OMB No. 1615-0061; Expires 01/31/2015

Form I-924A,, :.,
Supplement to Form 1-924:

Department of Homeland Security
U.S. Citizenship and Immigration Services

Part 1. Information About Principal of the Regional Center

----------------------------------r-~------------------~r----------------------

Name: Last
MASTROIANNI

First

Middle

NICHOLAS

A.

:, .
'. ·,
''

- - - - - - - - - - - - - - - - - - - L - - - - - - - - - - - - ' - - - - - - - - - - - - - - . ! ..

JnCareOf: U.S. IMMIGRATION FUND-NJ, LLC
Street Address/P.O. Box: 115 FRONT STREET, SUITE 300
City: JUPITER

I State: FL

(b)(S) Date ofBirth,....------.Fax Number
(mmlddlyyyy
(include area code): ( 5 61) 7 9 9-0 0 61

lzipCode: 33477
Telephone Number
(includeareacode): (561) 799-1883

Web site address: www. vi saeb- 5. com
USC IS-assigned number for the Designated Regional Center (attach the
Regional Center's most recently issued approval notice)

RCW 123 625 0 92 5 I

I. D.

12 3 625 0 92 5

Part 2. Application Type (check one)
18] a. Supplement for the Fiscal Year Ending September 30, 2 0 14

(YYYJ')

b. Supplement for a Series of Fiscal Years Beginning on October 1, _ _ (YYYJ') and Ending on September 30,

(YYYJ')

Part 3. Information About the Regional Center
(Use a continuation sheet, if needed, to provide information for additional management companies/agencies, regional center
principals, agents, individuals, or entities who are or will be involved in the management, oversight, and administration of the regional
center.)
A. Name of Regional Center: U.S. IMMIGRATION FUND-NJ, LLC

Street Address/P.O. Box:

115 FRONT STREET, SUITE 300

State: FL

City: JUPITER
Web site www. visaeb-5. com
Address:

Fax Number
(include area code): ( 5 61 ) 7 9 9 - 0 0 61

Zip Code: 334 77
Telephone
(include area code): ( 5 61 ) 7 9 9- 18 8 3

B. Name of Managing Company/Agency: U.S. IMMIGRATION FUND LLC

StreetAddress/P.O.Box:

115 FRONT STREET, SUITE 300

City: JUPITER

[ State: FL

Web site www. visaeb-5. com
Address:

[zip Code: 334 77

Fax Number
(561) 799-0061 Telephone
(561) 799-1883
(include area code):
(include area code):

C. Name of Other Agent: N I A

Street Address/P.O. Box:
City:

I

State:

Fax Number
(include area code):

Web site

lllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll

Izip Code:

Telephone
(include area code):
Fonn I-924A 01103/'

RCW14349521 01
egarcia2

1924A

12/15/2014
1

 Part 3. Information About the Regional Center (Continued)
Answer the following questions for the time period identified in Part 2 of this form. Note: If extra space is needed to complete any
item, attach a continuation sheet, indicate the item number, and provide the response.
1. Identify the aggregate EB-5 capital investment and job creation has been the focus of EB-5 capital investments sponsored through
the regional center. (Note: Separately identify jobs maintained through investments in "troubled businesses.")

I

A

EB-5 Capital Investment

UT OF ESCROW

Aggregate Jobs Maintained

Aggregate Direct and Indirect Job Creation

PROJECT UNDER CONSTRUCTION

N/A

(b)(4)
2. Identify each industry that has been the focus of EB-5 capital investments sponsored through the Regional Center, and the resulting
aggregate EB-5 capital investment and job creation. (Note: Separately identify jobs maintained through investments in "troubled
businesses".)
a. Industry Category Title:

NAJCS Code for the Industry Category

2

CONSTRUCTION

3

2

6

---

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

SEE EXHIBIT 3.2

PROJECT ONDER CONSTRUCTION

N/A

b. Industry Category Title:

NAICS Code for the Industry Category

N/A

-----

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

c. Industry Category Title:

Aggregate Jobs Maintained:

NAICS Code for the Industry Category

N/A

--

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

3. Provide the following information for each job creating commercial enterprise located within the geographic scope of your
regional center that has received EB-5 investor capital:
Industry Category Title:

a. Name of Commercial Enterprise:

NAICS 2362 & CODES IN EXHIBIT 3.3.A

65 BAY STREET FUNDING, LLC

(b)(4)

Address (Street Number and Name):

City:

State:

Zip Code:

115 FRONT ST., STE. 300

JUPITER

FL

33477

"' ...., ita! Investment:

EE EX 3.3.A

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

PROJECT ONDER CONSTRUCTION

N/A

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities that
have or will create or maintain jobs for EB-5 purposes?

0

No

~Yes

Form I-924A 01/03113 Y Page 2

2

 Part 3. Information About the Regional Center (Continued)
If yes, then identifY the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated with each job creating business.
Industry Category Title:

(1) Business Name:

MORGAN STREET DEVELOPERS URBAN RENEWAL

co.

NAICS 2362

&

CODES IN EXHIBIT 3.3.A

Address (Street Number and Name):

City:

State:

Zip Code:

666 FIFTH AVE.

NEW YORK

NY

10103

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

PROJECT UNDER CONSTRUCTION

N/A

(b)(4)
EE EX 3.3.A

Industry Category Title:
N/A
Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

b. Name of Commercial Enterprise:

Zip Code:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

State:

Zip Code:

FL
Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities that
have or will create or maintain jobs for EB-5 purposes?

D No 0

Yes

If yes, then identifY the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated with each job creating business.
Industry Category Title:

(1) Business Name:

N/A
Address (Street Number and Name):

City:

State:

Zip Code

NY
EB-5 Capital Investment

Direct and Indirect Job Creation

Jobs Maintained

Form I-924A 01103/13 Y Page 3

3

 Part 3. Information About the Regional Center (Continued)
(2) Business Name:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

c. Name of Commercial Enterprise:

State:

Zip Code:

Jobs Maintained:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

State:

Zip Code:

FL
Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

No

0

Yes

If yes, then identify the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated with each job creating business.
Industry Category Title:

(1) Business Name:

N/A
Address (Street Number and Name):

City:

State:

Zip Code:

NY
EB-5 Capital Investment:

Direct and Indirect Job Creation:

(2) Business Name:

Jobs Maintained:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

Zip Code:

Form I-924A 01/03113 Y Page 4

4

 Part 3. Information About the Regional Center (Continued)
d. Name of Commercial Enterprise:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation: Aggregate Jobs Maintained:

State:

Zip Code:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

0

No

Yes

If yes, then identify the name and address of each job creating business, as well as the amount of EB-5 capital investment and
job creation/maintenance associated with each job creating business.
(1) Business Name:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

(2) Business Name:

Zip Code:

Industry Category Title:

N/A
Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

Zip Code:

Industry Category Title:

e. Name of Commercial Enterprise:
N/A
Address Street Number and Name:

City:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation: Aggregate Jobs Maintained:

State:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

Zip Code:

No

0

Yes

Form I-924A 01/03113 Y Page 5

5

 Part 3. Information About the Regional Center (Continued)
If yes, then identifY the name and address of each job creating business, as well as the amount of EB-5 capital investment and
job creation/maintenance associated with each job creating business.
(1) Business Name:

Industry Category Title:

N/A

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

State:

(2) Business Name:

Zip Code:

Jobs Maintained:

Industry Category Title:

N/A

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

State:

Zip Code:

Jobs Maintained:

4. Provide the total number of approved, denied and revoked Form I-526 petitions filed by EB-5 investors making capital
investments sponsored by the regional center. (Note: If an adverse action was ultimately reversed and the petition was approved,
then note the case as approved.)
Form 1-526 Petition Final Case Actions

(b)(4)
A

Denied
0

Revoked
0

5. Provide the total numoer or a pprovea, aemed and revoked Form 1-829 petitions filed by EB-5 investors making capital

investments sponsored by the regional center. (Note: If an adverse action was ultimately reversed and the petition was approved,
then note the case as approved.)
Form 1-829 Petition Final Case Actions
Approved
0

Denied
0

Revoked
0

NOTE: USCIS may require case-specific data relating to individual EB-5 petitions and the job creation determination and further
information regarding the allocation methodologies utilized by a regional center in certain instances in order to verifY the aggregate
data provided above.

Form I-924A 01103113 Y Page 6

6

 Part 4. Applicant Signature Read the information on penalties in the instructions before completing this section. If
someone helped you prepare this petition, he or she must compete Part 5.
I certifY, under pena of perjUry under the laws of the United States of America, that this supplemental form and the evidence
submitted with it . e all true artd correct. I authorize the release of any information from my records that U.S. Citizenship and
1
Immigration Se . ices needs td determine eligibility for the benefit being sought. I also certifY that I have authority to act on behalf of
1
the Re~·
n er.
Printed Name of Applicant

Date (mmldd/yyyy)

NICHOLAS A. MASTROIANNI

Daytime Phone Number
(Area/Country Codes)

E-Mail Address
NICK@USIFUND.COM

(561)799-1883

Relationship to the Regional Center Entity (Managing Member, President, CEO, etc.)
PRESIDENT & CEO

Part 5. Signature of Person Preparing This Form, If Other Than Above (Sign Below)
I declare that I prepared this form using information provided by someone with authority to act on behalf of the Regional Center, and
the answers and information are those provided by the Regional Center.

/

Attorney or Representative: In the event of a Request for Evidence (RFE), may the USCIS contact
you by Fax or E-mail?

D No

~/rre~r~."

Printed Name of Preparer

Date (mm/ddlyyyy)

IGNACIO A. DONOSO

!d. II/ /;'I

i1jlf3tu

vf~~t~

Firm fame and Add res~~

~Yes

7

DONOSO & ASSOCIATES, LLC
4720 MONTGOMERY LANE, SUITE 430
BETHESDA, MD 20814
I. A.

Daytime Phone Number
(Area/Country Codes)
(301) 276-0653

Fax Number (Areal
Country Codes)

E-Mail Address
IGNACIO.DONOSO@DONOSOLAW.COM

Form I-924A 01/03/13 Y Page 7

7

 U.S. Immigration Fund-NJ, LLC
Form I-924A- Supplement for Annual Reporting 2014
Unique Identifier I.D. # RCW 1236250925
Year Ending: Sept. 30, 2014

Exhibit 3.2 - Response to Part 3, Box 2
All Industries of Focus & Aggregate EB-5 Investment

1.

Residential Building Construction

2361

Cumulative (Below)

2.

Nonresidential Building Construction

2362

Cumulative (Below)

Architectural, Engineering & Related

5413

Cumulative (Below)

Lessors of Residential Buildings *

5311

Cumulative (Below)

Real Estate Property Managers

5313

Cumulative (Below)

Wholesale Trade

4200

Cumulative (Below)

AGGREGATE EB-5 CAPITAL INVESTMENT:

(b)(4)
*New Industry Codes added pursuant to the EB-5 Policy Memorandum of May 30, 2013 regarding
investments in the 65 Bay Street Project sponsored by the U.S. Immigration Fund-NJ, LLC.

8

 U.S. Immigration Fund-NJ, LLC
Form I·924A- Supplement for Annual Reporting 2014
Unique Identifier I.D. # RCW 1236250925
Year Ending: Sept. 30, 2014

Exhibit 3.3.A- Response to Part 3, Box 3.a
65 Bay Street Funding, LLC

6.
(b)(4)

Nonresidential Building Construction

2362

Cumulative (Below)

Architectural, Engineering & Related

5413

Cumulative (Below)

Lessors of Residential Buildings *

5311

Cumulative (Below)

Real Estate Property Managers

5313

Cumulative (Below)

Wholesale Trade

4200

Cumulative (Below)

AGGREGATE EB-5 CAPITAL INVESTMENT

.......
1 _ _____.

* New Industry Code added pursuant to the EB-5 Policy Memorandum of May 30, 2013 regarding
investments in the 65 Bay Street Project sponsored by the U.S. Immigration Fund-NJ, LLC.

** As of October 1, 2014

9

 Confidentialhtlonnation

I.A.DONOSO
& ASSOCIATES, LLC

December 12, 2014
U.S. Citizenship & Immigration Services
California Service Center
Attn: EB-5 Processing Unit
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677
Via Federal Express
Re:

Form I-924A- Regional Center Annual Reporting- FY 2014
U.S. Immigration Fund-NJ, LLC
RCW1236250925/I.D.1236250925

Dear Immigration Officer,
Enclosed is the completed Form I-924A, Annual Reporting Supplement, for the U.S. Immigration
Fund-NJ, LLC.
Please Note: The U.S. Immigration Fund-NJ, LLC changed its address in December of 2014 to the
following:
115 Front Street, Suite 300, Jupiter, Florida 33477
We trust that the enclosed Form I-924A and the accompanying evidence complies with the annual
reporting requirements established by the USCIS. Please do not hesitate to contact me at (301) 2760653 or by email at ignacio.donoso@donosolaw.com.

I.A. Donoso
& Associates, LLC
'I

(
<::~---,

1

~\

~

~·
. vlJV0

jJ ' CJ

Igna · Don

~

·ng Attorney
cc:

U.S. Immigration Fund-NJ, LLC

4720 MONTGOMERY LANE +:• SUITE 430 •:• BETHESDA<- MD 20814 +:• TEL. (301) 276-0653
WWW .DONOSOLAW .COM

10

 U.S. Immigration Fund-NJ, LLC
Form I-924A- Supplement for Annual Reporting 2014
Unique Identifier I.D. # RCW 1236250925
Year Ending: Sept. 30, 2014

USCIS Regional Center Approval Letter
for the
U.S. Immigration Fund-NJ, LLC

11

 U.S. Department of Homeland Security
24000 Avila Road, 2"~ Floor
Laguna Niguel, CA 92677

U.S. Citizenship
and Immigration
Services

Date:

MAY 2 9 2013

Nicholas A. Mastroianni
U.S. hnmigration Fund- NJ, LLC
1295 U.S. Highway 1, Suite 300
North Palm Beach, FL 33408

Application:

Form 1-924, Application for Regional Center under the Im111igrant Investor Pilot
Program

Applicant(s):
Re:

Nicholas A. Mastroianni
Initial Regional Center Designation
U.S. Immigration Fund- NJ, LLC
RCW 1236250925 I RCW 1236250925

This notice is in reference to the Form I-924, Application for Regional Center Under the Immigrant
Investor Pilot Program that was filed by the applicant with the U.S. Citizenship and Immigration Services
("USC.IS") on December 27, 2012. The Form I-924 application was filed to request' approval of initial
regional center designation under the Immigrant Investor Program. The Immigrant Investor Program was
established under § 61 0 of the Department of Commerce, Justice and State, the Judiciary. and Related
AgenciesAppropriationsActofl993 (Pub.L. 102-395,0ct. 6,1992, 106Stat.l874).
I. Executive Swnmary of Adjudication
I.

Effective the date of this notice, USCIS approves the Fonn I-924 request to designate U.S.
Immigration Fund- NJ, LLC as a qualifying participant in the Immigrant Investor Program.

II. Regional Center DesignatiQ!!

USCIS approves the applicant's request to focus, proi:note economic growth, and offer capital investment
opportunities in the following geographic area and industry categories:

www.uscis.gov

12

 U.S Immigration Fund- NJ. LLC I RCW1236250925/ ID
Page 2 of 4

A. Geographic Area

Note: An amendment request is required if investment opportunities arise outside approved geographic
area.
B. Industry Categories
......__ • ·
0

N".Alt{ ·' ·; · ·, ,;.. ,t·: · .·' :··\ :· ., . ,~- • . '. ·... :'ind.ustiy N~e._;,:::.._. .....,__;_:___;.·;_.____..__--...;______

____ ?._~---.Bonresidential ~uilding Construction
2361
Residential Building.....:C:.:o:.::n:::.:st:::.:ru::c:.::tio:.:n:::.__ _ _ _ _ _ _ _ _ _ _ _ _ _-1
5313
Real Estate Property Managers
5413
Architectural, Engineering, and Relat~:.::d:.::S:.:::er::..;v.:.:ic:.:e.:..s-------------~
4200
..,,
' •Trade
Note: . An amendrnent request is required if investment opportunities arise outside approved industry
categories.
IlL

Iob Creation

USCIS approves the geographic area and industry categories noted above based on the economic impact
analysis presented and reviewed in conjunction with the adjudication of this regional center proposal. The
job creation methodology presented in the economic impact analysis and underlying business plan is found
to be teasonable based on the following inputs, when applying the RIMS II economic model:

(b)(4)
,·:.:·:·:,:

4200
53111

Rental Income Operations

* Indirect and induced jobs only
The approval of this Form I-924 application is based upon the economically and statistically valid
assumptions and estimates provided in the business plan for job creation. Please refer to the input and
multiplier analysis table above.
'This actual project does not have the factual details necessary to be in compliance with the requirements
described in Matter ofHo, 22 I&N Dec. 206 (Assoc. Comm'r 1998), and therefore, USCIS's approval of the
hypothetical job creation estimates presented in the Form 1-924 Will not be accorded deference and may
not be relied upon by an individual investor when filing the Form I-526. The business plan and job

13

 U.S Immigration Fund NJ, LLC I RCW1236250925/ ID
Page 3 of 4

creation estimates will receive a de novo review by USCIS when an individual investor files Form I-526.
Once an actual project is adjudicated upon the filing of the initial Form I-526 related to the 1~924
hypothetical project approval, USCIS will give deference to subsequent Forms I~526 when the critical
assmnptions remain materially unchanged from the initially-approved Fonn I-526.
When filing Form 1"526, it will be the responsibility of the individual investor to submit a comprehensive,
detailed and credible business plan, showing by a preponderance of the evidence that his or her investment
in the new commercial enterprise will create not fewer than 10 full-time positions. If prior to filing a form
I-829, the job creation estimated in the business plan submitted by the individual investor materially
changes or will not be realized, then it will be the responsibility of the EB-5 investor to notify USCIS of an
agreed upon methodology to allocate job creation among eligible investors.
V. Guidelines for Filing Form I-526 Petitions

Each i:fJ.dividual petition, in order to demonstrate that it is affiliated with' the U.S. Immigration Fund NJ,
LLC, in conjunction wit:h addressing all the requirements for an individual immigrant investor petition,
shall also contain the following:
1. A copy of this regional center approval notice and designation letter including all subsequent

amendment approval letters (if applicable).
2. An economic impact analysis which reflects a job creation methodology required at 8 CFR § 204.6
(j)(4)(iii) and shows how the capital investment by an individual immigrant investor will create
not fewer than ten (I 0) indirect jobs for each immigrant investor.
3. A comprehensive, detailed and credible business plan for an actual project that contains the factual
details necessary to be in compliance with the requirements described in Matter of Ho, 22 I&N
Dec. 206 (Assoc. Comm'r 1998).
4. Legally executed organizational documents of the commercial enterprise.
VI. Designee's Responsibilities in the Operations of the Regional Center

As provided in 8 CFR § 204.6 (m)(6), to ensure that the regional center continues to meet the
requirements of section 6IO(a) of the Appropriations Act, a regional center must provide USCIS with
updated information to demonstrate the regional center is continuing ro promote economic growth,
improved regional productivity. job creation, and increased domestic capital investment in the approved
geographic area. Such information must be submitted to USCIS on an annual basis or as otherwise
requested by USCIS. The applicant must monitor all investment activities under the sponsorship of the
regional center and to maintain records in order to provide the information required on the Form I-924A
Supplement to Form I-924. Form l-924A, Supplement to Form I-924 Application is available in the
"Forms" section on the USCIS website at www.uscis.gov.

14

 U.S Immigration Fund- NJ, LLC I RCW1236250925/ ID
Page 4 of 4

Regional centers that remain designated for participation in the Immigrant Investor Program as of
September 30th of a calendar year are required to file Form I-924A Supplement in that year. The Form I924A Supplement with the required supporting documentation must be filed on or before December 29th
of the same calendar year.
The failure to timely file a Form I-924A Supplement for each fiscal year in which the regional center has
been designated for participation in the Immigrant Investor Program will result in the issuance of an intent
to terminate the participation of the regional center in the Immigrant Investor Program, which may
ultimately result in the termination of the designation of the regional center.
The regional center designation is non-transferable, as any changes in management of the regional center
will require the approval of an amendment to the approved regional center designation.
If the applicant has any questions concerning the regional center designation under the Immigrant Investor
Program, please contact the USCIS by email atUSCIS.ImmigrantinvestorProgram@uscis.dhs.~ov.
Sincerely,

Daniel' M. Renaud
Acting Chief, Immigrant Investor Program

cc: Ignacio A. Donoso, Esq.

15

 FedEx Ship Manager- Print Yo·· Label(s)

From: (301) 276-0653
Ignacio Donoso

Origin ID: OBTA

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Express

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4720 Montgomery Lane
Suite 430
BETHESDA, MD 20814

Page 1 of 1

Ship Date: 12DEC14
ActWrj. 1.0 LB
CAD: 104983165/INET3550
Delivery Address Bar Code

J142214002303uv

SHIP TO: (800) 375-5283

BILL SENDER

Ref#

Il

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Attn: EB-5 Processing Unit
USCIS, California Service Center
24000 Avila Road, 2nd Floor

IIIIIIIW!~ ~~~II~ I~ ll~~lllll

1111111111111111111111

U.S. mnigl'lllion Fund· NJ, LLC

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LAGUNA NIGUEL, CA 92677

TRKII

I 0201 I

7722 0908 1049

XHJORA

·15 DECAA
OVERNIGHT

92677
CA-US

SNA

522G2/DC75/8AC9

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12/12/2014

16

 ,,.

t

RECEIPT NUMBER

CASE TYPE 1924A

RCWI434952101

Supplement to Form 1-924

RECEIVED DATE

APPLICANT
MASTROIANNI , NICHOLAS A

December 15, 2014
NOTICE DATE

December 15, 2014
IGNACIO A DONOSO
I A DONO SO ASSOCIATES LLC
RE: US IMMIGRATION FUND NJ LLC
4720 MONTGOMERY LANE STE 430
BETHESDA MD 20814

PAGE
I of I
NOTICE TYPE:

Receipt Notice

Receipt Notice - This notice confirms that USCIS received your application or petition as shown above. Please reference the receipt number. above. on
any correspondence with USCIS. If any of the above information is incorrect, please immediately contact us at
USCIS.ImmigrantlnvestorProgram@dhs.gov to let us know. This will help avoid future problems.

This notice does not grant any immigration status or benefit. It is not even evidence that this case is still pending. It only shows that the application or
petition was filed on the date shown.
Processing time Processing times vary by kind of case. You can check our website at www.uscis.gov for our current processing times for this kind of
case at the particular office to which this case is or becomes assigned. If you do not receive an initial decision or update from us within our current
processing time. email us at USCIS.ImmigrantlnvestorProgram@dhs.gov. Save this notice. and any other notice we send you about this case. and please
make and keep a copy of any papers you send us by any means along with any proof of delivery to us. Please have all these papers with you if you
contact us about this case.
If your address changes -If your mailing address changes while you case is pending, notify us at USClS.ImmigrantlnvestorProgramla}dhs.gov.
otherwise you may not receive notice of our action on this case.

Please see the additional information on the back. You will be notified separately about any other cases you filed.
U.S. CITIZENSHIP & IMMIGRATION SVC
CALIFORNIA SERVICE CENTER
P.O. BOX 30111
LAGUNA NIGUEL CA 92607-0111
1111111111111 111111111 IIIII IIIII 11111111111111111111 IIIII IIIII IIIII 11111111
Customer Service Telephone: (800) 375-5283

17

 OMB No. 1615-0061; Expires 03!31/2016

Form I-924A,
Supplement to Form 1-924

Department of Homeland Security
U.S. Citizenship and Immigration S1:1rvices

Part 1. Information About Principal of the Regional Center
Name: Last
MASTROIANNI

First

Middle

NICHOLAS

A.

In Care Of: U.S. IMMIGRATION FUND-NJ, LLC

---------------------------------------------------------------------------------------Street Address/P.O. Box: 115 FRONT STREET 1 SUITE 300

I State:

City: JUPITER

(b)(6)

IZip Code:

FL

Date of Birth ,__ _ _ _....,. Fax Number
(mm/dd/yyyy):l
(includeareacode): (561) 799-0061
Web site address:

~
~

"'
334 77

Telephone Number
(include area code): ( 5 61) 799-18 8 3

vlWW. visaeb-5. com

USCIS-a.;;signed number for the Designated Regional Center (attach the
Regional Center's most recently issued approval notice)

RCW 1236250925/ I. D. 1236250925

Part 2. Application Type (Select one)

[8]

a. Supplement for the Fiscal Year Ending September 30. 2 015 (YYYJ]

b. Supplement for a Series ofF iscal Years Begirming on October 1,

(rYH) and Ending on September 30,

OTYl}

Part 3. Information About the Regional Center
(Use a continuation sheet, if needed, to provide infonnation for additional management companies/agencies, regional center
principals, agents, individun.ls, or entities who are or will be involved in the management, oversight, and administration of the regional
center.)
A. Name of Regional Center: U.S. IMMIGRATION FUND-NJ, LLC

StreetAddress/P.O. Box:

115 FRONT STREET 1 SUITE 300

State: FL

City: JUPITER
Web site www. visaeb-5. com

Address:

ZipCode: 33477

Fax Number
Telephone
(includeareacode): ( 561 ) 799 - 0061 (includeareacode): (561) 799-1883

B. Name of Managing Company/Agency: U.S. IMMIGRATION FUND LLC

StreetAddress/P.O. Box:

115 FRONT STREET, SUITE 300

City: JUPITER

/ State: FL

Web site www. visaeb-5. com
Address:

IZipCode: 33477

FaxNumber
(561) 799-0061 Telephone
(561) 799-1883
(include area code):
(include area code):

C. Name of Other Agent:

Street Acldress/P.O. Box:
State:

City:

I\U\1111 Ill\ Ill Ill\ II IIIII Ill II IIIII 11111111111111111111111111111111111111

RCW1534453564
egarcia2

1924A

Fax Ntm1ber
(include area code):

Zip Code:
Telephone
(include area code):
Fonn I-924A 03/18/15 Y Page 1

12/1 0/2015
18

 Part 3. Information About the Regional Center (Continued)
Answer the following questions for the time period identified in Part 2 of this fonn. Note: If extra space is needed to complete any
item, attach a continuation sheet, indicate tile item number, and provide the response.

1. Identity the aggregate EB-5 capital investment and job creation has been the focus ofEB-5 capital investments sponsored through
the regional center. (Note: Separately identi(v jobs maintained through investments in "troubled businesses.")

.I

Aggregate EB-5 Capital Investment I

Aggregate Jobs Maintained

Aggregate Direct and Indirect Job Creation

(b)(4~

I( Total in Progress)

N/A

2. Identify each industry that has been ti1e focus ofEB-5 capital investments sponsored through tile Regional Center, and the resulting
aggregate EB-5 capital investment and job creation. (Note: Separately identify jobs maintained through investments in ''troubled
businesses''.)
a. Industry Category 'l'itle:

NAICS Code for the Industry Category

CONSTRUCTION

2

Aggregate EB-5 Capital Investment:

(b)(4)

Aggregate Direct and Indirect Job Creation:

I( Total

in Progress)

b. Industry Category lltle:

3

6

0

---

Aggregate Jobs Maintained:
N/A

NAICS Code for the Industry Category

-----Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

c. Industry Category Title:

Aggregate Jobs Maintained:

NAICS Code for the Industry Category
--

Aggregate EB-5 Capital Investment

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

3. Provide the following infonnation for each job creating commercial enterprise located within the geographic scope of your
regional center that has received EB-5 investor capital:
Industry Category Title:

a. Name of Commercial Enterprise:

65 BAY STREET FUNDING LLC

Address (Street Number and Name):

CONSTRUCTION

City:

State:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Zip Code:

SAME AS ABOVE

Aggregate EB-5 Capital Investment:

(b)(4)

(In Progress)
H

.

for investment into other business entities that
Does ll11S co-;; commerctm e
"t:1 v10 a" a V<Olllv
have or will create or maintain jobs for EB-5 purposes?

0No

[&] Yes

Fotm l·924A 03/18/15 Y Page 2

19

 ..

Part 3. Information About the Regional Center (Continued)
If yes, then identify the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated \Vith each job creating business.
Industry Category Title:

(1) Business Name:

SEE ATTACHMENTS

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

(2) Business Name

Zip Code:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capit1l Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

b. Name of Commercial Enterprise:

Zip Code:

Industry Category Title:

Address (Street Number and Name):

City:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

State:

Zip Code:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise S(.."fVe as a vehicle for investment into other business entities that
have or will create or maintain jobs for EB-5 purposes?

0No

Yes

If yes, then identify the name and address of each job creating business, as well as the amount ofEB-5 capital investment and job
creation.lmaintenance associated with each job creating business.
Industry Category 'fitle:

(l) Business Name:

Address (Street Number and Name):

City:

EB-5 Capital Investment

Direct and Indirect Job Creation

State:

Zip Code

Jobs Maintained

Fonn I-924A 03/1&!15 Y Page 3

20

 Part 3. Information About the Regional Center (Continued)
(2) Business Name:

Industry Category Title:

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

c. Name of Commercial Enterprise:

State:

Zip Code:

Jobs Maintained:

Industry Category Title:

Address (Street Number and Natne ):

City:

Aggregate EB-5 Capital Investment

Aggregate Direct and Indirect Job Creation:

State:

Zip Code:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

No

Yes

If yes, then identify the name and address of each job creating business, as well as the amount ofEB-5 capital investment and job
creation/maintenance associated with each job creating business.
Industry Category Title:

(1) Business Name:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment

Direct and Indirect Job Creation:

Jobs Maintained:

(2) Business Name:

Zip Code:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

Zip Code:

Fonn I-924A 03/18/15 Y Pag..: 4

21

 Part 3. Information About the Regional Center (Continued)
d. Name of Commercial Enterprise:

Industry Category Title:

Address (Street Number and Name):

City:

State:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle tor investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

Zip Code:

DYes

0No

If yes, then identify the name and address of each job creating business, as well a..;; the amount of EB-5 capital investment and
job creation/maintenance associated with each job creating business.
(1) Business Name:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

(2) Business Name:

Zip Code:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

e. Name of Commercial Enterprise:

Zip Code:

Industry Category Title:

Address Street Number and Name:

City:

State:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does tllis EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

Zip Code:

No

DYes

Fotm 1·924A 03118/15 Y PageS

22

 Part 3. Information About the Regional Center (Continued)
Ifyt:s. then identifY the name and address of each job creating business, as well as the amount ofEB-5 capital investment and
job creation/maintenance associated with each job creating business.
Industry Category ·ritle:

(l) Business Name:

Address (Street Nruuber and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

(2) Business Name:

State:

Zip Code:

Jobs Maintained:

Industry Category Title:

State:

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Zip Code:

Jobs Maintained:

4. Provide the total number of approved, denied and revoked Fom1 I-526 petitions filed by EB-5 investors making capital
investments sponsored by the regional center. (Note: If an adverse action was ultimately reversed and the petition was approved,
then note the case as approved.)
Form I-526 Petition Final Case Actions
Approved

(b)(4)

I

Denied

I

Revoked

NONE

0

5. Provide the total number of approved, denied and revoked Fonn I-829 petitions filed by EB-5 investors making capital
investments sponsored by the regional center. (Note: If m1 adverse action was ultimately reversed and the petition \vas approved,
then note the case as approved.)
Form 1-829 Petition Final Case Actions
Approved

NONE FILED YET

Denied

N/A

Revoked

N/A

NOTE: USCIS may require case-specific data relating to individual EB-5 petitions and the job creation detennination and further
infonnation regarding the allocation methodologies utilized by a regional cc'llter in certain instances in order to verify the aggregate
data provided above.

Fonn l·924A 03/18/15 Y Page 6

23

 Part 4. Applicant Signature Read the information on penalties in the instructions before completing this section. If
someone helped you prepare this petition, he or she must compete Part 5.

a m
one Number
(Area/Country Codes)

Printed Name of Applicant

Date (mmldd/yyyy)

NICHOLAS A. MASTROIANNI

t> E. C.

1 1 zol

E-Mail Address

NICK@USIFUND.COM

(561) 799-1883

Relationship to the Regional Center Entity (Managing Member, President, CEO, etc.)

PRESIDENT & CEO

Part 5. Signature of Person Preparing This Form, If Other Than Above (Sign Below)
I declare that I prepared this form using information provided by someone with authority to act on behalf of the Regional Center, and
the answers and information are those provided by the Regional Center.

Attorney or Representative: In the event of a Request for Evidence (RFE), may the USCIS contact
you by Fax or E-mail?

0

' Pre parer
Signature of

Printed Name of Preparer

Date (mm/dd/yyyy)

IGNACIO A. DONOSO

{ l j ()~ }15-

......._.._,,

~

~,--

:__tt,<.. Li ··~ q

'\.

\

',D,f..-· <..'{.: .~ £;

t

No

~Yes

I

Firm Name and Address

DONOSO & ASSOCIATES, LLC
4800 MONTGOMERY LANE, SUITE 640
BETHESDA, MD 20814
I. A.

Daytime Phone Number
(Area/Country Codes)

(301) 276-0654

Fax Nurn ber (Area/
Country Codes)

E-Mail Address

IGNACIO.DONOSO@DONOSOLAW.COM

Form I-924A 03/18/15 Y Page 7

24

 l-924A Annual Reporting Supplement- 2015
U.S. Immigration Fund-NJ, LLC
Fiscal Year Ending Sept. 30,2015
Offering No. l

(b)(4)

New Commercial Enterprise Name:

65 Bay Street Funding, LLC

TEA Project:

Yes

Maximum Capital Raise:
Maximum Number ofEB-5 Investors:
Inception Date:

07/2013

1-526 Processing Progress as of09/30/2015
# of 1-526 Petitions Filed
in F¥2014

# of 1-526 Petitions
Approved

# of 1-526 Petitions

# of 1-526 Petitions Still
Pending in FY 2014

Denied

(see attached list of
names and Rt>ceipt #'s)

(b)(4)

D

D

Since Inception:

I

Since Inception:

D

I

D

D

[]Inception:

Since Inception:

D

1-829 Processing Progress as of09/30/2015
# of 1-829 Petitions Filed

(b)(4)

#of 1-829 Petitions
Approved

# of 1-829 Petitions
Denied

# of 1-829 Petitions Still
Pending

(see attached list of
names and Receipt #'s)

D

D

D

D

Financial and Job Creation Progress as of09/30/2015
# oflnvestors

# oflnvestors

Subscribed in

Funded Capital
toNCE in FY

Total EB-5
Capital Funded
tu NCE ($)in

2014

FY2014

FY2014

(b)(4)

D
D
olnception

Total EB-5
Capital Loaned
to Bormwer ($)

D

Total jobs
Projected for
Total Capital
Raise

D

Totai:loils.
created as of
09/30 based on
money borrowed
under Loan
Project Under

Construction

Since Inception:

D

25

 I-924A Annual Reporting Supplement
U.S. Immigration Fund-NJ, LLC
Fiscal Year Ending Sept. 30, 2015

(b)(4)

New Commercial Enterprise Name:

Offering No. 2
65 Bay Street Funding, LLC

TEA Project:

Yes

Maximum Capital Raise:
Maximum Number ofEB-5 Investors:
Inception Date:

05;2015

1-526 Processing Progress as of09/30/2015
# of I-526 Petitions Filed

# of I-526 Petitions

# of 1-526 Petitions Still
Pending

# of I-526 Petitions
Denied

Approved

(see attached list of
names and Receipt #'s)

D

...__.....1

D

D

1-829 Processing Progress as of 09/30/2015
# of I-829 Petitions Filed
(see attached list of
names and Receipt #'s)

D

#of I-829 Petitions
Approved

# of 1-829 Petitions
Denied

D

# of I-829 Petitions Still
Pending

0

D

Financial and Job Creation Progress as of 09/30/2015
# of Investors
Subscribed

D

#of Investors
Funded Capital
toNCE

TotalEB-5
Capital Funded
toNCE ($)

Total EB-5
Capital Loaned
to Borrower ($)

Total jobs
Projected for
Total Capital
Raise

I ··~:o

D

Total Jobs
created as of
09/30 based on
money borrowed
nnderLoan

Project Under
Construction

(b)(4)

26

 '

I.A. DONOSO & J\SSOCIJ\TfS, LLC

December 9, 2015
U.5. Citizenship & Immigration Services
California Service Center
Attn: EB-5 Processing Unit
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677
Via Federal Express
Re:

Form I-924A- Regional Center Annual Reporting- 2015
U.S. Immigration Fund-NJ, LLC

Dear Immigration Officer,
Enclosed is the completed Form I-924A, Annual Reporting Supplement, for the U.S. Immigration
Fund-NJ, LLC for fiscal year ending September 30,2015.
We trust that the enclosed Form I-924A and the accompanying evidence complies with the annual

reporting requirements established by the USCIS. Please do not hesitate to contact me at (301) 2760653 or by email at ignado.donosu'V}donosoluW.(\m1.
LA. Donoso & Associates, LLC

Managing Attorney

4800 Montgomery Lane

Suite 640
Bethesda MD 20814
(301) 276-0653

www.aonosolaw.com

,
27

 RECEIPT NUMBER

CASE TYPE I924A

Supplement to Form 1-924

RCWJ534453564

APPLICANT
MASTROIANNI. NICHOLAS A

RECEIVED DATE

December 10,2015
NOTICE DATE

December 10,2015
U S IMMIGRATION FUND NJ LLC
115 FRONT ST STE 300
JUPITER FL 33477

PAGE
I of I

NOTICE TYPE:

Receipt Notice

Receipt Notice -This notice confirms that USCIS received your application or petition as shown above. Please reference the receipt number, above, on any correspondence with USCIS. If any of the above
mformation ts incorrect, please immediately contact us at USCIS.ImmigrantlnvestorProgram@dhs.gov to let us know. This will help avoid future problems
This notice does not grant any immigration status or benefit. It is not even evidence that this case is still pending. It only shows that the application or petition was filed on the date shown.
Processing time- Processing times vary by kind of case. You can check our website at www.uscis.gov for our current processing times for this ktnd of case at the particular office to which this case is or
becomes assigned. If you do not receive an initial decision or update from us within our current processing time, email us at USCIS.ImmtgrantlnvestorProgram@dhs.gov. Save this notice, and any other nottce
we send you about this case, and please make and keep a copy of any papers you send us by any means along with any proof of delivery to us. Please have all these papers with you if you contact us about
this case.

If your address changes -If your mailing address changes while you case is pending. notify us at USCIS.ImmigrantlnvestorProgram@dhs.gov. othetwise you may not receive notice of our action on this
case.

Please see the additional information on the back. You will be notified separately about any other cases you filed.
U.S. CITIZENSHIP & IMMIGRATION SVC
CALIFORNIA SERVICE CENTER
P.O. BOX 30111
LAGUNA NIGUEL CA 92607-0111
Customer Service Telephone: (800) 375-5283

111111111111111111111111111111111111111111111111111111111111111111111111111

28

 OMB No. 1615-0061; Expires 01/31/2015

Form I-924A,
Supplement to Form 1-924

Department of Homeland Security
U.S. Citizenship and Immigration Services

Part 1. Information About Principal of the Regional Center
Name: Last
MASTROIANNI

First

Middle

NICHOLAS

A.

In Care Of: U. S . I.MM:I GRAT I ON FUND- NJ, LLC
Street Address/P.O. Box: 1295 U.S. HIGHWAY ONE, SUITE 300

(b)(6)

City: NORTH PALM BEACH
Date of Birth

Numbt::r
ludeareacode): (561) 799-0061

(mm/ddyyyy)

Web site add t;...,...,.

\zip Code: 33408

\State: FL

www.v...L;::,at:::::J.J··...; ..

