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SENNEVILLE · EB-5 FIELD GUIDE

What should my project send me while hiring is behind schedule?

Sources checked:

THE DIRECT ANSWER

For direct jobs, request payroll and records establishing qualifying positions. For a permitted regional-center method, identify the expenditure, economic-model inputs, and other evidence required. A revised forecast explains expectations; it does not replace proof of actual events.

Building a file that survives a two-year gap

Take a hypothetical food-processing project in Ohio that sends quarterly updates. You request, in writing, monthly payroll summaries plus a written explanation whenever the forecast changes. Corporate records such as minutes approving a phase delay or construction draw schedules can be relevant to eligibility.

If an update contradicts an earlier statement, have the project reconcile the two before the discrepancy reaches a filing. For a direct-hire enterprise, wage and hour records, tax withholding filings and supporting personnel files establish that qualifying positions actually exist, while a headcount summary alone leaves the reviewer unable to verify who was hired and for how long. For a regional-center project relying on economic modeling, the inputs behind the model matter as much as its output, so expenditure records, invoices and disbursement or construction draw documentation supporting those inputs should accompany any updated report.

Ask the project to identify which inputs changed and why whenever a revised projection replaces an earlier one, rather than accepting a new total without an explanation tied to the underlying records.