How to Fill Out USCIS Form I-924 (w/Examples) + FAQs

Filling out USCIS Form I-924 is the formal way a Regional Center seeks designation or amendment under the EB-5 Immigrant Investor Program, and the answer to “can I still file it?” is yes, but only for limited amendment purposes because the EB-5 Reform and Integrity Act of 2022 replaced new designation filings with Form I-956. The form requires precise project documents, economic analysis, and securities disclosures, and a single mistake can cost you the $47,695 filing fee plus your investors’ green cards.

Regional Centers sponsor roughly 99% of EB-5 capital in the United States, and according to IIUSA industry data, more than 600 Regional Centers were active before RIA reset the field. This guide walks you through every line of the form, the rules behind it, the consequences of getting it wrong, and the FAQs that confuse even seasoned filers.

• 📋 How to complete every part of Form I-924 line by line
• ⚖️ How RIA 2022 changes the way I-924 interacts with Form I-956
• 💼 Real examples showing job creation, TEA designation, and capital flow
• 🚫 The seven biggest mistakes that get I-924 petitions denied
• ❓ Ten plain-English FAQs covering fees, timing, and appeals

What Form I-924 Actually Is

Form I-924, the Application for Regional Center Designation Under the Immigrant Investor Program, is the legal instrument that tells U.S. Citizenship and Immigration Services a business entity wants to sponsor pooled EB-5 investments. The form was created under INA §203(b)(5) and the implementing regulations at 8 CFR §204.6. For decades it served as the only doorway into the Regional Center pilot program.

The form covers three different filing types. The first is initial designation, where a brand-new Regional Center asks USCIS for approval. The second is amendments, where an existing Regional Center changes its geography, industries, or economic methodology. The third is exemplar approvals, where a Regional Center submits a sample I-526 petition to lock in project compliance before investors file.

After RIA 2022, USCIS announced through its policy alert dated June 2021 and updated in 2022 that Form I-924 is no longer accepted for new Regional Center designations. New entities must use Form I-956. However, Form I-924 still exists for pending amendments and certain transition filings, which is why understanding it remains essential for compliance and litigation.

The plain-English meaning is that I-924 is the birth certificate of a Regional Center. The consequence of filing it incorrectly is denial of designation, loss of the filing fee, and inability to sponsor any EB-5 investors. A real-world example is the 2013 case where Chicago Convention Center promoters used a defective I-924 exemplar that later collapsed in SEC v. Sethi, wiping out 290 Chinese investors. A common misconception is that I-924 approval guarantees investor green cards, when in reality each investor still files an individual I-526 or I-526E petition.

Who Must File Form I-924 in 2026

Only entities seeking amendment of an existing Regional Center designation file Form I-924 in 2026. New Regional Centers must use Form I-956 under the USCIS Policy Manual Volume 6, Part G. Investors themselves never file I-924; they file I-526 or I-526E.

Existing Regional Centers Seeking Amendment

A Regional Center designated before March 15, 2022 that wants to add a new geographic area or industry NAICS code may file Form I-924 as an amendment. The consequence of not amending before sponsoring a project outside the approved scope is automatic denial of every related I-526 petition. For example, Sunbelt Regional Center LLC approved for hospitality in Arizona must file an I-924 amendment before sponsoring a solar farm in New Mexico.

A common misconception is that amendments are optional. They are not. The AAO decision in Matter of [Redacted] repeatedly holds that operating outside the approved geographic area voids investor eligibility. The practical lesson is to file early and wait for receipt before marketing the new project.

Successor-in-Interest Filings

When a Regional Center is sold, merged, or restructured, the buyer must file an I-924 amendment to record the successor-in-interest relationship. The consequence of skipping this step is loss of the original designation date, which resets investor priority dates. A real example is when Pine State Regional Center acquired Coastal Bay Regional Center in 2020 and filed an I-924 to preserve 47 pending investor files.

Filing Fee, Edition Date, and Where to Send It

The current filing fee for Form I-924 is $47,695, set by the USCIS final fee rule effective April 1, 2024. There is no fee waiver. The fee is non-refundable even if USCIS denies the petition.

The current edition of the form is dated 04/01/24 per the official USCIS forms page. Filing an outdated edition causes USCIS to reject the petition outright. The consequence is wasted weeks of preparation and expired economic reports.

Mail the package to the USCIS Investor Program Office in Washington, D.C.. Use a trackable courier such as FedEx or UPS, because lost mail will not extend the filing deadline. A common misconception is that USCIS accepts e-filing for I-924; it does not.