Telephone Number
(include area code): (561) 799-1883

om

USCIS-assigned number for the Designated Regional Cenk-'1' (attach the
Regional Center's most recently issued approval notice)

RCW 12 3 62 50 9 2 5 I I . D. 12 3 62 50 9 2 5

Part 2. Application Type (check one)
[8] n. Supplement for the Fiscal Year Ending September 30, 2 013 (YrYY)

D

b. Supplement for a Series of Fiscal Years Beginning on October 1, _ _ (YYYl) and Ending on September 30, _ _ (l'YY1}

Part 3. Information About the Regional Center
(Use a continuation sheet, if needed, to provide infonnation for additional management companies/agencies, regional center
principals, agents, individuals, or entities who are or will be involved in the management, oversight, and administration of the regional
center.)
A. Name ofRegional Center: U.S. I.MM:IGRATION FUND-NJ, LLC

StreetAddress/P.O.Box:

1295 U.S. HIGHWAY ONE, SUITE 300

State: FL

City: NORTH PALM BEACH
Web site www. visaeb-5. com
Address:

Fax Number
(include area code): ( 5 61 ) 7 99 - 00 61

ZipCode: 33408
Telephone
(includeareacode): (561) 7 99-18 83

B. NamcofManagingCompany/Agency: N/A
Street Address/P.O. Box:
City:

J

Web site
Address:

State:

Fax Number
(include area code):

Jzip Code:
Telephone
(include area code):

C. Name of Other Agent:

Street Address/P.O. Box:

I

City:

State:

Fax Number
(include area code):

llllllllllll\llllll\llllllllllllllllllllllllllllllllllllllllllll\llllllllll

jzip Code:
Telephone
(include area code):
Form I-924A 01/03/13 Y Page 1

RCW1335051353
egarcia2

1924A

12/13/2013

29

 Part 3. Information About the Regional Center (Continued)
Answer the following questions for the time period identified in Part 2 of this form. Note: If extra space is needed to complete any
item, attach a continuation sheet, indicate the item number, and provide the response.
1. Identity the aggregate EB-5 capital investment and job creation has been the focus of EB-5 capital investments sponsored through

the regional center. (Note: Separately identity jobs maintained through investments in "troubled businesses.")
Aggregate EB-5 Capital Investment

(b)(4)

Aggregate Direct and Indirect Job Creation

I PROJECT

UNDER CONSTRUCTION

Aggregate Jobs Maintained

N/A

2. Identity each industry that has been the focus ofEB-5 capital investments sponsored through the Regional Center, and the resulting
aggregate EB-5 capital investment and job creation. (Note: Separately identity jobs maintained through investments in "troubled

businesses".)
a. Industry Category Title:

CONSTRUCTION
Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

SEE EXHIBIT 3.2

PROJECT UNDER CONSTRUCTION

NAICS Code for the Industry Category
2 3 6 2
--Aggregate Jobs Maintained:

N/A

b. Industry Category Title:

NAICS Code for the Industry Category

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

c. Industry Category Title:

-----Aggregate Jobs Maintained:

NAICS Code for the Industry Category
--

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

-

Aggregate Jobs Maintained:

3. Provide the following information for each job creating commercial enterprise located within the geographic scope of your

regional center that has received EB-5 investor capital:

a. Name of Commercial Enterprise:

Industry Category Title:

65 BAY STREET FUNDING, LLC

(b)(4)

NAICS 2362

&

CODES IN EXHIBIT 3.3.A

Address (Street Number and Name):

City:

State:

Zip Code:

1295 US HWY ONE, STE. 300

NORTH PALM BEACH

FL

33408

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

PROJECT UNDER CONSTRUCTION

N/A

'"'" "'"'·

T

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities that
have or will create or maintain jobs for EB-5 purposes?

0

No

[8] Yes

Fonn I-924A 01/03/13 Y Page 2

30

 U.S. Immigration Fund-Nf, LLC
Form I-924A- Supplement for Annual Reporting 2012
Unique Identifier I.D. # RCW 1236250925
Year Ending: Sept. 30, 2013

Exhibit 3.2 -Response to Part 3, Box 2
All Industries of Focus & Aggregate EB-5 Investment

Residential Building Construction
i

2.

Nonresidential Building Construction

3.

2362

Cumulative (Below)

5413

Cumulative (Below)

4.

Lessors of Residential Buildings *

5311

Cumulative (Below)

5.

Real Estate Property Managers

5313

Cumulative (Below)

6.

Wholesale Trade

4200

Cumulative (Below)

AGGREGATE EB-5 CAPITAL INVESTMENT:

(b)(4)

*New Industry Codes added pursuant to the EB-5 Policy Memorandum of May 30, 2013 regarding
investments in the 65 Bay Street Project sponsored by the U.S. Immigration Fund-NJ, LLC.

31

 U.S. Immigration Fund-Nf, LLC
Form I-924A- Supplement for Annual Reporting 2012
Unique Identifier I.D.# RCW 1236250925
Year Ending: Sept. 30, 2013

Exhibit 3.3.A- Response to Part 3, Box 3.a
65 Bay Street Funding, LLC

Residential Building Construction

(b)(4)

Nonresidential Building Construction

2362

Cumulative (Below)

3.

Architectural, Engineering and Related

5413

Cumulative (Below)

4.

Lessors of Residential Buildings*

53111

Cumulative (Below)

AGGREGATE EB-5 CAPITAL
INVESTMENT

*New Industry Code added pursuant to the EB-5 Policy Memorandum of May 30, 2013 regarding
investments in the 65 Bay Street Project sponsored by the U.S. Immigration Fund-NJ, LLC.
** As of October 1, 2013

32

 Part 3. Information About the Regional Center (Continued)
If yes, then identify the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated with each job creating business.
(1)

Industry Category Title:

Business Name:

MORGAN STREET DEVELOPERS URBAN RENEWAL
Address (Street Number and Name):

(b)(4)

co.

NAICS 2362

&

CODES IN EXHIBIT 3.3.A

City:

State:

Zip Code:

666 FIFTH AVE.

NEW YORK

NY

10103

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

PROJECT UNDER CONSTRUCTION

N/A

EE EXH 3.3.A
(2) Business Name

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

b. Name of Commercial Enterprise:

Address (Street Number and Name):

Zip Code:

Industry Category Title:

City:

State:

Zip Code:

FL
Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities that
have or will create or maintain jobs for EB-5 purposes?

D No

DYes

If yes, then identify the name and address of each job creating business, as well as the amount of EB-5 capital investment and job
creation/maintenance associated with each job creating business.
Industry Category Title:

(1) Business Name:

Address (Street Number and Name):

City:

State:

Zip Code

NY
EB-5 Capital Investment

Direct and Indirect Job Creation

Jobs Maintained

Fonn I-924A 01/03/13 Y Page 3

33

 Part 3. Information About the Regional Center (Continued)
(2) Business Name:

Industry Category Title:

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

c. Name of Commercial Enterprise:

Address (Street Number and Nmne):

State:

Zip Code:

Jobs Maintained:

Industry Category Title:

City:

State:

Zip Code:

FL
Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

No

Yes

If yes, then identify the name and address of each job creating business, as well as the mnount ofEB-5 capital investment and job
creation/maintenance associated with each job creating business.
(1) Business Nmne:

Address (Street Number and Name):

Industry Category Title:

State:

City:

Zip Code:

NY
EB-5 Capital Investment:

Direct and Indirect Job Creation:

(2) Business Name:

Jobs Maintained:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

Zip Code:

Fonn I-924A 0\103/B Y Page 4

34

 Part 3. Information About the Regional Center (Continued)
d. Name of Commercial Entetprise:

Industry Category Title:

Address (Street Number and Name):

City:

State:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation:

Aggregate Jobs Maintained:

Does this EB-5 commercial enterprise serve as a vehicle for investment into other business entities
that have or will create or maintain jobs for EB-5 purposes?

Zip Code:

0

DYes

No

If yes, then identify the name and address of each job creating business, as well as the amount ofim-5 capital investment and
job creation/maintenance associated with each job creating business.
(1) Business Nan1e:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

(2) Business Name:

Zip Code:

Industry Category Title:

Address (Street Number and Name):

City:

State:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Jobs Maintained:

Zip Code:

Industry Category Title:

e. Name of Commercial Enterprise:

Address Street Number and Name:

City:

Aggregate EB-5 Capital Investment:

Aggregate Direct and Indirect Job Creation: Aggregate Jobs Maintained:

State:

Does tlus EB-5 commercial enterprise serve as a vehicle for investment into oilier business entities
that have or will create or maintain jobs for EB-5 purposes?

Zip Code:

No

0

Yes

F01m I-924A 01!03/13 Y Page 5

35

 Part 3. Information About the Regional Center (Continued)
If yes. then identify the name and address of each job creating business, as well as the amount ofEB-5 capital investment and
job creationJmaintenance associated with each job creating business.
(1) Business Name:

Industry Category Title:

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

State:

(2) Business Name:

Zip Code:

Jobs Maintained:

Industry Category Title:

State:

Address (Street Number and Name):

City:

EB-5 Capital Investment:

Direct and Indirect Job Creation:

Zip Code:

Jobs Maintained:

-t Provide the total mm1ber of approved, denied and revoked Form I-526 petitions filed by EB-5 investors making capital
investments sponsored by the regional center. (Note: If an adverse action was ultimately reversed and the petition was approved,
then note the case as approved.)
Form l-526 Petition Final Case Actions

(b)(4)

Approved

Denied
0

Revoked
0

..

5. Provide the total number of approved, denied and revoked Fonn I-829 pet1t10ns ftled by EB-5 investors making capital

investments sponsored by the regional center. (Note: If an adverse action was ultimately reversed and the petition was approved,
then note the case as approved.)
Form I-829 Petition Final Case Actions
Approved
0

Denied
0

Revoked
0

NOTE: USCIS may require case-specific drtta relating to individual EB-5 petition<<> and the job creation detenuination and further
information regarding the allocation methodologies utilized by a regional C(.:nter in certain instances in order to verify the aggregate
data provided above.

Fonn l-924A Oli03!13 Y Page 6

36

 Part 4. Applicant Signature Read the i1~[ormation on penalties in the instructions before completing this section. If
someone helped you prepare this petition, he or she must compete Part 5.
I certity, under penalty of petjmy under the laws of the United States of An1erica, that this supplemental fonn and the evidence
submitted \vith it are all true and correct. I authorize the release of any infonnation from my records that U.S. Citizenship and
Immigration Services needs to detennine eligibility for the benetit being sought. I also certify that I have authority to act on behalf of
the Regional Center.
Printed Name of Applicant

Date (mmldd(vyyy)

NICHOLAS A. MASTROIANNI

12/12/2013

E-Mail Address
NICK@USIFUND.COM

(561) 799-1883

Relationship to the Regional Center Entity (Managing Member, President, CEO, etc.)
PRESIDENT & CEO

Part 5. Signature of Person Preparing This Form, If Other Than Above (Sign Below)
I declare that I prepared this fonn using infonnation provided by someone with authority to act on behalf of the Regional Center, and
the answers and infonnation are those provided by the Regional Center.
Attorney or Representative: In the event of a Request for Evidence (RFE), may the USC IS contact
you by Fax or E-maiP

0

No

[8] Yes

--,,

---

Printed Name ofPreparer

Signature 9fPreparer
~'-

/

.
' .'----";!-·
/

It ( {.c~I'[_/[, Y0\L'"t S;L

Date (mm/dd~vyyy)

"----··

Firm,_Name and Address

'

~

v

:'::-::_

, IGNACIO A. DONOSO

12/13/2013

v __/

I. A. DONOSO & ASSOCIATES, LLC

4720 MONTGOMERY LANE, SUITE 430
BETHESDA, MD 20814

Daytime Phone Number
(>lrea:Country Codes)
( 301) 276-0654

Fax Number (.4rea/
Country Codes)

E-Mail Address
IGNACIO.DONOSO@DONOSOLAW.COM

Fonn l-924A 01!03/13 Y Page 7

37

 Confidential Information

I

Attorney-Client Privileged

& ASSOCIATES, LLC

December 12, 2013
U.S. Citizenship & Immigration Services
California Service Center
Attn: EB-5 Processing Unit
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677
Via Federal Express
Re:

Form 1·924A- Annual Reporting
U.S. Immigration Fund-NJ, LLC
RCW 1236250925

Dear Immigration Officer,
Enclosed is the completed Form I-924A, Annual Reporting Supplement, for the U.S. Immigration
Fund-NJ, LLC. We also enclosed Form G-28 for the undersigned, should you require any
additional information regarding this filing.
We trust that the enclosed Form I-924A and the accompanying evidence complies with the annual
reporting requirements established by USCIS. Please do not hesitate to contact me at (301) 2760654 or by email at ignacio.donoso@donosolaw.com.
LA. Donoso & Associates, LLC

...
Ig ado Donoso
Managing Attorney
cc: U.S. Immigration Fund-NJ LLC (attention: Nicholas A. Mastroianni)
Encl. (as described above)

4720 MONTGOMERY LANE •:0 SUITE 430 •!• BETHESDA •!• MD 20814 •:0 TEL. (301} 276-0653
-------------- ··-·

--------~--------

-----------------

WWW .DONOSOLAW .COM

38

 U.S. Immigration Fund-NJ,"LLC
Form I-924A- Supplement for Annual Reporting 2012
Unique Identifier I.D. # RCW 1236250925
Year Ending: Sept. 30, 2013

FORM I-924A
FOR THE U.S. IMMIGRATION FUND-NJ, LLC

39

 U.S. Immigration Ftmd-NJ, LLC
Form I-924A -Supplement for Annual Reporting 2012
Unique Identifier l.D. # RCW 1236250925
Year Ending: Sept. 30, 2013

USCIS Regional Center Approval Letter
for the U.S. Immigration Fund-NJ, LLC

40

 U.S. Department of Homeland Security
24000 Avi!:a Road, 2.., Floor
Laguna Niguel,CA 92677

U.S. Citizenship

and hnmigrat1on.
Services

Date:

HAY 2 9 2013

Nicholas A. Mastroianni
U.S. Ilnmigration Fund- NJ, LLC
12 9 5 U.S. Highway 1, Suite 300
North Palm Beach, FL 33408

Application:

Form I-924, Application for Regional Center under the Immigrant Investor Pilot
Program

App1ic'am(s):

Nicholas A. Mastroianni
Initial Regional Center Designation
U.S. Immigration Fund- NJ, llC

Re:

RCW 1236250925 I RCW 1236250925

· This notice is in reference to the Form !·924, Application for Regional Center Under the Immigrant

Investor Pilot Program that was filed by the applicant with the U.S. Citizenship and Immigration Services
("USCIS") on December 27, 2012. The Form I-924 application was filed to request approval of initial
regional center designation under the Immigrant Investor Program. The lrnl.Iligrant Investor Program was
established under § 610 of the Department of Commerce, Justice and State, the Judiciary, and Related
Agencies Approp:ri.ations Act of 1993 (Pub. L. l 02-395, Oct 6, 1992, l 06 Stat. 1874).
I. Ex.ecutive_~ymrni!U_of Adjudication
I.

Effective the date of this notice, USCIS approves the Form I-924 request to designate U.S.
Immigration Fund NJ, LLC as a qualifying participant in the Immigrant Investor Program.

II. Regional Center :Pesignation
USCIS approves the applicant's request to focus, promote economic growth, and offer capital investment
opportunities in rhe following geographic area and indusrry caregories:

www.uscis.gov
41

 U.S Immigration Fund- NT. LLC I RCW1236250925/ ID
Page 2 of 4

A. Geographic Area

5;~!~- .. ·1 ·~1:g•n: ESS~>~~L. ~id~e£.[:~~:J~~~~f;as,:~. :~~ u~;n
Note: An amendment request is required if investment opportunities arise outside approved geographic
area.
B. Industry Categorie.<>

--·.· NAlcS :
··_:~:=---l~3 ~'-·. ~-?P!.~~~~~!i<4.!3~~~~tion
E
L
t
!':!~ite~tural,
1•

,, ..·

.:,.. ,

··'

:'tn<;J.U.SiryN~1e

· ·

---------~

-------------~~~-------~---~-.

6 2 ·.·.
2 361 ______ -~~~dential Buildil!&_S:?~n_st_r_uc_t_io_n____________.

~--~~}-~

Real Estate P~<?PE!:t~anage:rs
!
Englneering,_an.d Related Servic~~-Wholesale Trade
___.____________ _j
Note: . An amendment request is required if investment opportunities arise outside approved industry
ca tegor.i es.

5413
~.....____4..._2..._00~.

_

_j

USCIS approves the geographic area and industry categories noted above based on the economic impact
analysis presented and reviewed in conjuncti.on with the adjudication of this regional center proposaL The
job creation methodology presented in the economic impact analysis and underlying business plan is found
to be r.easonable based on the following inputs, when applying the RIMS II economic model:

(b)(4)

!--'-----·---·..--··--·-+-A_r_cl_1i_te_c_tl_lr_al~nd

Engineerin Services

Rental Income 0

* Indirect and induced jobs only
The approval of this Form I-924 application is based upon the economically and statistically valid
assumptions and estimates provided in the business plan for job creation. Please refer to the input and
multiplier analysis table above.
This actual project does not have the factual details necessary to be in compliance with the requirements
described in Maner ofHo, 22 I&N Dec. 206 (Assoc. Comm'r 1998), and therefore. USOS's approval of the
hypothetical job creacion estimates presented in the Form 1·924 will not be accorded deference and may
not be relied upon by an individual investor when filing the Form 1-526. The business plan and job

42

 U.S Immigration Fund- NJ, LLC I RCW1236250925/ ID
Page 3 of4

creation estimates will receive a de novo review by USCTS when an individual investor files Form I-526.
Once an actual project is adjudicated upon the filing of the initial Form 1-526 related to the 1·924
hypothetical project approval, USCIS will give deference to subsequent Forms I-526 when the critical
assumptions remain materially unchanged from the initially-approved Form I-526.
When filing Form l-526, it wlll be the responsibility of the individual investor to submit a comprehensive,
detailed and credible business plan, showing by a preponderance of the evidence that his or her investment
in the new commercial enterprise will create not fewer than 10 full-time positions. If prior to filing a form
r-8 29, the job creation estimated in the business plan submitted by the individual investor materially
changes or will not be realized, then it will be the responsibility of the EB-5 investor to notify USCIS of an
agreed upon methodology to allocate job creation among eligible investors.

Each iJ?.dividlJa] petition, in order to demonstrate that it is affiliated with. the U.S. Immigration Fund NJ,
LLC, in conjunction with addressing all the requ)remenrs for an individual immigrant investor petition,
shall also contain the following:
1. A copy of this regional center approval notice and desi.gnation lerter including all subsequent
amendm.ent approval letters (if applicable).
2. An economic impact analysis which reflects a job creation methodology required at 8 CFR § 204.6
(j) (4) (iii) and shows how the capital investment by an individual immigrant investor will create
not fewer than ten ( 10) indirect jobs for each immigrant investor.

3. A comprehensive, detailed and credible business plan for an actual project that contains the factual
details necessary to be in compliance with the requirements described in Matter .Qf Ho, 22 I&l..J
Dec. 206 (Assoc. Comm'r 1998).
4. Legally executed organizational documents of the commercial enterprise.
VI. Designee's ResponsiJ?.Hiti~j!l the Operatj,om of the Regional Center
As provided in 8 CFR § 204.6 (m)(6), to ensure that the :regional center continues to meet the
requirements of section 61 O(a) of the Appropriations Act, a regional center must provide users with
updated information to demonstrate the regional center is continuing to promote economic growth,
improved regional productivi.ty, job creation, and increased domes{ic capital investment in the approved
geographic area. Such information must be submitted to USCIS on an annual basts or as otherwise
requested by USCIS. The applicant must monitor all invesnnent activities under the sponsorship of the
regional center and to maintain records in order to provide the information required on the Form I-924A
Supplement to Form J-924. Form I-924A, Supplement to Form I-924 Application is available in the
"Forms" section on the USCIS website at W¥lW.UScis.gov.

43

 U.S Immigration Fund- NJ, LLC i RCW1236250925/ ID
Page 4 of 4

Regional centers that remain designated for participation in the Immigrant Investor Program as of
September 30th of a calendar year are required to file Form I-924A Supplement in that year. The Form I924A Supplement with the required supporting documentation must be filed on or before December 29'11
of the same cale.ndar year.
TI1e failure to timely file a Form I-924A Supplement for each fiscal year in which the regional center has
been designated for participation in the Immigrant Investor Program will result in the issuan<::e of an intent
to terminate the participation of the regional center in the Immigrant rnvesto:r Program, which may
ultimately result in the termination of the designation of the regional center.
The regional center designation is non-transferable, as any changes in management of the regional center
will require the approval of an amendment to the approved regional center designation.
If the applicant has any questions concerning the regional center designation under the rmmigrant Investor
Program, please contact the USCIS by email atUSCIS.ImmigrantlnvestorProgram@uscis.dhs.gov.
Sincerely,

Daniel" M. Renaud
Acting Chief, Immigrant Investor Program

cc: Ignacio A. Donoso, Esq.

44

 ..
I,;,

'"

RECEIPT NUMBER

CASE TYPE !924A

RCW133505l353

Supplement to Form 1-924

RECEIVED DATE

APPLICANT
MASTROIANNI , NICHOLAS A

December 13, 2013
NOTICE DATE

December 16.2013
IGNACIO A DONOSO
RE: US IMMIGRATION FUND NJ LLC
4720 MONTGOMERY LANE STE 430
BETHESDA MD 20814

'"''

II'

PAGE
1 of 1
NOTICE TYPE:

Receipt Notice

>!l:,;i'! 1

Receipt Notice · This notice confirms that USCIS received your application or petition as shown above. Please reference the receipt number, above, on
any correspondence with USC IS. If any of the above information is incorrect, please immediately contact us at
USCIS.ImmigrantlnvestorPrograrn@dhs.gov to let us know. This will help avoid future problems.
This notice does not grant any immigration status or benefit. It is not even evidence that this case is still pending. It only shows that the application or
petition was filed on the date shown.

Processing time- Processing times vary by kind of case. You can check our website at www .uscis.gov for our current processing times for this kind of
case at the particular office to which this case is or becomes assigned. If you do not receive an inith~J decision or update from us within our current
processing time, email us at USCIS.ImmigrantlnvestorProgram@dhs.gov. Save this notice, and any other notice we send you about this case, and please
make and keep a copy of any papers you send us by any means along with any proof of delivery to us. Please have all these papers with you if you
contact us about this case.
If your address changes- If your mailing address changes while you case is pending, notify us at USCIS.ImmigrantlnvestorPrograrn@dhs·.g~v; ·
otherwise you may not receive notice of our action on this case.

Please see the additional information on the back You will be notified separately about any other cases you fileo.
U.S. CITIZENSHIP & IMMIGRATION SVC
CALIFORNIA SERVICE CENTER
P.O. BOX 30111
LAGUNA NIGUEL CA 92607-0 Ill
lllllllli 111111111111111111111111111111111111111111111111111111111111111111
Customer Service Telephone: (800) 375-5283

45

 CIS Immigrant Investor Program
From:

Sent:
To:

Cc:
Subject:

USCIS Immigrant Investor Program
Monday, August 17, 2015 12:28 AM
nick@usifund.com
IDONOSO@FOSTERQUAN.COM; ignacio.donoso@donosolaw.com
Request for Clarification US Immigration Fund - NJ [ID1236250925]

Dear US IMMIGRATION FUND- NJ Principal:
US IMMIGRATION FUND- NJ ("the Regional Center") applied for designation as a regional center on
12/21/2012. On 5/29/2013, USCIS designated the Regional Center as a regional center and authorized its
participation in the Immigrant Investor Program.
In reviewing the Regional Center's I-924A filing for fiscal year 2014, RCW1434952101, USCIS notes the
following:
Regional center and related commercial enterprises that utilize names that contain the words "United States,"
"U.S.," "US" and "Federal" may falsely imply a relationship between the entity using the name, and USCIS, DHS
and the United States Government. In addition, use of such names on websites, promotional and other
marketing materials may be considered deceptive acts or practices and false advertisements in violation of
Federal laws governing unfair trade and false advertisements. See 15 U.S.C. §§ 45 and 52. IPO may refer
regional centers and related commercial enterprises with questionable naming conventions to the Federal
Trade Commission for further action.

Additionally, use of the words "Federal" or "United States," in advertising by businesses engaged in the
financial services sector may be a violation of 18 U.S.C. § 709, which prohibits false advertising or misuse of
names to indicate Federal agency. IPO may refer regional centers and related commercial enterprises with
questionable naming conventions to the Department of Justice for further action.

Due to the fact that the Regional Center's name contains the word "US" the Regional Center may be in
violation of laws as described above. Please submit evidence that the regional center has adopted a name
that does not contain words that may be in violation of U.S. law.
Please respond within 90 business days of the date of this email via email to:
USCIS.ImmigrantlnvestorProgram@uscis.dhs.gov. Should you need additional time to submit the requested
evidence, please respond to this email with your time extension request.
Sincerely,

Immigrant Investor Program
U.S. Citizenship and Immigration Services

46

 DA0018

47

~.S. Department of Homeland Security

'-t/ 000 Avila Road, 2"d Floor
Laguna Niguel, CA 92677

U.S. Citizenship
and Immigration
Services

Date: ·

.tfAy 2 9 2013

Nicholas A. Mastroianni
U.S. Immigration Fund- N], LLC
1295 U.S. Highway 1, Suite 300
North Palm Beach, FL 33408

Application:

Form I-924, Application for Regional Center under the Immigrant Investor Pilot
Program

Applicant( s):
Re:

Nicholas A. Mastroianni
Initial Regional Center Designation
U.S. Immigration Fund N], LLC
RCW 1236250925 I ID 1236250925

This notice is in reference to the Form I-924, Application for Regional Center Under the Immigrant
Investor Pilot Program that was filed by the applicant with the U.S. Citizenship and Immigration Services
("USCIS") on December 27, 2012. The Form I-924 application was filed to request approval of initial
regional center designation under the Immigrant Investor Program. The Immigrant Investor Program was
established under § 610 of the Department of Commerce, Justice and State, the Judiciary, and Related
Agencies Appropriations Act of 1993 (Pub. L. 102-395, Oct. 6, 1992, 106 Stat. 1874).
I. Executive Summary of Adjudication

1. Effective the date of this notice, USCIS approves the Form I-924 request to designate U.S.
Immigration Fund- N], LLC as a qualifying participant in the Immigrant Investor Program.
II.

Re~ional

Center Designation

users approves the applicant's request to focus,
oppor~unities

promote economic growth, and offer capital investment
in the following geographic area and industry categories:

COPY
www.uscis.gov
48

 .&lepartment ofBoatelaad Seeurity

"

U.S. Citizenship and ~gmtion Servi<:ea
A#

IUeeipt#

RCW123625092S
Notice Dam

..

·'

''

1of8

A ril9, 2013

Ignacio A. Donoso

A :

FosterQuan, LLP
RE: U.S. IMMIGRATION FUND-NJ
600 Travis St., Suite 2000
Houston, TX 77002

FOC: esc
Jiifefift'tf:ii'oT1Denl31myrtJProc~cn:s't!'tsin""g~"'"''

Coversheet

RETURN THIS BLUE PROCESSING COVERSHEET ON TOP OF YOUR
RESPONSE TO THE INTENT TO DENY.
Note: You are given.until

·

·.May 9, 2013 . in whieh to submit the requatecHnformation to

the address at the bottom Of this nodet.

RESPONSE TO AN INTENT TO DENY

For more information, visit oar website at WWW.uscis.gov

Or call us at

1-800-375-5283

Telephone service for the hearing impaired: 1-800-767-1833

For non..US Postal Service
Attn: EB & RC Proposal
24000 Avila Road, r' Floor

Laeuna Niguel, CA 12877

CSC4639 WS25097 INVESTOR BRANCH MP

49

 ~enter

I RCW1236250925/ IDl236250925

NOTICE OF INTENT TO DENY
notice is in reference to the Form I-924, Application for Regional Center Under the Immigrant
rm·"stor Pilot Program, rhat was flled by U.S. Immigration Fund-NJ Regional Center ("applicant") at the
c,1 Jifomia Service Center on December 21, 2012. The U.S. Citizenship and Immigration Services ("USCIS")
has completed its revicvv of the application for designation as a regional center under the Immigrant
Investor .Program ('"Program"). The Program was estabbshed under § 610 of the Department of
c:ommerce, Justice and State, the Judiciary, and Related Agencies Appropriations Act of 1993 (Pub. L. 10239 5, Oct. 6, !992, l 06 Stat. 18 74). The purpose of this notice is to notify the applicant that USCIS intends
to deny its application requesting designation as a regional center.
I. Procedural History

The proposed Regional Center entity was established on December 7. 2012 ln the state of Florida and is
structured as a limited liability company. The applicant is requesting jurisdiction over a geographic area
include:

Name of State
New jersey

Counties
Bergen, Essex, Hudson, Middlesex, Monmouth, Morris, Passaic and
Union

Additionally, the applicant plans to offer EB-5 capital investment opportunities in affiliated ne.w
commercial enterprises, organized as limited partnerships, focusing on projects in the foUowing industry

Che capital investment projects will involve a combination of equity investments and loans to job creating
,.,nJ·pnwicP< located within the proposed bounds of the Regional Center.
On December 12, 2012, the applicant filed its Form I-924 requesting regional center designation. On
20, 2013, USCIS issued a request for additional evidence ("RFE") as the initial application did nor
under 8 C.F.R. § 204.6(m) (3. The response to the RFE was received on March 5, 2013.

\ttdm:E::1t

to

lTD Coversheet

50

 lJS.lmmigrarion Fund- NJ Regional Center I RCW1236250925/ ID1236250925
3 of 8

II. Regional Center- Relevant Statute and Regulations

Sccnon 610 of the Departments of Commerce, Justice and State, the Judicia.ry, and Related Agencies
1\ppropriations Act of 1993, Pub. L. 102-395, (8 USC 1153 note), as amended by Section402 of the Visa
Wa.iver Permanent Program Act of 2000, Pub. L. 106-396, provides:

(a) Of the visas otherwise available under section 203(b)(S) of the Immigration and
Nationality Act (8 U.S.C. 11 53(b)(5)), the Secretary of State, together with the Attorney
General, shall set aside visas for a program to impletnent the provisions of such section. Such
program shall involve a regional center in the United States for the promotion of economic
growth, including increased export sales, improved regional productivity, job creation, and
increased domestic capital investment.
(b) For purposes of the program established in subsection (a), beginning on October 1, 1992,
but no later than October I, 1993, the Secretary of State, together with the Attorney General,
shall set aside 3,000 visas annually for flve years to include such aliens as are eligible for
admission under secrion 203(b)(S) of the Immigration and Nationality Act and this section, as
\vell as spouses or children which are eligible, under the terms of the Immigration and
~ationality Act, to accompany or follow to join such aliens.

(c) In determining compliance \\lith section 203(b)(S)(A)(iii) of the Immigration and Nationality
Act, and notwithstanding rhe requirements of 8 CFR 204.6, the Attorney General shall pennit
aliens admitted under the program described in this section to establish reasonable rnerhodologies
for determining the number of jobs created by the program, including such jobs which are
estimaced to have been created indirectly through revenues generated from increased exports,
improved regional productivity, job creation, or increased domestic capital investment resulting
hom the program.
The regulation at 8 CFR § 204.6(m) provides:
(3) Requirements for regional centers. Each regional center wishing to participate in the
Immigrant Investor Program shall submit a proposal to the Assistant Commissioner for
Adjudications, which:
(i) Clearly describes how the regional center focuses on a geographical region of the
United States, and how it will promote economic growth through increased export
sales, improved regional productivity, job creation, and increased domesti.c capital
mvestment;

(ii) Provides in verifiable detail how jobs will be created indirectly through increased
exports;

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51

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
4

8

(iii) Provides a detailed statement regarding the amount and source of capital which
has been committed to the regional center, as well as a description of the promotional
efforts taken and planned by the sponsors of the regional center;

(iv) Contains a detailed prediction regarding the manner in which the regional center
will have a positive impact on the regional or national economy in general as re.flected
by such factors as increased household earnings. greater demand for business services,
milities. maintenance and repair, and construction both within and without the
regional center; and

(v) Is supported by economically or statistically valid forecasting tools, including, but
not limited to, feasibility studies, analyses of foreign and domestic markets for the
goods or services to be exported, and/ or multiplier tables.
(4)

***

( 5) Decision to participate in the Immigrant Investor Program. The Assistant
Commissioner for Adjudications shall notify the regional center of his or her decision on
the request for approval to participate in the Immigrant Investor Program, and, if the
petition is denied, of the reasons for the denial and of the regional center's right of appeal
to the Associate Commissioner for Examinations. Notification of denial and appeal rights,
and the procedure for appeal shall be the same as those conta.ined in 8 CFR 103.3.
In reviewing this application, USCIS has to determine whether the request for regional center designation
has met all of the regulatory criteria and thereby will maintain a regional cemer within which aliens
11
'''""" Hl''' to obtain permanent resident status under section 203(b)(5) of the Act will be able to successfully
t>stablish a new commercial enterprise (as described in 8 CFR § 204.6(h)) with the qualifying investment.
dut will benefit the United States economy and creare l 0 full time jobs, including jobs indirectly created
through the new commercial enterprise.

HI. Issues

A. Issue 1: The applicant was requested to provide a detailed and itemized constructjon timeline
and transparent, objective and verifiable data.
The applicant submitted a letter from Sam Gersh'v'vin, the president of Westminster Communities
and the person responsible for all the project's constructiOIHelated activities. The letter indicated
that the 26-month construction rimeline is reasonable. The letter lists the relevant phases of the
construction e±Tort but does not provide a timeline in detailed and itemized form. Therefore, the
applicant has yet to submit a derailed and .itemized construction timeline.

Attachment to lTD Coversheet

52

 U.S Immigration Fund- NJ Regional Center J RCW1236250925/ ID1236250925
S of8

•

This issue will remain unresolved until the applicant submits an itemized construction
timeline shovving all relevant phases of the construction effort.

•

The issue will also remain unresolved until the applicant provides transparent, objective,
and veri.fiable data illustrating that the proposed construction timehne and budget are
within a reasonable range when compared to industry standards.

B. Issue 2: The applicant was requested to clarify specific unresolved issues in the Impact
Analysis.

The applicant solicited the expertise of Evans, Carroll, and Associates (Evans-Carroll) to conduct the
economic impacr analysis. Evans···Carroll calculates the potential economic impacts of the
construction expenditures (hard and soft) and the leasing operations of the apartment building.
Economic Impact Model Useq (IMPLAN. RJMS H REDYN, eJ&l
. RIMS II calibrated for the following counties in the State of New Jersey: Hudson, Essex, Union,
Bergen, Passaic, Morris, Monmouth, and Middlesex.

(b)(4)

l_____

Hard Construction: Evans-Carroll uses a hard const111ction expenditure estimate of ..
.,las a
final demand input into RIMS II.
a. Transparency: The parameters are based on a construction budget prepared by the Kushner
Companies-the project developer-and the KA.BR Group--a real esta.r.e holding company.
However, the construction cost budget presented on page 37 of the economic impact analysis
is illegible. The applicant must provide a legible construction cost budget that is detailed and
itemized.
b. Applicability: The parameters are applicable to the project. Please note, however, that the
applicant does not provide a verifiable, detailed, and itemized construction cost timeline (see
Issue 1, above). Thus, the applicant may only take credit for the indirect and induced jobs
resulting from the hard construction expenditures.
c. Reliability: The construction cost budget is verified by Sam Gershwin, the president of
Westminster Communities and person responsible for the construction of rhe projeC(. Thus,
the parameters are reliable.
d. Up-toDate: The parameters are up-to-date.
•

Issues a. and b. remain unresolved.

Soft Construction Costs: Evans-Carroll uses the following soft construction expenditures estimates as
final demand inputs into RIMS II:
I.

Category

I FF&E

Expenditure F,stimate

(b)(4)

~chitectural and Engineering Services

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53

 U.S. Immigration Fund NJ Regional Center I RCW1236250925/ 101236250925
Page 6 of 8

Transparency: The parameters are based on a construction budget prepared by the Kushner
Companies, the project developer and the KABR Group, a real estate holding company.
However, the construction cost budget presented on page 37 of the economic impact analysis
is illegible. The applicant must provide a legible construction cost budget that is detailed and
it.emized.
b. Applicability: The parameters are applicable to the projecL
c. Reliability: The parameters are verified by the construction manager and are reliable.
d. Up-to-Date: The parameters are up-to-date.

a.

•

(b)(4)

Issue a. remains unresolved

~. Leasing Operations: Evans-Carroll calculates a rental i.ncome estimate ofl
Hor the fhst
year of operations and uses this estimate as a final de.mand input into RIMS ll.
a. Transparency: The rental income estimate is based on a detailed and itemized pro forma
financial statement provided by the Kushner Companies and the KABR Group. Thus, the
parameters are transparent
b. Applicability: The parameters are not fully applicable because the rental income estimate
includes parking revenue. It is not an acceptable methodology to include revenue derived
from parking operations because parking operations do not pertain to real estate leasing
activities.
c. Reliability: The parameters are reliable.
d. Up-to-Date: The parameters are up-to date.

•

Issue b. remains unresolved.

The taple below presents a summary of the critical assumptions used to derive the model inputs.

/361/2362

d Comtruction cost expenditure estimate is based on the

(b)(4)

~··--·--·~-~t'./·~e':--'eliJo'::p::ejr·~s::co::n::st=:ru:"".:c;.;;ti::o::;:n:::co~s=t.::b::Ju~;:jgioleiiit.---~c:.-::r--:-::-:L::-I
S3lll

! (a) Rental revenue estunate ot ~
fased on the
'
developer's pro forma
..__ _ __.
(b Deflated ro 2008 dollar terms.
et

l\Iulriplier(s) Used {Direct Employment. Dirs;ct Eflect Earnings. Final Demand Output. etc.) and Aualysls of
3:\ppli carion of Multiplier
The results of the analysis are summarized in the table below.
1
I

. Activity
, Construction

NAICS Code

I! Input

RIMS II
Multiplier

1

(b)(4)

Total

Jobs

I

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54

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
Page 7 of 8

(b)(4)

I

Soft Costs:
FF&E

~ot

Archit.cctural md Engineering Services

5413

• Rent<illncome Operations

!

Provided

--

53111

, Total

'lndinict and induced jobs only
It appears that RIMS II is used in an inappropriate manner. It is not an acceptable methodology to include

revenue derived from parking operations because parking operations do not pertain to real estate leasing
activities.

•

Please calculate employment impacts from parking operations separarely using the
appropriate industry multiplier.

•

Please provide the NAICS indusrry code pertaining to FF&E expenditures.

IV. Decision

This notice serves as notification of users· intemion to deny the applicant's request for designation as a
rF<a1nn~• center as the Fonn I-924 does not meet the regulatory requirements at 8 C.F.R. § 204.6(m)(3).
the applicant is afforded thirty ( 30) days from the date of this notice to submit additional
infor~ation, evidence or arguments in support of the application. Additionally, when USCIS serves a
notice by mail, three (3) days are added to the prescribed period in which to respond. See 8 C.F.R.
l 0 3..5a(b). Any response to this notice should include a detailed analysis that rebuts the grounds for denial
above. corroborated by credible independent documentary evidence all of which ,vilJ be considered
a decision is rendered.
V. Review Board Option
Pursuant to 8 C:.F.R § l03.2(b)(9), USCIS has the authority to request the applicant's appearance for either
an in-person interview at the California Sexvice Center (CSC) or a telephonic interview. Should the
applicant prefer an in-person or telephonic interview, please indicate as such in response to this notice of
mtenr to deny.

However, be advised that USCIS will need to review any additional infonnation, evidence, or arguments
applicant wishes to submit in support of the application before a review board may be scheduled.
review of the applicant's response, the applicant will then be contacted via the USeiS Immigra.nr
f.nvestor Program mailbox at 1!SCIS.IrnmigrantinvestorProgram(Zilusci.s.dhs.go;::. for further instructions
regarding the time and date of the interview.

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 U.S. Immigration Fund NJ Regional Center I RCW123625092S/ ID1236250925
8 of8

The interview will last approximately 60 minutes. During this time, the applicant \vi.U be given the
opportunity to present additional information regarding the pending case. The CSC will issue a written
decisicm at a later date, after full consideration of the \'\rritten record and statements made during the
interview.

Failure to respond to this notice of intent to deny will result in the denial of the application based on the
above stated reasons .

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56

 Confidential Information

:orney-Ciient Privileged

600 Travis Street
Suite 2000
Houston. TX 77002
713.229.8733 office
713.228.1303 fax
www.fosterquan.com

RQuAN,LLP
II

iLHSiV[ IMMIGRATION LAW FIRM

April18, 2013
Ms. Rosemary Melville, Director
USCIS- California Service Center
24000 Avila Road, 2nd Floor
Laguna Niguel, California 92677

Via Federal Express
Re:

Response to Notice of Intent to Deny I-924 Application
Regional Center Name:
US Immigration Fund - NJ
Process:
I-924 Application For Original Designation
Receipt No.:
RCW 1236250925
Regional Center I.D.:
123-625-0925
Date Application Filed:
December 21,2012
EXPEDITED PROCESSING APPROVED

Dear Ms. Melville:
We are immigration counsel to the US Immigration Fund-NJ, LLC ("USIF-NJ"), in
relation to the above-captioned I-924 Application (RCW 123-625-0925) ("Application"). This
letter, its exhibit list and attached Exhibits constitutes the response of the USIF-NJ to the Notice
of Intent to Deny ("NOID Response").

A.

Procedural History

On December 21, 2012, USIF filed the Application with U.S. Citizenship & Immigration
Services ("USC IS") requesting that the Application be processed with Expedited Processing.
On February 4, 2013, USCIS notified the USIF-NJ by email that the Application would
be processed with Expedited Processing.
On February 20, 2013, USCIS issued a Request for Evidence issued in relation to the
above captioned Application ("RFE").
On March 4, 2013, USIF-NJ submitted its written response to the RFE.
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57

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On April9, 2013, USCIS issued a Notice oflntent to Deny the Application ("NOID").
Unless otherwise defined herein, all capitalized terms used in this NOID Response shall
have the same meaning ascribed to them in the Business Plan (as defined below).
B.

Timely Filed

The NOID provided USIF-NJ until May 9, 2013 to submit its response. This NOID
Response, filed on Aprill8, 2013, is thus timely filed.

