors and project sponsors must quickly address the critical issues. (Note: USCIS’s RFE/NOID templates are generic, confusing, and scary to novice readers. Cutting through the nonsense to find what they're really asking for is an indispensable skill.)
USCIS deals in probabilities. The officer has to believe that the project/business is likely to happen pursuant to the business plan in the record, albeit on a revised timeline, so that jobs will be created. Adjudicators know that things often do not go according to plan. They do not want to read a sob story. They really don't care why four years have passed with no observable progress or who is to blame for it. They care only that the problems have been solved and the project/business will happen and create jobs so that the petitioner will be eligible for the benefit sought.
Responding to an RFE or NOID is more art than science. What you don’t say matters as much as what you do say. Less is more. Good writing is essential. Tone is important. Respect is compulsory. Genuine gratitude is helpful. Snark, while so very tempting, is counterproductive. And, importantly, don’t go cheap when hiring someone to produce a response.
(Don't call me. I'm fully booked. This is just FYI.)