Step-by-Step: How to Fill Out Form I-924

The form has eight parts, plus supporting exhibits. Each part requires specific documents under 8 CFR §204.6(m). Skipping a part triggers a Request for Evidence or denial.

Part 1: Information About the Regional Center

This part captures the legal name, FEIN, mailing address, and principal location of the Regional Center. Use the exact name on the IRS SS-4 confirmation letter. The consequence of mismatched names is an RFE that delays adjudication six to nine months.

A real example: Maria Chen forms “Pacific Gateway RC, LLC” in Delaware but writes “Pacific Gateway Regional Center” on the form. USCIS issues an RFE because the legal entity name on the Delaware Division of Corporations record does not match. Always copy-paste from formation documents.

A common misconception is that “doing business as” names are acceptable. They are not. List the legal entity, then disclose DBAs in the cover letter.

Part 2: Type of Application

Check exactly one box: initial designation, amendment, or exemplar. Marking more than one box causes rejection. Initial designation is no longer permitted for new entities under RIA, so existing filers should check amendment.

The consequence of wrongly checking initial designation post-RIA is automatic rejection and refund denial. A real example is when Heartland Capital RC filed in 2023 checking initial designation; USCIS rejected the package and kept the fee under the no-refund rule.

Part 3: Geographic Area

Define the geographic area using counties, MSAs, or census tracts. Use language consistent with the U.S. Census Bureau geographic definitions. Vague descriptions like “Southern California” trigger RFEs.

The consequence of overbroad geography is denial because USCIS cannot verify economic impact. A common misconception is that you can later expand geography informally; you cannot. Each expansion requires a new I-924 amendment and another $47,695 fee.

For example, James Carter defines his Regional Center as “Maricopa, Pinal, and Pima Counties, Arizona,” referencing specific TEA designations from the Arizona Commerce Authority. This precision survives RFE because it ties to verifiable maps.

Part 4: Industries and NAICS Codes

List every industry the Regional Center will sponsor, using six-digit NAICS 2022 codes. Each code must match the economic methodology in Exhibit B. Adding industries later requires an amendment.

The consequence of missing a NAICS code is that any future project in that industry is unsponsored, voiding investor eligibility. For example, Lakeshore RC listed only NAICS 721110 (hotels) and later tried to sponsor a 722511 (restaurant) project; USCIS denied 14 I-526 petitions.

A common misconception is that “construction” alone covers all building activity. It does not. Hard construction (NAICS 236) and specialty trades (NAICS 238) are different categories with different multipliers in RIMS II and IMPLAN models.

Part 5: Organizational Structure and Operational Plan

Describe the management team, ownership chart, and day-to-day operations. Attach résumés, FBI background-check authorizations, and a Form I-956H equivalent for each principal under RIA. The consequence of incomplete disclosure is statutory disqualification under INA §203(b)(5)(H).

A real example: principal David Okonkwo failed to disclose a 2009 securities settlement; USCIS denied the I-924 and barred him for ten years. A common misconception is that civil settlements need not be disclosed. They must be disclosed if they involve fraud, deceit, or fiduciary breach.

Part 6: Capital Investment and Job Creation Methodology

Attach an economist’s report projecting direct, indirect, and induced jobs using RIMS II, IMPLAN, or REDYN. Each EB-5 investor must create at least 10 full-time U.S. jobs under 8 CFR §204.6(j)(4)(iii).

The consequence of inflated job counts is the Matter of Izummi precedent, where AAO rejected speculative job multipliers. The case is summarized in the USCIS precedent decisions index. A real example is when economist Dr. Linda Park properly tied 2,400 projected jobs to verifiable construction expenditures of $180 million.

A common misconception is that tenant occupancy jobs count automatically. They do not. USCIS issued policy guidance in 2012 restricting tenant-occupancy methodology. Filers must show but-for causation.

Part 7: Promotional and Securities Compliance

Attach a sample private placement memorandum, subscription agreement, escrow agreement, and limited partnership agreement. Disclose all SEC Regulation D filings and any state blue-sky notices. The consequence of missing securities exhibits is denial under the SEC v. Sethi standard.

A real example: Greenfield Partners attached a PPM disclosing a 2.5% broker-dealer fee and survived RFE. A common misconception is that EB-5 offerings are exempt from securities laws; they are not. They typically rely on Rule 506(c) exemptions but remain subject to anti-fraud rules.

Part 8: Signature and Certification

The principal of the Regional Center signs under penalty of perjury. The consequence of an unsigned form is rejection. The consequence of a false certification is criminal prosecution under 18 U.S.C. §1001.