C.

Response to the NOID

BriefSummary of Project
The initial sample (hypothetical) project of the USIF-NJ is the construction and operation
of a 50-story, 417 unit, luxury residential condominium building at 88 Morgan Street (corner of
Baytown), in Jersey City, Hudson County, New Jersey, with attached parking spaces, amenities
and approximately 4,000 square feet of office space ("88 Morgan Street Projecf' or "Project'}
Please note that the 88 Morgan Street Project is a replica of the residential tower already
built directly adjacent, and known as the "Trump Plaza I" in Jersey City, New Jersey. Reference
to the residential tower previously built on the contiguous site named "Trump Plaza I" is stated
in the Business Plan at pages 1, 4, 6 (with map) and 38.

Analysis of the NOID
The NOID states two (2) elements in the Application that require additional evidence: (1)
the construction timeline set out in the Business Plan attached at Exhibit 19 of the original
Application ("Business Plan"), and (2) the Economic Impact Analysis conducted by Evans,
Carroll & Associates attached at Exhibit 20 of the original Application ("Economic Analysis").
We analyze each of the requests for additional evidence and provide responses to each
below.
1.

Issue 1: Construction Timeline and Budget
(a)

NOID on Construction Timeline

The NOID requests at page 4, Section A. I, that USIF-NJ submit an itemized construction
timeline showing all relevant phases of the construction effort. The NOID also states that the
USIF-NJ must provide "transparent, objective and verifiable data illustrating that the proposed
construction timeline and budget are within a reasonable range when compared to industry
standards.''
2

58

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This issue in the NOID is a continued analysis of an issue raised by USCIS in the RFE.
USCIS stated in the RFE that the construction timeline as set out in the Business Plan does not
present "verifiable detail" that it will span 26 months, starting with excavation approximately in
February or March of 2013 and ending with the acquisition of a temporary certificate of
occupancy for the building in April of 2015 ("Construction Timeline'l
The RFE requested a "detailed and itemized construction timeline showing all relevant
phases of the construction effort." The RFE further requested "transparent, objective, and
verifiable data illustrating that the proposed construction timeline and budget are within a
reasonable range when compared to industry standards."
In response to the NOID, and in addition to the evidence that USIF-NJ has already
submitted in the Application and the Response to the RFE, USIF-NJ is submitting the following
additional evidence:
• Detailed and itemized construction timeline, enclosed at NOID Exhibit 1.
The detailed Construction Budget Timeline enclosed at NOID Exhibit 1 shows the
relevant phases of construction of the Project, the projected time period during which the
budgeted expenditures will be made to complete the construction, and the estimated dollar figure
for each of the budgeted construction costs.
The detailed Construction Budget Timeline at NOID Exhibit 1 is fully responsive to the
NOID's request on this issue. It breaks down major budget items such as construction hard costs
into specific dollar amounts that match the phases of construction. It further explains how much
of the total cost of construction is projected to be spent during each phase of construction.
(b)

Evidence that the proposed construction timeline and budget are within a
reasonable range when compared to industry standards.
Construction Timeline & Industry Standards

USCIS asks for evidence that the Construction Budget Timeline in NOID Exhibit 1 is
"within a reasonable range when compared to industry standards", as supported by "transparent,
objective and verifiable data". [emphasis added]
We have already submitted in RFE Exhibit 2, a letter dated February 28, 2013, signed by
Mr. Sam Gershwin with a copy of his resume in RFE Exhibit 3. Both of these documents are
attached hereto as NOID Exhibit 2, for your convenience.
Mr. Gershwin is a real estate professional with over 35 years of experience in the field of
construction management. He has risen to the position of President of Westminster
Communities and member of the Board of Directors of the Kushner Companies, and in that
position is the person responsible for all construction and construction-related activities for the
3

59

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Kushner Companies - one of the largest real estate companies in the New York with assets with
billions of dollars and millions of square feet of commercial real estate under its management. In
the Gershwin letter of February 28, 2013, Mr. Gershwin unequivocally states:

"I have personally worked on the development of the construction budget
for the 88 Morgan Street Project. Based on my experience and
knowledge of industry standards, the construction timeline as set forth in
the Business Plan is a reasonable projection of the time it will take to
complete the construction of the apartment tower and related
improvements on the property is consistent with similar current and past
projected completed by Kushner Companies."
Mr. Gershwin then confirms the phases of construction of the Project that are estimated
to take 26-months to complete.
The analysis and evaluation of the Projecfs estimated 26-month construction time line by
Mr. Gershwin is eminently credible and detailed. It alone should provide persuasive evidence
that the 26-month construction timeline for the Project is accurate and within a reasonable range
compared to industry standards.
Further evidence of the reasonableness of the estimated 26-month construction timeline
for the Project comes from the real world. The evidence that USIF-NJ has submitted for the
Project confirms that it is Phase II of the companion tower, Trump Plaza Residences, which is
already completed as Phase I. This fact is stated in the Business Plan (at Page 4 of Exhibit 19 of
the Application), and as also confirmed in the Architect's Soft Construction Budget for the
Project, submitted as RFE Exhibit 5, which refers to the Project as the "replica" tower of the
Trump Plaza Residences.
Trump Plaza Residences is a 55 story residential tower with 445 units, underground
parking, and retail space. Trump Plaza Residences has 5 more stories than the Project. All
information about its history confirms that it took over 24 months to complete, from 2006 to
2008. Specifically, we attach in NOID Exhibit 3 the Wikipedia web page for Trump Plaza
Residences, as well as the web pages for the Trump Plaza Residences available at
SkyscraperPage.com and Emporis.com, all of which confirm that the Trump Plaza Residences
was started in 2006 and completed in 2008. We also attach in NOID Exhibit 3 copies of
newspaper articles from the period, which confirm that the start of construction was announced
to the media on September 23, 2005 (New York Times, "Latest Trump Venture is in Jersey
City", September 23, 2005), and was completed and ready for occupancy by approximately April
of 2008 (The Real Deal, New York City Real Estate News, "Inside the Open Houses: Jersey City
Comes a Long Way", January 2, 2008). The evidence of the construction time line from Trump
Plaza Residences serves to confirm the accuracy and reasonableness of the construction timeline
in relation to industry standards.
Finally, we surveyed publicly available information regarding the time it to complete
smaller residential apartment towers in Jersey City, NJ, in recent years. Our review of publicly

4

60

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Privileged

available information regarding the construction of three towers: Marbella Apartments; Liberty
View Towers; Hudson Green (77 Hudson Street). See NOID Exhibit 6. We set out the results
of this survey below:
' Name of Building

Number ofFioors

(:ompletion Period

Liberty View Towers

36

2001 to 2003 (24 months)

Marbella Apartments

40

2001 to 2003 (24 months)

i

Hudson Greene (77 Hudson St.)

: 48

i

2006 to 2009 (over 24 months)

!

Monaco

47

Dec. 2008 to 2011

i

In each case, the buildings had fewer floors than the Project, and required at least 2 years
or more to complete.
Construction Budget & Industry Standards

The issue of whether the construction budget for the Project is within a reasonable range
when compared to industry standards is squarely addressed by the letter from Sam Gershwin
dated February 28, 2013, attached hereto at NOID Exhibit 2. The letter from Sam Gershwin
unequivocally confirms that the construction budget is reasonable. It reads:

"the "hard construction cost" and the furniture, fixtures, and equipment
("FF&E") budgeted amounts are based on the current plans and
specifications for the construction. Those costs are a reasonable
projection based on industry standards and my experience on
comparable construction projects. The "soft cost" amount budgeted for
this Project is based primarily on an agreement between the Kushner
Companies and its architect. The budget from that Architectural
Agreement is attached to this letter."
We have obtained additional evidence of industry standards from the analysis of Dr.
Michael Evans, who provides a revised Economic Analysis for the Project dated April 11, 2013,
attached hereto at NOID Exhibit 4 ("Revised Economic Analysis"). In the Revised Economic
Analysis, at page 41, Dr. Evans confirms that publicly available industry data sources ratify the
accuracy of the construction budget for the Project:

(b)(4)

"USCIS has requested that these figures be related to industry standards.
According to R. S. Means, Square Foot Costs, 34th Annual Edition (2013}, the
average construction cost per square foot for an apartment building on a national
~ basis i~
Ithe average cost for an underground parking garage is
L____J These figures should be multiplied by the regional coefficient for Jersey
City, NJ, which is 1.1 0, hence raising these figures to aboud
5

I

(b)(4)

61

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Confidential Information

·.orney-Ciient Privileged

respectively. These numbers can be compared with the cost per square foot
given in the above table of I
I The figure for the apartment
building is below industry standards; the figure for the parking garage is above
industry stfndards. but the weighted average of these two comQonents of the
building is
1compared to the R S. Means average figure o1

I

(b)(4)

We note that there is an apparent contradiction in the text of the NOID regarding this
issue. At Section A, Issue 1, at the 2nd bullet point at the top of page 5, the NOID requests that
the USIF-NJ provide "transparent, objective and verifiable data illustrating that the
proposed construction timeline and budget are within a reasonable range when
compared to industry standards." [emphasis added]
In the subsequent text, at Section B, Issue 2, on page 5, the NOID clearly states that it
found the evidence of the construction budget to be reliable:
"c. Reliability: The construction cost budget is verified by Sam Gershwin, the
president of Westminster Communities and person responsible for the
construction of the project. Thus, the parameters are reliable."
The same statement is found at point 2.c on page 6 of the NOID regarding Soft
Construction Costs.
The statement in the NOID that the construction budget verified by Sam Gershwin is
"reliable" appears to be conclusive on the question of the reliability of the information provided
on the construction budget and timeline. We have nevertheless provided additional evidence to
support this point in relation to Section A, Issue 1.
Preponderance of the Evidence

Finally, we take this opportunity to highlight that the 88 Morgan Street Project is
submitted as a sample project for the USIF-Nl This is not an Exemplar application. The
requirement by USCIS that the USIF-NJ submit the detailed Construction Budget Timeline or
else face denial of the Application is far beyond the controlling standard of proof.
The preponderance of the evidence standard, as set out in the Supreme Court's decision
in Cardozo-Fonseca, 480 U.S. 421 (1987), requires proof that a fact is more likely than not (a
greater than 50 percent chance that a fact is true). The evidence already submitted with the
Application and the RFE Response provides reliable, detailed and objective evidence of the
budget and the construction timeline. The Construction Budget Timeline submitted with this
NOID Response, as well as additional new evidence such as the Revised Economic Analysis,
provide substantially and indisputable evidence of the accuracy of the construction budget and
construction timeline for the Project. Moreover, the evidence provided establishes the fact that
the construction budget and timeline "fall within a reasonable range when compared to industry
6

62

 Confidential Information,

orney-Ciient Privileged

standards'' - and far exceed the standard of proving a fact on a preponderance of the evidence
standard.
Additionally, the requirements stated in the NOID that the USIF-NJ submit an itemized
construction timeline and that the application provide "transparent, objective and verifiable data
illustrating that the proposed construction timeline and budget are within a reasonable range
when compared to industry standards" are not supported by controlling Regulations at 8 C.F .R.
Section 204.6(m)(3)(iii) and (v), or by the USCIS precedent decision in Matter of Ho, Interim
Decision #3363 (WAC 98 0072 50493) July 31, 1998.

2.

Issue 2: Clarify Unresolved Issues with the Economic Analysis
(a) Hard Costs

USC IS states in the NOlO, at page 5, Section B.l, that the text of the construction budget
on page 37 of the Economic Analysis previously submitted with the Application and RFE
Response is not legible. Therefore, the Hard Construction Costs estimates from the Project's
construction budget are not "Transparent". Additionally, the NOID states that the Hard
Construction Costs estimates from the budget at page 27 of the Economic Analysis are
applicable, but the duration of the construction is not "verified" because the construction costs
timeline was not previously submitted. USC IS requests that these two issues be resolved.
In response to the NOID, these two issues have been resolved by the USIF-NJ.
First, the Project's economist, Dr. Michael Evans, of Evans, Carroll & Associates, has
prepared the Revised Economic Analysis, attached hereto at NOID Exhibit 4, which includes a
legible copy of the Construction Costs estimates previously submitted.
(b)(4)

Please note that the job creation estimates from Dr. Evans have changed slightly because
he too realized that the text of the Construction Costs budget from the previous drafts was not
entirely clear. Dr. Evans prepared a letter to this effect, which we attach at NOID Exhibit 5.
For example, he states on Page 36 of the Revised Economic Analysis that: "The line items
included in the hard cost are the building costs ofl
I and the parking garage costs of
I
Ifor a total of I
I In the earlier versions of the Economic Analysis,
he had previously estimated the hard costs to be I
I
The aforesaid changes in job creation estimates are not material to this Project c:Jnew
permanent jobs in the Revised Economic Analysis vers~ew permanent jobs in the
previous Economic Analysis- representing a difference o
obs). The difference ofniobs is
less than 1% of the Hard Construction Costs job creation es 1mate, and the Project con~ues to
have an ample number of jobs in excess of the minimum job creation requirements for each EB-5
investor.
(b)(4)

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Second, USIF-NJ is now submitting, in NOID Exhibit 1, a detailed Construction Budget
Timeline, as well as additional new evidence, that, coupled with the evidence already submitted,
provides USCIS with verifiable data supporting the proposed construction timeline and the fact
that they fall within a reasonable range when compared to industry standards.

(b) Soft Construction Costs

USC IS states in the NOID, at page 6, Section B.2, that the text of the construction budget
on page 37 of the Economic Analysis previously submitted with the Application and RFE
Response is not legible. Therefore, the Soft Construction Costs estimates from the Project's
construction budget are not "Transparent".
In response to the NOID, this issue has been resolved by the USIF-NJ. The Project's
economist, Dr. Michael Evans, of Evans, Carroll & Associates, has prepared the Revised
Economic Analysis, attached hereto at NOID Exhibit 4, which includes a legible copy of the
construction budget estimates previously submitted.
(c) Leasing Operations

USCIS states in the NOID, at page 6, Section B.3, that the USIF-NJ overestimates the
revenue from rental income because the revenue from parking is included in the dollar figures
for rental income. USCIS states as follows:

"The parameters are not fully applicable because the rental income estimate
includes parking revenue. It is not an acceptable methodology to include
revenue derived from parking operations because parking operations do not
pertain to real estate leasing activities.''

(b)(4)

In response to the NOID, USIF-NJ has removed the projected revenue from parking
operations from .its estimate of rental income, and applied the new lower estimate of rental
income as an input in the Revised Economic Analysis. Specifically, USCIS will find this change
stated in the Executive Summary of the Revised Economic Analysis, at page 3, which it states:
"Parkins revenue is also excluded'\ and states the reduced dollar figure for rental revenue to be
I
I Additionally, this revised dollar figure for rental revenue appears at page 47 and
48 of the Revised Economic Analysis. The impact of the lower rental revenue dollar figure
results in a total decrease in job creation of0new full-time positions (down to Dew jobs
fromOew jobs).
(b)(4)
USIF-NJ has made this change to comply with the NOID. USIF-NJ, however, believes
that the analysis of USCIS on this issue is, respectfully, erroneous. There are two reasons why
USIF-NJ believes there is an error in the USCIS analysis of the parking revenue.
First, the Project is a residential tower and the leasing activity of its operations inherently
includes parking spaces that are "leased" to tenants. As stated in the Business Plan, Private
8

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Placement Memorandum~ and the Economic Analysis and Revised Economic Analysis, the
Project will be a luxury apartment building located at 88 Morgan Street in Jersey City, NJ, with
417 apartment units, 214 parking spaces, and about 4,000 square feet of retail space. The Project
is not a mixed-use commercial facility, such as a shopping mall, which is open to the public and
has a parking garage serving the general public. Instead, the 21 7 parking spaces of the building
are primarily intended for the use of the residents of the Project. The revenue generated from the
parking spaces of the Project will be generated from tenants and owners of the Project. This is
significant because there is no factual basis to consider the rental revenue from the 217 parking
spaces to be in any way different that the rental revenue generated by the leasing of apartments
or the leasing of storage lockers. It is part and parcel of the same business. Moreover, it is not
appropriate to consider the parking revenue to be generated from a separate business (which
would require a separate and distinct NAICS code for parking activities). The NAICS code for
parking activities, NAICS code 812930, is for "establishments primarily engaged in providing
parking spaces for motor vehicles." [emphasis added] This is patently not the case of a
residential apartment tower with a parking garage in the basement. The revenue generated from
leasing parking spaces in the Project should therefore have been unquestionably included in the
revenue from leasing operations.
(b)(4)

Second, these changes in job creation estimates are not material to this Project, and thus
are beyond the standard of proof as set out in the controlling Regulations for estimating job
creation from the Project. The change requested by USCIS- and adopted by the USIF-NJ in the
Revised Economic Analysis- caused job creation to be reduced byOnew full time positions
(down to
new jobs fromOnew jobs). This change represents an approximately 2%
change in job creation of jobs resulting from operations, and less than 1% of all jobs resulting
from the Project. The reduction of[]lobs is not material to the job creation estimate, and the
Project continues to have an ample number of jobs in excess of the minimum job creation
requirements for each EB-5 investor.

D

(d) FF&E

(b)(4)

USCIS states in the NOID, at page 5, Section B.2, that furniture, fixtures and equipment
("FF&E") expenses should be excluded from the Economic Analysis because they are not
supported by the appropriate NAICS Codes for the Wholesale Trade Industry.
In response to the NOID, USIF-NJ has maintained the FF&E cost estimates and is hereby
adding the required NAICS industry codes for the Wholesale Trade Industry to obtain approval
for counting such expenditures in FF&E in the job creation estimates, as set out below:
....
CSCode··

--u~

Industry Name
Commercial and Institutional Real Estate Construction

2362

Residential Real Estate Construction

2361

Lessors of Real Estate

53111

------~-~

9

65

 Confidential Information

, Architectural, Engineering & Related Services

i

:orney-Ciient Privileged

5413

......... ,.......................................................................................................................................................................................................................

Furniture and Home Furnishing Merchant Wholesalers

4232

Professional and Commercial Equipment and Supplies Merchant 4234
Wholesalers
Household Appliances and Electrical and Electronic Goods 4236
; Merchant Wholesalers

The revised NAICS codes are stated in the Revised Economic Analysis attached hereto at
NOID Exhibit 2. Further, we submit at NOID Exhibit 7 a new list of the NAICS codes
requested on Form 1-924 for this Application.

C.

Conclusion and Requested Action

The above information and attached evidence, together with the evidence set out in the
Application, addresses all of the issues raised in the NOID. The new evidence submitted with
this NOID Response is probative, verifiable and detailed, and clearly explains that USIF-NJ has
satisfied its evidentiary burden in this I-924 application for original regional center designation.
We trust that USCIS will find the foregoing analysis and evidence in order, and we look
forward to your favorable adjudication of this 1-924 Application. We thank you in advance for
your consideration of this NOID Response.
Should there be any questions or should USCIS require additional information, please do
not hesitate to contact me at (713)335-3993 or by email at idonoso(a)fosterquan.com.

Sincerely,

cc:

Nicholas Mastroianni, II
Mark Giresi
10

66

 Confidential Information

:orney-Ciient Privileged

Exhibit List to Notice of Intent to Deny
I-924 Application
U.S. Immigration Fund - NJ
DOCUMENT

TAB No.

Detailed and itemized construction timeline for the Project.

1.

Evidence of Reliability of Construction Timeline and Budget from Sam
Gershwin, President of Westminster Communities:

2.

•

Industry Letter dated February 28, 2013, from Sam Gershwin,
President of Westminster Communities, the affiliate of Kushner
Companies, and a real estate construction professional with over
35 years of experience.

•

Executive Profile of Mr. Sam Gershwin from Bloomberg Business
Week (businessweek.com) dated March 1, 2013

Information regarding Trump Plaza Residences, the already completed replica
tower of the Project.
•

Wikipedia web page for Trump Plaza Residences.

•

Web pages for the Trump Plaza Residences available at
SkyscraperPage.com and Emporis.com.

3.

• New York Times, "Latest Trump Venture is in Jersey City'\
September 23, 2005).
•

The Real Deal, New York City Real Estate News, "Inside the Open
Houses: Jersey City Comes a Long Way", January 2, 2008).

Revised Economic Analysis prepared by Evans, Carroll & Associates for the
88 Morgan Street Project dated April II, 2013.

4.

Letter from Evans, Carroll & Associates explaining change in the dollar
figure for hard costs of the Project dated Apri116, 2013.

5.

Publicly available information regarding the construction of three recent and
comparable residential towers in Jersey City, New Jersey: Marbella

6.
11

67

 Confidential Information

torney-Ciient Privileged

Apartments; Liberty View Towers; Hudson Green (77 Hudson Street), and
Monaco.
Revised NAICS codes for the Application and Revised Form I-924.

7.

12

68

 uQ•~<-NJ

DOCUMENT
Detailed and itemized construction timeline for the Project.

Response to NOID

TAB No.
1.

69

 (b)(4)

~

Budget
Total

88 MORGAN STREET (a.k.a. 65 BAY STREET)
CONSTRUCTION BUDGET TIMELINE

Feb.
2013

(a)

m

~

Q.4

m

m

2013

2013

2013

2014

2014

~
2014

Q.4

ru

2014

2015

TOTAL

Summary:
Hard Costs
Parking
Development Fees
FF&E

SubTotal
Dtt~lled Br~akd~n:

Permits
Excavation
Concrete Foundation, Waterproofing, and Pilings

f

Super Structure Framing (beginning to end)
Mechanicals, Electrical, Plumbing and Sprinkler Systems
Exterior Walls
Interior Framing
Drywall
Interior Finishes
Punch List and Temporary Certificate of Occupancy Items
Final Cleaning
Totals

(a) ·Construction Start Date estimate is subject to change based on funding.

Copy of 65 BAY STREET CONSTRUCTION TIM ELINE v3 04182013 FINAL
4/18/2013

70

 U~'l:i-NJ

DOCUMENT
Evidence of Reliability of Construction Timeline and Budget from Sam
Gershwin, President of Westminster Communities:

Response to NOID

TAB No.
2.

• Industry Letter dated February 28, 2013, from Sam Gershwin,
President of Westminster Communities, the affiliate of Kushner
Companies, and a real estate construction professional with over
35 years of experience.
• Executive Profile of Mr. Sam Gershwin from Bloomberg Business
Week (businessweek.com) dated March 1, 2013

71

 Thursday, February 28, 2013
Subject:

88 Morgan Street, Jersey City, New Jersey Project

To Whom It May Concern,
I am President of Westminster Communities, responsible for all construction and construction~
related activities for Kushner Companies. Kushner Companies is a group of real estate
development and management companies and is engaged in the mixed-use commercial
development project located at 88 Morgan Street Jersey City, New Jersey (the Project").
11

I have worked in multiple capacities over the past 35 years in the field of construction and
construction management. I have personally managed over 100 construction projects totaling
more than $25 Billion in construction costs. I have had management responsibilith:is for the
creation of commercial construction budgets and the day-to~day management of construction
budgets and activities. I am also responsible for the creation and management of the
construction budget for the 88 Morgan Street Project and am personally involved on a daily
basis with the present design of the construction documents and will be involved on a daily
basis with the overall management of the construction activities for this Project.
I have personally worked on the development of the construction budget for the 88 Morgan
Street Project. Based on my experience and knowledge of industry standards, the construction
timeline as set forth in the Business Plan is a reasonable projection of the time it will take to
complete the construction of the apartment tower and related improvements on the property
is consistent with similar current and past projects completed by Kushner Companies. The
relevant phases of construction are as follows and will take approximately 26 months to
complete:
•
•
•
•
•
•
•
•

Excavation
Concrete Foundation and Waterproofing
Tower Building Construction begins
Tower Building Construction completed
Roofing and Tower Crane Areas
Interior Finishes
Mechanicals, Electrical, Plumbing and Sprinkler Systems
Punch List and Temporary Certificate of Occupancy items

72

 In addition, the "hard construction cost" and the furniture, fixtures, and equipment ("FF&E")
budgeted amounts are based on the current plans and specifications for the construction.
Those costs are a reasonable projection based on industry standards and my experience on
comparable construction projects. The "soft cost" amount budgeted for this Project is based
primarily on an agreement between Kushner Companies and its architect. The budget from
that Architectural Agreement is attached to this letter.
Based on my 35 years of experience in the field of construction and construction management
and my review of the construction plans and other available information relative to the
proposed construction of the 88 Morgan Street Project, it is my professional opinion that the
hard cost, soft cost and FF&E budget outlined in the 88 Morgan Street Business Plan is an
accurate projection of the estimated costs to complete the Project.

Sincerely,

Sam Gerswhin
President
Westminster Communities

I
-I

73

 Sam Gershwin: Executive Profile & Biography- Businessweek

3/1/13 2:36AM

March 01, 2013 2:35AM ET

Real Estate Management and Development
Company Overview of Kushner Companies, LLC
Snapshot

Overview

Board Members

Committees

Executive Profile

Sam M. Gershwin
Director and President of Westminster Communities LLC, Kushner Companies, LLC

Age

Total Calculated Compensation This person is connected to 1 Board Members in 1 different
organizations across 1 different industries.
See Board Relationships

Background

Sam M. Gershwin serves as President of Westminster Communities LLC, the construction division of
Kushner Companies. For the past 25 years, Mr. Gershwin served as a corporate officer and managing
member of single-asset real estate development companies. Active in his community, Mr. Gershwin has CoChaired the Livingston Township 9/11 Memorial Committee. He serves as Director of Kushner Companies.
He serves as a member of the Board of Governors for Crestmont Country Club and serves on the Board of
Trustees of Temple Beth Shalom in Livingston. He holds a B.S. degree in Civil Engineering from Lafayette
College in Easton, Pennsylvania, and an M.B.A. from Seton Hall University in South Orange, New Jersey.
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byTaboola

Corporate Headquarters

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666 Fifth Avenue
New York, New York 10103

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United States

Stocks Options

There is no Stock Options data available.
Phone: 212-527-7000
Fax: 212-527-7007
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Page 1 of 2

74

 Sam Gershwin: Executive Profile & Biography

Businessweek

3/1/13 2:36AM

--~------------------------------Board Members Memberships
Director and President of Westminster
Communities LLC

Kushner Companies, LLC

Education

BS
Lafayette College

MBA
Seton Hall University

Other Affiliations

Lafayette College
Seton Hall University

Businessweek
More About "sam gershwin westminster
communities"
Lifestyle

Westminster Dog Show Viewer's Guide:

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Page 2 of 2

75

 U~n:-_NJ

DOCUMENT
Information regarding Trump Plaza Residences, the already completed replica
tower of the Project.
•

Wikipedia web page for Trump Plaza Residences.

•

Web pages for the Trump Plaza Residences available at
SkyscraperPage.com and Emporis.com.

Response to NOID

TAB No.
3.

• New York Times, "Latest Trump Venture is in Jersey City'',
September 23, 2005).
•

The Real Deal, New York City Real Estate News, "Inside the Open
Houses: Jersey City Comes a Long Way", January 2, 2008).

76

 Trump Plaza Uersey City)- Wikipedia, the free encyclopedia

4/17/13 8:25PM

Coordinates: 40.7195"N 74.0365"W

Trump Plaza (Jersey City)
From Wikipedia, the free encyclopedia

Trump Plaza also known as Trump Plaza Residences, is
the first of two planned apartment complex buildings to be
built in Jersey City, New Jersey. Trump Plaza Residences is
532 ft tall ( 162 m) and has 55 floors.lt was completed in
2008. The building has 1,743,760 sq ft (162,001 m) of space
and 445 units.lt is the tallest residential building in New
Jersey.1 11It is the third largest building in Jersey City.

Trump Plaza

The second building, Trump Plaza II, will be 484ft tall
( 148 m) and have 50 floors. This building will begin
construction soon. Both building are designed by DeWitt
Tishman Architects LLP. The cost of the two buildings is
$415 million.
In May 2010, developer Dean Geibel retained Commercial
real estate firm William Procida Inc. to assist in finding
investors for Trump Plaza II.

See also
• List of tallest buildings in Jersey City

References

General information

I. " "New model residence unveiled at Trump Plaza Residences
in Jersey City" The Union City Reporter; October 17, 201 0;
Page 9

Status

Complete

Type

Residential

Coordinates

External links

Construction started 2006
Completed

• Emporis (http://www.emporis.com/en/wm/cx/?
id=trumpplaza-jerseycity)
• Trump Plaza 1 (http://skyscraperpage.com/cities/?
buildingiD=40941)
• Trump Plaza 2 (http://skyscraperpage.com/cities/?
buildingiD=40942)
• Trump Plaza Photos

2008

Height
Roof

532ft (162m)

Technical details
Floor count

55

Floor area

1,743,760 sq ft (162,001 m)

Design and construction

II
I

Architect

DeWitt Tishman Architects

LLP

Trump Plaza II
General information
Status
http 1/en.wlkipedla.org/wiki/Trump_Piaza_Uersey_City)

Page 1 of 2

77

 Trump Plaza Uersey City)

Wikipedia, the free encyclopedia

4/17/13 8:25PM

Type

Residential
8eight

Roof

484ft (148m)
Technical details

Floor count 50
Design and construction
Architect

DeWitt Tishman Architects LLP

(http://photos .livingonthehudson .com/2009/12/ 10/trump-plaza-jersey-city-condos-4/)
• Trump Plaza in The Real Deal (http://therealdeal.com/newyork/articles/nj-developer-dean-geibel-tapswilliam-procida-to-find-financial-aid-for-stalled-condos)
Retrieved from "http://en .wikipedia.org/w/index .php?title=Trump_Plaza_(Jersey_City)&oldid=550409299"
Categories: Skyscrapers in Jersey City, New Jersey i Residential buildings completed in 2008
Skyscrapers between 100 and 149 meters . Skyscrapers between 150 and 199 meters
Residential skyscrapers in the United States
• This page was last modified on 15 April2013 at 02:44.
• Text is available under the Creative Commons Attribution-ShareAlike License; additional terms may
apply. By using this site, you agree to the Terms of Use and Privacy Policy.
Wikipedia® is a registered trademark of the Wikimedia Foundation, Inc., a non-profit organization.

http //en .wi ki pedia.org/wiki/Trump_Piaza_Uersey_City)

Page 2 of 2

78

 Trump Plaza I, jersey City- SkyscraperPage.com

4117113 8:12PM

Marble Restoration.

• Comparison Diagram
Compare this buildmg to notable
structures of the world

WWIN.Iovemarble.com

Bring Your Marble Back to Life! Restore,Polishing,Repair,Cieaning
Like this build1ng on Facebook

Trump Plaza I
88 Morgan Street
Jersey City NJ United States
Status:
built
Construction Dates
Began
2006
Finished
2008
Floor Count
55
Floor Area
162,001 m'
Units I Rooms
445

Heights
Roof

Value

Building Uses
- residential
Structural Types
- highrise
Architectural Style
- postmodern
Materials
-glass
-steel
-limestone
- concrete, reinforced

Source I Comments

532ft

• View All Drawjngs 121
• View Antares41 's Diaaram
• View Jersey City Diagram
• View New .Jersey Diagram
• View United States Diagram

Description
• Architect: DeWitt Tishman Architects LLP.
• Constructors: AJD Construction Company, Eastern Concrete
Materials Inc., Forsa Construction Company, Rempel Bros.
Concrete Ltd.
• Developer: Applied Development Corporation.
• Others: Bovis Lend Lease LMB Inc., Corus Bank, Goldstein
Associates PLLC, Metro Homes LLC, Panepinto Properties, The
Marketing Directors Inc., The Trump Organization.
• Google Search

Aerial View I Map - Location within Jersey City

~Show marker

tc• the Worldwide
Who network for

Succeso;;ful '·Nornen.

0
G
Q

Rich Dad
Education
Free

2~Ho1

e

View Jersey Cjty Map Centered on Building
View Full Jersey City Map
View Jersey Citv Development Map
Vjew Bui!djoq on Google Maps

u· Seminars·

http: 11 skyscraperpage.com/ citiesl?buildingl0=40941

Page 1 of 2

79

 Trump Plaza I, jersey City- SkyscraperPage.com

'
attendees,

'~·'-'

:")'" .v.

up today!

4/17/13 8:12PM

"""""

uo you see any mcorrect aata on tms page·1 1-'lease let our eanors Know 01 any correct;ons you can
make by posting them in the Database Correctjons section of the discussion forum (open to the public).

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a Conditions

All content displayed on and contain&d w1thm this page is subject to Skyscraper Source Media Inc.'s Temls and Condit1ons. No content
displayed on this page may be reproduced, in whole or m part, without prior written permission by Skyscraper Source Media Inc AU content
©Copyright Skyscraper Source Media Inc

Switch heights to
Mfters

http: //s kyscraperpage.com/ cities/?building1Dm40941

Page 2 of 2

80

 Trump Plaza Residences I Buildings I EMPORIS

Your Location:

4/17/13 8:13PM

WQ.d.d.---+ North America---+ l.LS.A...---+ New Jersey---+ Jersev City---+ Trump Plaza Residences

Trump Plaza Residences
Tweet

I] C<?fiillt

rnir

Purchase Images View all 75 images

Identification
Name

Trump Plaza Residences

EBN

244213

Map

http: 1lwww .em pori s.com 1building /tru mp-plaza-residences-j ersey-city-nj-u sa

Page 1 of 2

81

 Trump Plaza Residences

I Buildings I EMPORIS

4117113 8:13PM

Structure in general
Building type

skyscraper

Building status

existing [completed]

Structural material

concrete

Architectural style

postmodern

Usage
Main usage

residential condominium

Location
Main Address

88 Morgan Street

Address as text

88 Morgan Street

ZIP

07302

Complex

Trump Plaza

City

Jersev Citv

State

NewJersev

Country

U.S.A.

Technical Data
Height (architectural)

532.01 ft

Fioors (above ground)

55

D

Construction start
Construction end

http: 1lwww .em pori s.com 1building ltru mp-plaza -residences-jersey-city-nj-u sa

Page 2 of 2

82

 Latest Trump Venture Is in jersey City- New York Times

4/17/13 9:37PM

WIJ.!l· Regjster Now

Metro
Campaigns

New York/Region
Home

New York/Region

.Q.I2i.ni.2!!!

Latest Trump Venture Is in
Jersey City
# [Bv Til\ A KELLEY :-i
Sjgo In to E-Mail This
Published: Septem~_j

.!!1. Prjnter-friendly
JERSEY CITY, Sept. 22- With a
trio of trumpeters playing a fanfare,
4, Save Article
Donald .1. Trump on Thursday
helped unveil an artist's rendering of
THE EAST
his latest project, Trump Plaza:
WATCH !RAJLER
Jersey City. The new luxury
condominium development would
be the tallest residential development in the state.

The $415 million project will
include two towers, 50
storjes and 55 stories,;,ith
862 condominium units and
23,000 square feet of retail
space. The towers will be at
Washington and Bay Streets,
a few blocks from the
Hudson River and near the
Powerhouse Arts District. "It
really cements Jersey City as
the hottest place to be in the
Northeast," said Mayor

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Jerramiah T. Healy. "It's a
Oona ld .1. Tnunp battled the wind
Thursday at the unveiling of a
$415 million luxury condo project,
frump Plaza: Jersey City.

big step in the great progress
Jersey City has made in the
past years." Each condo unit
will receive a 20-year
property tax abatement, but
Mr. Healy said the city
would receive more money
from development and
building fees the developers
paid than the city would have
received in property taxes.
The Trump Organization will
manage the complex, which

htW //www.nytlmes.com /2005/09/23/nyregion/23trump.html?_r~O

Page 1 of 3

83

 Latest Trump Venture Is in Jersey City- New York Times

Wilt

4/17/13 9:37PM

mcmue a ousmess

center, and amenities for
residents like a movie
Rendering of Trump Plaza: Jersey
theater, an 8,000-square-foot
City. ncar the lludson River.
fitness center, and a heated
outdoor rooftop pool.
Apartments will feature
marble bathrooms and exotic wood floors.
The price of the units, which will range in size from 750 to
2,224 square feet, has not been determined, said Dean Scott
Geibel, founder of Metro Homes L.LC, a developer from
Hoboken. He noted that the units will be cheaper than
comparable condos in Manhattan. At Grandview, another of
Mr. Geibel's residential projects in Jersey City, farther from
the waterfront, condominiums sold for about $600 a square
foot, with a range of$289,000 to $906,000, and all but one
unit has sold since it opened last year, a spokesman for
Metro Homes said.
Mr. Geibel called the project "a poster child for smart
growth," because of its proximity to PATH stations, light
rail, and the ferry to Manhattan.
Barbara Netchert, the executive director of the Jersey City
Redevelopment Agency, said earlier plans called for office
space development on the property, which is now a parking
lot and had been a warehouse and rail yards.
"It was converted to residential, as has most of the projects
in the city." she said. "The office market was flat, and the
economics were moving more for residential."

Mayor Healy called the project a benchmark for the city.
"W e'vc done great for the last 20 years, but this takes it to
another level," he said. Mr. Trump, who three times
declared himself the biggest developer in New York City, a
description his competitors dispute, noted that in moving
west of Manhattan, he was going against the usual
developer's path, "but I've usually been pretty good at
predicting trends." Construction is expected to start in two
months and last two years. Mr. Trump estimated that 1,200
to I ,300 workers would be employed in the construction. At
560 feet, the tallest of the towers would still rank below the
state's tallest building, the 781-foot Goldman Sachs tower
nearby at 30 Hudson Street.
At one point before the project's picture was unveiled, a
gust of wind flipped Mr. Trump's swooping hair.
"Sec, my hair is real, folks," he said. "If it weren't, with this
wind, you'd have a much bigger story than these two
buildings, there's no doubt in my mind."
Real hair or not, Mr. Trump impressed city leaders.
"As a New York mogul, when he crosses the river, it's a
magic step," said the city council president, Mariano Vega.
http://www.nyt•mes.com/2005/09/23/nyregion/23trump.html?_r~O

Page 2 of 3

84

 Latest Trump Venture Is in Jersey City

4/17/13 9:37PM

New York Times

More Articles in New York Region>

2 bedroom condo for
~
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Today~

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Page 3 of 3

85

 Inside the Open Houses: Jersey City comes a long way

THE

4/17/13 9:45PM

DEAL

NEW YORK CiTY REAL ESTATE NEWS

Inside the Open Houses: Jersey City comes a long way
Young professionals in area upgrade as condo projects become more upscale
/j

:.:008

D:rsr1n Gooi

When asked to describe the appeal of Jersey City, one condo shopper summed up his answer in one telling word: convenience.
Indeed, this is where any discussion about Jersey City inevitably begins. Query home buyers or renters on why they're considering it, or ask brokers
how they market it, and their responses will almost always cite the close proximity to Manhattan, the easy access to PATH stations, and the under 30minute commute to the city.
Based on an informal survey of open house attendees, Jersey City- which once had a reputation for corruption, crime and urban decay, and has more
recently attracted some real estate trailblazers - is now seeing a critical mass of young professionals.
And those who are looking for an alternative to the high-priced co-ops and condos in New York City or an upgrade frorn other nearby New Jersey
apartments are finding that they have options, including a soon-to-be-opened Trump building and an area with an increasing number of amenities,
including new shops and cafes.
Take Adrian, the condo buyer who invoked the word "convenience" when asked at a recent Saturday afternoon open house why he was looking in
Jersey City. He's an Internet technology professional who has lived in the area since 1997 and is now looking to upgrade from a one-bedroom facing
the Hudson River to something even larger.
"I've had many opportunities to live in Manhattan," said Adrian, who declined to give his last name. "But I didn't want to because Jersey City is quieter,
more affordable and cleaner."
On this particular day, Adrian was browsing at Dixon Mills, a 467-unit former factory complex that began a condo conversion in March 2007. The
property's general manager, Jon Ha, said that 50 percent of his customers are from within Jersey City. He described Dixon Mills' vicinity, a stone's
throw rrom VanVorst Park, as "similar to Park Slope, Carroll Gardens or Brooklyn Heights because it has a neighborhood feel."
Ha had two open houses. One was a 1,400-square-foot, two-level, two-bedroom penthouse unit for $675,000. The other was a 852-square-foot onebedroom for $362,000.
"The rental market in downtown Jersey City is sizzling hot, so it makes sense to buy," Ha added.
David and Meredith, both 26, were looking to do just that as they checked out an open house at 208 Brunswick, close to Hamilton Park. Having rented
in the area he works at a bank in downtown Manhattan, she at a law firm in western New Jersey- they are already Jersey City converts.
Meredith, who also declined to give her last name, said, "There's a lot more character in the homes" than in Hoboken, where they've also looked.
Weichert Realty agent Dan Pelosi said Jersey City's ability to retain its residents is a fairly recent phenomenon.
"People will rent or buy something here and then trade up," Pelosi said. "It's not like when they can afford a house, they move to the suburbs. That's
really a change, and it shows great neighborhood stability."
Pelosi pointed to quality housing stock. as well as the city's well-known affordability, for convincing people to drop anchor there.
"They're not building any more Civil War-era brownstones," he said.
At the end of 2006, New York Magazine pronounced that Jersey City would be the next "hot" destination for hip homebuyers. A handful of cute, newly
opened cafes and boutiques along Grove and Barrow streets are further signs of that ascendance.
But what may raise Jersey City's profile the most, according to Pelosi and several other realtors, is the imminent arrival of Trump Plaza Jersey City. The
first apartments are expected to be available in April 2008.
bring nearly 1,000 luxury units to the already-developing waterfront with

http: 1/the real deal.com/ iss ues_articles/ inside-the-open-houses-jersey-city-comes-a -long-way I

Page 1 of 2

86

 Inside the Open Houses: jersey City comes a long way

4/17/13 9:45PM

""'

Still, many brokers have predicted that it is places just like Jersey City, which are in the process of major transformations, that will be first to feel the
effects of the softening market. They said there could be a real problem in filling all of the new construction that was started during the construction
boom, before the subprime crisis hit.
That is less because the Jersey City market had subprime borrowers and more because it draws a lot of young professionals from the city who may
have more difficulty borrowing money in this less generous credit environment [see "Jersey City market skirts the housing storm" in the November 2007
issue of The Real Dea~.
Some are already seeing the slowdown. "It's dead across the board," said Coldwell Banker agent Laura Ann Knecht. But others had a far less gloomy
take, describing more of a sense of selectivity and patience than of a lack of interest.
David and Meredith, the banker and lawyer, dismissed the 1,1 00-square-foot loft-style apartment they saw at 208 Brunswick as "too much like a studio"
for their taste. The asking price had already been dropped to $405,000 from $419,000.
Another couple, both mid-20s professionals, concluded that six blocks to the PATH station was just too far for them.
"It used to be that people would look at three properties, and they were ready to sign an offer; now, they want to see over 30, and they're still not sure,"
said another local Coldwell agent, who asked not to be named.
Jason Rowley, a 33-year-old investor who already owns two properties in Jersey City, said he worries "every day" whether this is a bad time to buy in
the area. ''The risk today is in its being overbuilt," Rowley said. Nonetheless, there he was on a chilly pre-holiday Saturday scouting potential third
properties.
"It's hard to believe that in the long term, this place won't retain its value," he said.

