Civitas Capital Group’s Mine Ekim Co-Authors Analysis of the EB-5 Rulemaking Comment Record

Mine Ekim, Managing Director, Legal & Head of Investor Experience at Civitas Capital Group, has co-authored an article in the Fall 2026 issue of IIUSA’s Regional Center Business Journal on what the public comment record on the Department of Homeland Security’s July 2026 proposed EB-5 rule reveals about where the EB-5 program stands four years into the EB-5 Reform and Integrity Act of 2022 (RIA).

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Written with Jill Jones of JTC Group, the article reads the 463 published comments not for the merits of any single provision, but for where commenters converged and where they split. EB-5 industry groups, regional centers, and investors aligned on bridge financing, the definition of “person involved,” source of funds for non-EB-5 capital, and the rule’s effective date, while investors and institutions diverged on sustainment and redeployment.

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The authors find that the EB-5 industry is defending reliance interests rather than seeking new rights, that EB-5 investors have emerged as a distinct constituency, and that the RIA’s integrity framework – fund administration, audits, and bona fides vetting – is no longer contested.

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Read the full article (pp. 66-69).