Civitas Capital Group’s Mine Ekim Offers Insights on EB-5 Policy Shifts

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Mine Ekim, Managing Director, Legal & Head of Investor Experience at Civitas Capital Group, has co-authored an article in the Spring 2026 issue of IIUSA’s Regional Center Business Journal examining how USCIS is administering the EB-5 program four years into the EB-5 Reform and Integrity Act of 2022 (RIA).

Written with Steven C. Reingold and Rohit Kapuria of Saul Ewing LLP, the article traces the USCIS policy shifts now shaping EB-5 adjudications: the November 2025 decision in Moody v. Mayorkas, which rolled EB-5 filing fees back to pre-April 2024 levels and left investors reconciling corrected USCIS receipts; the USCIS move to a balanced first-in, first-out (FIFO) approach effective March 30, 2026; and continued high rates of requests for evidence (RFEs), notices of intent to deny (NOIDs), and notices of intent to revoke (NOIRs) tied to source- and path-of-funds documentation.


The authors also examine the EB-5 filing surge expected ahead of the September 30, 2026 grandfathering deadline, and what heightened USCIS scrutiny means for petition quality and practitioner preparedness.

Read the full article (pp. 45-47).

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