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http: //thereat deal.com 1iss ues_articles I ins ide-the-open-houses-jersey-city-comes-a-long-wayI

Page 2 of 2

87

 Uf..

DOCUMENT
Letter from Evans, Carroll & Associates explaining change in the dollar
figure for hard costs of the Project dated April16, 2013.

~J

Response to NOlO

TAB No.
5.

88

 Evans, Carroll & Associates, Inc.
2785 NW 26th St.
Boca Raton, Fl 33434
561-470-9035
Apri116, 2013
Attention: EB-5 Unit
USC IS
California Service Center
24000 Avila Road, 200 Floor
Laguna Niguel, CA 92677

Re:

U.S. Immigration Fund- NJ, LLC
1-924 Application for Regional Center Designation
Clarification of Revised Economic Impact Analysis & Response to USCIS
Notice of April9, 2013

Dear USCIS Officer:
At the request of the U.S. Immigration Fund - NJ, LLC ("USIF-NJ"), Evans,
Carroll & Associates has prepared a revised Economic Impact Analysis dated April 11 ,
2013, for the sample project of the USIF-NJ known as "88 Morgan Streef'. A copy of
the revised Economic Impact Analysis is attached to this letter.
Please note that the revised dollar figures for hard costs, and for land, interest
and contingencies are based on the same budget as before, but have been corrected.
An error was previously made because the budget figures were illegible. The same
budget data is found in the revised Economic Impact Analysis at Section 8, page 36 and
following.
Please do not hesitate to contact Evans, Carroll &Associates should you have
any questions regarding this letter or the attached Economic Impact Analysis.
Sincerely,

Michael K Evans

89

 U~··

DOCUMENT
Revised NAICS codes for the Application and Revised Fonn I-924.

'JJ

Response to NOID

TAB No.
7.

90

 Part 3. Information About the Regional Center (Continued)
5. Describe the past, current, and future promotional activities for the regional center. Include a description of the budget for this
activity, along with evidence of the funds committed to the regional center for promotional activities. Submit a plan of operation
for the regional center that addresses how EB-5 investors will be recruited, the method(s) by which the capital investment
opportunities will be offered to the investors, and how they will subscribe or commit to the investment interest.

6. Describe whether and how the regional center is engaged in supporting a due diligence screening of its alien investor's lawful
source of capital and the alien investor's ability to fully invest the requisite amount of capital. Also, describe the regional center's
prospective plans in this regard if they differ from past practice.

7. Identify each industry that has or will be the focus of EB-5 capital investments sponsored through the regional center.
Industry Category Title:
!Nonresidential building construction I

Is the Form I-924 application supported by an economic analysis and
underlying business plan for the determination of prospective EB-5
job creation through EB-5 investments in this industry category?
No- Attach an explanation

NAJCS Code for the Industry Category:
-

3

6

I:8J

2
---

Industry Category Title:

IRP·~·ir1Pl1tial

hoi lr1inrr construr:tinn

I

3

6

Is the Form I-924 application supported by an economic analysis and
underlying business plan for the determination of prospective EB-5
job creation through EB-5 investments in this industry category?

D No - Attach an explanation

NA!CS Code for the Industry Category:
'l

Yes

~Yes

1

-----Industry Category Title:
!Lessors of Residential Buildings

NA!CS Code for the Industry Category:
~3

1

---

1

1

I

Is the Form I-924 application supported by an economic analysis and
underlying business plan for the determination of prospective EB-5
job creation through EB-5 investments in this industry category?

D No- Attach an explanation
~Yes

--

SEE ATTACHED EXHIBIT "A" FOR
COMPLETE LIST OF NAICS CODES

Fonn 1-924 01/03/13 Y Page 4

91

 EXHIBIT A TO FORM I-924
U.S. IMMIGRATION FUND-NJ
RESPONSE TO PART 3, QUESTION 7

NAICS Codes
The U.S. Immigration Fund- NJ's investment in new projects will focus in
the following industries and economic sectors, which are described according to
the North American Industry Classification System codes and titles:

Industry Name

NAICSCode

';

,,,,,

2362

Commercial and Institutional Real Estate Construction
Residential Real Estate Construction
!

Lessors of Real Estate

1

i

2361
53111

, Architectural/ Engineering & Related Services
Furniture and Home Furnishing Merchant Wholesalers

4232

Professional and Commercial Equipment and Supplies Merchant 4234
Wholesalers
' Household Appliances and Electrical and Electronic Goods 4236
Merchant Wholesalers

92

 Department of Homeland Securit)

U..
S Citizenship and Immigration SerVIces

I-797E, Notice of Action

A#

AppllcationiPetitlon

Receipt#

ApplleantJPetitioner

1924, Application for Regional Center under Immigrant Investor Pilot Program

RCW1236250925
Notice Date

April9, 2013

U.S. Immigration Fund-N J

I1 of8

Beneficiary

Page

Ignacio A. Donoso
FosterQuan, LLP
RE: U.S. IMMIGRATION FUND-NJ
600 Travis St., Suite 2000
Houston, TX 77002

Intent to Deny Processing
Coversheet

RETURN THIS BLUE PROCESSING COVERSHEET ON TOP OF YOUR
RESPONSE TO THE INTENT TO DENY.

May 9, 2013

Note: You are given until
the address at the bottom of this notice.

in which to submit the requested information to

RESPONSE TO AN INTENT TO DENY

•

For more information, visit our website at WWW. USCIS.gov
Or call us at

1-800-375-5283

Telephone service for the hearing impaired: 1-800-767-1833

For non-US Postal Service
Attn: EB 5 RC Proposal
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677

CSC4639 WS25097 INVESTOR BRANCH MP
You will be notified separately about any other applications or petitions you filed. Save this notice. Please enclose a copy of it
if you write to us about this case, or if you file another application based on this decision. Our address is:
USCIS ·CALIFORNIA SERVICE CENTER

~~G~~~ ~~~~EL, CA 92607-0590
800-375-5283

lllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll
RCW1236250925
Formi-797E
93

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
Page 2 of 8

NOTICE OF INTENT TO DENY

This notice is in reference to the Form I-924, Application for Regional Center Under the Immigrant
Investor Pilot Program, that was filed by U.S. Immigration Fund-NJ Regional Center ("applicant") at the
California Service Center on December 21, 2012. The U.S. Citizenship and Immigration Services ("USCIS")
has completed its review of the application for designation as a regional center under the Immigrant
Investor Program ("Program"). The Program was established under § 61 0 of the Department of
Commerce, Justice and State, the Judiciary, and Related Agencies Appropriations Act of 199 3 (Pub. L. I 02395, Oct. 6, 1992, 106 Stat. 1874). The purpose of this notice is to notify the applicant that USCIS intends
to deny its application requesting designation as a regional center.
I. Procedural History

The proposed Regional Center entity was established on December 7, 2012 in the state of Florida and is
structured as a limited liability company. The applicant is requesting jurisdiction over a geographic area
to include:

Counties
Hw1son, Middlesex, Monmouth, Morris, Passaic

Additionally, the applicant plans to offer EB-5 capital investment opportunities in affiliated new
commercial enterprises, organized as limited partnerships, focusing on projects in the following industry
categories:
NAICS

2362
2361
5313
5413

'"-----~

'

y ('

Non residential Rniklino Construction
Residential '"' .,
Construction
Real Estate Property "
ll .,.,
and Related Services
'

The ca_pital investment projects will involve a combination of equity investments and loans to job creating
enterprises located within the proposed bounds of the Regional Center.
On December 12, 2012, the applicant filed its Form I-924 requesting regional center designation. On
February 20, 2013, USCIS issued a request for additional evidence ("RFE") as the initial application did not
qualify under 8 C.F.R. § 204.6(m)(3. The response to the RFE was received on March 5, 2013.

Attachment to lTD Coversheet

94

 U.S. Immigration Fund
Page 3 of 8

NJ Regional Center I RCW1236250925/ ID1236250925

II. Regional Center- Relevant Statute and Regulations
Section 610 of the Departments of Commerce, Justice and State, the Judiciary, and Related Agencies
Appropriations Act of 1993, Pub. L. 102-395, (8 USC 1153 note), as amended by Section 402 of the Visa
Waiver Permanent Program Act of 2000, Pub. L. 106-396, provides:
(a) Of the visas otherwise available under section 203(b)(5) of the Immigration and
Nationality Act (8 U.S.C. 115 3 (b) (5)), the Secretary of State, together with the Attorney
General, shall set aside visas for a program to implement the provisions of such section. Such
program shall involve a regional center in the United States for the promotion of economic
growth, including increased export sales, improved regional productivity, job creation, and
increased domestic capital investment.
(b) For purposes of the program established in subsection (a), beginning on October 1, 1992,
but no later than October 1, 1993, the Secretary of State, together with the Attorney General,
shall set aside 3, 000 visas annually for five years to include such aliens as are eligible for
admission under section 203 (b) (5) of the Immigration and Nationality Act and this section, as
we.ll as spouses or children which are eligible, under the terms of the Immigration and
Nationality Act, to accompany or follow to join such aliens.
(c) In determining compliance with section 203 (b) (5) (A) (iii) of the Immigration and Nationality
Act, and notwithstanding the requirements of 8 CFR 204.6, the Attorney General shall pennit
aliens admitted under the program described in this section to establish reasonable methodologies
for determining the number of jobs created by the program, including such jobs which are
estimated to have been created indirectly through revenues generated from increased exports,
ir:qproved regional productivity, job creation, or increased domestic capital investment resulting
from the program.
The regulation at 8 CFR § 204.6(m) provides:
(3) Requirements for regional centers. Each regional center wishing to participate in the
Immigrant Investor Program shall submit a proposal to the Assistant Commissioner for
Adjudications, which:
(i) Clearly describes how the regional center focuses on a geographical region of the
United States, and how it will promote economic growth through increased export
sales, improved regional productivity, job creation, and increased domestic capital
investment;

(ii) Provides in verifiable detail how jobs will be created indirectly through increased
exports;

Attachment to lTD Coversheet

95

 U.S. Immigration Fund
Page 4 of 8

NJ Regional Center I RCW1236250925/ ID1236250925

(iii) Provides a detailed statement regarding the amount and source of capital which
has been committed to the regional center, as well as a description of the promotional
efforts taken and planned by the sponsors of the regional center;
(iv) Contains a detailed prediction regarding the manner in which the regional center
will have a positive impact on the regional or national economy in general as reflected
by such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the
regional center; and
(v) Is supported by economically or statistically valid forecasting tools, including, but
not limited to, feasibility studies, analyses of foreign and domestic markets for the
goods or services to be exported, and/ or multiplier tables.

(4)

***

(5) Decision to participate in the Immigrant Investor Program. The Assistant
Commissioner for Adjudications shall notify the regional center of his or her decision on
the request for approval to participate in the Immigrant Investor Program, and, if the
petition is denied, of the reasons for the denial and of the regional center's right of appeal
to the Associate Commissioner for Examinations. Notification of denial and appeal rights,
and the procedure for appeal shall be the same as those contained in 8 CFR 10 3. 3.
In reviewing this application, USCIS has to determine whether the request for regional center designation
has met all of the regulatory criteria and thereby will maintain a regional center within which aliens
seeking to obtain permanent resident status under section 203(b)(5) of the Act will be able to successfully
establish a new commercial enterprise (as described in 8 CFR § 204.6(h)) with the qualifying investment
that will benefit the United States economy and create 10 full-time jobs, including jobs indirectly created
through the new commercial enterprise.

III. Issues
A. Issue 1: The applicant was requested to provide a detailed and itemized construction timeline
and transparent, objective and verifiable data.
The applicant submitted a letter from Sam Gershwin, the president of Westminster Communities
and the person responsible for all the project's construction-related activities. The letter indicated
that the 26-month construction timeline is reasonable. The letter lists the relevant phases of the
construction effort but does not provide a timeline in detailed and itemized form. Therefore, the
applicant has yet to submit a detailed and itemized construction timeline.

Attachment to lTD Coversheet

96

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
Page 5 of 8

•

This issue will remain unresolved until the applicant submits an itemized construction
timeline showing all relevant phases of the construction effort.

•

The issue will also remain unresolved until the applicant provides transparent, objective,
and verifiable data illustrating that the proposed construction timeline and budget are
within a reasonable range when compared to industry standards.

B. Issue 2: The applicant was requested to clarify specific unresolved issues in the Impact
Analysis.

The applicant solicited the expertise of Evans, Carroll, and Associates (Evans-Carroll) to conduct the
economic impact analysis. Evans-Carroll calculates the potential economic impacts of the
construction expenditures (hard and soft) and the leasing operations of the apartment building.
Economic Impact Model Used (IMPLAN. RIMS II REDYN. etc.)
. RIMS II calibrated for the following counties in the State of New Jersey: Hudson, Essex, Union,
Bergen, Passaic, Morris, Monmouth, and Middlesex.
(b)(4)
Model Inputs (initial change in final demand. initial change in direct jobs. etc.)

o4

I

1. Hard Construction: Evans-Carroll uses a hard construction expenditure estimate
as a
final demand input into RIMS II.
a. Transparency: The parameters are based on a construction budget prepared by the Kushner
Companies-the project developer-and the KABR Group-a real estate holding company.
However, the construction cost budget presented on page 3 7 of the economic impact analysis
is illegible. The applicant must provide a legible construction cost budget that is detailed and
itemized.
b. Applicability: The parameters are applicable to the project. Please note, however, that the
applicant does not provide a verifiable, detailed, and itemized construction cost timeline (see
Issue 1, above). Thus, the applicant may only take credit for the indirect and induced jobs
resulting from the hard construction expenditures.
c. Reliability: The construction cost budget is verified by Sam Gershwin, the president of
Westminster Communities and person responsible for the construction of the project. Thus,
the parameters are reliable.
d. Up-to-Date: The parameters are up-to-date.
•

Issues a. and b. remain unresolved.

2. Soft Construction Costs: Evans-Carroll uses the following soft construction expenditures estimates as
final demand inputs into RIMS II:
Category

FF&E

Expenditure Estimate

(b)(4)

Architectural and Engineering Services

Attachment to lTD Coversheet

97

 U.S. Immigration Fund~ N] Regional Center I RCW1236250925/ ID1236250925
Page 6 of 8

a.

Transparency: The parameters are based on a construction budget prepared by the Kushner
Companies, the project developer and the KABR Group, a real estate holding company.
However, the construction cost budget presented on page 37 of the economic impact analysis
is illegible. The applicant must provide a legible construction cost budget that is detailed and
itemized.
b. Applicability: The parameters are applicable to the project.
c. Reliability: The parameters are verified by the construction manager and are reliable.
d. Up-to-Date: The parameters are up-to-date.
(b)(4)
•

Issue a. remains unresolved

3. Leasing Operations: Evans-Carroll calculates a rental income estimate of t
Ifor the first
year of operations and uses this estimate as a final demand input into RIMS II.
a. Transparency: The rental income estimate is based on a detailed and itemized pro forma
financial statement provided by the Kushner Companies and the KABR Group. Thus, the
parameters are transparent.
b. Applicability: The parameters are not fully applicable because the rental income estimate
includes parking revenue. It is not an acceptable methodology to include revenue derived
from parking operations because parking operations do not pertain to real estate leasing
activities.
c. Reliability: The parameters are reliable.
d. Up-to-Date: The parameters are up-to-date.
•

Issue b. remains unresolved.

The taple below presents a summary of the critical assumptions used to derive the model inputs.

NAICS Code
2361/2362

Result/Model
Input

Critical Assumption Used
Hard Construction cost expenditure estimate is based on the
developer's construction cost bud2et.
(a) Rental revenue estimate
developer's pro forma
(b) Deflated to 2008 dollar terms.

(b)(4)

oq

53111

lbased on the

5413

Soft construction cost estimates are based on the developer's

Not Provided

construction cost budget

Multiplier(s) Used (Direct Emplovment. Direct Effect Earnings. Final Demand Output. etc.) and Analysis of
Application of Multiplier
The results of the analysis are summarized in the table below.

Activity

NAICS Code

Construction

2361/2362

Input

I

RIMS II

Total

Multiplier

Jobs

(b)(4)

I

Attachment to lTD Coversheet

98

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
Page 7 of 8

(b)(4)

I

Soft Costs:
FF&E

Not Provided

Architectural and Engineering Services

5413

Rental Income Operations

I

I

53111

Total
*Indirect and induced jobs only

It appears that RIMS II is used in an inappropriate manner. It is not an acceptable methodology to include
revenue derived from parking operations because parking operations do not pertain to real estate leasing
activities.
•

Please calculate employment impacts from parking operations separately using the
appropriate industry multiplier.

•

Please provide the NAICS industry code pertaining to FF&E expenditures.

IV. Decision
This notice serves as notification of USCIS' intention to deny the applicant's request for designation as a
regional center as the Form I-924 does not meet the regulatory requirements at 8 C.P.R. § 204.6(m)(3).
Therefore, the applicant is afforded thirty (30) days from the date of this notice to submit additional
infor~ation, evidence or arguments in support of the application. Additionally, when USCIS serves a
notice by mail, three (3) days are added to the prescribed period in which to respond. See 8 C.P.R.
103.5a(b). Any response to this notice should include a detailed analysis that rebuts the grounds for denial
raised above, corroborated by credible independent documentary evidence all of which will be considered
before a decision is rendered.

V. Review Board Option
Pursuant to 8 C.F.R § 103.2(b)(9), USCIS has the authority to request the applicant's appearance for either
an in-person interview at the California Service Center (CSC) or a telephonic interview. Should the
applicant prefer an in-person or telephonic interview, please indicate as such in response to this notice of
intent to deny.
However, be advised that USCIS will need to review any additional information, evidence, or arguments
the applicant wishes to submit in support of the application before a review board may be scheduled.
Upon review of the applicant's response, the applicant will then be contacted via the USCIS Immigrant
Investor Program mailbox at USCIS.ImmigrantlnvestorProgram@uscis.dhs.gov for further instructions
regarding the time and date of the interview.

Attachment to lTD Coversheet

99

 U.S. Immigration Fund- NJ Regional Center I RCW1236250925/ ID1236250925
Page 8 of 8

The interview will last approximately 60 minutes. During this time, the applicant will be given the
opportunity to present additional information regarding the pending case. The CSC will issue a written
decision at a later date, after full consideration of the written record and statements made during the
interview.
Failure to respond to this notice of intent to deny will result in the denial of the application based on the
above stated reasons.

Attachment to lTD Coversheet

100

 Department ofHomeland ~ecu::.•.
U.S. Citizenship and ~igration SerVices

Ignacio A Donoso
FosterQuan, .LLP
Re: U. S.IMMIGR.ATION Ft.JN]).NJ
600 Travis St., Suite 1000
Houston, TX 77002

RETURN TBI~ NOTI<;E ()NTO~b~ ~ REQUJtSIEJ);;INF9Rl\IA'tiON.
LISTED ON THE ATTACHED SHEET.
ote: You are .given until
M~I
address at the bottom of this notice;.·

I~·; 20f3

.

in whieh to ~libntit the ~nested blformition id

Please note the recruired .~eadlinefor providing a ~on~~ to thi~·~eq#e~t.f()r Evj~~nc~. ~e ~~1~e
reflects the maximum period for respo~dingto this RFE. >Ht:)wev~, since;rtlany bp~igrati~~,benefits
time sensitive, you are encouraged to respond to this request as ectrtY as possiblebut no la~{31' than the ·
provided on the requ~t.

are

Pm·smnJt to 8 C.F.R..lO~.Z(b)(ll) failure to submit ALL evidence reqpested at qpe time mayres~lt in
denial of your application~

:For more information, visit our website at
Or call us at
.,.

WWW:.tiSCis.gov

1-800-375-5283

elepbone service for the hearillgi~paired: t.aoo-7~7-l833
CSC4639 WS25097 DIV m MP

101

 U5. Immigration Fund- N] I RCW 1236250925 I ID1236250925
2.

A request for initial designation as a Regional Center under the Immigrant Investor Program ("Program")
or an amendment to an existing Regional Center designation, may involve:
1. A request for review of an exemplar Form I-526, Immigrant Petition by Alien Entrepreneur, prior
to the filing of Form I-52 6 petitions by individual alien entrepreneurs with USCIS and/ or;
2. In the case of a Regional Center amendment request, a review of a new spcciflc capital investment
project where the Regional Center designation involved a review of an exemplar capital
investment project.
lt appears that the applicant is requesting initial designation as a Regional Center under the Program.
I. Background:

The proposed Regional Center entity, U.S. Immigration Fund · · · NJ, IJ.C (USI:FNJ), was established on
December 7, 20 12 in the state of New Jersey, and is structured as a Limited Liability Company. USIFNJ is
requesting jurisdiction over a geographic area within the State of New Jersey, including the following
counties: Bergen, Essex, Hudson, Middlesex, Monmouth, Morris, Passaic and Union Counties. USIFNJ
plans to offer EB-5 capital investment opportunities in affiliated new commercial enterprises, organized as
Limited Partnerships and focusing on projects in the following industry categories:

Building

Valid?

Applicable?

Yes

construction of the mixed-use residential and

Yes, this NAICS code applies to the hard
retail L1 cili~¥.

2361

5313

S413

Yes, this NAICS code applies to the hard

Residential
Construction

Yes

Real Estate Property Mana~!ers

Yes

Architectural,

En)!ill(~erin)!,

Related Services

Yes

construction of the mixed-use residential and

retail facilit
Yes, this NAICS code applies to leasing and
management operations of the mixed-usc
residential and
construction of the mixed"use residential

retail

capital investment projects will involve a combination of an equity investment and loan to job
creating enterprises located within the proposed bounds of the Regional Center.
The applicant's proposed project, 88 Morgan Street Funding, LLC, involves the construction and operations
of a 50-story luxury rental apartment building in Jersey City, Hudson County, New Jersey. The project will

ATTACFiMEN'l' TO 1797

102

 U.S. Immigration Fund
Page 3

(b)(4)

NJ I RCW!236250925 I ID123625092.5

0

consist of 417 rental apartment units, 217 parking spaces, and approximately 4,000 square feet of retail
space adjacent to Tn;mp Plaza I. The applicm t estimates that the project will
Jof which
be fromOmmigrant investors, and generate approximate]
'obs.

I

lwill

(b)(4)
II. Evidentiary Requirements for Regional Center Proposals

8 CFR 204.6 (m) (3), which is appended to this notice, describes the evidence that must be submitted in
support of a Regional Center proposal. After review of the proposal, the following information, evidence
and/ or clariflcation is required. Note that in response to this notice, that it is helpful to provide a cover
lcuer that acts as an executive summary, followed by a table of contents with sections that are tabbed at the
bottom of the page.
A. Construction Timeline

The applicant asserts that construction will span 26 months, beginning with excavation in February or
March, 2013 and ending with the acquisition of a temporary certificate of occupancy in April 2015.
However, the timeline lacks verifiable detail.
•

Please present a detailed and itemized construction timeline showing all relevant phases of the
construction dTort.

•

Also, please provide transparent, objective, and verifiable data illustrating that the proposed
construction limeline and budget are within a reasonable range when compared to industry
standards.

B. Economic ImpaJ:t Analysis.
applicant solicited the expertise of Evans, Carroll & Associates (Evans-Carroll) to conduct the economic
impact analysis. Evans-Carroll calculates the potential economic impacts of the construction and operations
of a 417-unit luxury apartment tower in Jersey City, Hudson County, New Jersey.
The Economic Impact Model used is RIMS II calibrated for the counties of Hudson, Essex, Union, Bergen,

Passaic, Morris, Monmomh, and Middlesex.
Model Inputs (initial change in final demand, initial change in direct jobs, etc.) are as follows:

(b)(4)

lin

l . Hard Construction: Evans-Carroll usesl
estimated hard construction costs from the pro
forma financial section of the business p.lan as an input into the RIMS II model.
a. Transparency: The parameters are transparent. They are clearly sourced from the pro fonna
financial section of the business plan.
b. Applicability: The parameters are not applicable. The hard construction costs are inflated due to
the inclusion of contingency costs and police fees.

ATTACHMENT TO 1797

103

 U.S. Immigration Fund- NJ I RCW1236250925 I !D12362.50925
Page 4

c.

Reliability: The parameters are not reliable. They are not supported by verifiable data and
analysis or a comparison to industry standards.
d. Up-to-Date: The parameters appear up-to-date.

(b)(4)
2.

•

Please resolve Issues b. and c.

tn

F~&E: Evans-Carrollusesl
estimated FF&E costs from the pro forma financial section
of rhe business plan as an mpul mto the RIMS II model
a. Transparency: The parameters are transparent. They are clearly sourced from tbe pro f(.>rma
flnancial section of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are not reliable. They are not supported by veri.fiable data and
analysis or a comparison to industry standards.
d. Up-to-Date: The parameters appear up-to-date.
(b)(4)

•

Please resolve Issue c.

I

lin

3. Operations: Evans-Carroll uses
estimated annual apartment rental income from the
pro forma flnancial section of the business plan costs as an input into the RIMS II model
a. Transparency: The parameters are transparent. They are clearly sourced from the market
analysis and pro forma financial section of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are reliable. The market analysis presents competing developments
that substantiate most of the revenue assumptions used in the analysis.
d. Up-to-Date: The parameters appear up-to-date. (b)(4)
4.

Soft Construction: Evans-Carroll use4
~n estimated soft construction costs from the pro
forma flnancial section of the business plan as an input into the RIMS II model
a. Transparency: The parameters are transparent. They are dearly soun;ed from the pro forma
financial secti.on of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are not reliable. They are not supported by verifiable data and
analysis or a comparison to industry standards.

d. Up-to-Date: The parameters appear up to·date.
•

Please resolve Issue c.

III. General issues

Translations:

Any dtH:;ument containing a foreign language submitted to users shall be accompanied by a full English
translation that the translator has certif1ed as complete and accurate, and by the translator's certification that
he or she is competent to translate from the foreign language into English.

,\TTACHM!:NTTO I· 797

104

 U.S. Immigration Fund
Page 5

NJ I RCW123625092 5 I ID 1236250925

Copies:
Unless specifically required that an original document be filed with an application or petition, an ordinary
legible photocopy may be submitted. Original documents submitted when not required will remain part of
the record, even if the submission was not required.

NOTES:
Any document submitted to the USCIS containing a foreign language, must be accomponied by o full English Jan9uage translation thut
hns been certified by the translator as complete and accurate, und thut the translawr is competent to translate from the foreign language
into English. Submit dear and leaible copies of all requested evidence. If dear and legible copies are not possible, submit the original
documents. These origindls will be returned, if requested.
P!ense provide an index of any submitted evidence and include corresponding tabs for each section of evidence.

IV. Regulatory References
The regulation at 8 CFR 103.2(a)(3) provides the following deflnitions:
(3) Representation. An applicant or petitioner may be represented by an attorney in the United States,
as dcf1ned in l.l(f) of this chapter, by an attorney outside the United States as ddined in 292.J(a)(6)
of this chapter, or by an accredited representative as defined in 292.1 (a) (4) of this chapter. A
beneficiary of a petition is not a recognized party in such a proceeding. An application or petition
presented in person by someone who is not the applicant or petitioner, or his or her representati.ve as
deflned in this paragraph, shall be treated as if received through the mail, and the person advised that
the applicant or petitioner, and his or her representative, will be notif1ed of the decision. Where a
notice of representation is submitted that is not properly signed, the application or petition will he
processed as if the notice had not been submitted.

The regulation at 8 CFR 204.6(e) provides the following definitions:
Qualifying employee means a United States citizen, a lawfully admitted permanent resident, or
immigr;mt lawfully authorized to be employed in the United States including, but not limited
conditional resident, a temporary resident, an asylee, a refugee, or an alien remaining in the United
under suspension of deportation. This definition does not include the alirm entrepreneur, the
entrepreneur's spouse, sons, or daughters, or any nonimmigrant alien.

other
to, a
States
alien

Regiol'lal center means any economic unit, public or private, which is involved with the promotion of
economic growth, including increased export sales, improved regional productivity, job creation, and
increased domestic capital investment.
The regulation at 8 CFR 204.6(j)(4)

provides~

X1T;\CHMEN 7 TO 1·797

105

 U.S. Immigration Fund-· NJ I RCW123625092S /JD 1236250925
Page 6

cn~ation

--

(i) GeneraL To show that a new commercial enterprise will create not fewer than ten ( 10) full-time
positions for qualifying employees, the petition must be accompanied by:
(A) Documentation consisting of photocopies of relevant tax records, Form I 9. or other similar documents
for ten ( 10) qualifying employees, if such employees have already been hired following the establishment
of the new commercial enterprise; or

(B) A copy of a comprehensive business plan showing that, due to the nature and projected size of the new
commercial enterprise, the need for not h~wer than ten ( 10) qualifying emp.loyees will result, including
approximate elates, within the next two years, and when such employees will be hired.
Troubled business. To show that a new commercial enterprise which has been established through a
capital investment in a troubled business meets the statutory employment creation requirement, the
petition must be accompanied by evidence that the number of existing employees is being or will be
maintained at no less than the pre-investment level for a period of at least two years. Photocopies of tax
records, Forms I-9, or other relevant documents for the qualifying employees and a comprehensive
business plan shall be submitted in support of the petition.
(iii) Immigrant Investor Pilot Program, To show that the new commercial enterprise located within a
regional center approved for participation in the Immigrant Investor Pilot Program meets the statutory
employment creation requirement, the petition must be accompanied by evidence that the investment will
create full-time positions for not fewer than 10 persons either directly or indirectly through revenues
generated from increased exports resulting from the Pilot Program. Such evidence may be demonstrated by
reasonable methodologies including those set forth in paragraph (m)(3) of this section.

The regulation at 8 CFR 204.6(m) (1) provides:
( 1) Scope. The Immigrant Investor Pilot Program is established solely pursuant to the provisions of
section 610 of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies

Appropriation Acr, and subject to all conditions and restrictions stipulated in that section. Except as
provided herein, aliens seeking to obtain immigration benefits under this paragraph continue to be
subject to all conditions and restrictions set forth in section 203 (b )(S) of the Act and this section.
The regulation at 8 CFR 204.6(m)(3) provides:
(3) Requirements for regional centers. Each regional center wishing to participate in the Immigrant
Investor Pilot Program shall submit a proposal to the Assistant Commissioner for Adjudications, which:

ATTACHMENT TO H97

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 U.S. Immigration Fund
Page 7

NJ I RCW1236250925 / ID12362S0925

(i) Clearly describes how the regional center focuses on a geographical region of the United States,
and how it wlll promote economic growth through increased export sales, improved regional
productivity, job creation, and increased domestic capi.tal investment;
(H) Provides in verifiable detail how jobs will be created indirectly through increased exports;

(iii) Provides a detailed statement regarding the amount and source of capital which has been
committed to the regional center, as well as a description of the promotional efforts taken and
planned by the sponsors of the regional center;
(iv) Contains a detailed prediction regarding the manner in which the regional center will have a
positive impact on the regional or national economy in general as reflected by such factors as
increased household earnings, greater demand for business services, utilities, maintenance and
repair, and construction both within and without the regional center; and

(v) Is supported by economically or statistically valid forecasting tools, including, but not limited
to, feasibility studies, analyses of foreign and domestic markets f(x the goods or services to be
exported, and/ or multiplier tables.

Note that promoting economic growth through increased export sales is no longer a requirement.
The regulation at 8 CFR 204.6(m)(6) provides:

Tennination of participation of regional centers. To ensure that regional centers continue to meet the
requirements of section 610(a) of the Appropriations Act, a regional center must provide USCIS with
updated information to demonstrate the regional center is continuing to promote economic growth,
improyed regional productivity, job creation, or increased domestic capital investment in the approved
geographic area. Such infmmation must be submitted to USCIS on an annual basis, on a cumulative basis,
and/or as otherwise requested by USCIS, using a fonn designated for this purpose. USCIS will issue a
notice of intent to tem1inate the participation of a regional center in the pilot program if a regional center
fails to submit the required information or upon a detennination that the regional center no longer serves
the purpose of promoting economic growth, including increased export sales, improved regional
productivity, job creation, and increased domestic capital investment. The notice of intent to tenninate
shall be made upon notice to the regional center and shall set forth the reasons for tennination. The
regional center must be provided 30 days from receipt of the notice of intent to terminate to offer
evidence in opposition to the ground or grounds alleged in the notice of intent to tem1inate. If USCIS
determines that the regional center's participation in the Pilot Program should be tenninated, USCIS shall
notify the regional center of the decision and of the reasons for termination. As provided in 8 CFR 103.3,
the regional center may appeal the decision to USClS within 30 days after the service of notice
( 6)

ATTACHMENT TO 1-797

107

 Confidential Information I Attorney-client privileged

!HE

CC>r,·:Fr<EtH~SiVE

600 Travis Street
Suite 2000
Houston, TX 77002
713 229.8733 office
713228.1303fax
www.fosterquan.com

IMMIGRATION LAW FIRM

February 28, 2013
Ms. Rosemary Melville
Director
USCIS -California Service Center
24000 Avila Road, 2nd Floor
Laguna Niguel, California

Via Federal Express
Re:

Response to Request for Evidence on Pending I-924 Application
Regional Center Name:
US Immigration Fund- NJ
Process:
I-924 Application For Original Designation
Receipt No.:
RCW 1236250925
Regional Center I.D.:
123-625-0925
Date Application Filed:
December 21, 2012
EXPEDITED PROCESSING APPROVED

Dear Ms. Melville:
We are immigration counsel to the US Immigration Fund-NJ, LLC ("USIF-NJ"), in
relation to the above-captioned 1-924 Application (RCW 123-625-0925) ("Application").
On February 4, 2013, USCIS notified the USIF-NJ by email that the Application would
be processed with Expedited Processing. Should USC IS approved this Application, investors in
the first project of the USIF-NJ (the 88 Morgan Street project) will shortly begin filing I-526 visa
petitions and we understand that such I-526 visa petitions will similarly be granted expedited
processing.
USF-NJ has reviewed the Request for Evidence issued by U.S. Citizenship &
Immigration Services on February 20, 2013 ("RFE''), in relation to the above captioned
Application.
This letter, its exhibit list and attached Exhibits constitutes the response of the USF-NJ to
the RFE ("RFE Response''). Unless otherwise defined herein, all capitalized terms used in this
RFE Response shall have the same meaning ascribed to them in the Business Plan (as defined
below).
1

108

 Confidential Information I Attorney-client privileged

A.

Timely Filed

The RFE provided USIF-NJ until May 15, 2013 to submit its response. This response,
filed on February 28, 2013, is thus timely filed.

B.

Response to the RFE
Brief Summary ofProject

The initial sample (hypothetical) project of the USIF-NJ is the construction and operation
of a 50-story, 417 unit, luxury residential condominium building at 88 Morgan Street (comer of
Baytown), in Jersey City, Hudson County, New Jersey, with attached parking spaces, amenities
and approximately 4,000 square feet of office space ("88 Morgan Street Project").
Please note that the 88 Morgan Street Project is a replica of the residential tower already
built directly adjacent, and known as the "Trump Plaza I" in Jersey City, New Jersey. Reference
to the residential tower previously built on the contiguous site named "Trump Plaza I" is stated
in the Business Plan at pages 1, 4, 6 (with map) and 38.
Analysis of the RFE
The RFE states two (2) elements in the Application that require additional evidence: (1)
the construction timeline set out in the Business Plan attached at Exhibit 19 of the original
Application ("Business Plan"), and (2) the Economic Impact Analysis conducted by Evans,
Carroll & Associates attached at Exhibit 20 of the original Application ("Economic Analysis").
We analyze each of the requests for additional evidence and provide responses to each
below.
1. Construction Timeline
(a)

RFE on Construction Timeline

The RFE states that the construction timeline as set out in the Business Plan does not
present "verifiable detail" that it will span 26 months, starting with excavation approximately in
February or March of 2013 and ending with the acquisition of a temporary certificate of
occupancy for the building in April of 2015 ("Construction Timeline").
The RFE requests the following documents to be provided in response to the questions
regarding the Construction Timeline:

2

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 Confidential Information I Attorney-client privileged

• "Please present a detailed and itemized construction timeline showing all relevant
phases of the construction effort."
•

(b)

"Also, please provide transparent, objective, and verifiable data illustrating that the
proposed construction tirneline and budget are within a reasonable range when
compared to industry standards."
Response to RFE on Construction Timeline

In response to the RFE regarding the Construction Timeline, USIF-NJ is submitting new
evidence to support the Business Plan originally submitted in the Application. We note that the
Business Plan stated, at page 35, that the Owner of the Property and the Project provided the
Construction Timeline. We also note that the Business Plan, at page 35, included a list of phases
of the 88 Morgan Street Project.
As stated in page 38 of the Business Plan, the Owner is 88 Morgan Street LLC, a joint
venture company owned by some of the most highly regarded developers of apartment buildings
and commercial real estate in New Jersey and New York. The Business Plan reads as follows:
"In February of 2012, the KABR Group and Kushner Companies (the "Ownership")
established a Joint Venture to manage the entitlement, development, and operation of a 50
story rental apartment building, consisting of 417 rental apartments, 217 parking spaces, and
approximately 4,000 sq.ft. of retail space adjacent to Trump Plaza I.
Kushner Companies is a diversified real estate organization headquartered in New York
with extensive experience in the ownership, management, development, and redevelopment
of properties, owning over 13,000 multi-family apartments nationwide. Historically, the
company has developed, acquired and successfully managed over 30,000 apartments, half of
which was sold to AIG in 2007 for $2 billion.
KABR Group is a diversified real estate investment company dedicated to the timely and
opportunistic purchase of real estate assets in the New York metro region. The group
currently owns and operates a diverse portfolio of properties in several states."

We attach in RFE Exhibit 1 background information on the history and business of the
Owner (both as to the Kushner Companies and the KABR Group). The superlative track record
of success of the Kushner Companies and KABR Group is a genuine American success story.
The vast experience of these two companies in the New York and New Jersey residential real
estate development market is un-matched. Together, the Kushner Companies and the KABR
Group have decades of experience in the residential construction industry in New York and New
Jersey, and have several billion dollars worth of completed construction work. The evidence
enclosed in RFE Exhibit 1 from the 2012 Yearly Report of the Kushner Companies confirms that
it alone owns over 2,500,000 square feet of commercial and residential real estate in New York
and New Jersey, and manages over 15,000 apartments (after acquiring over 6,000 residential
apartments in 2012). The affiliated companies of Kushner Companies include Westminster

3

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 Confidential Information I Attorney-client privileged

Capital, Westminster Management, Westminster Communities and Westminster Hotels. The
evidence attached at RFE Exhibit 1 establishes the Owner's long track record of success in the
construction industry and confirms its expertise and knowledge of residential real estate
construction costs in the relevant target market.
We attach in RFE Exhibit 2 a letter dated February 28, 2013, written by Sam Gershwin,
who is the President of Westminster Communities, and is the person responsible for all
construction and construction related activities for the Kushner Companies ("Construction
Manager's Letter"). Mr. Gershwin is a construction management professional with over 35
years of experience in the construction industry in New York and New Jersey. The Construction
Manager's Letter confirms that the Construction Timeline enclosed in RFE Exhibit 1 is accurate
based on the years of experience in comparable construction projects that Mr. Gershwin and the
Owner have completed. Mr. Gershwin states unequivocally in the Developer's Letter as follows:
"I have personally worked on the development of the construction budget for the
88 Morgan Street Project. Based on my experience and knowledge of industry
standards, the construction timeline as set forth in the Business Plan is a
reasonable projection of the time it will take to complete the construction of the
apartment tower and related improvements on the property is consistent with
similar current and past projects completed by The Kushner Companies."
The Construction Manager's Letter continues:
"The relevant phases of construction are as follows and will take approximately
26 months to complete:
•
•
•
•
•
•
•
•

Excavation
Concrete Foundation and Waterproofing
Tower Building Construction begins
Tower Building Construction completed
Roofing and Tower Crane Areas
Interior Finishes
Mechanicals, Electrical, Plumbing and Sprinkler Systems
Punch List and Temporary Certificate of Occupancy items."