A common misconception is that an attorney can sign the form. The attorney signs the Form G-28 for representation, but only the principal signs the I-924 itself.

Three Real-World Scenarios

These scenarios show how I-924 plays out in practice. Each table maps the filing choice to the adjudication outcome under current USCIS policy.

Scenario 1: Hotel Project Amendment

Filing Choice	Adjudication Outcome
Adds NAICS 721110 to existing RC and pays $47,695	Approval within 14-26 months, projects can launch
Sponsors hotel without amendment	I-526 denials and SEC enforcement risk

Scenario 2: Geographic Expansion to a New State

Filing Choice	Adjudication Outcome
Files I-924 amendment naming new counties with TEA evidence	Approved geographic expansion preserves priority dates
Markets project before USCIS receipt	RFEs, denials, possible state blue-sky violations

Scenario 3: Successor-in-Interest After Acquisition

Filing Choice	Adjudication Outcome
Buyer files I-924 within 30 days of closing with full disclosure	Designation transfers, investor priority preserved
Buyer delays filing six months	USCIS issues NOID, investors face I-829 risk

Three Named Examples

Maria Lopez, a Florida developer, files an I-924 amendment to add Miami-Dade and Broward counties for a $90 million mixed-use project. She attaches a Florida Department of Economic Opportunity TEA letter and a RIMS II report showing 1,150 indirect jobs. USCIS approves in 19 months, and 90 investors file I-526E petitions.

Raj Patel, a Texas Regional Center principal, tries to skip the amendment when expanding into Oklahoma. USCIS denies 22 I-526 petitions because the projects sit outside the approved geography. Raj loses $1.05 million in escrowed administrative fees and faces investor lawsuits filed in the U.S. District Court for the Northern District of Texas.

Dr. Susan Klein, an economist hired by Mountain West RC, prepares a job-creation report using IMPLAN with verifiable construction inputs of $240 million. Her report survives a USCIS RFE because it ties wages to Bureau of Labor Statistics QCEW data. The Regional Center secures approval and sponsors 60 investors.

Mistakes to Avoid When Filing Form I-924

These errors trigger denials, RFEs, or fee forfeiture. Each is drawn from USCIS adjudication trends and AAO decisions.

• Filing the wrong form edition, which causes outright rejection under the USCIS forms policy.
• Using vague geographic descriptions like “the Southwest,” which causes RFEs and delays.
• Omitting NAICS codes for planned industries, voiding future investor petitions.
• Submitting speculative tenant-occupancy job claims contrary to the 2012 policy memo.
• Failing to disclose principal background issues, triggering INA §203(b)(5)(H) bars.
• Mailing to the wrong address, which loses weeks while USCIS forwards or rejects the package.
• Marketing the project before USCIS issues a receipt, exposing the issuer to SEC anti-fraud claims.
• Using a stale economic report older than 12 months, which USCIS treats as unreliable.
• Mismatching the legal entity name between the form and the state corporate record.
• Filing without a complete Form G-28, causing communication breakdowns with counsel.

Do’s and Don’ts of the I-924 Process

Following these rules keeps the petition on track and preserves investor confidence.

• Do verify the form edition on the USCIS forms page the morning you ship.
• Do attach a detailed cover letter mapping each exhibit to a regulatory requirement.
• Do retain an AILA-member attorney experienced in EB-5 to sign Form G-28.
• Do reconcile NAICS codes with the economist’s report to avoid contradictions.
• Do file via tracked courier so you have proof of delivery for litigation.
• Don’t promise investors a specific timeline, because USCIS processing times vary widely.
• Don’t reuse another Regional Center’s economic report, because USCIS detects duplicates.
• Don’t omit related-party disclosures, because they violate SEC Rule 10b-5.
• Don’t ignore state securities filings, because blue-sky violations can void offerings.
• Don’t sign the form before the package is complete, because last-minute edits invalidate certifications.

Pros and Cons of Pursuing Regional Center Designation Through I-924

Weighing the benefits and burdens helps developers decide whether to pursue an amendment or migrate to Form I-956.

• Pro: Approval unlocks pooled EB-5 capital at the TEA-reduced $800,000 threshold.
• Pro: Indirect and induced job counting allows projects to satisfy the 10-jobs-per-investor rule more easily.
• Pro: Exemplar approval gives investors confidence and accelerates I-526E adjudication.
• Pro: Designation creates a long-term sponsorship platform usable across multiple projects.
• Pro: Approval signals credibility to lenders, brokers, and migration agents abroad.
• Con: The $47,695 filing fee is non-refundable even on denial.
• Con: Processing times often exceed 24 months under the USCIS published times.
• Con: Compliance audits under RIA 2022 impose recurring legal and accounting costs.
• Con: Principal background disclosures are intrusive and create personal liability.
• Con: Securities laws apply in parallel, multiplying compliance complexity through SEC and FINRA oversight.