These phases are exactly the same as those stated in the Business Plan because they are
standard for developments of the Kushner Companies and part of its know-how for successful
project development.
We further enclose in RFE Exhibit 3 a copy of the "Executive Profile" of Mr. Sam
Gershwin publicly available from the internationally renowned business information provider,
Bloomberg Business Week (businessweek.com), where it confirms his decades of experience
and senior role as President of Westminster Communities, LLC and member of the Board of
Directors of the Kushner Companies.
4

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 Confidential Information I Attorney-client privileged

Based on the evidence already submitted in the Application, and the new evidence
attached to this RFE Response, we believe that USIF-NJ has provided detailed evidence
supported by verifiable information that confirm the accuracy of the Construction Timeline for
the 88 Morgan Street Project.
2. Economic Analysis
(a)

RFE on Economic Analysis

The RFE finds three (3) areas of the Economic Analysis that require additional evidence:

c::J

1. Hard Construction Costs. The RFE states as follows: "Evans, Carroll uses
I
lin estimated hard construction costs from the pro forma financial section of
the business plan as an input into the RIMS II model." The RFE then states two
deficiencies with this amount of estimated hard construction costs. First, they were
"not applicable" because the
hard construction costs included
"contingency costs and police fees". Second, the hard construction costs amount was
not "reliable" because it is "not supported by verifiable data and analysis or a
comparison to industry standards."

I

(b)(4)

(b)(4)

lin

lin

2. FF&E Costs. The amount ofl,.- - -..... estimated FF&E costs from the pro
forma financial section of the Business Plan were considered by USCIS not to be
"reliable" because it is "not supported by verifiable data and analysis or a comparison
to industry standards." (Please Note: "FF&E" means "Furniture, Fixtures &
Equipment").

lin

3. Soft Construction Costs. The amount o~
estimated soft construction
costs from the pro forma financial section of the Business Plan were considered by
USC IS not to be "reliable" because it is "not supported by verifiable data and analysis
or a comparison to industry standards."
(b)

Response to RFE on Economic Analysis

In response to the RFE on the Economic Analysis, we are pleased to attach in RFE
Exhibit 4 a revised Economic Analysis completed by Evans, Carroll & Associates and which is
dated February 28, 2013 ("Revised Economic Analysis").
USIF-NJ has not revised the pro forma for the 88 Morgan Street Project as stated in the
Business Plan. The Revised Economic Analysis does not change the job creation estimates from
the original Economic Analysis dated December 7, 2012, because they original job creation
estimates were accurate and based only on the EB-5 eligible hard construction costs.

5

112

 Confidential Information I Attorney-client privileged

The Revised Economic Analysis includes clarifying text that better explains the figures
used in the calculations. The Revised Economic Analysis is fully responsive to the concerns
raised by USCIS in the RFE. We discuss each of these issues raised by the RFE below.

(b)(4)

1. Hard Construction Costs. The Economic Analysis originally submitted with the
Application did not include in its calculation of job creation impacts the entire
amount of the I
lin hard construction costs. Rather, the Economic
Analysis prepared by Evans, Carroll subtracted the amount of the construction
contingency of I
Iand the amount ofl
lfor Jersey City Police,
from the estimated hard construction costs used in the RIMS II analysis (together
with other hard construction costs not eligible for job creation estimates under the
EB-5 program). This was stated in the original Economic Analysis at various points.
For example, it can be found on Page 3, at the Executive Summary; at page 4, Table
A- "Summary of Employment and Revenue Estimates", and at page 36, at the first
paragraph of Section 8. We cite the literal text of the Economic Analysis at page 36,
Section 8, below:

I

(b)(4)

I

"Table 8-1 shows the total develo ment budget of
of
this a
s EB-5 eli ible hard construction
'*"""'~...__..,._....,.s architectura, engineering, and related fees, and
IS purchases of furniture, fixtures, and equipment (FF&E).
"'r''!:~e""r~e~al~l g [
fconsists primarily of land costs, interest
costs, contingencies, and fees." [emphasis added]
Thus, the Economic Analysis removed from the totaf
lestjmate g'
construction hard costs the a~onnt of the construction contingency ol
)
and the amount od
~or Jersey City Police.
(b)(4)

Dr. Michael Evans, of Evans, Carroll & Associates, prepared the Revised Economic
Analysis, dated February 28, 2013, which confirms that the Economic Analysis did
not include the full estimated amount
Jn hard construction costs. The
revision confirms that the Revised Economic Analysis subtracted the amount of the
construction contingency otl
land the amount
for Jersey City
Police (together with other hard and soft construction costs not eli ible for job
creation estimates under the EB-5 program) from the tota.;.le;,;;s~ti~m;;;;;a;,;;,;;te;.,;o~-~~~
hard construction costs, to arrive at the lower estimate o
~~"""'"'!'-~~
EB-5 hard construction costs. The Revised Economic Analysis now
at page 36, as follows:

o4

I

(b)(4)

I

I

"Table 8-1 shows the total ~evelopment budget of
I Of
this amount, about!
:
lis EB-5 eligible hard construclion rosts.
I
fis architectura , engineering, and related fees, and
I
I is urchases of furniture, fixtures, and equipment (FF&E). The
remaining
consists primaril of land costs, interest costs,
contingencies, an ees. The total o
n EB-5 eli ible hard

I

6

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 Confidential Information I Attorney-client privileged

(b)(4)

2. FF&E Costs. The estimated cost amount for FF&E in the pro forma remains used in
the Revised Economic Analysis. To provide verifiable detail of the FF&E expenses
for the 88 Morgan Street Project, we refer to the Construction Manager's Letter,
which confirms the accuracy of this expenditure amount for FF &E as stated in the pro
forma budget. The Construction Manager's Letter (attached in RFE Exhibit 2)
confirms that the amount of all budget estimates is reasonable, and conforms to both
industry parameters and many years of experience in similar construction projects.
3. Soft Construction Costs. The estimated cost amount for soft construction costs in
the pro forma remains used in the Revised Economic Analysis. To provide verifiable
detail of the soft construction costs expenses for the 88 Morgan Street Project, we
have obtained evidence from the Owner that confirms the accuracy of this
expenditure amount for soft construction costs as stated in the pro forma. The
Construction Manager's Letter attached in RFE Exhibit 2 confirms that the amount
of all budget estimates is reasonable, and conforms to both industry parameters and
the previous projects completed by the Kushner Companies in the recent past.
Further, the USIF-NJ provides the soft cost budget from the architect for the 88
Morgan Street Project, which is attached in RFE Exhibit 5. Please note that the
architect's soft construction costs budget is based on the replica tower "Trump JC"
that is on the same site neighboring the 88 Morgan Street Project. The architect goes
so far as to note that "full release will be given from original architect to use plans".
Reference to the residential tower previously built on the contiguous site named
"Trump Plaza I" is stated in the Business Plan at pages 1, 4, 6 (with map) and 38.
Thus, USIF-NJ has provided an Economic Analysis and new and detailed documentary
evidence with this RFE Response that, together with the evidence in the Application, respond
completely to the issues raised by USCIS in the RFE regarding the Economic Analysis.

C.

Conclusion and Requested Action

The above information and attached evidence, together with the evidence set out in the
Application, addresses all of the issues raised in the RFE. The new evidence submitted with this
RFE Response is probative, verifiable and detailed, and clearly explains that USIF-NJ has
satisfied its evidentiary burden in this I-924 application for original regional center designation.

7

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 Confidential information I Attorney-client privileged

We trust that USCIS will find the foregoing analysis and evidence in order, and we look
forward to your favorable adjudication of this I-924 Application. We thank you in advance for
your consideration of this RFE Response.
Should there be any questions or should USCIS require additional information, please do
not hesitate to contact me at (713)335-3993 or by email at idonoso@fostcrquan.com.

Sincerely,
FOSTERQUAN, LLP

\

Ignacio A. Donoso
Partner

cc:

Nicholas Mastroianni, II
Mark Giresi

8

115

 Confidential Information I Attorney-client privileged

Exhibit List to Request For Evidence

1-924 Application
U.S. Immigration Fund- NJ
DOCUMENT

TAB No.

Background evidence regarding the superlative business experience and
lengthy track record of success of the Kushner Companies and KARB Group,
the two companies that are Owners of the 88 Morgan Street Project through
their affiliate, 88 Morgan Street, LLC.

1.

Letter dated February 28, 2013, from Sam Gershwin, President of
Westminster Communities, the affiliate of Kushner Companies, and a real
estate construction professional with over 35 years of experience.

2.

Executive Profile of Mr. Sam Gershwin from Bloomberg Business Week
(businessweek.com) dated March 1, 2013.

3.

Revised Economic Analysis prepared by Evans, Carroll & Associates for the
88 Morgan Street Project dated February 28, 2013.

4.

Architect's Soft Construction Cost Budget for 88 Morgan Street Project

5.

9

116

 1-924 Application- US Immigration Fund-NJ
Response to RFE
RCW 1236250925

DOCUMENT
Background evidence regarding the superlative business experience and
lengthy track record of success of the Kushner Companies and KARB Group,
the two companies that are Owners of the 88 Morgan Street Project through
their affiliate, 88 Morgan Street, LLC.

TAB No.
1.

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LETTER FROM THE PRESIDENT
Kl;:)lf:t:r· Cumpanies is a diversified mal tJst.at.e or·rpnization hrmdquartered in New
York

City. Our" Company rs responsible tor the ownership. rnanagernent, development

Ctw national reach r.ons1sts of rnor'e
;.:•CJ,OOO rnultifnrnily apartments. as well as 8 rnillion sq1mrn fm't of office.
:t•:I:J::xrral and retail space throughout New York, New Jersey. Pennsylvania,
!\!l<wvland, Cltlio and Illinois.
;·ii'rl n.:develuprmmt of nurnemus pmperties.

;) was <3nothrlr busy year·. We Acquir·ed over· $1 billion of pr·operties in adriitron

:>ir.J:,in£1 sorne record-breaking leases. In conjunction with our' partners, we also
portron of our 666 Frfth Avenue retail for more than $700 million. We are

w1th ou1' str·ategic and rneasur·ed growth and plan to continue to rnake
<>cr!u::,it.ions as the rnarket pr·os<~nt.s opportuniticlt>
cornpany remains [JUided by its tJxperienctJ and ability to emote long-term value
,.;: r'Eitcqically focused markets. We continue to attract the best talent in the
and remain focused on gmwing our or·gi:mizatiun with talented professionals
·.rvith our assets. I am plt1ased to rrJport t,hat Kushner Companies is str·on[Jer
and we stand poised for continusd gr'owth with our· valued partners.

,Jar·ed Kushner
President and CEO

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 A . . . 
h/MW/gw mam/avg/mag . ..27Kushner Companies, LLC: Private Company Inform

. - Businessweek

3/l/13 3:05AM

March 01, 2013 3:03AM ET

Real Estate Management and Development
Company Overview of Kushner Companies, LLC
People

Company Overview

Key Executives For Kushner Companies, LLC

Kushner Companies, LLC, a diversified real estate
Mr. Charles Ramat
Chie Executive Officer and President
company, engages in the ownership, management,
development, and redevelopment of multifamily
apartments, as well as office, industrial, and retail
Mr. Jeffrey Freireich
Vice
Chairman
spaces in New York, New Jersey, Pennsylvania, and
Illinois. Its management services include scrutinizing
Mr. Richard Stadtmauer
marketing, pricing, tenant relations, amenities, and
Vice Chairman
maintenance issues for property operations; and
development services include purchasing raw land,
Mr. Charles F. McClafferty
and developing commercial and residential
Chief Financial Officer
properties. The company also engages in
acquisitions by executing joint ventures with various
Mr. Sam M. Gershwin
Director and President of Westminster Communities
institutional partners; leasing activities through a
LLC
tenant base and a broker network to deal with
brokers, bankers, and contractors for commercial real Compensation as of Fiscal Year 2012.
estate operations; and finance activities. In addition, it
constructs single-family housings, multifamily
complexes, active adult communities, commercial
office buildings, and urban shopping centers.
Kushner Companies, LLC was founded in 1954 and
is based in New York, New York.
Hide Detailed Description

666 Fifth Avenue
New York, NY 10103
United States

Phone: 212-527-7000
Fax:
212-527-7007
www.kushnercompanies.com

Founded in 1954

From Around the Web

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byTaboola

Page 1 of 2

142

 Kushner Companies, LLC: Private Company Inform~,

- Businessweek

3/1/13 3:05AM

Kushner Companies, LLC Key Developments

Kushner Companies, LLC Presents at CRE's Inaugural Gold Coast Investment Summit,
Feb-26-2013
Feb 6 13

Kushner Companies, LLC Presents at CRE's Inaugural Gold Coast Investment Summit, Feb-26-2013. Venue:
Maritime Pare, Jersey City, New Jersey, United States. Presentation Date & Speakers: Feb-26-2013, Darin
Raiken, Director of Acquisitions, James Block, Director of Finance.

CIT Group Inc. Provides Financing for Kushner Companies, LLC
Jan 14 13

CIT Group Inc. announced that CIT Real Estate Finance arranged a first lien term loan for Kushner
Companies, LLC. The financing will be used to renovate a 1,000-unit residential apartment complex in the
Northeast. Financing was provided by CIT Bank, the U.S. commercial bank subsidiary of CIT. Terms of the
transaction were not disclosed.

Kushner And Rockpoint Reportedly To Acquire 10 Maryland Apartment Complexes
Aug 7 12

Kushner Companies, LLC and Rockpoint Group, L.L.C. are buying 10 Maryland apartment complexes in a
transaction valued at $500 million, GlobeSt.com reports.

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http·// i nvesti ng.businessweek.com{research/ stocks/private/snapshot.asp?privcapld;6 76216

Page

2 of 2

143

 Home

2/28/13 3:53 PM

Building Opportunity
THE KABR GROUP is dedicated to the opportunistic purchase of select real estate assets.
Throughout the past several years, the company has been extremely active in acquiring value-add
properties
Learn more>

http

1/kabrgroup.com/

Page 1 of 1

144

 The Kabr Group

2128113 3:54PM

The KABR Group
The KABR Group was founded by Kenneth Pasternak, Laurence Rappaport, and Adam Altman in
2008. They are experienced real estate professionals and entrepreneurs who have a successful
and proven track record as owners and operators of Real Estate.
Headquartered in Ridgefield Park, NJ, the first two funds sponsored by the KABR Group raised
approximately $45,000.000 each, of which in excess of 50% of the monies raised was equity
contributed by the sponsor. The initial fund was launched at the end of 2008 as a response to the
impending real estate crisis.
OUR TEAM>
The KABR Group has opportunistically acqUired select real estate assets througt1 the market cycle
bottom. It has achieved success from its ability to identify, purchase and manage properties from
highly motivated sellers at discounts to their intrinsic value. KABR targets returns in excess of 18%.
Unencumbered by the typical "market peak" purchases, KABR employs a fresh balance sheet to
acquire and work through distressed, mismanaged and over-leveraged properties.
KABR is expected to raise its third fund in 2013. For more information, please email us at
info@kabrgroup.com.

http •11kabrgro up.com 1index. php Icompany lthe-kabr-group

Page 1 of 1

145

 KENNETH PASTERNAK

2128113 3:55PM

KENNETH PASTERNAK
CHAIRMAN OF KABR INVESTMENT COMMITTEE
Mr. Pasternak has over 25 years of experience investing in real estate. The Pasternak Family Office
currently owns and/or operates approximately $100 million worth of real estate assets.
Mr. Pasternak began his career at Spear, Leeds & Kellogg in 1979 and eventually became the head

of all capital markets. In 1995, Mr. Pasternak co-founded Knight Trading Group. a publicly traded
multi-billion dollar financial services company. Mr. Pasternak served as Knight"s Chairman and

NEWS>

CEO from its founding through 2002. While there, Mr. Pasternak engaged in more than $1 billion of
capital transactions and managed a $5 billion balance sheet. Under his leadership, Knight"s market
capitalization exceeded $5 billion. After retiring from Knight Trading Group, Mr. Pasternak founded
Chestnut Ridge Capital, LLC, a Northern New Jersey family office with over $300 million in assets
under management.
KABR was formed in 2008 when Mr. Pasternak conducted a capital raise among family and friends.
In addition to serving on the boards of publicly traded as well as private institutions, Mr. Pasternak is
currently serving as the Chairman of the KABR Company. Mr. Pasternak is also a General Partner
in the development of the Belleayre Resort in upstate New York, a two hotel, 1,400 acre resort with
over 1 million square feet of planned construction.
For more information, please visit: http 1/en.wikiped;a.org/wiki/Kenneth_Pasternak

KENNETH PASTERNAK I LAURENCE RAPPAPORT I ADAM ALTMAN

http •1I kabrg roup.com I index. php I company I ou r-tearn I it ern I 108- ken neth-pasternak

Page 1 of 1

146

 LAURENCE RAPPAPORT

2/28/13 3:55PM

LAURENCE RAPPAPORT
CHIEF EXECUTIVE OFFICER
Laurence J. Rappaport, Esq., has over 25 years of experience as an owner, developer and
practicing lawyer. As early as 1979, Mr. Rappaport purchased. rehabilitated and sold approximately
18 apartments buildings in Hoboken, New Jersey.
Later he obtained approvals for, developed, constructed and/or sold in excess of 600,000 square
feet of shopping centers, apartments, office buildings and industrial facilities, as well as developed,

NEWS>

built and operated manufactured home communities, townhouse communities and single family
sub-divisions.
Over the last two decades, Mr. Rappaport has also served as legal counsel to numerous
developers, managers and investors involved in real estate transactions and operations. Currently,
Mr. Rappaport owns and manages approximately 500 residential units in the New York/New Jersey
area as well as significant office and industrial assets totaling over 250,000 square feet.
Additionally, Mr. Rappaport is developing an industrial park in East Windsor, New Jersey, which will
consist of 225,000 square feet of flex office/warehouse space.

KENNETH PASTERNAK I LAURENCE RAPPAPORT I ADAM ALTMAN

http

11 kabrgroup.com/index.php Icompany /our-team/item/ 109-laurence-rappaport

Page 1 of 1

147

 2128113 3:56PM

ADAM ALTMAN

ADAM ALTMAN
MANAGING DIRECTOR
Mr. Altman is a real estate investor and entrepreneur with over 10 years of experience on both the
buy and sell-side of the business.
Before joining KABR. Mr. Altman was a senior member of the Acquisitions and Development group
for a multi-billion healthcare company. In that capacity, Altman managed and sold troubled assets
within the firm"s real estate portfolio and identified real estate sites on which to build and operate

NEWS>

healthcare facilities.
Mr. Altman also served as a portfolio manager and analyst for Chestnut Ridge Capital and the
Pasternak Family Office.

KENNETH PASTERNAK

I LAURENCE RAPPAPORT I ADAM ALTMAN

http: II kabrgrou p.com 1i ndex.php I company I our-team /item I 110-adam-altman

Page 1 of 1

148

 Portfolio

2/28/13 3:58PM

ALL

NEW JERSEY

NEW YORK

FLORIDA

191:\ ROUTE 9N

207-5 UNION STREET

2263 MORRIS AVENUE

OTHER

MANALAPAN, NJ

JERSEY CITY, NJ

BRONX, NY

40,000 square foot building includes onsite

16 Unit apartment rental building located in

parking, newly renovated lobby, upgraded

Jersey City, NJ

32 Unit apartment rental building located at
2263 Morris Avenue in the Bronx, NY

2342 RYER A VENUE

3 ADP BOULEVARD

30 JOURNAL SQUARE

BRONX, NY

32 Unit apartment rental building located at

ROSELAND, NJ
Four-story office building on 5 acres located in

JERSEY CITY, NJ
KABR along with Kushner Companies acquired

2342 Ryer Avenue in the Bronx, NY

the highly desirable Roseland sub-market. The

historical Jersey Journal building located one

building is approximately 77,000 RSF

block from the Journal Square PATH station.

bathrooms and new building conference room.

http/ I kabrgroup.com/index.php/ gallery

Page 1 of 4

149

 Portfolio

2/28/13 3:58PM

3131 APPLING ROAD

3210 RIVERDALE AVENUE

330, 350. 352 MOTOR PARKWAY

BARTLETT, TN

BRONX, NY

HAUPPAUGE, NY

The facility consist of 263,000 square feet
warehouse and offices.

3210 Riverdale Avenue, Bronx NY is a high-end
residential property which is located in the
desirable Riverdale section of the Bronx.

amenities include on-site cafe, a bank branch,
24/7 access, and ample parking.

-165 COLUMBUS AVE

535 CONNECTICUT AVE

55 CHALLENGER ROAD

currently used as assembly, distribution,

130,000 square foot office building, property

VALHALLA, NY

NORWALK, CT

RIDGEFIELD PARK, NJ

Located on Columbus Ave in Valhalla, NY the

The 175,000 square foot, class A suburban

KABR along with Kushner Companies acquired

building is setback and secluded from the

office building is newly renovated and located

the debt collateralized by 55 Challenger Road in

normal noise and congestion of an office park.

directly off of 1-95, offering excellent visibility.

Ridgefield Park, NJ.

611 ROUTE 46

7 BECKER FARM ROAD

85 CHALLENGER ROAD

HASBROUCK HEIGHTS, NJ

ROSELAND, NJ

RIDGEFIELD PARK, NJ

611 Route 46 is a 138,000 square foot Class B

Four-story office building on 5 acres located in

office building purchased by KABR in 2009.

the highly desirable Roseland sub-market The
building features include full service cafe ...

85 Challenger Road is a 235,000 square foot
Class A office building purchased by KABR in

ALLWOOD ATRIUM
http 1/kabrgroup.com/index.php/gallery

ARLINGTON APPARTMENTS

2009.

BAY STREET DEVELOPMENT
Page 2 of 4

150

 Portfolio

2/28/13 3:58PM
CLIFTON,NJ

JACKSONVILLE, FL

The All wood Atrium consist of two newly

KABR II purchased the 220+ residential units

In 2011, The KABR Group acquired the land

renovated 1st class four story office buildings

comprise a gated community in the Jacksonville

and development rights to the 2nd phase of the

with 17,200 SF per floor.

area.

Trump Jersey City complex.

FRANKLIN AVE PLAZA

LIVINGSTON SHOPPING
CENTER

MOLJNT' PROSPECT TOWERS

GARDEN CITY, NY

JERSEY CITY, NJ

NEWARK, NJ

Franklin Avenue Plaza, located in Garden City,

LIVINGSTON, NJ

Located at 380 and 402 Mt. Prospect Avenue.

NY, consists offour Class A office buildings,

The 120,000 square feet center is a 2 big-box-

Beautifully renovated spaceous apartments in

store strip mall that enjoys a privileged location

two vintage Forest Hill high-rise towers.

together with structured parking.

in one of the main corridors of the area.

PARK AT BOULDERCREST

TANGLEWOOD

THE PARK AT CHANDLER

ATLANTA, GA

WAREN ROBING, GA
Tanglewood- 159 unit Garden Style Apartment
community located in Warner Robbins, GA. For
leasing information

DECATUR,GA
Park at Candler- 275 unit Garden Style
Apartment communitv located at the erimeter
intersection of
A
•kalb.

Park at Bouldercrest 288 unit Garden Style
Apartment community located at the Perimeter
intersection of 1-295 in Dekalb

TOP

WEST CHASE

WILLOW LAKE APARTMENTS

AUSTELL, GA

JACKSONVILLE, FL

http I /kabrgroup.com/index.phpjgallery

Page 3 of 4

151

 2/28/13 3:58PM

Portfolio

West Chase is a 288 unit Garden Style
Apartment community located minutes from the
Perimeter intersection of 1-20 and 1-295.

http: 11 kabrgroup.com /index.php/ gallery

Page 4 of 4

152

 1-924 Application- US Immigration Fund-NJ
Response to RFE
RCW 1236250925

DOCUMENT
Letter dated February 28, 2013, from Sam Gershwin, President of
Westminster Communities, the affiliate of Kushner Companies, and a real
estate construction professional with over 35 years of experience.

TAB No.
2.

153

 Thursday, February 28, 2013
Subject:

88 Morgan Street, Jersey City, New Jersey Project

To Whom It May Concern,
I am President of Westminster Communities, responsible for all construction and constructionM
related activities for Kushner Companies. Kushner Companies is a group of real estate
development and management companies and is engaged in the mixed-use commercial
development project located at 88 Morgan Street, Jersey City, New Jersey (the "Project").
I have worked in multiple capacities over the past 35 years in the field of construction and
construction management. I have personally managed over 100 construction projects totaling
more than $25 Billion in construction costs. I have had management responsibilities for the
creation of commercial construction budgets and the day-to-day management of construction
budgets and activities. I am also responsible for the creation and management of the
construction budget for the 88 Morgan Street Project and am personally involved on a daily
basis with the present design of the construction documents and will be involved on a daily
basis with the overall management of the construction activities for this Project.
I have personally worked on the development of the construction budget for the 88 Morgan
Street Project. Based on my experience and knowledge of industry standards, the construction
timeline as set forth in the Business Plan is a reasonable projection of the time it will take to
complete the construction of the apartment tower and related improvements on the property
is consistent with similar current and past projects completed by Kushner Companies. The
relevant phases of construction are as follows and will take approximately 26 months to
complete:
•
•
•
•
•
•
•
•

Excavation
Concrete Foundation and Waterproofing
Tower Building Construction begins
Tower Building Construction completed
Roofing and Tower Crane Areas
Interior Finishes
Mechanicals, Electrical, Plumbing and Sprinkler Systems
Punch List and Temporary Certificate of Occupancy items

154

 In addition, the "hard construction cost" and the furniture, fixtures, and equipment (11 FF&E")
budgeted amounts are based on the current plans and specifications for the construction.
Those costs are a reasonable projection based on industry standards and my experience on
comparable construction projects. The 11 SOft cosf' amount budgeted for this Project is based
primarily on an agreement between Kushner Companies and its architect. The budget from
that Architectural Agreement is attached to this letter.
Based on my 35 years of experience in the field of construction and construction management
and my review of the construction plans and other available information relative to the
proposed construction of the 88 Morgan Street Project, it is my professional opinion that the
hard cost, soft cost and FF&E budget outlined in the 88 Morgan Street Business Plan is an
accurate projection of the estimated costs to complete the Project.

Sincerely,

Sam Gerswhin
President
Westminster Communities

155

 1-924 Application- US Immigration Fund-NJ
Response to RFE
RCW 1236250925

DOCUMENT
Executive Profile of Mr. Sam Gershwin from Bloomberg Business Week
(businessweek.com) dated March 1, 2013.

TAB No.
3.

156

 Sam Gershwin: Executive Profile & Biography-

Busir~;:.,~week

311113 2:36AM

March 01, 2013 2:35AM ET

Real Estate Management and Development
Company Overview of Kushner Companies, LLC
Snapshot

Overview

Board Members

Committees

Executive Profile

Sam M. Gershwin
Director and President of Westminster Communities LLC, Kushner Companies, LLC

Age

Total Calculated Compensation This person is connected to 1 Board Members in 1 different
organizations across 1 different industries.
See Board Relationships

Background

Sam M. Gershwin serves as President of Westminster Communities LLC, the construction division of
Kushner Companies. For the past 25 years, Mr. Gershwin served as a corporate officer and managing
member of single-asset real estate development companies. Active in his community, Mr. Gershwin has CoChaired the Livingston Township 9/11 Memorial Committee. He serves as Director of Kushner Companies.
He serves as a member of the Board of Governors for Crestmont Country Club and serves on the Board of
Trustees of Temple Beth Shalom in Livingston. He holds a B.S. degree in Civil Engineering from Lafayette
College in Easton, Pennsylvania, and an M.B.A. from Seton Hall University in South Orange, New Jersey.
Collapse Detail

From Around the Web

byTaboola

Corporate Headquarters

Annual Compensation

666 Fifth Avenue
New York, New York 10103

There is no Annual Compensation data available.

United States

Stocks Options

There is no Stock Options data available.
Phone: 212-527-7000

Fax: 212-527-7007
Total Compensation

There is no Total Compensation data available.
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Page 1 of 2

157

 Sam Gershwin: Executive Profile & Biography-

Busi~:~,sweek

3/1/13 2:36AM

Board Members Memberships

Director and President of Westminster
Communities LLC

Kushner Companies, LLC

Education

BS
Lafayette College

MBA
Seton Hall University

Other Affiliations

Lafayette College
Seton Hall University

Businessweek
More About "sam gershwin westminster
communities"

\Vrstminster Dog Show Viewer's Guide:

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Page 2 of 2

158

 1-924 Application- US Immigration Fund-NJ
Response to RFE
RCW 1236250925

DOCUMENT
Revised Economic Analysis prepared by Evans, Carroll & Associates for the
88 Morgan Street Project dated February 28, 2013.

TAB No.
4.

159

 Economic Impact of Developing a Luxury Apartment Building
Located in Jersey City, NJ, for the US Immigration Fund, LLC
and its New EB-5 Regional Center in Northern New Jersey

Prepared for:
The U. S. Immigration Fund

Prepared by:
Michael K. Evans
Evans, Carroll & Associates, Inc.
2785 NW 26th St.
Boca Raton, FL 33434
561-470-9035
mevans@evanscarrollecon.com

February 28, 2013

160

 2

Table of Contents
1. Executive Summary

3

2. Tabulation of Principal Results

4

3. Introduction and Scope of Work

8

4. Brief Introduction to the RIMS II Model and its Multipliers

9

5. Methodology for Calculating Indirect Jobs

12

6. Economic Parameters for 8 Counties in New Jersey

17

7. Location of Hotel, Maps of Area, and TEA Analysis

32

8. Economic Impact of Construction Activity

36

9. Economic Impact of Rental Income

45

10. Summary Statistics for Entire Project

51

Appendix: Resume of Dr. Michael K. Evans

53

161

 3

1. Executive Summary
• The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space.

(b)(4)

• The economic impact results are calculated using the RIMS II input/output model for
the following 8 counties in New Jersey: Hudson, Essex, Union, Bergan, Passaic,
Morris, Monmouth, and Middlesex. These counties are chosen based on commuting
patterns, as explained later in this report.

162

 4

2. Tabulation of Principal Results
Table A shows the annual revenue, the final demand multiplier, and the total
number of jobs created by the construction and operations of the apartment building.
Since the construction will take more than two years, the economic impact figures for
the hard construction costs and appropriate soft costs include direct as well as indirect
and induced jobs. All figures are permanent jobs.
Table A. Summary of Employment and Revenue Estimates

(b)(4)

Table B1 shows the NAICS codes for each type of economic activity.
descriptions are taken from:
http://www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2012

The

Table B1. NAICS Codes for Each Type of Activity
2362 _Nonresidential Building Construction
2361_Residential Building Construction
53111.Lessors of Residential Buildings and Dwellings
5413_Architectural, Engineering, and Related Services

Table B-2 shows the print screen of all the RIMS II multipliers used in this study.
Please note that for purchases of FF&E, the multiplier used is the construction multiplier
excluding direct jobs, calculated as

I

I

(b)(4)

163

 5
Table 82. Print Screen of Multipliers
230000 Construction
531000 Real estate
541300 Architectural, engineering, and related services
812900 Other personal services

(3)
(1) (2)
(4)
(5) (6)
2.0346 0.5600 11.7739 1.1005 1.80511.9882
1.4670 0.2244 13.2613 1.0810 1.9496 1.2985
1.9921 0.5483 10.2148 1.2297 1.8728 2.5874
1.8509 0.3285 9.0272 1.09512.8866 2.7787

Region Definrtion Bergen. NJ; Essex, NJ; Hudson, NJ; Middlesex, NJ; Monmooth, NJ; Morris, NJ; Passaic. NJ; Union, NJ
'Includes Government enterprises.
1 Each ently in column 1 represents the total dollar change in output that occurs mall industries fot each addrt1onal dollar of ou!put delivered to
final dlitmand by the industry corresponding to the 'itntry.
2. Each entry in column 2 represents the total dollar change in earnings of households employed by all mdustries for each additional dollar of
oulput defrvered to final demand by the industly corresponding to the ently.
3. Each entry in column 3 represents the total thange in number of jobs that occurs in all industries lor each addrtional 1 million dollars of oulput
delivered to final demand by the industry corresponding to the entry. Because the employment multipliers are based on 2008 data, the output
delivered to final demand should be in 2008 dollars.
4. Each entry in column 4 represents the total dollar change in value added that octurs 1n all industries for each additional dollar of output
delivered to final demand by the mduslry corresponding to the entry.
5 Each entry in column 5 represents the total dollar change in earnings of households employed by all mdustries for each addational dollar of
eam1ngs paid directly to households employed by the industly correspond in~ to the entry.
6. Each entry in column 6 represents the total change 10 number of jobs in a landustries. for each addiliol\Jl job in U1e industry corresponding to
the entry.
NOTE --Multipliers are based on the 2002 Benchmark Input-Output Table for the Nation and 2008 regioMI data. Industry Us! A identifies the
tndustnes corresponding to the entnes.
SOURCE-Regional Input-Output Modeling System (RIMS II), Regional Product Division, Bureau of Economic Analysis

Table C shows the annual level of household income, and the output for utilities,
maintenance and repair construction, manufacturing output, and professional and
business support services for the construction and operation of the 88 Morgan Street
apartment building.

(b)(4)

Table C. Summary Measures of Economic Impact for Construction and
Rental income of 88 Morgan Street Apartment Building

164

 6

Household Earnings (Labor Income)

The jobs created by the project subsequently create new sources of household
income. The household income created within the re ional center by the construction of
the 88 Morgan Street apartment buildin is about
with another I
I
from the purchases of FF&E and
rom arc 1ectural and engineering
services. Household income would a so nse a outl
from the rental income (b)(4)
of the apartments, for a total of abou1

I

I

The details used to calculate these figures are given throughout the report.
Separate tables are provided for the total number of jobs created, the average earnings
per new worker, and the total increase in earnings for construction and operation of the
hotel. In each case, the RIMS II inpuVoutput model has been used to calculate the
number of jobs in each major industrial classification, the average earnings per
employee, and hence total earnings. The number of jobs by industrial classification is
based on calculations imbedded in the RIMS II model for each of the activities as
summarized in Table A and documented in detail throughout this report.
Demand for Business Services, Utilities, Maintenance and Construction, and New
SupplierNendor Relationships Created with Manufacturers

(b)(4)

The total economic impact of the regional center from the supplier purchases and
business relationshi:s for the construction and operation of the hotel will create
approximately
in additional economic activity across the region for the
project. These supP 1er purchases are calculated from the indirect increase in output
generated by the RIMS II model. It should be noted that some of these supplier
industries might potentially locate within the regional center, and their economic output
is included in this total.

I

I

The estimate of supplier purchases is based on the commodity data in the RIMS
II input-output model. This data specifies the amount and type of commodity input
needed to maintain specific types of business operations. The model estimates the
supplier purchases based on the types of jobs and number of jobs that will be created
within the regional center. In addition, the model allocates the supplier purchases to
businesses within the region, based on trade flow data from the U.S. Bureau of
Economic Analysis.
Utilities include services such as electricity, natural gas, and water and sewer
facilities. The economic impact on utility services total aboutl
lrespectively.
Most of this represents the use of utilities by occupants of the apartments.
(b)(4)
Maintenance and repair services include some building and construction activity
on existing buildings. The regional center would create an economic impact of about
I
I These expenditures represent permanent, ongoing maintenance on the
buildings after they are completed; they do not reflect the initial construction costs.

165

 7

New supplir/yendgr re!afonships with manufacturers would create an economic
impact of about _
. Most of this output represents purchases of locally
produced materials and parts for the construction of the building; some of these
expenditures are the purchase of locally produced supplies for the hotel.
(b)(4)

The regional center will also create demand for various types of business
services, including professional and scientific services, management of companies,
administrative services, and build~:
and waste management services. The
impact of this activity totals about
Most of this represents payments to
architects and engineers for the c :Sl ldll activities; it also includes outsourcing of
professional service activities for operating the hotel, such as lawyers and accountants.

::ort

I

The figures given in Table C represent only a brief summary of the detailed
calculations that have been undertaken and are reported in tabular format throughout
the report. The figure for utility output, for example, represents the sum of utility output
for each of the categories of economic activity listed in Table A. For repair and
maintenance construction office, this figure represents the amount spent times he
input/output coefficient showing the total amount of output perl
k:>f construction
expenditures. The same methodology applies to all the other figures given in Table C.
Detailed figures may be found in the tables in Sections (8) and (9), which provide
estimates of indirect jobs by industry category.

166

 8

3. Introduction and Scope of Work
The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space. This report contains the
economic impact results for the construction of the building and apartment rentals,
based on the RIMS II input/output model for the following 8 counties in New Jersey:
Hudson, Essex, Union, Bergan, Passaic, Morris, Monmouth, and Middlesex.
Section (4) contains a brief description of the RIMS II models and its various
multipliers, and Section (5) contains additional information explaining how the indirect
jobs are calculated. Section (6) contains and analyzes the key statistics for the sixcounty area used to calculate the RIMS II multipliers. Tables 6-1, 6-2, 6-3 and 6-4 show
the data for employment by major occupation and industrial classification, income
distribution by deciles, mean and median household and family income, and poverty
rates for the eight counties used to calculate the multipliers for this study, and compares
these figures to the U.S. totals or averages.
Table 6-5 shows key labor market statistics over the past decade for the State of
New Jersey, each of these counties, and the 8-county total. Tables 6-6 and 6-7 show
the level and growth rate of population and personal income for these same areas.
Table 6-8 shows the commuting patterns for Hudson County, and explains how these
figures are used to determine the counties included in the multiplier analysis. Section
(7) contains a map of the location of the building and maps of the area.
Section (8) presents the economic impact tables for the hard construction costs,
EB-5 eligible soft construction costs, and purchases of FF&E. Separate sets of tables
are presented for each category of construction for the increase in employment, output,
and earnings, and the average level of output and earnings per new worker, for the 20
major industrial classifications in the RIMS II input/output model. Section (9) discusses
the number of jobs and revenue estimates for the rental income from the apartments,
retail space, and parking, and presents similar tables for the detailed industry results.
Section (10) summarizes the RIMS II model results.

167

 9

4. Brief Guide to RIMS II Input/Output Model
The following material has been condensed from the RIMS II User Handbook.
Introduction and General Comments
Effective planning for public- and private-sector projects and programs at the
State and local levels requires a systematic analysis of the economic impacts of these
projects and programs on affected regions. In turn, systematic analysis of economic
impacts must account for the inter-industry relationships within regions because these
relationships largely determine how regional economies are likely to respond to project
and program changes. Thus, regional input-output (1-0) multipliers, which account for
inter-industry relationships within regions, are useful tools for conducting regional
economic impact analysis.
In the 1970s, the Bureau of Economic Analysis (BEA) developed a method for
estimating regional 1-0 multipliers known as RIMS (Regional Industrial Multiplier
System), which was based on the work of Garnick and Drake. In the 1980s, BEA
completed an enhancement of RIMS, known as RIMS II (Regional Input-Output
Modeling System), and published a handbook for RIMS II users.
In 1992, BEA
published a second edition of the handbook in which the multipliers were based on
more recent data and improved methodology. In 1997, BEA published a third edition of
the handbook that provides more detail on the use of the multipliers and the data
sources and methods for estimating them.
RIMS II is based on an accounting framework called an 1-0 table. For each
industry, an 1-0 table shows the industrial distribution of inputs purchased and outputs
sold. A typical 1-0 table in RIMS II is derived mainly from two data sources: SEA's
national 1-0 table, which shows the input and output structure of nearly 500 U.S.
industries, and SEA's regional economic accounts, which are used to adjust the national
1-0 table to show a region's industrial structure and trading patterns.
Using RIMS II for impact analysis has several advantages. RIMS II multipliers
can be estimated for any region composed of one or more counties and for any industry,
or group of industries, in the national 1-0 table. The accessibility of the main data
sources for RIMS II keeps the cost of estimating regional multipliers relatively low.
Empirical tests show that estimates based on relatively expensive surveys and RIMS 11based estimates are similar in magnitude.
SEA's RIMS multipliers can be a cost-effective way for analysts to estimate the
economic impacts of changes in a regional economy. However, it is important to keep in
mind that, like all economic impact models, RIMS provides approximate order-ofmagnitude estimates of impacts. RIMS multipliers are best suited for estimating the
impacts of small changes on a regional economy. For some applications, users may
want to supplement RIMS estimates with information they gather from the region
undergoing the potential change. To use the multipliers for impact analysis effectively,

168

 10

users must provide geographically and industrially detailed information on the initial
changes in output, earnings, or employment that are associated with the project or
program under study. The multipliers can then be used to estimate the total impact of
the project or program on regional output, earnings, and employment.
RIMS II is widely used in both the public and private sector. In the public sector,
for example, the Department of Defense uses RIMS II to estimate the regional impacts
of military base closings. State transportation departments use RIMS II to estimate the
regional impacts of airport construction and expansion. In the private-sector, analysts
and consultants use RIMS II to estimate the regional impacts of a variety of projects,
such as the development of shopping malls and sports stadiums.
RIMS II Methodology

RIMS II uses SEA's benchmark and annual 1-0 tables for the nation. Since a
particular region may not contain all the industries found at the national level, some
direct input requirements cannot be supplied by that region's industries. Input
requirements that are not produced in a study region are identified using SEA's regional
economic accounts.
The RIMS II method for estimating regional 1-0 multipliers can be viewed as a
three-step process. In the first step, the producer portion of the national 1-0 table is
made region-specific by using six-digit NAICS location quotients (LQs). The LQs
estimate the extent to which input requirements are supplied by firms within the region.
RIMS II uses LQs based on two types of data: SEA's personal income data (by place of
residence) are used to calculate LQs in the service industries; and SEA's wage-andsalary data (by place of work) are used to calculate LQs in the non-service industries.
In the second step, the household row and the household column from the
national 1-0 table are made region-specific. The household row coefficients, which are
derived from the value-added row of the national 1-0 table, are adjusted to reflect
regional earnings leakages resulting from individuals working in the region but residing
outside the region. The household column coefficients, which are based on the personal
consumption expenditure column of the national 1-0 table, are adjusted to account for
regional consumption leakages stemming from personal taxes and savings. In the last
step, the Leontief inversion approach is used to estimate multipliers. This inversion
approach produces output, earnings, and employment multipliers, which can be used to
trace the impacts of changes in final demand on and indirectly affected industries.
Advantages of RIMS II

There are numerous advantages to using RIMS II. First, the accessibility of the
main data sources makes it possible to estimate regional multipliers without conducting
relatively expensive surveys. Second, the level of industrial detail used in RIMS II helps
avoid aggregation errors, which often occur when industries are combined. Third, RIMS
II multipliers can be compared across areas because they are based on a consistent set

169

 11
of estimating procedures nationwide. Fourth, RIMS II multipliers are updated to reflect
the most recent local-area wage-and-salary and personal income data.

Overview of Different Multipliers
RIMS II provides users with five types of multipliers: final demand multipliers for
output, for earnings, and for employment; and direct-effect multipliers for earnings and
for employment. These multipliers measure the economic impact of a change in final
demand, in earnings, or in employment on a region's economy.
The final demand multipliers for output are the basic multipliers from which all
other RIMS II multipliers are derived. In this table, each column entry indicates the
change in output in each row industry that results from a $1 change in final demand in
the column industry. The impact on each row industry is calculated by multiplying the
final demand change in the column industry by the multiplier for each row. The total
impact on regional output is calculated by multiplying the final demand change in the
column industry by the sum of all the multipliers for each row except the household row.
RIMS II provides two types of multipliers for estimating the impacts of changes
on earnings: final demand multipliers and direct effect multipliers. These multipliers are
derived from the table of final demand output multipliers.
The final demand multipliers for earnings can be used if data on final demand
changes are available. In the final demand earnings multiplier table, each column entry
indicates the change in earnings in each row industry that results from a $1 change in
final demand in the column industry. The impact on each row industry is calculated by
multiplying the final demand change in the column industry by the multipliers for each
row. The total impact on regional earnings is calculated by multiplying the final demand
change in the column industry by the sum of the multipliers for each row.

Employment Multipliers
RIMS II provides two types of multipliers for estimating the impacts of changes
on employment: final demand multipliers and direct effect multipliers. These multipliers
are derived from the table of final demand output multipliers.

(b)(4)

The final demand multipliers for employment can be used if the data on final
demand changes are available. In the final demand employment multiplier table, each
c['umn entJ indicates the change in employment in each row industry that results from
a
change in final demand in the column industry. The impact on each row
industry 1s calculated by multiplying the final demand change in the column industry by
the multiplier for each row. The total impact on regional employment is calculated by
multiplying the final demand change in the column industry by the sum of the multipliers
for each row.

170

 12
The direct effect multipliers for employment can be used if the data on the initial
changes in employment by industry are available. In the direct effect employment
multiplier table, each entry indicates the total change in employment in the region that
results from a change of one job in the row industry. The total impact on regional
employment is calculated by multiplying the initial change in employment in the row
industry by the multiplier for the row.

Choosing a Multiplier
The choice of multiplier for estimating the impact of a project on output, earnings,
and employment depends on the availability of estimates of the initial changes in final
demand, earnings, and employment. If the estimates of the initial changes in all three
measures are available, the RIMS II user can select any of the RIMS II multipliers. In
theory, all the impact estimates should be consistent. If the available estimates are
limited to initial changes in final demand, the user can select a final demand multiplier
for impact estimation. If the available estimates are limited to initial changes in earnings
or employment, the user can select a direct effect multiplier.

5. Methodology for Calculating Indirect Job Gains

In spite of the explanation of the RIMS II model given directly above, some
USC IS adjudicators have asked for further clarification about how that model is used to
determine the increase in the number of indirect jobs. That is an important issue
because, unlike the direct job count, which can be verified by USCIS from various
payroll and withholding documents, the calculation of indirect jobs cannot be verified
directly but depends on mathematical calculations.
The general concept is based on the coefficients in the input/output model itself
(the same methodology applies to RIMS II, IMPLAN, or any other generally recognized
and accepted input/output model). In any given year, the government calculates how
much input is used for a given production of output. The detailed figures are taken from
the Economic Censuses taken once every five years; the figures are then updated from
various annual supplements.
Basically the process has two steps, each of which is described next in greater
detail. The first is to determine the amount of output, and hence the number of jobs,
required to produce a given amount (say $1 million) of the final product or service.
These are national coefficients. The second is to determine what proportion of those
goods and services are purchased within the local region (the regional purchase
coefficients, or RPCs).
In the case of a manufacturing process, the national coefficients are based on
production functions: how much coke per ton of steel, how much steel per motor
vehicle, how much flour for a loaf of bread, and so on. However, most of the jobs are

171

 13
created in the service sector, where Commerce Department data are used to determine,
for example, how much restaurants spend on laundry services, how much airlines
spend for attorneys, and so on. These figures are based on information contained in
the various Economic Censuses. The national coefficients would also determine, for
example, how many architects and engineers would be hired for a construction project
of a given scope and size, and how many new employees at financial institutions would
be required to handle the additional cash flow generated by the new business. Both of
these are discussed below in greater detail.
Even after these coefficients are determined, however, the regional purchase
coefficients (RPC) must still be estimated. If, for example, a trucking firm spends 1% of
its revenue on accountants, how much of that money is spent on local firms, and how
much is spent outside the region?

(b)(4)

That answer depends on various factors. The most important is the amount of
the good or service produced within the region. If a trucking firm, for example, were
located in a small county with no accountants, obviously it would not spend any of that
money locally. That sets a lower limit but is not generally the case. Instead, a
balancing algorithm is used.
Suppose, for example, that all the firms producing, distributing, or selling goods
and services in a given county spentl
lon accountini seodces
Also,
suppose that total billings of all accountants in the county were
In that
case, local accountants could handle all the local business, plus business from
nei hborin counties. If, on the other hand, total accountant billings in the county were
onl
local firms could not spend more than half of the money on local

I

Of course it is possible that there are adequate resources in the county but local
firms choose to use companies outside the county; perhaps prices or service is better.
No input/output model can account for such anomalies. On the other hand, given
transportation costs, it would be highly unusual for a firm to be located in a given
location and not serve the nearby businesses, instead choosing only those clients who
were farther away.
The RIMS II model - and other regional input/output models - assigns regional
purc_hase coefficients. (RPCs) in. all ca~es where the local industrx owc:a:es :~o:~~~:
serv1ces from local f1rms. Th1s matnx could have as many a1
_ ~- -------elements, although in practice many of them are zero. Large~c~o~u~n'r.'!1e~w"""1~""""'""""'--'
variety of businesses have more non-zero elements than small counties with relatively
few businesses.
In general, the RPCs tend to be close to zero for most manufactured goods, and
close to unity for most services. While there are many exceptions to this rule, most
firms will use financial, professional, business, and health care services that are located
in that county or contiguous areas.

172

 14

(b)(4)

To take just one example of many, consider the number of new jobs created by
architects and engineers for a new construction project of any given size. Most
construction cost manu~as those published by R. S. Means, indicate that those
costs are usually about
f the total job. According to the national input/output
file, the figures are
or commercial construction and
for industrial
construction.

D

These figures can be compared with the proportions of architects and engineers
in the specific regional area, based on the RIMS II data that are used to determine the
economic multipliers in the specific co~group. For this d-countJ group, the
input/output model shows proportions of L...J for commercial an
for industrial
construction, indicating that c:::J of the architects and engineers for commercial jobs
and Oar industrial jobs are hired locally. These figures are fairly typical of other
locations and regions; except for "signature" buildings designed by famous names, most
architects and engineers live in the same region as the buildings that are being
constructed.
To summarize to this point, the number of indirect jobs as a proportion of direct
jobs depends on (a) the national relationships, and (b) the regional purchase
coefficients. In our presentation for the businesses in this report, we provide further
discussion of those industries with the largest number of indirect jobs. However, there
are a few industries that produce relatively large numbers of jobs in almost all cases,
and these can be generally discussed at this stage in order to avoid repeating this
information several times. The industries discussed here include banking, real estate,
legal and accounting, architects and engineers, other professional services,
employment services, other business services, restaurants, and government. In all of
these cases, the vast majority of workers are hired locally. Our comments for the rest of
this section are based on the assumption of a
investment; the results are
linear.

I

I

Banking and credit: On an aggregate basis, for everyl
I in deposits,
very broadly defined (M3}, there is about 1 new banking employee. As a rough rule of
thumb, the size of M3 is roughly equal to the size of GOP. Hence we would expect
abouQew banking employee for everyl
lincrease in output, as calculated
from the RIMS II model.
(b)(4)

Real estate: Additional real estate employees are based on two factors. One is
the leasing activity of the new building, and the other is the increase in residential real
estate activity as people get new jobs, either within the area or by moving into the area.
On a lease basis, a ~investment is likely to result in a building of 80,000
square feet. If it lease~
quare foot, that would be I
Iin annual lease
payments, and with a
ission would generatel
In revenues, which
would account for abou
ew real estate employees (the figure would be less for
industrial buildings). The increase in employment would also result in some real estate
activity as workers moved into better housing in the same location, or moved in from
other areas. In a normal year, there are about
sales of new and existing
homes for a lab~f about
Hence if the total increase in
employment werL_Jat would imply
real estate transactions; if they average

173

 (b)(4)

15

I

Icommission, that would b~
ber home or a total otl
which would support approximately 1 new real estate job.
.....__ _......

Legal & Accounting: Each of these accounts for aboutc::::::t:>f total employment;
so if there were a total increase
lobs, we would expect an average of Qw
employees in this classification.

ot

Architects & Engineers: almost all of these jobs stem from the new construction
activity. This category has already been discussed above; for fl
(;onstruction
project, which would create aboutr-lew construction jobs, we would expect aboutD
new jobs in architects and engineersro1 a commercial project and'
*ew jobs for an
industrial project.
Other professional services: This category includes employees in consulting,
scientific research and development, advertising, and management, as well as several
other smaller, specialized categories. In general, consulting, management, and the all
other category each accou~ about
of total employment, and R&D and
advertising account for abouL.J:>f total employment, for a total of about O f total
employment. This figure will vary widely depending on the degree to which consultants
and R&D are used by the new business.

D

Employment services: On a national average basis, 1 out of every 45 people is
employed by this industry. Here again, the figures will vary widely depending on (a) the
proportion of people who are hired through employment agencies, and (b) the
proportion of the work that is outsourced to employment services.
Business support services include office management, travel arrangement,
security, credit bureaus, telemarketing, and back-office jobs that are outsourced, such
as direct mail, copying, and duplicating services. The back-office services would vary
widely depending on the type of new business; retail stores, for example, would print
and distribute more advertising brochures than ~nufacturing operation. On a
national average basis, these jobs account for aboutLJof total employment.
Building support services, which includes janitorial services, lawn maintenance,
and waste m~ment. For an office building of 80,000 sguare feet, the cost would be
approximate
q ft per year for maintenance, or I
I which would support
about[}ew JO s; ere again, the figure would be lower for industrial buildings.
Restaurants: This category reflects business meals. Of course the number of
business meals depends greatly on the type of business; lawyers, accountants, and
consultants will have more business meals than manufacturing plants or water
treatment facilities. On a national average basis, Commerce Department figures show
that total restaurant sales in 2007 were I
I while consumer expenditures at
restaurants werel
] However, that figure also includes tips, which are not
included in restaurant sales. After subtracting c::Jor tips, that indicates about,..,- - -..
I
In food and beverage purchases by consumers, indicatin abou1
for
business expenses. With a labor force of ~oximatel
hat is eqUivafent
to aboutl
lper employee. Hence ifL.Jlew jobs were crea ea, business meal

I

(b)(4)

174

 (b)(4)

16
expenses would rise an average of I
INhich would imply aboutc:::::Jlew indirect
jobs in the restaurant industry. These figures are likely to be somewhat higher when
direct jobs are created for office buildings and hotels.
Government: The increase in public sector employees represents the amount
funded by increased real estate taxes. For a construction project with $10 million in
hard costs, the total value is likely to be betwee~
tNhen one includes
furniture, fixtures, equipment, and land values. Using a national average property tax
rate of c::::lhat would raise I
tNhich would create I
new jobs
in the public sector.

175

 17

6. Economic Parameters for Hudson, Essex, Union, Bergen, Passaic,
Morris, Middlesex, and Monmouth Counties
This section is organized as follows. Tables 6-1, 6-2, 6-3 and 6-4 show the data
for employment by major occupation and industrial classification, income distribution by
deciles, mean and median household and family income, and poverty rates for the eight
counties used to calculate the multipliers for this study, and compares these figures to
the U.S. totals or averages. Table 6-5 shows key labor market statistics over the past
decade for the State of New Jersey, each of these counties, and the 8-county total.
Tables 6-6 and 6-7 show the level and growth rate of population and personal income
for these same areas. Table 6-8 shows the commuting patterns for Hudson County,
and explains how these figures are used to determine the counties included in the
multiplier analysis.
Table 6-1. Key Economic Statistics for Hudson and Counties Compared to the U.
S. Economy, 201 0 Data

-"

%

u.s.

%

520,559
359,487
359,408
312,480
46,928
79
161,072

100.0%
69.1%
69.0%
60.0%
9.0%
0.0%
30.9%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

100.0%
37.3%
20.4%
24.2%
7.2%
10.9%

312,480
118,514
54,500
75,993
22,231
41,242

100.0%
37.9%
17.4%
24.3%
7.1%
13.2%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

100.0%
0.2%
5.6%
6.1%
2.4%
9.6%
7.1%
3.5%
9.2%
12.8%
26.0%
7.5%

312,480
88
17,452
25,036
12,919
31,641
24,887
10,909
34,463
42,737
60,295
23,187

100.0%
0.0%
5.6%
8.0%
4.1%
10.1%
8.0%
3.5%
11.0%
13.7%
19.3%
7.4%

139,033,928
2,646,975
8,686,813
14,439,691
3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%

Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

612,565
400,770
400,523
344,146
56,377
247
211,795

100.0%
65.4%
65.4%
56.2%
9.2%
0.0%
34.6%

OCCUPATION
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production & transportation

344,146
128,336
70,110
83,284
24,850
37,566

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs

344,146
839
19,412
21,063
8,192
33,180
24,477
11,875
31,756
44,064
89,318
25,779

Essex

%

Hudson

176

 18
Other private services
Public administration

17,380
16,811

5.1%
4.9%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)

275,417
28,243
16,478
28,288
25,719
32,635
44,176
31,262
32,280
14,778
21,558
52,394
80,167

100.0%
10.3%
6.0%
10.3%
9.3%
11.8%
16.0%
11.4%
11.7%
5.4%
7.8%
104.7%

Families
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)
Mean family income (dollars)
Per capita income (dollars)

16,461
12,405

5.3%
4.0%

6,913,449
7,187,193

5.0%
5.2%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

.117.4%

238,692 100.0%
19,411
8.1%
14,462
6.1%
24,152
10.1%
20,533
8.6%
29,768
12.5%
18.8%
44,776
26,814
11.2%
31,304
13.1%
4.9%
11,757
15,715
6.6%
54,817 109.5%
76,339 111.8%

175,731
12,211
6,627
15,282
15,561
19,250
26,811
21,661
25,935
13,439
18,954
66,439
97,237
29,674

100.0%
6.9%
3.8%
8.7%
8.9%
11.0%
15.3%
12.3%
14.8%
7.6%
10.8%
109.6%
122.6%
113.9%

147,709
8,382
7,409
14,311
12,795
20,209
27,360
16,708
21,969
8,032
10,534
57,978
81,559
29,798

100.0%
5.7%
5.0%
9.7%
8.7%
13.7%
18.5%
11.3%
14.9%
5.4%
7.1%
95.7%
102.8%
114.3%

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609
79,338
26,059

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

Median earnings for workers
Median earnings for male full-time
Median earnings for female full-time

32,961
49,597
41,317

114.1%
106.7%
113.0%

35,677
50,563
41,173

123.5%
108.7%
112.6%

28,899
46,500
36,551

PERCENTAGE BELOW POVERTY LEVEL
All families
All people

13.9%
16.7%

123.0%
109.2(%

13.7%
16.5%

!21.2%
107.8%

11.3%
15.3%

Please note that in these tables, the percentage figures in regular type refer to the overall category in
that column, while the figures in red are relative to the U.S. average figures

The income distributions in Essex and Hudson Counties can best be described
as "fat-tailed", with greater than average percentages in the highest and lowest income
brackets. To elaborate, 11% of families in each of the two counties earn less than
$15,000 a year, compared to 8% nationally - while 11% of Essex families and 7% of
Hudson families earn $200,000 or more, compared to 5% for the U.S. This dichotomy
can also be seen in the high mean household incomes ($80K in Essex and $76K in

177

 19
Hudson, versus $68K for the U.S.) and large share of families living in poverty (14% in
each county, versus 11% for the nation).
Turning to the occupation data, both counties have lower than average shares in
manufacturing as well as the arts, entertainment, hotel, and food service industries and higher than average shares in transportation and finance. The counties differ in the
mix of workers in the education and health care industries, as Essex (26%) has a higher
proportion than average and Hudson has a lower proportion at 19% - the smallest of
the five counties.

Table 6-2. Key Economic Statistics for Union and Bergen Counties Compared to
the U. S. Economy
Category

Union

%

Bergen

%

EMPLOYMENT STATUS

u.s.

%

2010
420,828

100.0%

727,196

100.0%

243,832,923

100.0%

291,604

69.3%

478,944

65.9%

156,966,769

64.4%

291,560

69.3%

478,892

65.9%

155,917,013

63.9%

255,497

60.7%

438,302

60.3%

139,033,928

57.0%

Unemployed

36,063

8.6%

40,590

5.6%

16,883,085

6.9%

Armed Forces

44

0.0%

52

0.0%

1,049,756

0.4%

129,224

30.7%

248,252

34.1%

86,866,154

35.6%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

Management & professional

90,913

35.6%

201,513

46.0%

49,975,620

35.9%

Service occupations

43,165

16.9%

55,159

12.6%

25,059,153

18.0%

24.4%

114,453

26.1%

34,711,455

25.0%

8.7%

28,908

6.6%

12,697,304

9.1%

36,863

14.4%

38,269

8.7%

16,590,396

11.9%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

177

0.1%

919

0.2%

2,646,975

1.9%

Construction

17,557

6.9%

24,897

5.7%

8,686,813

6.2%

Manufacturing

24,870

9.7%

40,015

9.1%

14,439,691

10.4%

Wholesale trade

10,869

4.3%

19,216

4.4%

3,941,066

2.8%

Retail trade

25,990

10.2%

47,458

10.8%

16,203,408

11.7%

Transportation & utilities

18,211

7.1%

22,703

5.2%

6,843,579

4.9%

7,394

2.9%

16,169

3.7%

3,015,521

2.2%

Population 16 years and over
In labor force
Civilian labor force
Employed

Not in labor force

OCCUPATION
Civilian employed population 16+

Sales and office occupations
Construction, maintenance, repair
Production & transportation

62,273
22,283

INDUSTRY
Civilian employed population 16+
Agriculture & mining

Information

178

 20
Finance, insurance, & real estate
Professional & administrative

21,793
29,021

8.5%

45,159

10.3%

9,275,465

6.7%

11.4%

58,730

13.4%

14,710,089

10.6%

22.6%

32,311)07

23.2%

Educational services & health care

53,596

21.0%

99,084

Arts, entertain, hotel, food svcs

19,342

7.6%

28,699

6.5%

12,859,572

9.2%

Other private services

13,531

5.3%

20,540

4.7%

6,913,449

5.0%

Public administration

13,146

5.1%

14,713

3.4%

7)87,193

5.2%

Total households

183,882

100.0%

333,002

100.0%

114,567,419

100.0%

Less than $10,000

10,740

5.8%

15,136

4.5%

8,757,190

7.6%

$10,000 to $14,999

6,138

3.3%

12,370

3.7%

6,668,865

5.8%

$15,000 to $24,999

15,300

8.3%

24,587

7.4%

13)65,380

11.5%

$25,000 to $34,999

14,321

7.8%

23,753

7.1%

12,323,322

10.8%

$35,000 to $49,999

23,549

12.8%

33,430

10.0%

16,312,385

14.2%

$50,000 to $74,999

31,943

17.4%

53,157

16.0%

20,940,859

18.3%

$75,000 to $99,999

21,678

11.8%

40,999

12.3%

13,526,500

11.8%

$100,000 to $149,999

31,378

17.1%

56,634

17.0%

13,544,839

11.8%

$150,000 to $199,999

11,796

6.4%

34,456

10.3%

4,809,998

4.2%

$200,000 or more

17m9

9.3%

38,480

11.6%

4,518,081

3.9%

Median household income (dollars)

66,665

133.2%

77,389

154.6%

50,046

Mean household income (dollars)

94,659

138.7%

105,488

154.5%

68,259

131,811

100.0%

236,574

100.0%

76,089,045

100.0%

Less than $10,000

6,001

4.6%

6,237

2.6%

3,824,251

5.0%

$10,000 to $14,999

2,973

2.3%

4,959

2.1%

2,660,781

3.5%

$15,000 to $24,999

8,903

6.8%

11,365

4.8%

6,770,812

8.9%

$25,000 to $34,999

8,224

6.2%

12,914

5.5%

7,332,318

9.6%

$35,000 to $49,999

15,365

11.7%

19,255

8.1%

10,578,051

13.9%

17.6%

36,079

15.3%

14,990,631

19.7%

12.0%

29,860

12.6%

10,638,931

14.0%

19.4%

49,242

20.8%

11,261,766

14.8%

13.4%

INCOME AND BENEFITS

Families

$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999

23,157
15,838
25,630

$150,000 to $199,999

10,400

7.9%

31,650

4,130,868

5.4%

$200,000 or more

15,320

11.6%

35,013

14.8%

3,900,636

5.1%

Median family income (dollars)

77,361

127.6%

97,394

160.7%

60,609

107,812

135.9%

123,384

155.5%

79,338

Per capita income (dollars)

33,267

127.7%

39,409

151.2%

26,059

Median earnings for workers

35)14

12t9S".i

44,350

153.5%

28,899

Median earnings for male full-time

5U95

llOJ.%

63,074

135.6%

46,500

Median earnings for female full-time

43,496

119.0%

51,103

139.8%

36,551

Mean family income (dollars)

179

 21

PERCENTAGE BELOW POVERTY LEVEL
All families

8.70%

rrory,,

5.6%

49.6%

11.30%

All people

11.10%

72.5%

6.8%

44.4%

15.30%

Union County is mixed, with many high-income suburban areas but also lowincome areas by the railroad tracks. As a result it has a high proportion of households
and families at the upper end of the income scale, but almost a proportional amount at
the lower end of the scale. As a result, while the median and mean income levels are
above average and the poverty levels are below average, these figures are smaller than
would be expected from a typical suburban county, and well below Bergen County. By
comparison, Bergen County has about three times the national average in the top
income bracket, and only about half in the bottom bracket. As a result, median family
income for Union County is 128% of the national average, while the figure for Bergen
County is 161% of the average. Similarly, the poverty rate for all families is 77% of the
national average for Union County, but only 50% for Bergen County.
In terms of employment distribution by occupation, both counties have a fairly
robust manufacturing base, only slightly below the national average. Most of the other
sectors are also close to those averages, with slightly higher proportions for financial
and professional services.

Table 6-3. Key Economic Statistics for Morris and Passaic Counties Compared to
the U.S. Economy

u.s.

Morris

%

Passaic

%

389,318

100.0%

392,154

100.0%

243,832,923

100.0%

265,835

68.3%

251,834

64.2%

156,966,769

64.4%

265,835

68.3%

251,834

64.2%

155,917,013

63.9%

242,762

62.4%

223,928

57.1%

139,033,928

57.0%

Unemployed

23,073

5.9%

27,906

7.1%

16,883,085

6.9%

Armed Forces

0

0.0%

0

0.0%

1,049,756

0.4%

123,483

31.7%

140,320

35.8%

86,866,154

35.6%

242,762

100.0%

223,928

100.0%

139,033,928

100.0%

117,011

48.2%

72,732

32.5%

49,975,620

35.9%

Service occupations

31,488

13.0%

41,066

18.3%

25,059,153

18.0%

Sales and office occupations

61,530

25.3%

55,173

24.6%

34,711,455

25.0%

Construction, maintenance, repair

13,971

5.8%

15,773

7.0%

12,697,304

9.1%

Production & transportation

18,762

7.7%

39,184

17.5%

16,590,396

11.9%

Category
EMPLOYMENT STATUS
Population 16 years and over
In laborforce
Civilian labor force
Employed

Not in labor force

%

2010

OCCUPATION
Civilian employed population 16+
Management & professional

180

 22

INDUSTRY
242,762

100.0%

223,928

100.0%

139,033,928

100.0%

605

0.2%

106

0.0%

2,646,975

1.9%

Construction

13,025

5.4%

12,406

5.5%

8,686,813

6.2%

Manufacturing

29,462

12.1%

30,737

13.7%

14,439,691

10.4%

Wholesale trade

8,531

3.5%

9,361

4.2%

3,941,066

2.8%

Retail trade

24,489

10.1%

27,233

12.2%

16,203,408

11.7%

Transportation & utilities

11,615

4.8%

10,168

4.5%

6,843,579

4.9%

Information

10,352

4.3%

5,816

2.6%

3,015,521

2.2%

Finance, insurance, & real estate

26,164

10.8%

17,055

7.6%

9,275,465

6.7%

Professional & administrative

33,295

13.7%

25,463

11.4%

14,710,089

10.6%

Educational services & health care

55,177

22.7%

50,431

22.5%

32,311,107

23.2%

Arts, entertain, hotel, food svcs

12,728

5.2%

16,915

7.6%

12,859,572

9.2%

Other private services

8,589

3.5%

11,461

5.1%

6,913,449

5.0%

Public administration

8,730

3.6%

6,776

3.0%

7,187,193

5.2%

Total households

177,786

100.0%

161,527

100.0%

114,567,419

100.0%

Less than $10,000

5,141

2.9%

14,538

9.0%

8,757,190

7.6%

$10,000 to $14,999

3,562

2.0%

7,604

4.7%

6,668,865

5.8%

$15,000 to $24,999

10,598

6.0%

17,286

10.7%

13,165,380

11.5%

$25,000 to $34,999

10,446

5.9%

17,003

10.5%

12,323,322

10.8%

$35,000 to $49,999

15,265

8.6%

19,142

11.9%

16,312,385

14.2%

$50,000 to $74,999

27,277

15.3%

26,057

16.1%

20,940,859

18.3%

$75,000 to $99,999

25,266

14.2%

17,637

10.9%

13,526,500

11.8%

$100,000 to $149,999

33,587

18.9%

24,127

14.9%

13,544,839

11.8%

$150,000 to $199,999

20,542

11.6%

10,658

6.6%

4,809,998

4.2%

$200,000 or more

26,102

14.7%

7,475

4.6%

4,518,081

3.9%

Median household income (dollars)

91,469

182.8%

53,993

107.9%

50,046

121,784

178.4%

73,618

107.9%

68,259

128,754

100.0%

113,041

100.0%

76,089,045

100.0%

Less than $10,000

1,983

1.5%

7,061

6.2%

3,824,251

5.0%

$10,000 to $14,999

1,149

0.9%

2,987

2.6%

2,660,781

3.5%

$15,000 to $24,999

4,287

3.3%

10,418

9.2%

6,770,812

8.9%

$25,000 to $34,999

5,257

4.1%

10,897

9.6%

7,332,318

9.6%

$35,000 to $49,999

9,063

7.0%

11,966

10.6%

10,578,051

13.9%

$50,000 to $74,999

18,910

14.7%

19,967

17.7%

14,990,631

19.7%

$75,000 to $99,999

18,470

14.3%

13,043

11.5%

10,638,931

14.0%

Civilian employed population 16+
Agriculture & mining

-··--

INCOME AND BENEFITS

Mean household income (dollars)
Families

--

-·

181

 23
$100,000 to $149,999

27,700

21.5%

20,577

18.2%

11,261,766

14.8%

$150,000 to $199,999

18,007

14.0%

9,254

8.2%

4,130,868

5.4%

$200,000 or more

23,928

18.6%

6,871

6.1%

3,900,636

5.1%

107,639

ln6%

65,248

107.7%

60,609

141,174

1ns~;,

84,767

106.8%

79,338

44,393

t70.4%

25,244

96.9'!{,

26,059

Median family income (dollars)
Mean family income (dollars)
Per capita income (dollars)

···~-.

Median earnings for workers

48,157

166.6%

30,444

105.3%

28,899

Median earnings for male full-time

77,163

165.9%

46,945

101.0%

46,500

Median earnings for female full-time

55,422

151.6%

37,130

101.6%

36,551

All families

3.7%

32. 7'Yz,

12.5%

110.6'%

11.30%

All people

6.0%

39.2%

15.7%

102.6%

15.30%

PERCENTAGE BELOW POVERTY LEVEL

Morris County is a typical upscale suburban county; Passaic County is mixed,
somewhat like Union County, with pockets of poverty as well as islands of affluence. In
Morris County, median family income is 178% of the national average, similar to but
even higher than Bergen County, while Passaic is only 108% of the average, similar to
but lower than Union County. The poverty levels reflect this difference in income; for all
families, the rate is only 1/3 of the national average for Morris County, but 110% of that
average for Passaic County.
Both counties have a higher than average proportion of the workforce in
manufacturing, at 12.1% for Morris County and 13.7% for Passaic County, compared to
10.4% nationally. Both counties also have a higher than average proportion of workers
in financial and professional services, although the increment is much smaller for
Passaic County. Offsetting these bulges, both counties have a much smaller than
average proportion of workers in arts, entertainment, leisure, hotels, and restaurants.

Table 6-4. Economic Profile of Middlesex and Monmouth Counties and
Comparison with the U.S., 2010 Data
Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

Middlesex

647,766
436,439
436,344
392,654
43,690
95
211,327

% Monmouth
100.0%
67.4%
67.4%
60.6%
6.7%
0.0%
32.6%

499,682
334,514
334,163
305,172
28,991
351
165,168

%

u.s.

%

100.0%
66.9%
66.9%
61.1%
5.8%
0.1%
33.1%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

OCCUPATION

182

 24
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production & transportation

392,654
170,323
55,446
99,238
25,049
42,598

100.0%
43.4%
14.1%
25.3%
6.4%
10.8%

305,172
131,997
46,342
81,326
21,803
23,704

100.0%
43.3%
15.2%
26.6%
7.1%
7.8%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs
Other private services
Public administration

392,654
628
18,052
39,615
17,826
43,951
26,800
12,486
36,177
52,832
83,080
29,705
15,450
16,052

100.0%
0.2%
4.6%
10.1%
4.5%
11.2%
6.8%
3.2%
9.2%
13.5%
21.2%
7.6%
3.9%
4.1%

305,172
1,043
16,060
20,781
10,399
33,644
14,981
13,058
33,142
39,280
70,468
24,158
11,999
16,159

100.0%
0.3%
5.3%
6.8%
3.4%
11.0%
4.9%
4.3%
10.9%
12.9%
23.1%
7.9%
3.9%
5.3%

139,033,928
2,646,975
8,686,813
14,439,691
3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572
6,913,449
7,187,193

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%
5.0%
5.2%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)

278,877
9,344
8,634
20,963
17,484
28,013
52,023
41,574
59,641
23,338
17,863
76,443
91,077

100.0%
3.4%
3.1%
7.5%
6.3%
10.0%
18.7%
14.9%
21.4%
8.4%
6.4%
152.7'%

100.0%
3.7%
3.4%
8.6%
7.2%
9.0%
14.7%
12.9%
18.5%
9.9%
12.1%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

133.4%

234,582
8,749
7,916
20,280
16,779
21,105
34,504
30,287
43,322
23,299
28,341
80,816
109,907

Families
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)

203,542
3,425
3,594
10,298
10,039
18,530
36,692
32,490
51,013
21,178
16,283
88,678

100.0%
1.7%
1.8%
5.1%
4.9%
9.1%
18.0%
16.0%
25.1%
10.4%
8.0%
146.3'}(,

159,264
3,542
2,250
7,999
8,157
11,826
20,099
23,504
36,806
19,441
25,640
101,714

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

161.5%

161.0%

100.0%
2.2%
1.4%
5.0%
5.1%
7.4%
12.6%
14.8%
23.1%
12.2%
16.1%
167.8%

183

 25
Mean family income (dollars)
Per capita income (dollars)

102,733
32,017

129.5%
122.9%

132,616
41,434

167.2%

Median earnings for workers

40,270

139.3%

42,266

146.3%

28,899

Median earnings for male full-time
Median earnings for female full-time

61,557
47,101

132.4%
128.9%

71,576
52,072

153.9%
142.5%

46,500
36,551

All families

5.1%

45.1%

5.0%

44.2%

11.3%

All people

7.7%

50.3%

6.6%

43.1%

15.3%

15'L0%

79,338
26,059

PERCENTAGE BELOW POVERTY LEVEL

Middlesex and Monmouth Counties are prototypical wealthy suburbs, with
median household incomes more than 50% higher than the U.S. figures and poverty
rates half of the national averages or less. Monmouth County has an especially high
share of the wealthy, with 12% of households earning $200,000 or more compared to
4% for the U.S.
Consistent with their high-income profiles, both counties have high percentages
of white-collar workers - 43% in each county, compared to 36% nationally. Similar to
the other counties in the region, Middlesex (9%) and Monmouth (11%) have high shares
of workers in the finance and insurance industries - compared to 7% for the U.S.
Unlike Middlesex County, Monmouth County has a lower than average proportion of its
workforce in manufacturing, at 7%.
Table 6-5. Labor Market Statistics for 8 Counties in Northern New Jersey, 20022011 Data
Labor Force

Employed

Unemployed

Un Rate,%

New Jersey
2002

4,370,809

4,117,265

253,544

5.8
5.9

2003

4,363,896

4,108,397

255,499

2004

4,358,908

4,144,223

214,685

4.9

2005
2006

4,404,451
4,465,067

4,207,738
4,257,899

196,713
207,168

4.5
4.6

2007

4,456,306

4,264,617

191,689

4.3

2008

4,509,110

4,262,281

246,829

5.5

2009

4,546,443

4,138,364

408,079

9.0

2010

4,554,076

4,116,640

437,436

9.6

2011

4,556,186

4,131,832

424,354

9.3

Bergen
2002

466,326

442,760

23,566

5.1

2003

465,115

441,480

23,635

5.1

2004

462,702

443,247

19,455

4.2

184

 26
2005

467,206

449,791

17,415

3.7

2006

473,275

455,022

18,253

3.9

2007

472,991

456,594

16,397

3.5

2008

478,584

457,046

21,538

4.5

2009

480,720

443,620

37,100

7.7
8.3

2010

476,243

436,522

39,721

2011

479,131

441,277

37,854

7.9

2002

371,383

344,532

26,851

7.2

2003

369,164

342,304

26,860

7.3

2004

363,454

340,905

22,549

6.2
5.6

Essex

2005

361,843

341,544

20,299

2006

364,175

343,012

21,163

5.8

2007

362,785

343,281

19,504

5.4

2008

366,007

341,853

24,154

6.6

2009

367,125

329,526

37,599

10.2

2010

370,372

329,355

41,017

11.1

2011

370,417

330,337

40,080

10.8

2002

296,200

273,503

22,697

7.7

2003

292,204

270,633

21,571

7.4

2004

287,381

269,725

17,656

6.1

2005

288,312

272,630

15,682

5.4

2006

290,204

274,266

15,938

5.5

2007

290,990

276,383

14,607

5.0
6.4

Hudson

2008

294,408

275,666

18,742

2009

299,839

268,570

31,269

10.4

2010

310,845

277,281

33,564

10.8

2011

312,467

280,302

32,165

10.3

2002

390,439

23,246

5.6

2003

Middlesex
413,685
411,128

388,372

22,756

5.5

2004

410,464

391,663

18,801

4.6

2005
2006

415,943

398,420

17,523

421,868

403,617

18,251

4.2
4.3

2007

421,754

405,387

16,367

3.9

2008

425,916

404,463

21,453

5.0

427,408

391,354

36,054

8.4

2010

436,381

398,449

37,932

8.7

2011

436,228

399,546

36,682

8.4

2009

185

 27

308,550

17,176

5.3

2003

Monmouth
325,726
323,789

306,191

17,598

5.4

2004

322,012

307,448

14,564

4.5

2005

324,105

310,869

13,236

4.1

13,481

4.1

2002

2006

329,093

315,612

2007

332,191

319,687

12,504

3.8

2008

335,353

318,975

16,378

4.9

2009

336,577

308,793

27,784

8.3

2010

329,433

300,427

29,006

8.8

2011

329,571

301,254

28,317

8.6

2002

265,499

253,291

12,208

4.6

2003

266,068

253,862

12,206

4.6

2004

265,376

255,660

9,716

3.7
3.3

Morris

2005

267,813

259,088

8,725

2006

272,237

263,196

9,041

3.3

2007

272,580

264,282

8,298

3.0

2008

275,584

264,528

11,056

4.0

2009

275,118

255,839

19,279

7.0

2010

272,994

252,965

20,029

7.3

2011

272,849

253,719

19,130

7.0

2002

236,848

220,154

16,694

7.0

2003

236,729

219,363

17,366

7.3
6.2

Passaic

2004

233,946

219,516

14,430

2005

235,518

222,610

12,908

5.5

2006
2007

237,194

13,250

5.6

237,294

223,944
224,527

12,767

2008

240,836

224,443

16,393

5.4
6.8

2009

244,838

218,118

26,720

10.9

2010

244,764

216,367

28,397

11.6

2011

246,012

218,724

27,288

11.1

2002

269,672

252,547

17,125

6.4

2003

268,107

251,137

16,970

6.3

2004

265,034

250,970

14,064

5.3

2005

265,654

252,991

12,663

4.8

255,487

13,034

4.9

Union

2006

268,521

186

 28
2007
2008
2009
2010
2011

267,960
271,553
273,728
275,137
275,886

255,865
255,902
248,504
248,502
249,244

12,095
15,651
25,224
26,635
26,642

4.5
5.8
9.2
9.7
9.7

2002
2003
2004
2005
2006
2007
2008
2009
2010
2011

8 counties
2,645,339
2,632,304
2,610,369
2,626,394
2,656,567
2,658,545
2,688,241
2,705,353
2,716,169
2,722,561

2,485,776
2,473,342
2,479,134
2,507,943
2,534,156
2,546,006
2,542,876
2,464,324
2,459,868
2,474,403

159,563
158,962
131,235
118,451
122,411
112,539
145,365
241,029
256,301
248,158

6.0
6.0
5.0
4.5
4.6
4.2
5.4
8.9
9.4
9.1

The unemployment rate for this part of New Jersey is very similar to the profile
for the overall U. S., although the figures in 2010 and 2011 are marginally lower. By
individual county, Hudson, Essex, Union, and Passaic counties have rates that are
above the 8.9% level for 2011, while Bergen, Middlesex, Morris, and Monmouth are
below average. According to BLS statistics as of December 1, 2012, there were almost
250,000 unemployed people in this 8-county region in 2011.