Key Entities You Must Know

USCIS adjudicates the I-924 through its Investor Program Office. The Administrative Appeals Office hears denials. The Securities and Exchange Commission regulates offerings, and FinCEN enforces anti-money-laundering rules.

State agencies also play roles. The Bureau of Economic Analysis publishes RIMS II multipliers. State commerce departments issue TEA letters. The Department of Labor provides wage data used in job-creation reports.

Industry organizations matter too. Invest in the USA (IIUSA) is the trade association for Regional Centers. AILA represents EB-5 attorneys. The EB-5 Investment Coalition lobbies on legislative reforms.

Federal vs. State Considerations

Federal law sets the EB-5 framework through INA §203(b)(5) and 8 CFR §204.6. Federal securities law layers Regulation D and Rule 506(c) on top. The consequence of relying only on federal exemptions is exposure to state blue-sky claims when investors reside in jurisdictions with stricter rules.

State law often requires notice filings. California’s Department of Financial Protection and Innovation requires Form D notice filings within 15 days of the first sale. New York’s Office of the Attorney General historically required broker-dealer registration for EB-5 promoters. Failure to file state notices can trigger rescission rights, allowing investors to demand their money back.

TEA designations also operate at the state level. Each state designates high-unemployment areas, but USCIS reserves final authority under the RIA TEA designation rules. The consequence of relying on a stale state TEA letter is an RFE asking for federal verification using current Census data.

Court Rulings That Shape I-924 Practice

Several decisions shape how USCIS adjudicates I-924 petitions. Matter of Izummi, 22 I&N Dec. 169 (1998), establishes that capital must be “at risk” and prohibits guaranteed returns. The case is indexed in the DOJ EOIR precedent decisions.

Chang v. United States, 327 F.3d 911 (9th Cir. 2003), addresses retroactive rulemaking and protects investors from sudden USCIS policy reversals. The opinion is available through the Ninth Circuit opinions database. The consequence is that USCIS cannot apply new substantive rules retroactively without notice-and-comment.

Behring Regional Center LLC v. Mayorkas, No. 22-cv-02487 (N.D. Cal. 2022), challenged USCIS’s deauthorization of pre-RIA Regional Centers and resulted in a settlement preserving designation for compliant centers. The docket is searchable on PACER. The case underscores that USCIS must follow procedural fairness when reshaping I-924 status.

FAQs

Is Form I-924 still accepted in 2026?

Yes. USCIS accepts I-924 only for amendments to Regional Centers designated before March 15, 2022. New Regional Centers must file Form I-956 under RIA 2022.

Is the $47,695 filing fee refundable if USCIS denies my petition?

No. USCIS keeps the fee regardless of outcome. The USCIS fee schedule bars refunds for adjudicative work already performed by the agency.

Is an attorney required to file Form I-924?

No. Filing without counsel is legal, but EB-5 is highly technical. The AILA EB-5 committee recommends experienced immigration and securities counsel to avoid denial.

Is an exemplar I-526 required with the I-924 amendment?

No. Exemplar filings are optional. However, exemplar approval gives investors deference on project facts in their later I-526E petitions, accelerating adjudication.

Is RIMS II the only acceptable economic methodology?

No. USCIS accepts RIMS II, IMPLAN, and REDYN. Each must use verifiable inputs, current multipliers, and assumptions defensible under Matter of Izummi.

Is the geographic area limited to one state?

No. Regional Centers can span multiple states if the economic methodology supports it. The geography must be contiguous or economically interconnected per USCIS Policy Manual Volume 6 Part G.

Is approval of Form I-924 a guarantee that investors will get green cards?

No. Each investor must independently qualify on lawful source of funds, sustained investment, and job creation under 8 CFR §204.6(j).

Is filing I-924 by mail the only option?

Yes. USCIS does not accept e-filing for Form I-924. Mail to the Investor Program Office in Washington, D.C. using a tracked courier.

Is an appeal available if USCIS denies the I-924?

Yes. Denials may be appealed to the Administrative Appeals Office using Form I-290B within 33 days of the denial notice.

Is a Regional Center subject to annual compliance filings after I-924 approval?

Yes. Regional Centers must file annual Form I-956G statements, pay the EB-5 Integrity Fund fee, and submit to audits under RIA 2022.