Table

6~6.

2011
2010
2009

2008
2007
2006
2005
2004
2003
2002
2011/10
2010/09
2009/08

Level and Growth Rate of Population, State of New Jersey, 8 Counties
in the Northern New Jersey, and the Total of these Counties
(Table is divided into Sections A and B for easier viewing)
New Jersey
Bergen
Essex
Hudson
Union
8,821,155
785,137
641,224
911,004
539,494
8,799,593
906,184
784,099
634,979
537,475
8,755,602

900,319

781,943

8,711,090

895,328
890,817
889,406
891,446
893,378
892,214

778,165

890,647

778,996
781,027
786,341
791,305
795,167
795,625

0.53%
0.65%
0.56%

0.13%
0.28%
0.49%

8,677,885
8,661,679

8,651,974
8,634,561

8,601,402
8,552,643
0.25%
0.50%
0.51%

628,572

Middlesex
814,217
810,747

532,434

805,204

619,533

527,528

613,637

799,191
792,137

614,813
615,554

524,960
525,153
526,161
526,916
527,611
527,625

781,582
775,973
769,280

0.98%
1.02%
1.46%

0.38%
0.95%
0.93%

0.43%
0.69%
0.75%

613,577
614,664
614,607

786,890
787,329

187

 29
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

0.38%
0.19%
0.11%
0.20%
0.39%
0.57%

0.51%
0.16%
-0.23%
-0.22%
0.13%
0.18%

-0.11%
-0.26%
-0.68%
-0.63%
-0.49%
-0.06%

0.96%
0.01%
-0.18%
0.01%
-0.03%
-0.12%

0.49%
-0.04%
-0.19%
-0.14%
-0.13%
0.00%

0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

2011/02

0.34%

0.25%

-0.15%

0.45%

0.25%

0.63%

Middlesex
814,217
810,747
805,204
799,191
792,137
786,890
787,329
781,582
775,973
769,280

Monmouth
631,020
630,920
628,669
627,348
626,644
626,934
627,838
628,605
627,413
624,532

Morris
494,976
492,681
490,779
489,743
488,355
487,486
485,472
483,997
481,000
477,234

Passaic
502,007
501,606
498,641
494,904
492,886
492,730
493,600
493,981
494,915
494,571

8 counties
5,319,079
5,298,691
5,266,561
5,231,740
5,208,432
5,203,203
5,212,851
5,214,371
5,209,106
5,195,068

2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

0.43%
0.69%
0.75%
0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

0.02%
0.36%
0.21%
0.11%
-0.05%
-0.14%
-0.12%
0.19%
0.46%

0.47%
0.39%
0.21%
0.28%
0.18%
0.41%
0.30%
0.62%
0.79%

0.08%
0.59%
0.76%
0.41%
0.03%
-0.18%
-0.08%
-0.19%
0.07%

0.38%
0.61%
0.67%
0.45%
0.10%
-0.19%
-0.03%
0.10%
0.27%

2011/02

0.63%

0.11%

0.41%

0.17%

0.26%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002

Population growth in this 8-county area was not only well below the 1% rate for
the U.S, but was less than half the rate in New Jersey; since that is the figure for the
entire state, the growth rate was only about 1/5 of that for the other 9 counties in New
Jersey. The pattern reversed course at mid-decade, with an actual decline from 2004
through 2007 being followed by an average growth rate of 0.5% from 2008 to 2011.

Table 6-7. Level and Growth Rate of Personal Income, Billions of Dollars, State of
New Jersey, 8 Counties in Northern New Jersey, and the Total of these Counties

2011

New Jersey
462.49

Bergen
60.21

Essex
41.58

Hudson
30.38

Union
27.98

188

 30
2010
2009
2008
2007
2006
2005
2004
2003
2002

443.74
430.96
454.21
436.12
411.43
379.65
365.26
347.69
341.56

57.44
56.36
61.09
60.04
55.78
50.55
48.66
45.62
46.24

40.01
37.98
40.20
38.83
36.93
33.99
32.77
30.81
30.14

28.75
26.82
26.57
24.21
22.69
21.15
19.99
19.24
19.00

26.63
25.76
27.59
26.64
25.54
23.28
22.54
21.87
21.51

2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

4.23%
2.97%
-5.12%
4.15%
6.00%
8.37%
3.94%
5.05%
1.80%

4.83%
1.91%
-7.73%
1.75%
7.63%
10.34%
3.90%
6.65%
-1.33%

3.91%
5.34%
-5.53%
3.53%
5.14%
8.65%
3.73%
6.37%
2.21%

5.66%
7.20%
0.96%
9.76%
6.69%
7.26%
5.81%
3.88%
1.30%

5.08%
3.35%
-6.63%
3.57%
4.31%
9.72%
3.29%
3.06%
1.70%

2011/02

3.42%

2.98%

3.63%

5.35%

2.96%

Middlesex
40.06
38.34
37.58
39.53
37.22
34.78
32.14
31.00
30.07
29.55

Monmouth
36.82
35.59
34.79
37.22
36.15
33.68
30.87
29.78
27.75
27.36

Morris
35.50
34.18
32.98
36.25
34.77
33.11
30.55
29.42
27.32
26.93

Passaic
21.69
20.64
20.03
20.57
19.83
18.66
17.41
16.48
16.13
15.92

8 counties
294.23
281.58
272.31
289.02
277.68
261.17
239.95
230.64
218.81
216.63

4.50%
2.02%
-4.95%
6.20%
7.01%
8.22%
3.70%
3.10%
1.76%

3.45%
2.31%
-6.53%
2.97%
7.35%
9.09%
3.66%
7.32%
1.43%

3.87%
3.65%
-9.04%
4.28%
5.01%
8.37%
3.85%
7.67%
1.47%

5.09%
3.04%
-2.60%
3.74%
6.26%
7.17%
5.61%
2.22%
1.28%

4.49%
3.41%
-5.78%
4.08%
6.32%
8.84%
4.04%
5.41%
1.00%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

189

 31

3.44%

2011/02

3.35%

3.12%

3.49%

3.46%

The growth in personal income over the decade for this 8-county region was the
same as the rest of New Jersey, and about 0.3% per year lower than the U.S. economy.
The decline in 2009 was obviously tied to the financial markets, but was not nearly as
severe as the swings in Manhattan and the suburban counties in New York State. Of
particular interest is that income actually continued to rise in Hudson County in 2009 in
spite of the increasing concentration of financial institutions who have moved across the
river from New York City; it was the only county in this group where income did not
decline in 2009. The rebound in 2010 and 2011 for the entire region continued to be
close to the national average; for Hudson County, the increase was well above average.
Finally, we turn to the commuting patterns. In determining the economic impact
of new job creation, it is necessary to choose the counties that form the relevant area
for analysis. The economic multipliers will be higher as the number of counties included
in the area increases. If the proportion of the workforce covered rises above 95%, that
would include too many jobs that are not directly related to the new project. If that
proportion falls below 90%, the multipliers would probably be understated. Hence the
commuting patterns of the workforce data from the 2000 Census are used to determine
the optimal mix of counties to be included in the multiplier calculations. These
commuters spend most of their paychecks in the counties where they live, so the
economic impact of the new project creates some new induced jobs in bordering
counties. Also, some of the goods and services purchased by the new businesses are
produced or purchased from establishments in neighboring counties.
Table 6-8 can be interpreted as follows. In 2000, there were 223,225 people in
the Hudson County workforce. Of these, 121 ,352 lived in Hudson County, 25,444 lived
in Bergen County, and so on. We have included counties that accounted for 84.1% of
the total Hudson County workforce, which is below the usual level because many of the
commuters live in far-flung counties that have few links with Hudson County.
Table 6-8. Commuting Patterns for Hudson County, NJ
Total Hudson County Workforce
Living in these counties:
Hudson Co. NJ
Bergen Co. NJ
Essex Co. NJ
Middlesex Co. NJ
Union Co. NJ

223,225
121,352
25,444
16,193
8,706
8,251

Passaic Co. NJ

6,468

Monmouth Co. NJ

6,165

Morris Co. NJ
Total these 8 counties
% in these 8 counties

4,806
197,835
84.1%

190

 32
7. Location of Building, Maps of Area, and TEA Analysis
Figure 7-1. Location of 88 Morgan Street, Jersey City

4.!

~:t,

t:r

.;

J

191

 33
Figure 7-2. Location of Building in the 8-County Area

P1~~

Island
VVIII'WI<:i<

Vernon,

wI

I

192

 34

Figure 7-3. County Map of New Jersey

      

     

  


 

 

         
    

  



191'!

    
 






WW
3 







 
  
  
   

 

 



     
  
 
  
 

   
   
 
 

  


?a 


  
   
 
 
 

      



 

 

 
 
   
 

193

35

TEA Analysis
A TEA can be formed from CTs 3,4,5,6,7,8,11, 12,01,12.02, 15, 22,23, 25, 26,
30, 31, 32 33, 44, 45,46,50, 51, 52, 53, and 55; the locations of these CTs are shown in
Figure 7-4. The Property is located in CT 26. A letter of certification is expected from
the New Jersey Department of Labor.

Figure 7-4. Census Tract Map of Jersey City

194

 36
8. Economic Impact of Construction Expenditures

(b)(4)

Table 8-1 shows the total development budget otl
I Of this
amount, about I
lis EB-5 eligible hard construction costsl
lis
architectural, engineering, and related fees, andl
is purchases of furniture,
fixtures, and equipment (FF&E). The remaining 1
consists primarily of land
costs, interest costs, contingencies, and fees. The total a
I in EB-5
eligible hard construction costs used in the RIMS II calculation expressly excludes, the
ures stated in the Detailed Construction Budget set out in Table 8-2: (i)
n Construction Contingency; (ii) I
tor Bond Completion, and (iii)
or Jersey City Police.

U

Table 8-1. Sources and Uses of Funds

(b)(4)

The details of the budget are given in Table 8-2. We have subtracted certain
items from the Hard Cost figure given in Table 8-1 that are not EB-5 eligible; the
remaining amount includes building, parking, and site preparation. EB-5 eligible soft
costs are architectural, engineering, and surveying fees. THE FIGURES FOR THE
CONTINGENCY ALLOWANCE, JERSEY CITY POLICE, BOND COMPLETION AND
INSURANCE HAVE BEEN EXCLUDED FROM THE HARD COST CALCULATIONS

195

 37
Table 8-2. Detailed Construction Budget

Development Budget

(b)(4)

In general, USCIS has indicated that current-dollar numbers should be deflated
to the year in which the input/output coefficients were calculated, which in this case is
2008. For construction expenditures, however, prices have actually dropped since then,
as shown in the Turner construction index.
The estimated values used in the impact analysis are as follows: 2012, 829;
2013, 845, and 2014, 862 (a 2% annual growth rate). For projects being constructed in
2013 and 2014, the average level would be 854, which is well below the 908 level
reached in 2008.

196

 38
Quarter

Index:

fl.%

3rd Quarter 201.2

832

0.73

2nd Quarter 2012
1st Quarter 2012
4th Quarter 201.1

826
821
818

0,61
0.37
0.49

Year

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999

··Average Index
812
799
832
908
854
793
717
655
621
619
613
595
570

1.6
-4.0
-8A

6.3
7.7

10.6
9.5
5A

0.3
1.0
3.0
4.4
3.8

Turner has prepared the construction cost forecast for more than 80 years. Used
widely by the construction industry and Federal and State governments, the building
costs and price trends tracked by The Turner Building Cost Index may or may not reflect
regional conditions in any given quarter. The Cost Index is determined by several
factors considered on a nationwide basis, including labor rates and productivity, material
prices and the competitive condition of the marketplace. This index does not necessarily
conform to other published indices because others do not generally take all of these
factors into account. Further information about this index is available at:

http://www.turnerconstruction.com/cost-index
The next six tables show the economic impact of (a) hard construction costs, {b)
EB-5 eligible soft costs, and (c) purchases of FF&E. In all cases, the tables show the
impact for the 20 major industrial classifications in the RIMS II input/output model; in all
cases, only indirect and induced impacts are included. Please note that in these and
succeeding tables, output and earnings are given in thousands of dollars.

197

 39

Table 8-3. Increase in Employment, Output, and Earnings for Hard Construction
Costs of 88 Morgan Street
(b)(4)

Table 8-3 shows there will be a total of I
liobs created from the hard
on costs of the 88 Morgan Street building. Output would rise aboutl
Table 8-4
hile household earnings would increase by aboutl
average rtput per new worker is about
!Nhde average earnings
are about

Ci

I

(b)(4)

Table 8-4. Output and Earnings Per New Worker, Hard Construction Costs for 88
Morgan Street

198

 40

(b)(4)

For equipment purchases, USCIS has agreed to count jobs indirectly created
outside the geographical boundaries of a Regional Center (RC) in determining whether
the RC's business plan complies with EB-5 regulations. The policy change was
expressed in a December 3, 2010, letter from USC IS Director Alejandro Mayorkas in
response to a letter from Senator Patrick Leahy, Chairman of the Senate Judiciary
Committee.
Mayorkas wrote: "USC IS interprets the law to require that a regional center focus
its EB-5 capital investment activities on a single, contiguous area within the defined
geographic jurisdiction requested by the regional center. Nevertheless, we agree that
the law does not further mandate that all indirect job creation attributable to a regional
center take place within that jurisdiction. I will, therefore, ensure that USCIS policy
reflects this understanding of the law."
The regulations include the following language: "The regulation at 8 CFR
204.6.(m) provides [that] ... Each regional center ... shall submit a proposal, which ...
Contains a detailed prediction regarding the manner in which the regional center will
have a positive impact on the regional or national economy in general as reflected by
such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the regional
center" (emphasis added).
It is highly unlikely that the FF&E is manufactured in the NYC area, and we are
not making that claim. One possibility is to use the indirect and induced jobs created by
the production of the FF&E outside the regional center. The justification for this
approach is as follows:

199

 41

The regulations include the following language: "The regulation at 8 CFR
204.6.(m) provides [that] ... Each regional center ... shall submit a proposal, which ...
Contains a detailed prediction regarding the manner in which the regional center will
have a positive impact on the regional or national economy in general as reflected by
such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the regional
center" (emphasis added).
The drawback to that approach, however, is that in general no information is
available indicating the jurisdiction where the FF&E was produced, so we do not know
which set of multipliers to use. Hence we have used an alternative approach, which is
to claim that the indirect and induced jobs created by the installation of the FF&E in the
NYC area can be legitimately included in the EB-5 job count.
These jobs would include all of the activities that occur within the region:
transportation and distribution of the FF&E to the hotel site, purchasing margins at the
wholesale and possibly retail level, and most importantly, the construction jobs that are
used in the installation of the FF&E. This generally involves substantial construction
activity in terms of installing bathroom fixtures, electronic equipment,
telecommunications systems, and other construction jobs associated with preparing the
hotel rooms for clients. For this reason, then, the FF&E calculations are based on the
indirect and induced final demand and employment multipliers for the
construction sector.

Table 8-5. Increase in Employment, Output, and Earnings, Purchases of FF&E
for 88 Morgan Street, Indirect and Induced Effects Only

(b)(4)

200

 42

(b)(4)

the
(b)(4)

Table 8-5 shows there will be a total of Oindirect and induced jobs created from
rcha es of FF&E for the 88 Morgan Street building. Output would rise about
while household earnings would increafe by about~
ITable 8-6

~output per new worker is about

:hile average earnings

are about L___..J

Table 8-6. Output and Earnings Per New Worker, Purchases of FF&E for 88
Morgan Street, Indirect and Induced Effects Only

(b)(4)

-

201

 43
In terms of what soft costs are EB-5 eligible, we rely on the information given in
the NAICS coding manual, which is summarize as follows:
541310 Architectural Services
This industry comprises establishments primarily engaged in planning and designing residential,
institutional, leisure, commercial, and industrial buildings and structures by applying knowledge of design,
construction procedures, zoning regulations, building codes, and building materials.

541330 Engineering Services
This industry comprises establishments primarily engaged in applying physical laws and principles of
engineering in the design, development, and utilization of machines, materials, instruments, structures,
processes, and systems. The assignments undertaken by these establishments may involve any of the
following activities: provision of advice, preparation of feasibility studies, preparation of preliminary and
final plans and designs, provision of technical services during the construction or installation phase,
inspection and evaluation of engineering projects, and related services.

236220 Nonresidential Building Construction
This industry comprises establishments primarily responsible for the construction (including new work,
additions, alterations, maintenance, and repairs) of commercial and institutional buildings and related
structures, such as stadiums, grain elevators, and indoor swimming facilities. This industry includes
establishments responsible for the on-site assembly of modular or prefabricated commercial and
institutional buildings. Included in this industry are commercial and institutional building general
contractors, commercial and institutional building operative builders, commercial and institutional building
design-build firms, and commercial and institutional building project construction management firms.

Table 8-7. Increase in Employment, Output, and Earnings for EB-5 Eligible Soft
Construction Costs of 88 Morgan Street Project
(b)(4)

~----------------------------------------------------------------~-

202

 "'

Department of Homeland Securicy

I-797E, Notice of Action

U.S. Citizenship and Immigration Servit.... ;
A#

Application/Petition

Receipt#

Applicant/Petitioner

1924, Application for Regional Center under Immigrant Investor Pilot Program

RCW1236250925
Notice Date

February 20, 2013

U. S. Immigration Fund-N J

I1 of7

Beneficiary

Page

Ignacio A Donoso
FosterQuan, LLP
Re: U. S. IMMIGRATION FUND-NJ

Request for Evidence

600 Travis St., Suite 2000
Houston, TX 77002

RETURN THIS NOTICE ON TOP OF THE REQUESTED INFORMATION
LISTED ON THE ATTACHED SHEET.

May 15, 2013

Note: You are given until
the address at the bottom of this notice.

in which to submit the requested information to

Please note the required deadline for providing a response to this Request for Evidence. The deadline
reflects the maximum period for responding to this RFE. However, since many immigration benefits are
time sensitive, you are encouraged to respond to this request as early as possible but no later than the date
provided on the request.
Pursuant to 8 C.F.R.103.2(b)(ll) failure to submit ALL evidence requested at one time may result in
the denial of your application.
For more information, visit our website at WWW. USCiS.gOV
Or call us at

1-800-375-5283

Telephone service for the hearing impaired: 1-800-767-1833
CSC4639 WS25097 DIV Ill MP

For non-US Postal Service
Attn: I!B 5 RC Proposal
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677

You will be notified separately about any other applications or petitions you filed. Save this notice. Please enclose a copy of it
if you write to us about this case, or if you file another application based on this decision. Our address is:
USCIS ·CALIFORNIA SERVICE CENTER
P.O. BOX 10590
LAGUNA NIGUEL, CA 92607-0590
800-375-5283

111111111111111111111111111111111111111111111111111111111111111111111111111

RCW1236250925
Fonn I-797E
203

 U.S. Immigration Fund
Page 2

NJ I RCW1236250925 I ID1236250925

A request for initial designation as a Regional Center under the Immigrant Investor Program ("Program")
or an amendment to an existing Regional Center designation, may involve:
1. A request for review of an exemplar Form I-526, Immigrant Petition by Alien Entrepreneur, prior
to the filing of Form I-526 petitions by individual alien entrepreneurs with USCIS and/or;
2. In the case of a Regional Center amendment request, a review of a new specific capital investment
project where the Regional Center designation involved a review of an exemplar capital
investment project.
It appears that the applicant is requesting initial designation as a Regional Center under the Program.
I. Background:

The proposed Regional Center entity, U.S. Immigration Fund- NJ, LLC (USIFNJ), was established on
December 7, 2012 in the state of New Jersey, and is structured as a Limited Liability Company. USIFNJ is
requesting jurisdiction over a geographic area within the State of New Jersey, including the following
counties: Bergen, Essex, Hudson, Middlesex, Monmouth, Morris, Passaic and Union Counties. USIFNJ
plans to offer EB-5 capital investment opportunities in affiliated new commercial enterprises, organized as
Limited Partnerships and focusing on projects in the following industry categories:
Regional Center NAICS Codes
NAICS
Code
2362

2361

Industry Title
Nonresidential

Building

Construction
Residential

Valid?

Applicable?

Yes

Yes, this NAICS code applies to the hard
construction of the mixed-use residential and
retail facility.

Building

Construction

Yes, this NAICS code applies to the hard
Yes

construction of the mixed-use residential and
retail facility.
Yes, this NAICS code applies to leasing and

5313

Real Estate Property Managers

Yes

management operations of the mixed-use
residential and retail facility.

5413

Architectural, Engineering, and
Related Services

Yes, this NAICS code applies to the soft
Yes

construction of the mixed-use residential and
retail facility.

The capital investment projects will involve a combination of an equity investment and loan to job
creating enterprises located within the proposed bounds of the Regional Center.
The applicant's proposed project, 88 Morgan Street Funding, LLC, involve~ the construction and operations
of a SO-story luxury rental apartment building in Jersey City, Hudson County, New Jersey. The project will

ATTACHMENT TO l-797

204

 U.S. Immigration Fund
Page 3

(b)(4)

NJ I RCW1236250925 I ID1236250925

consist of 417 rental apartment units, 217 parking spaces, and approximately 4,000 sguare feet of retail
~nt to Trump Plaza I. The applicant estimates that the project will cost ~
~f which
L___Jwill be fromOmmigrant investors, and generate approximatelyDobs.

II. Evidentiary Requirements for Regional Center Proposals
8 CFR 204.6 (m)(3), which is appended to this notice, describes the evidence that must be submitted in
support of a Regional Center proposal. After review of the proposal, the following information, evidence
and/ or clarification is required. Note that in response to this notice, that it is helpful to provide a cover
letter that acts as an executive summary, followed by a table of contents with sections that are tabbed at the
bottom of the page.
A. Construction Timeline
The applicant asserts that construction will sparr--lonths, beginning with excavation in February or
March, 2 0 13 and ending with the acquisition ~emporary certificate of occupancy in April 2 0 15.
However, the timeline lacks verifiable detail.
•

Please present a detailed and itemized construction timeline showing all relevant phases of the
construction effort.

•

Also, please provide transparent, objective, and verifiable data illustrating that the proposed
construction timeline and budget are within a reasonable range when compared to industry
standards.

The applicant solicited the expertise of Evans, Carroll & Associates (Evans-Carroll) to conduct the economic
impact analysis. Evans-Carroll calculates the potential economic impacts of the construction and operations
of a 417 -unit luxury apartment tower in Jersey City, Hudson County, New Jersey.
The Economic Impact Model used is RIMS II calibrated for the counties of Hudson, Essex, Union, Bergen,
Passaic, Morris, Monmouth, and Middlesex.
Model. Inputs (initial change in final demand, initial change in direct jobs, etc.) are as follows:

lin

(b)(4)

estimated hard construction costs from the pro
1. Hard Construction: Evans-Carroll used
forma financial section of the business plan as an input into the RIMS II model.
a. Transparency: The parameters are transparent. They are clearly sourced from the pro forma
financial section of the business plan.
b. Applicability: The parameters are not applicable. The hard construction costs are inflated due to
the inclusion of contingency costs and police fees.

ATTACHMENT TO I-797

205

 U.S. Immigration Fund- NJ I RCW1236250925 I ID1236250925
Page 4

c.
d.

Reliability: The parameters are not reliable. They are not supported by verifiable data and
analysis or a comparison to industry standards.
Up-to-Date: The parameters appear up-to-date.
•

Please resolve Issues b. and c.

(b)(4)

I

2. FF&E: Evans-Carroll uses
~ estimated FF&E costs from the pro forma financial section
of the business plan as an input into the RIMS II model
a. Transparency: The parameters are transparent. They are clearly sourced from the pro forma
financial section of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are not reliable. They are not supported by verifiable data and
analysis or a comparison to industry standards.
d. Up-to-Date: The parameters appear up-to-date.
•

Please resolve Issue c.

(b)(4)

Jn

3. Operations: Evans-Carroll uses!
estimated annual apartment rental income from the
pro forma financial section oft e business plan costs as an input into the RIMS II model
a. Transparency: The parameters are transparent. They are clearly sourced from the market
analysis and pro forma financial section of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are reliable. The market analysis presents competing developments
that substantiate most of the revenue assumptions used in the analysis.
d. Up-to-Date: The parameters appear up-to-date.

(b)(4)

lin

4. Soft Construction: Evans-Carroll usesl
estimated soft construction costs from the pro
forma financial section of the business plan as an input into the RIMS II model
a. Transparency: The parameters are transparent. They are clearly sourced from the pro forma
flnancial section of the business plan.
b. Applicability: The parameters are applicable.
c. Reliability: The parameters are not reliable. They are not supported by verifiable data and
analysis or a comparison to industry standards.
d. Up-to-Date: The parameters appear up-to-date.
•

Please resolve Issue c.

III. General issues

Translations:
Any document containing a foreign language submitted to USCIS shall be accompanied by a full English
translation that the translator has certified as complete and accurate, and by the translator's certification that
he or she is competent to translate from the foreign language into English.

ATTACH!vfENT TO I-797

206

 U.S. Immigration Fund- NJ I RCW1236250925 I ID1236250925
Page 5

Copies:
Unless specifically required that an original document be filed with an application or petition, an ordinary
legible photocopy may be submitted. Original documents submitted when not required will remain part of
the record, even if the submission was not required.

NOTES:
Any document submitted to the USCIS containing a foreign language, must be accompanied by a full English language translation that
has been certified by the translator as complete and accurate, and that the translator is competent to translate from the foreign language
into English. Submit clear and legible copies of all requested evidence. If clear and legible copies are not possible, submit the original
documents. These originals will be returned, if requested.

Please provide an index of any submitted evidence and include corresponding tabs for each section of evidence.

IV. Regulatory References
The regulation at 8 CFR 103.2(a)(3) provides the following definitions:
(3) Representation. An applicant or petitioner may be represented by an attorney in the United States,
as defined in 1.1 (f) of this chapter, by an attorney outside the United States as defined in 2 92 .1 (a) (6)
of this chapter, or by an accredited representative as defined in 292.1 (a) (4) of this chapter. A
beneficiary of a petition is not a recognized party in such a proceeding. An application or petition
presented in person by someone who is not the applicant or petitioner, or his or her representative as
define~ in this paragraph, shall be treated as if received through the mail, and the person advised that
the applicant or petitioner, and his or her representative, will be notified of the decision. Where a
notice of representation is submitted that is not properly signed, the application or petition will be
processed as if the notice had not been submitted.
The regulation at 8 CFR 204.6(e) provides the following definitions:
Qualifying employee means a United States citizen, a lawfully admitted permanent resident, or other
immigrant lawfully authorized to be employed in the United States including, but not limited to, a
conditional resident, a temporary resident, an asylee, a refugee, or an alien remaining in the United States
under suspension of deportation. This definition does not include the alien entrepreneur, the alien
entrepreneur's spouse, sons, or daughters, or any nonimmigrant alien.
Regional center means any economic unit, public or private, which is involved with the promotion of
economic growth, including increased export sales, improved regional productivity, job creation, and
increased domestic capital investment.
The regulation at 8 CFR 204.6(j)(4) provides:

ATTACHMENT TO I-797

207

 U.S. Immigration Fund
Page 6

NJ I RCW1236250925 I ID1236250925

Job creation -(i) GeneraL To show that a new commercial enterprise will create not fewer than ten (1 0) full-time
positions for qualifying employees, the petition must be accompanied by:
(A) Documentation consisting of photocopies of relevant tax records, Form I-9, or other similar documents
for ten ( 10) qualifying employees, if such employees have already been hired following the establishment
of the new commercial enterprise; or
(B) A copy of a comprehensive business plan showing that, due to the nature and projected size of the new
commercial enterprise, the need for not fewer than ten (10) qualifying employees will result, including
approximate dates, within the next two years, and when such employees will be hired.
(ii) Troubled business. To show that a new commercial enterprise which has been established through a
capital investment in a troubled business meets the statutory employment creation requirement, the
petition must be accompanied by evidence that the number of existing employees is being or will be
maint~ined at no less than the pre-investment level for a period of at least two years. Photocopies of tax
records, Forms I-9, or other relevant documents for the qualifying employees and a comprehensive
business plan shall be submitted in support of the petition.
(iii) Immigrant Investor Pilot Program. To show that the new commercial enterprise located within a
regional center approved for participation in the Immigrant Investor Pilot Program meets the statutory
employment creation requirement, the petition must be accompanied by evidence that the investment will
create. full-time positions for not fewer than 10 persons either directly or indirectly through revenues
generated from increased exports resulting from the Pilot Program. Such evidence may be demonstrated by
reasonable methodologies including those set forth in paragraph (m) (3) of this section.
The regulation at 8 CFR 204.6(m)(l) provides:
( 1) Scope. The Immigrant Investor Pilot Program is established solely pursuant to the provisions of
section 610 of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies
Appropriation Act, and subject to all conditions and restrictions stipulated in that section. Except as
provided herein, aliens seeking to obtain immigration benefits under this paragraph continue to be
subject to all conditions and restrictions set forth in section 203(b)(5) of the Act and this section.
The regulation at 8 CFR 204.6(m)(3) provides:
(3) Requirements for regional centers. Each regional center wishing to participate in the Immigrant
Investor Pilot Program shall submit a proposal to the Assistant Commissioner for Adjudications, which:

ATTACHMENT TO I-797

208

 U.S. Immigration Fund NJ I RCW1236250925 I ID1236250925
Page 7

(i) Clearly describes how the regional center focuses on a geographical region of the United States,
and how it will promote economic growth through increased export sales, improved regional
productivity, job creation, and increased domestic capital investment;
(ii) Provides in verifiable detail how jobs will be created indirectly through increased exports;
(iii) Provides a detailed statement regarding the amount and source of capital which has been
committed to the regional center, as well as a description of the promotional efforts taken and
planned by the sponsors of the regional center;
(iv) Contains a detailed prediction regarding the manner in which the regional center will have a
positive impact on the regional or national economy in general as reflected by such factors as
increased household earnings, greater demand for business services, utilities, maintenance and
repair, and construction both within and without the regional center; and
(v) Is supported by economically or statistically valid forecasting tools, including, but not limited
to, feasibility studies, analyses of foreign and domestic markets for the goods or services to be
exported, and/ or multiplier tables.
Note that promoting economic growth through increased export sales is no longer a requirement.

The regulation at 8 CFR 204.6(m)(6) provides:
(6) Termination of participation of regional centers. To ensure that regional centers continue to meet the
requirements of section 610(a) of the Appropriations Act, a regional center must provide USCIS with
updated information to demonstrate the regional center is continuing to promote economic growth,
improved regional productivity, job creation, or increased domestic capital investment in the approved
geographic area. Such information must be submitted to USCIS on an annual basis, on a cumulative basis,
and/or as otherwise requested by USCIS, using a form designated for this purpose. USCIS will issue a
notice of intent to terminate the participation of a regional center in the pilot program if a regional center
fails to submit the required information or upon a determination that the regional center no longer serves
the purpose of promoting economic growth, including increased export sales, improved regional
productivity, job creation, and increased domestic capital investment. The notice of intent to terminate
shall be made upon notice to the regional center and shall set forth the reasons for termination. The
regional center must be provided 30 days from receipt of the notice of intent to terminate to offer
evidence in opposition to the ground or grounds alleged in the notice of intent to terminate. If USCIS
determines that the regional center's participation in the Pilot Program should be terminated, USCIS shall
notify the regional center of the decision and of the reasons for termination. As provided in 8 CFR 103.3,
the regional center may appeal the decision to US CIS within 30 days after the service of notice

ATTACHMENT TO I-797

209

 1B No. 1615-0105; Expires 04/30/2012

Department of Homeland Security

G-28, Not·. x of Entry of Appeara~e
as Attorney Oli' Accredited Representative

Part 1. Notice of Appearance as Attorney or Accredited

Representativ~

A. This appearance is in regard to immigration matters before:
171

l!J

.
~
1-924
USCIS -List the 10nn number(s): - - - - - - - - - -

D CBP - List th:l! specific matter in which appearance is entered:

ICE - List the specific matter in which appearance is entered:

B. 1 hereby enter my appearance as attorney or accredited representative at the re~~;uest of:
List Petitioner, Applicant, or Respondent. NOTE: Provide the mailing address of Petitioner, A~pplicant or Respondent being represented, and
not the address of the attorney or accredited representative, except when filed under VAWA. ·
'
Principal Petitioner, Applicant, or Respondent
First

Name: Last

A Number or Receipt
Number, if any

Middle

Petitioner

lZJ Applicant

US IMMIGRATION FUND-ttl LLC

0

Apt. No.

A.
City

STE 300

NORTH PALM t3EACH

MASTROIANNI, II

0

(

Respondent

State

Zip Code

FL

33408

named Attorney or Accredited Representative of any
Date
NOVEMBER 2, 2012

Part 2.
A.

[{] I am an· orney and a member in good standing of the bar of the hig~.test court(s) of the following State(s), possession(s), territory(ies),
commonwealth(s), or the District of Columbia: Califomia
I am not GZJ or 0 am subject to any order of any court 1)-'1" administrative agency disbarring, suspending, enjoining,
restraining, or otherwise restricting me in the practice oVtaw (If you are subject to any order(s), explain fully on reverse side).
I am an accredited representative of the following qualifi~d non-profit religious, charitable, social service, or similar organization
established in the United States, so recognized by the D;epartment of Justice, Board oflmmigration Appeals pursuant to 8 CFR 1292.2.
Provide name of organization and expiration date of ?..ccreditation:

B.

C.

out Attorney or Accredited Represr.:ntative (Check applicable items(s) below)

0

I am associated with
The attorney or accredited representative of record previously filed Form G-28 in this case, and my appearance as an attorney or
accredited representative is at his or her re•..juest (Ifyou check this item, also complete item A orB above in Part 1, whichever is
appropriate).

Part 3. Name and Signature of Attorney or Accredited Representative
I have read and understand the regulations and conditions contained in 8 CFR 103.2 and 292 governing appearances and representation
before the Department of Homeland Security. I declare under penalty of perjury under the laws of the United States that the information I
have
on this form is true and correct.
Name of Attorney or Accredited Repres0ntative
Attorney Bar Number(s), if any

178883
Signature of ttorney or ~iteli R resentative

./{,(?(£'~) I',_~. ~-LD--·
Compl

Date

NOVEMBER 3c ,2012

Address of Attorney r Or nization of Accredited Representative (Street Number and Street Name, Suite No., City, State, Zip Code)
uan, LLP, 600 Travis St., Sui 000, Houston, Texas 77002, USA

Phone Number (Include area code)

Fax Number, if any (Include area code)

E-Mail Address, if any

(713) 335-3993

{713) 228-1303

idonoso@fosterquan.com
Form G-28 (Rev. 04122109)N

FosterQuan, LLP

210

 ,

.
'

r .viR No. !615-0061; Expires 09/30/2012

Form 1~924, Application for Regional Center
Under the Immigrant Investor Pilot Program

Department. of Homeland Secul'ity
US. Citiz\!nship and lrnmigration Services

Fe
111111111 1111111111111111111111111111111111111111111111111111111111 11111111

RCW1236250925
egarcia2

1924

12/21/2012

[g) G-28 attached
A ttomey's State License No.
178883

Pat·t 1. Information About Principal of tbc Regional Center
1\amc:

CiO:

Last

First

/Middle

MASTROIANNI

UICHOLAS

Ill..

U.S. IMtviiGRATION FUND-NJ, LLC

~tr~d

Addrcss/P.O. Box:

1295 U.S. HIGHWAY 1, SUl'l'F: 300

NORTE PALM BEACH

(b)(6)

······-···---~~:;;;;;;;;;;;~~~~-----11~~~~---···········

Fax Number
(include area code):

ll;Jtc: of Birth
(mmiL!d/yyyy):

'Ncb site address:

WHW.

Part 2.

5617990061

5617991883

visaeb-5. com

Type (Check

a. Initial Application for Designation as a Regional Center

h. Amendment to an approved Regional Center application. Note the previous application receipt number, if any (also attach the
Regional Center's previous approval notice):
--~~~------------~~~--------------------

Part 3. Information About the

Center

a continuation sheet, if needed, to provide infonnation for additional management companies/agencies, Regional Center

mm,·'"""" agents, individuals or entities who are or will be involved in the management, oversight, and administration of the regional
A. \lame of Regional Cenkr: U.S. H1MIGRATION
Strect/\ddress/P.O.Box:
~~------

..... ........................................
_.

FUND-NLT

129') TJ.S. EJGll\•IAY 1, SlL.'.I'E: 300

-···········--·-----~--------.-------------·······------·-----~------..,---

State: FL

NORTE PAU1 BEACH

W;;b site address:

1

----------

.. ................
-.

Zip Code: 33408

Fax Number (include area code): Telephone Number (include area code):

.visacb-S.com

561'7990061

5617991883

I
1

1111 111111111111/llllllllllllllltlltllllllllllllllllllllllllllltllllltlllllllllllllm

1 1 1 1~1 1 1 1 1 1 ~tl tl l tl

Form I-924 (11:231!0)

211

 It ~~amc of rv1anaging Company/Agency: G. S. IMJI.HGHATION FUND, LLC

Socci Address/P.O. Box:

95 U.S. l!ICHltJAY l, SUITE .300

Web site address:

area code):

.v.isaeb-5.com

:161 990061

C. Name of Other Agent N/A
S1rc.:t Addrcss/P.O. Box:

Web site

area code):

D. C\mtinuation, if needed. to provide information for additional management companies/agencies, regional center principals, agents,
mdividuals or entities who are or will be involved in the management, oversight, and administration of the regional center.)
ATTACHED OPERATIONS PLAN AT EXHIBIT 12.
Il'ANT FOR REGIONJ\1 CENTEP. DESIGN.td'JON.

(b)(4)

1

~:li 1 ~1 1 1~ /Il ~ IIIIIIJI/1 1 1~ I ~I~ Il ~ !I~ ~I ~ ~ 1 ~1 1~ ~1 1 ~ 1 1~1 1~ 1 ~1 1 1 1

Iill 111 IIIII

IJVE1IGRATION E'UN[l-NJ

LLC IS THE

~ED

U.S. IMMIGRATION FUND-N.T, LLC IS

I'1ANl\.GED BY C.S. HlJVJIGHATION FOND, LLC.

1

U.S.

U.S. H1MIGRATION FOND, LL

I

..:ol

_I

I

Form l-924 (lll23il0) Page 2

ill/Ill

212

 Part 3. Information About the Regional Center (Continued)
Nott: If extra space is needed to complete any item, attach a continuation sheet, indicate the item number, and provide the response.
Ia. Describe the structure, ownership and control of the regional center entity.

(b)(4)
~~.",. SF:~:

A'I'TACHED OPEHA'.LIONS PLAN A'f EXHIBIT 12.

L.__jr.l\\iNED BY U.S. H1!•liGH!,TION fmJD,

LLC.

U.S. H4MIGRAT10N FUND-tM, LLC IS

U.S. liVH"lTGRAT!ON r'UND-NJ, LLC v'HLL llil:v::: A

h. D.tlc the Regional Center was cstablishcd(mmidcL'yyyy): 2 012-12-0 7

,., Organinlion Structure for the Regional Center:
I. '\gency of a U.S. State or Territory (identify)

------------------------------------

2. Corporation
3. Partnership (i.ncluding Limited Partnership)
4. Limited Liability Company (LLC)

5. Other (Explain) - - -....................--.-.. . . . . . . ._. . . ..
2..
('t

tbis regional center's designation ever been formally terminated by USCJS, or has the regional center ever filed a Form J-924
regional center proposal or amendment that was denied?
1\n

Yes- Attach a copy of the adverse decision, with an explanation, the date of decision, and case number, if any.

J. Dcscnhc the geographic area of the regional center. Note: This area must be contiguous. Provide a map of the geographic area.

County;

I:;3sex

County;

H:1dson County;

£-jiddlesex

y; Monmouth County, Passaic County; Union County, and Morris County, in the State
~1APS

PLF.}\SS SEE

OY 'rEE REGION .I\1 CENTER 1 S TE.RF.ITORY .ii.TTACHFD TN EXHIBI'r

De~cribe

tht! regional center's administration, oversight, and management functions that are or will he in place to monitor aH EB-5
investment activities and the allocation of the resulting jobs created or maintained under the sponsorship of tl1e regional

1 1 ~1 ~lil:ili l ~i~l ~l il~lil ~llll~l!l~l!~lll~l~~l111~!11111 ~1f~~~~~~~~~~~~~

i

1

Form 1-924 (! 1/23110) Pagd

213

 Part 3. Information About the Regional Center (Continued)
8a. Describe and document the current and/or prospective structure of ownership and control of the commercial entity(s) in which the
EB-5 alien investors have or will make their capital investments.
THE REGIONAL CENTER WILL FORM NEW LIMITED I..IA0iL1f'( (ii:-IP41i•WO CONSTITUTE THE NEW COMMERCIAL
ENTERPRISE THAT WILL BE THE TARGET OF INVESTMENT FOR
FOREIGN INVESTORS. THE LIMITED
uMliLirfc:oHf'\N'{ WILL BE MANAGED BY A MM·~E.IZ.
, WHICH WILL BE A COMPANY OWNED OR
AFFILIATED WITH US IMMIGRATION FUND, LLC.

b. Date commercial enterprise established, if any (mm/dd/yyyy): N/A

------

c. Organization Structure for commercial enterprise:
1. Corporation

fJ
IRJ
0

2. Partnership (including Limited Partnership)

3. Limited Liability Company (LLC)
4. Other (Explain)

d. Has or will the Regional Center or any of its principals or agents have an equity stake in the commercial enterprise?

D

No

~

Yes - Attach an explanation and documentation that outlines when and under what circumstances these remittances
will be paid.

e. Has or will the Regional Center or any of its principals or agents receive fees, profits, surcharges, or other like remittances
through EB-5 capital investment activities from this commercial enterprise, beyond the minimum capital investment threshold
required of the EB-5 alien entrepreneurs?
No

~

Yes- Attach an explanation and documentation that outlines when and under what circumstances these remittances
will be paid.

Part 4. Applicant Signature Read the information on penalties in the instructions before completing this section. If
someone help,

ou prepare this petition, he or she must compete Part 5.

I certify, under penal ofp, jury under the laws of the United States of America, that this form and the evidence submitted with it are
all t
correct. au
e the release of any information from my records that U.S. Citizenship and Immigration Services needs
to etermin eligi ity r t e benefit being sought. I also certify that I have authority to act on behalf of the Regional Center.
Daytime Phone Number
(Area/Country Codes)
(561) 799-1883

Date (mmlddlyyyy)
11/02/2012

E-Mail Address

NICHOLAS A. MASTROIANNI, II
Relationship to the Regional Center Entity (Managing Member, President, CEO, etc.)

PRINCIPAL AND REPRESENTATIVE OF THE SOLE MANAGER, US IMMIGRATION FUND, LLC
Form 1-924 (11123110) Page 5

214

 45
9. Economic Impact of Rental Income for Apartments, Retail Space,
and Parking Space
The building at 88 Morgan Street will be primarily residential, containing 417
apartments, 214 parking spaces, and about 4,000 square feet of retail space.
According to the developer, the Jersey City market place is one of the strongest rental
markets in New Jersey. Rents at comparable developments are well over $40/sq ft and
occupancies hover in the high 90s. The operating assumptions are shown in Table 9-1.
Table 9-1. Operating Assumptions for 88 Morgan Street, Jersey City, NJ
(b)(4)

Jperating Assumptions

The monthly rentals for comparable apartment buildings in Jersey City are shown
in Table 9-2.

215

 46

Table 9-2. Comparable Rents in Jersey City

 

 

 

. . .. Rent wath

 

 

Wm
L.mm:ss

216

47
The total annual rental income entered into the RIMS II model is hence
calculated as follows, based on the operating projections provided by the developer.
The figures for "Year 4", which is the first full year of occupancy, are used for these
calculations.
Table 9-3. Operating Projections, first 4 Years, for 88 Morgan Street Building

Detailed Operating Projections
(b)(4)

(b)(4)

In the first full year of operation, gross potential rent would be I
I
however that figure must be reduced by an expected 3% vacancy rate, 0.5% loss for
bad debts, and first-year rent concessions (essentially one free month) that amount to
another~
Hence total apartment rentals after subtracting these items
equals
This figure is then boosted by the expected revenue for
parking spaces, retail income, and other fees. There are 214 parking spaces and an
average monthly fee ofc::::Jmonth, adjusted for the 3% vacancy rate and 0.5% loss for
bad debts. Retail space of 4,000 square feet is expected to rent forOper square
foot, which is well below the arrale for comparable locations. Finally, fees from other
income are expected to be
per month per occupied unit, with the first-year

I

217

 48
adjustment for one month of free rent. Summing all these factors indicates total annual
rental income of
ltor the first full year of operation.
(b)(4)

I

This figure is in 2016 dollars, while the input/output coefficients are based on
2008 dollars, so it must be deflated. The CPI for rental; income medium-sized cities
rose 1.6% per year from 2008 to 2012, as shown in Table 9-4, so continujng that rate
forward to 2016, the deflator would be 1.134, indicating rental income of
in 2008 dollars.
' - - - - - -....

I

(b)(4)

Table 9-4. CPI for Primary Rental Income, Medium-Sized Cities

The detailed industry results for 1
..___.....t in rental income are shown in the
next two tables.
(b)(4)

Table 9-5. Increase in Employment, Output, and Earnings, Rental Income for 88
Morgan Street Building, 2008 Dollars

218

 49

(b)(4)

I

Table 9-5 shows there would be an increase of0permanent new jobs f r o o
rental income of the 88 Morgan Street building.
Total output would rise about
I
land household earnings would increase by about
Table 9-6 s ows
with average annual earnings of about
output per new worker would be about

I

I

I

I

I

(b)(4)
Table 9-6. Output and Earnings Per New Worker, Rental Income for 88 Morgan
Street Building, 2008 Dollars

219

 50

 

 

 

 

220

51

10. Summary Statistics for the Construction and Rental Income for
the 88 Morgan Street Building
Tables 10-1 and 10-2 show the combined economic impact of constructing and
rental income for the 88 Morgan Street Building. These results are the summation of
the data given in Sections (8) and (9), so the individual cells simply represent the sum
(or average) of these figures in the previous two sections.
Table 10-1. Increase in Employment, Output, and Earnings for Construction and
Operation of the 88 Morgan Street Building
(b)(4)

(b)(4)

rot

Table 10-1 shows that c::Jpermanent new jobs would be created by the
construction and rental income for the 88 Morgan Street building. Output
rise bJj
aboutl
l and household earnings would increase by about
Table 10-2 shows that the average output per new worker would be about
while average annual earnings would be aboutl

I

221

 52

Table 10-2. Output and Earnings Per New Worker for Construction and Operation
of 88 Morgan Street Building

(b)(4)

222

 53

Appendix: Resume of Dr. Michael K. Evans
mevans@evanscarrollecon.com

CURRENT AND PREVIOUS POSITIONS
• Chairman, Evans, Carroll & Associates, Inc., 1980-present
Economics)

(previously Evans

Economic consulting firm specializing in EB-5 immigration analysis, economic
impact studies of development projects and new construction, models of state and local
tax receipts, impact of current and proposed government legislation, and construction of
econometric models for individual industries and companies.
• Chief Economist, American Economics Group, 2000-2008.
Built a comprehensive state modeling system that provides economic analysis for
a variety of consulting projects (see below).
• Clinical Professor of Economics, Department of Managerial Economics and Decision
Sciences (MEDS), Kellogg Graduate School of Management, Northwestern University,
1996-99.
Taught courses in macroeconomics and business forecasting. Wrote textbooks
for both courses.
• Winner of Blue Chip Economic Indicator Award for most accurate macroeconomic
forecasts during the past four years, November 1999
• Founder and President, Chase Econometric Associates, 1970-1980
• Assistant and Associate Professor of Economics, Wharton School, University of
Pennsylvania, 1964-69. Co-developer of the original Wharton Model.
• Visiting Professor, Radford University, (Radford, VA), 1987
Chairman of Institute for International Economic Competitiveness
• Visiting Lecturer, Hebrew University (Jerusalem), 1966-67
Built econometric model of the Israeli economy
• Ph. D. in Economics, Brown University. Dissertation, "A Postwar Quarterly Model of
the United States Economy, 1948-1962". A. B. in Mathematical Economics, Brown
University

223

 54

PREVIOUS ACTIVITIES AND EDUCATION
• Contributing Editor, Industry Week
Wrote a column in each issue on economic and financial trends as they impact
the manufacturing sector.
• Editor, The Evans Report
Weekly newsletter discussing economic trends and financial markets. Pioneered
the concept of the Monthly Tracking Model to incorporate recent economic releases into
the overall economic forecast, including methods to predict these economic data.
• Consultant, National Printing Equipment and Supply Association
Prepared quarterly forecasts of shipments of printing equipment and graphic arts
supplies by product line, based on an econometric model constructed for NPES. Also
prepares analysis and forecasts of exports and imports by principal product line.
• Consultant, APICS -- The Educational Society for Resource Management,
Designed and developed the APICS Business Outlook Index, which used survey
data collected by the Evans Group to measure current production, production plans,
shipments, employment, new orders, unfilled orders, inventory stocks, and the
comparison of the actual to desired inventory/sales ratio to predict short-term changes
in manufacturing sector activity. The results of this survey appeared every month in
APICS: The Performance Advantage
• Consultant, American Hardware Manufacturing Association
Wrote a separate weekly edition of the Evans Report analyzing recent trends in
the hardware and housing industries, including forecasts of the hardware industry based
on an econometric model developed for AHMA.
• Board of Economists, Los Angeles Times
Wrote column every 6 weeks (5 other economists on the Board)
• Columnist, United Press International
Wrote twice-weekly column, "Dollars and Trends"
• Consultant, Senate Finance Committee,

224

 55
Built the first large-scale supply-side model of the U.S. economy
• Consultant, Environmental Protection Agency and Council on Environmental Quality
Estimated inflationary impact of government regulations
• Consultant, National Aeronautics and Space Administration
Estimate impact of R&D spending on productivity growth
• Consultant, U.S. Treasury
Estimated impact of investment tax credit and accelerated depreciation on capital
spending by industry
• Consultant, U. S. Department of Agriculture
Built large-scale econometric model of agricultural sector of U.S. economy
• Consultant, Organization of Economic Cooperation and Development
Built econometric model of the French economy

SAMPLE OF RECENT CONSULTING PROJECTS
A. Economic Impact of EB-5 Immigrant Investor Programs and New Markets Tax
Credits
For more information on these projects, see www.evanseb5.com
Key to symbols: N, new regional center, E, extension of existing center
List is current as of November 5, 2010. Totals to date are 136 new regional centers, 72
extensions, and 7 new markets tax credits, for a total of 215 projects
N• Calculated the economic impact of the construction and operation of an assisted
living center in Santa Ana, CA
N• Calculated the economic impact of the construction and operation of several BBQ
restaurants in South Florida.
N• Calculated the economic impact of the drilling oil wells in 8 counties in Texas and
Louisiana.

225

 56
N• Calculated the economic impact of operating coal mines for metallurgical coal in
West Virginia.
N• Calculated the economic impact of operating gold mines in Alaska.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Flushing, NY
N• Calculated the economic impact of constructing and operating two hotels, one in
downtown San Diego, and one in Escondido, CA
N• Calculated the economic impact of expanding and operating an auto racing track in
Palm Beach, FL
N• Calculated the economic impact of building and operating mobile housing villages
for disaster relief.
N• Calculated the economic impact of operating an "incubator" for research on medical
devices, preparations, and services in Houston, TX.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Denver, CO.
N• Calculated the economic impact of constructing and operating a charter school in
Miami/Dade County, FL
E• Calculated the economic impact of constructing and operating a hotel in Manhattan,
NY
N• Calculated the economic impact of constructing and operating hotels, assisted living
centers, and mixed-use commercial buildings in 8 counties in Southern California
N• Calculated the economic impact of constructing and operating a charter school in
Broward County, FL
N• Calculated the economic impact of renovating a former public housing project in
Chicago, IL
N• Calculated the economic impact of starting a high-tech company for optical displays
in Orlando and Gainesville, FL
N• Calculated the economic impact of constructing and operating luxury hotels in four
Southern California counties
E• Calculated the economic impact of expanding a manufacturing company in Ann
Arbor, Ml

226

 57
N• Calculated the economic impact of reconverting an old mill building into offices and
other commercial uses in Bristol County, MA

N• Calculated the economic impact of a film and TV production studio in Los Angeles,
CA
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings in 35 Texas counties.
N• Calculated the economic impact of constructing and operating the world's tallest
residential structure in Chicago, IL

N• Calculated the economic impact of constructing and operating a mixed-use
commercial and residential building in Seattle, WA

N• Calculated the economic impact of constructing and operating a hotel in Cleveland,
OH
N• Calculated the economic impact of a research facility in Jupiter, FL
N• Calculated the economic impact of constructing and operating an assisted living
center in Harry County, SC
N• Calculated the economic impact of constructing and operating a chain pharmacy in
Chicago, IL
E• Calculated the economic impact of constructing and operating a high-end hotel and
resort in Aspen, CO
N• Calculated the economic impact of constructing and operating an assisted living
center in Dallas, TX
E• Calculated the economic impact of constructing and operating an medical
assistance company in Bronx, NY
E• Calculated the economic impact of constructing and operating a mixed-use
commercial building in Queens, NY
E• Calculated the economic impact of operating a livery service in Queens, NY
N• Calculated the economic impact of constructing and operating residential properties
in Southern California
N• Calculated the economic impact of operating a film and TV production studio in Los
Angeles, CA
N• Calculated the economic impact of drilling oil wells in Montana

227

 58

N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for 43 counties in Texas
E• Calculated the economic impact of constructing and operating a restaurant and
dinner theater in Guam

N• Constructed an input/output model for the Commonwealth of the Northern Mariana
Islands, and used it to calculated the economic impact of constructing and operating a
restaurant in Saipan.
E• Calculated the economic impact of constructing and operating a new hotel in Miami,
FL

E• Calculated the economic impact of constructing and operating a resort and wellness
center in South Florida
N• Calculated the economic impact of expanding and operating a ski resort in
Vermont.
N• Calculated the economic impact of constructing and operating residential and
commercial buildings in 20 counties in South Central Texas
N• Calculated the economic impact of constructing and operating a hotel near the
Newark, NJ airport
E• Calculated the economic impact of constructing and operating a company to
process health insurance benefits in South Florida
E• Calculated the economic impact of constructing and operating a veterinary hospital
in Palm Beach County, FL
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for all counties in MA, CT, Rl, and NH
N• Calculated the economic impact of constructing and operating a residential
construction company in Maryland
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for the entire state of Oklahoma
N• Calculated the economic impact of constructing and operating a company for
manufacturing dental implants in Cuyahoga County, OH
N• Calculated the economic impact of constructing and operating a mixed-use
commercial facility in Brooklyn, NY

228

 59
N• Calculated the economic impact of constructing and operating an office building for
financial services in downtown Manhattan, NY
N• Calculated the economic impact of constructing and operating a mixed-use facility
in Southern California
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a mixed-use
commercial building in Seattle, WA
N• Calculated the economic impact of constructing and operating a charter school in
Arizona
N• Calculated the economic impact of constructing and operating a resort in
northeastern Utah
N• Calculated the economic impact of operating an online video game company
N• Calculated the economic impact of constructing and operating a hotel in New York
City
N• Calculated the economic impact of constructing and operating a fashion mall in
South Florida
E• Calculated the economic impact of construction and operation of a new automobile
assembly plant in Petersburg, VA
N• Calculated the economic impact of operating a call center for the U.S. government
in Muskogee, OK
N• Calculated the economic impact of developing a mixed-use commercial and
residential center in Scottsdale, AZ
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in New Jersey to process waste material on a pollution-free basis.
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in Washington State to process waste material on a pollution-free basis.
E• Calculated the economic impact of constructing and operating a new hotel in Coral
Gables, FL

229

 60

E• Calculated the economic impact of developing a new residential community in
Brevard County, and retail stores and restaurants in St. Lucie County, FL
N • Calculated the economic impact of a new business to store and process field crops
in Madison, MS
N• Calculated the economic impact of operating food service establishments and
assisted living centers in 40 counties in Texas.
E• Calculated the economic impact of developing a mixed-use commercial center in
Miami, FL
N• Calculated the economic impact of renovating a theater in New York City to show
film highlights of previous Broadway hits.
N• Calculated the economic impact of renovating and operating distressed buildings in
the San Francisco Bay area.
E• Calculated the economic impact of a mixed-use commercial center in Montgomery
County, TX
E• Calculated the economic impact of expanding a manufacturing facility to produce
more energy-efficient lighting in Sarasota, FL
N• Calculated the economic impact of developing facilities for amateur sporting events
in northern GA
N• Calculated the economic impact of developing a mixed-use commercial center in
Missoula, MT
N• Calculated the economic impact of operating call centers in Las Vegas, NV, and
other western Nevada counties
E• Calculated the economic impact of constructing and operating a proton cancer
treatment center in Boca Raton, FL
E• Calculated the economic impact of constructing and operating a "Green Box" facility
in Detroit to process waste material on a pollution-free basis.
E• Calculated the economic impact of renovating and expanding commercial property
in Lower Manhattan
N• Calculated the economic impact of constructing student housing and retail stores in
Davie, FL

230

 61
E• Calculated the economic impact of constructing residential housing near Harvard
University
E• Calculated the economic impact of developing mixed-use commercial centers in
Broward County, FL
E• Calculated the economic impact of renovating a Dallas apartment building
E• Calculated the economic impact of renovating and operating a nursing home in Las
Vegas, NV
E• Calculated the economic impact of constructing a hotel and shopping center in
Miami, FL
E• Calculated the economic impact of developing a design center in Miami/Dade
county, FL
E• Calculated the economic impact of developing and operating a chain of children's
playrooms and party facilities in South Florida
E• Calculated the economic impact of developing a new stadium for the Nets
basketball team, to be located in Brooklyn, NY
E• Calculated the economic impact of developing a Marriott hotel in Washington, D.C.
E• Calculated the economic impact of developing and operating a casino for foreign
patrons in Las Vegas, NV
E• Calculated the economic impact of operating a series of yogurt fast-food restaurants
in South Florida
E• Calculated the economic impact of constructing steel homes and commercial
buildings in South Florida
N• Calculated the economic impact of construction and operation of a farm
distillery in Vermont
N• Calculated the economic impact of purchase and renovation of deeply discounted
residential properties in South Florida
N• Calculated the economic impact of a hotel to be built near LaGuardia Airport in
Queens, NY
N• Calculated the economic impact for several mixed-use commercial and residential
properties for a regional center covering southern Wisconsin and northern Illinois.

231

 62
N• Calculated the economic impact for mixed-use commercial project in Flushing, NY
E• Calculated the economic impact for major new hotel near the Washington, D. C.
conference center
N• Calculated the economic impact of an assisted living center in suburban Atlanta,
GA
N• Calculated the economic impact of an office tower in mid-town Manhattan for the
diamond trade
N• Calculated the economic impact of three mixed-use commercial and residential
projects in Santa Clara County, CA
N• Calculated the economic impact of six mixed-use commercial and residential
projects in Los Angeles, Orange, Riverside, and San Bernardino counties
N• Calculated the economic impact of operating a chain of pizza restaurants in
southern Florida.
N• Calculated the economic impact of constructing and operating an assisted living
facility in Atlanta, GA
E• Calculated the economic impact of constructing and operating an expansion of
University Hospital in Cleveland, OH
E• Calculated the economic impact of a wastewater treatment plant in Victorville, CA
N• Calculated the economic impact of drilling for geothermal energy and constructing
and operating power plants in several counties in Nevada
E• Calculated the economic impact of a vacation club operation in Orlando, FL
E• Calculated the economic impact of constructing and operating an extended-stay
hotel in Boston, MA
E• Calculated the economic impact of constructing and operating an assisted living
facility in Walton County, FL
N• Calculated the economic impact of manufacturing and constructing residential and
commercial steel modular buildings in Lee County, FL
E• Calculated the economic impact of a chain of yogurt and juice stores and
restaurants in southern Florida

232

 63
E• Calculated the economic impact of two mixed-use commercial developments in
Orange County, CA.
E• Calculated a Targeted Employment Area by census tracts for six counties in the
Houston, TX metropolitan area
E• Calculated the expansion of new hybrid car manufacturing facility from Mississippi
to Tennessee and Virginia.
E• Calculated the economic impact of construction and operation of a skilled nursing
facility in Las Vegas, NV.
N• Calculated the economic impact of construction and operation of a proton cancer
treatment center and medical offices buildings in Los Angeles County, CA.
E• Determined the economic impact of improving facilities at the Port of Baltimore in
order to attract more shipping from the Panama Canal when the locks are widened.
N• Calculated the economic impact of a major hotel and resort area in Ft. Lauderdale,
FL.
N• Calculated the economic impact of building steel homes in South Florida, including
the local manufacture of steel fabricated parts.
E• Calculated the economic impact of constructing and operating a hotel at Times
Square in New York City.
N• Calculated the economic impact of a mixed-used residential and commercial project
in Atlanta, GA.
E• Calculated the economic impact of expanding and opening new restaurants in
Dallas, TX. In a separate project, calculated the economic impact of renovating,
refurbishing, and operating a boutique hotel in Dallas, TX.
E• Calculated the economic impact of building and operating low-income housing in
Boston, MA.
N• Calculated the economic impact of constructing and operating assisted living
facilities in eight rural Texas counties.
N• Calculated the economic impact of a mixed-use commercial project in Riverside
County, CA.
E• Calculated the economic impact of opening a manufacturing plant for "green" motor
vehicles in the Detroit, Ml area.

233

 64
E• Calculated the economic impact of constructing and operating hotels and
restaurants in Columbus, MS.
E• Calculated the economic impact of operating restaurants in the Hotel W in
Hollywood, CA.
N• Calculated the economic impact of a mixed-use commercial project in McCook, IL
(suburban Chicago).
N• Calculated the economic impact of constructing and operating a water-based
amusement facility in San Diego, CA.
N• Calculated the economic impact of a mixed-use commercial facility in suburban
Cincinnati, OH (project is in KY).
E• Calculated the economic impact of constructing and operating a casino, hotel, and
restaurant in Las Vegas, NV.
N• Calculated the economic impact of a new academic institution for alternative energy
in Santa Clarita, CA.
N• Calculated the economic impact of several mixed-used projects in San Francisco,
Alameda County, Santa Clara County, and Fresno County.
N• Calculated the economic impact of a super energy store and solar farm in Riverside
County, CA.
N• Calculated the economic impact of a prostate cancer treatment center in South
Carolina.
E• Calculated the economic impact of refurbishing and expanding retail space at the
George Washington Bridge in New York City.
E• Calculated the economic impact of building Atlantic Yards, new stadium for the New
York Nets, in Brooklyn, NY
N• Calculated the economic impact of an assisted living center and several mixed-use
commercial facilities in the Reno, NV area.
E• Calculated the economic impact of buying residential properties at deep discount
prices, refurbishing and selling them, in South Florida.
N• Calculated the economic impact for a fractional-ownership marina in Port Charlotte,
FL, plus office space, retail stores, restaurants, and a home brokerage office.
N• Calculated the economic impact of construction and operation of four retirement
homes in Vermont.

234

 65

E• Calculated the economic impact of an upscale retail shopping center in Vail, CO.
and a medical office building in Edwards, CO (both in Eagle County).
E• Calculated economic impact of a wind turbine manufacturing plant in Larimer
County, CO
N• Calculated economic impact of a hotel, retail stores, restaurants, office buildings,
and bank facilities in Pasadena, CA
N• Calculated economic impact of a luxury hotel and condominiums in Destin, FL
N• Calculated economic impact of constructing and operating a mixed-use commercial
project in Jupiter, FL
E• Determined whether 17 possible restaurant locations in Miami/Dade and Broward
Counties qualified as Targeted Employment Areas.
E• Determined the economic impact of opening and operating a slot-machine casino in
Hanover, MD, as part of a proposed EB-5 regional center for the Baltimore metropolitan
area.
N· Calculated the economic impact of renovating and expanding a restaurant on
Martha's Vineyard, MA, as part of an EB-5 regional center in that state.
N• Determined the economic impact of assembling and installing solar panels for
residences in the state of LA.
E• Determined a Targeted Employment Area for Dallas, TX as part of a proposed EB-5
regional center for the Dallas area.
N• Calculated the economic impact for various mixed used projects for a proposed
regional center for the entire State of Texas, including shopping centers, office buildings,
restaurants, assisted living centers, medical technology facilities, and other personal
and business services.
N• Calculated the economic impact for the construction and operation of several fastfood restaurants in 10 counties in central California.
N• Calculated the economic impact for the renovation and expansion of a shopping
mall in Greenville, SC.
E• Calculated the economic impact of buying existing apartment buildings at deep
discount prices, renovating and operating them, in 21 counties in FL.
N• Calculated the economic impact of building and operating an institute for proton
cancer therapy for a proposed EB-5 regional center in Brooklyn, NY.

235

 66
N• Calculated the economic impact of building and operating a mixed-use facility with
medical offices, hotels, and apartments for a proposed EB-5 regional center in Queens,
NY.
E• Determined a Targeted Employment Area for Philadelphia, PA as part of a proposed
EB-5 regional center for the Philadelphia area.
N• Calculated the economic impact of a proposed office building and mixed-use facility
for an EB-5 regional center in Dallas, Texas
N• Calculated the economic impact for various mixed-use projects for a proposed EB-5
regional center in the greater New York City area, including an extended stay hotel,
urgent care center, financial lending firm for alternative assets, retail stores, apartments,
office space, warehouses, industrial "flex" space, entertainment centers, restaurants,
conference and convention centers, nursing home and assisted living facilities, medical
offices, medical technology facilities, and high-tech manufacturing.
N• Calculated the economic impact of "green" hotels in 10 counties in Central California.
N• Calculated the economic impact of generic projects in manufacturing, financial
services, health services, hotels, and restaurants for a proposed regional center for the
state of Florida.
E• Calculated the economic impact of 12 different types of economic activity for an
expansion of the Palm Beach Regional Center to five contiguous counties.
N• Calculated the economic impact of a new auto parts plant in Alabama to supply
parts to Kia automobiles.
N• Calculated the economic impact of opening fast-food restaurants in Miami/Dade and
Broward counties in FL.
N• Calculated the economic impact of a mixed-use commercial center in Flushing,
Queens County, NY.
E• Calculated the economic impact of revitalizing and renovating part of the Brooklyn
Navy Yard for "green" manufacturing facilities.
E• Calculated the economic impact of 12 different types of economic activity for various
counties in Charlotte and Sarasota counties, FL
E• Calculated the economic impact of four new manufacturing and distribution
companies in Palm Beach County, FL.
N• Calculated the economic impact of developing a resort area and building residences
in rural Tennessee.

236

 67
N• Calculated the economic impact of developing and operating a resort area in
Southern Arizona.
N• Calculated the economic impact of revitalizing the depressed East Side of
Cleveland, Ohio, with new commercial and industrial buildings.
N• Determined the nationwide economic impact of a $1 billion investment in
Mississippi for a new hybrid motor vehicle plant.
N•
Determined the economic impact of expanding a shipyard in Southeastern
Louisiana.
N•
Calculated the economic impact of a new shopping center in Buena Vista,
California, and two other generic shopping centers in Los Angeles and San Bernardino
counties.
E• Calculated the economic impact of enhancing resort areas in eight rural counties in
Colorado.
N• Calculated the economic impact of the rehabilitation of Fitzsimons Village in Aurora,
Colorado, by adding an office building with medical labs, hotel, shopping center, and
residences.
E• Determined the economic impact of a mixed-use commercial center for the Kansas
City metropolitan area.
N• Calculated the number of jobs created for a film production company in New York
City.
N• Calculated economic impact of small-scale rooftop solar panels in various counties
in California.
N•
Calculated economic impact of 7 different types of proposed businesses for a
proposed regional center in the Bay Area of California.
N• Determined the economic impact of a new biological research park, office building,
and logistics center in Wooster, Ohio.
E• Calculated the economic effect of a mixed-use urban renewal project in Cleveland,
Ohio.
N• Calculated economic impact of dairy farm and cheese processing plant in Northern
California.

237

 68
N•
Determined economic impact of a shipyard, food processing plant, and
semiconductor plant for a proposed regional center in Louisiana and Mississippi.
N• Calculated the economic impact of a new gaming casino in Natchez, Mississippi.
N• Developed an Input/output Model for Guam, which was then used to calculate the
economic impact of several generic projects.
N•
Calculated the economic impact of a retail shopping center in suburban Los
Angeles County.
N• Prepared an economic impact analysis for the "timber to homes" project for a
proposed regional center in Colorado.
N•
Calculated the economic impact for a proposed regional center in Baltimore,
Maryland that would include the rebuilding of depressed areas in East Baltimore and
along the riverfront.
N• Prepared the economic analysis for a proposed EB-5 regional center for the entire
state of Florida that included impact calculations for 14 different types of industries.
N• Prepared the economic analysis for a proposed EB-5 regional center in the San
Francisco Bay area that included calculations for 10 different types of industries.
N• Prepared economic impact calculations for proposed EB-5 regional centers in New
York City and Northeastern New Jersey.
• Calculated the economic impact of a rehabilitated office building in Albuquerque, New
Mexico, including the increase in high quality jobs. NEW MARKETS
• Calculated the economic impact of a rehabilitated skilled nursing center in East Los
Angeles, California, including the impact on nearby census tracts. NEW MARKETS
N• Calculated the economic impact of development of warehouse and light industrial
manufacturing space in Las Vegas, Nevada.
N• Calculated the economic impact of rehabilitation and expansion of a vacation and
health spa in Sharon Springs, New York
N• Calculated economic impact of revitalizing an old resort hotel and adding new
facilities for Lake Geneva, WI.
• Calculated the employment and tax effects for a portfolio of projects undertaken under
the New Market capital program. NEW .v,,..,.,,",

238

 69

E• Calculated generic employment changes for proposed EB-5 project for an Inland
Port in Palm Beach County, FL
N• Calculated the economic impact of construction of El Monte Village in El Monte, CA.
• Calculated the economic impact of moving the Social Security Administration building
in Birmingham, AL, and revitalizing the surrounding neighborhood. NEW MARKETS
• Calculated the economic impact of rehabbing and expanding the Everett Mall in
Everett, WA.
MARKETS
• Determined the economic impact of building a new medical center in Charleston, SC

N• Calculated economic impact of expanding Sugarbush resort in VT. Study included
expansion of existing facilities and addition of new facilities.
• Calculated economic impact for new market tax credit program in Portsmouth, N.H.
Study included both overall economic impact, and the increase in employment and
income and the decrease in the unemployment rate and incidence of poverty in
individual census tracts.
N• Calculated the economic benefits of EB-5 programs for foreign investors for a
mixed-use construction project, including a hotel, retail stores, apartments, and a sports
stadium in the Washington, D. C. metropolitan area
N• Calculated the economic benefits of EB-5 programs for a mixed-used retail shopping
center in the New York City metropolitan area.
N• Calculated the economic benefits of EB-5 programs for foreign investors for
proposed shopping centers in five separate counties in Southern California, including
differential impacts of building the shopping centers in different counties.

B. Projects for State and Local Governments

• Constructed an econometric model for the State of New York and determined the
change in employment, labor income, and tax revenues for 43 different tax changes
proposed by the Governor's office.
• Constructed a detailed econometric model for the State of Pennsylvania to determine
the economic impact of the complete panoply of state taxes levied; the model contains
over 1,000 equations. In cooperation with American Economics Group, the model was

239

 70
developed to simulate the effect of changes in any state tax rate on households and
businesses by income deciles, household status, age of individuals, size of households,
and many other demographic variables. The change in business taxes can also be
simulated for detailed industry classifications.
• Determined whether the Washington, D.C. water and sewer authority should accept a
high bid for a new waste disposal system. Decision to reject has saved the authority
over $200 million, as construction prices turned down sharply as predicted.
• Built an econometric model to determine the "tax gap" caused by Internet sales for the
state of Minnesota.
• Determined appropriate levels of shelter grants individual counties in New York State,
and for utility allowances in New York City. Reviewed and prepared testimony in
ongoing court cases in these areas.
Calculated the economic impact of the revitalization of downtown Milwaukee,
Wisconsin.

C. Economic Impact of Casino Gaming

• Built an econometric model to predict the growth of the gaming industry over the next
decade, and the economic impact of that industry on employment and tax revenues at
the Federal and state levels.
• Estimated the economic impact of Indian casino gaming nationally and for the State of
Wisconsin.
• Determined the economic impact of the Oneida Indian gaming casino on the Green
Bay metropolitan area.
• Estimated the negative economic impact on the Milwaukee area if a new Indian
gaming casino were to be built in Kenosha, Wisconsin.

D. Economic Impact of Smoking Bans and Higher Taxes

• Testified on economic impact of smoking bans in Canada; certified as an expert
witness by the Court.
• Examined the impact of smoking bans on restaurant sales in several different
locations in the U.S. to determine how much sales changed when these bans were
imposed, and the differential effects depending on whether these bans were partial or
total.

240

 71

• Determined the cross-border effects on retail sales from differential rates in cigarette,
gasoline, and alcohol excise taxes
Determined the economic impact of higher cigarette taxes on minority group
employment.
• Estimated the economic impact and loss of Federal and state tax revenues when
higher cigarette prices lead to increased smuggling.

E. Consulting Projects for Travel and Tourism
• Built an econometric model to predict tourism trips and revenues for the major regions
of the U.S. economy.
• Constructed econometric models to predict tourism in Las Vegas and Orlando.
• Using the IMPLAN model, predicted economic impact of tourism and travel
expenditures for all counties in Pennsylvania.

F. Other Private Sector Consulting Projects
Calculated the revenue gain at the Federal, state and local level generated by
domestic manufacturing of Airbus parts and equipment.
• Calculated the economic impact of proposed EPA bans on fluoropolymer production.
• Estimated the size and economic importance of the fluoropolymer industry, and
calculated economic impact of shutting down domestic production.
• Built an econometric model to examine how U.S. tax and regulatory policies help
determine whether the gold mining industry would invest in the U.S. or other countries.
Testified before Congress to help defeat legislation inimical to the mining industry.
• Built an econometric model to predict consumer bankruptcies, based on recent growth
in consumer credit outstanding, the overall economic environment, and recent changes
in credit regulations
• Estimated the economic impact of the ethanol subsidy on the U.S. economy and
Farm Belt States, including the impact on the balance of payments, employment, and
tax receipts. Testified before Congress to help pass legislation to extent subsidies to
the ethanol industry.

241

 72
• Built an econometric model to determine the impact of updating and improving the
system of locks on the Upper Mississippi River on corn prices and exports, farm
income, and the overall economy.

BOOKS PUBLISHED
Macroeconomics for Managers, Blackwell, 2003
Practical Business Forecasting, Blackwell, 2002
Economic Impact of the Demand for Ethanol, Diane Publishing Company, 1998
How to Make Your Shrinking Salary Support You in Style for the Rest of Your Life,
Random House, 1991
The Truth About Supply-Side Economics. Basic Books, 1983.
A Supply-Side Model of the U. S. Economy, mimeo (prepared for Senate Finance
Committee), 1980.
An Econometric Model of the French Economy:
O.E.C.D, March 1969.

A Short-Term Forecasting Model.

Econometric Gaming (with L. R. Klein and M. J. Hartley). Random House, 1969.
Macroeconomic Activity: Theory, Forecasting and Control. Harper & Row, 1969.
The Wharton Econometric Forecasting Model (with L.R. Klein), Economics Research
Unit, Wharton School: University of Pennsylvania Press, 1967. Enlarged edition, 1968.
Over 30 articles in major academic journals and publications (list on request)

242

 1-924 Application- US Immigration Fund-NJ
Response to RFE
RCW 1236250925

DOCUMENT
Architect's Soft Construction Cost Budget for 88 Morgan Street Project

TAB No.
5.

243

 3/1/2013

Kushner Companies
65 Bay Street I 88 Morgan Street, Jersey City
HPA#l3046

(b)(4)

Programming/Entitlement Phase
Schematic Design
Design Development
Construction Documents
Bid/Permitting Phase
Architectural Sub Total Fee (Residential Tower)
CA Phase

MEP approx
Structural approx
Civil
Jurisdictional Site Planning
Construction Documents
Project Meetings
Construction Phase Services
Approximate fees listed below for additional services:
Landscape
Interiors
Acoustical
Telecom
Accessibility Consultant
Waterprooting
Lobby/Club/Fitness (assume 5,000 sq. ft.)
Curtain wall consultant
Total Fees

*Fees arc based on the terms of our AlA B101 master agreement
Parking and Tower is a replica of the Trump JC that is on same site. Fees based on the trump high rise architectural
cad drawings (all CD elevations, parking garage and CD details) to be reutilized for the new rental apartment tower.
Full release will be given from original architect to use plans. approx. 417 units with up to 5 new unit types per
common floor and 5 alternate floor plans in different locations, common area and amenities. 5,000 Square ft. of
Retail. Grace Jones and Walter Hughes are assigned to this project and are the primary contacts.
*For reimbursable expenses, the amount expended by the Architect will be billed pertaining to the Project as follows:
A. Expense of transportation and living when traveling in connection with the Project, long distance calls, fax
transmissions, and permit fees at a multiple of 1.0 times the amount expended. Personal plane travel will not be charged
only comparable commercial fares.
B. The expense of all reproductions including but not limited to, prints, photo copies, mylars, photo negatives, etc., as may
be required in the normal preparation of documents, as well as CADD plots, postage, supplies, handling and delivery
fees of all information between the Owner, the Architect, and various consultants or interested parties at a multiple of
1.0 times the amount expended.
Additional Services may be required if program change by ownership, additional services must be approved prior to billing

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 600 Travis Street
Suite 2000
Houston. TX 77002
713.229.8733 office
713.228.1303 fax
www.fosterquan.com

December 20, 2012

Ms. Rosemary Melville
Director
California Service Center
U.S. Citizenship & Immigration Services
Attn: EB-5 Processing Unit
24000 Avila Road, 2nd Floor
Laguna Niguel, CA 92677

Via Federal Express
Re:

Form I-924 Application EB-5 Regional Center Designation
Project Name:
U.S. Immigration Fund- NJ
Applicant:
U.S. Immigration Fund- NJ, LLC

URGENT EXPEDITED PROCESSING REQUESTED TO ATTRACT
INVESTMENT TO THE NEW JERSEY SHORE AREA DEVASTED BY
HURRICANE SANDY

Dear Ms. Melville:
We are hereby submitting the I-924 Application for Regional Center by U.S.
Immigration Fund - NJ, LLC, to obtain initial designation by U.S. Citizenship &
Immigration Services ("USCIS") for the US. Immigration Fund NJ.
The application is comprised of:
I. Filing Fee Check in the Amount of$6,230 for Form 1-924;
2. Form 1-924 Application for EB-5 Regional Center, duly executed;
3. Form G-28 Notice of Entry of Appearance as Attorney, duly executed;
4. This letter (pages 1 through and including 22), and
5. An Index, and attached Exhibits numbered 1 through and including 27.
(collectively, the "Application").

Page I of22

246

 The Application contains confidential commercial information, pursuant to 5
U.S.C. Sec. 552(b)(4). Thus, the applicant requests pre-disclosure notification per
Presidential Executive Order No. 12,600, 52 Federal Register 2371 (June 23, 1987), as to
all information and evidence submitted as part of this Application.

1.

Expedited Processing Request

Expedited Processing Request: We are submitting this Application with an urgent
request for Expedited Processing due to the need to attract investment to the areas
devastated by Superstorm Sandy in the events surrounding its landfall in New Jersey on
October 29, 2012. The Territory of the Regional Center (as defined below), includes
precisely the northern Jersey Shore area severely impacted by Superstorm Sandy in
Hudson County, Ocean County, Essex County and Middlesex County.
We enclose a Memorandum at Exhibit 23 that details the reason why this
Application falls squarely within the USCIS requirements for Expedited Processing,
supported by ample evidence at Exhibits 24, 25 and 26 from Federal and State
governments, and publicly available media sources, showing the urgent need for over $30
billion in new investment into New Jersey and Hudson County, Ocean County, Essex
County and Middlesex County, to rebuild after the devastation of Superstorm Sandy on
the New Jersey Shore area.

2.

The Applicant: U.S. Immigration Fund- NJ, LLC

U.S. Immigration Fund-NJ, LLC is a limited liability company newly organized
under the laws of the State of Florida on December 7, 2012 ("USIF-NJ" or the
"Company''). We enclose at Exhibit 1 a copy of the Articles of Formation of the
Company registered with the Secretary of State for New Jersey on December 7, 2012.
The Company was formed to conduct any lawful business, and in particular, to own,
manage and operate a designated Regional Center under the EB-5 Regional Center Pilot
Program 1 named the US. Immigration Fund- NJ ("Regional Center")
We enclose in Exhibit 2 a copy of the Minutes of the Action of the Sole Member
of the Company in Lieu of Organization meeting dated December 7, 2011 ("Minutes").
The key matters adopted in the Minutes included: adoption of the Company Agreement,
and adoption of the form of the Certificate of Membership Interest. The Minutes were
signed by the Sole Member, U.S. Immigration Fund, LLC ("USIF'').
1

Immigration & Nationality Act (INA), Section 203(b )(5); Appropriations Act ( 1993), Section 610.
Page 2 of22
247

 As of today, the ownership of the issued and outstanding membership interests in
the Company is set out in the Table below:
' Member Name

3.

ber Certificate No.

Geographic Territory of the Regional Center

The Regional Center's geographic jurisdiction will be comprised of the
contiguous territory of the following Counties in the State ofNew Jersey:
Bergen County;
Essex County;
Hudson County;
Middlesex County;
Monmouth County;
Passaic County;
Union County, and
Morris County (collectively, the "Territory").
The perimeter of the geographic jurisdiction of the Regional Center is constituted by the
uninterrupted outer boundary of the above-mentioned Counties in New Jersey. We
enclose maps outlining the Ten·itory in Exhibit 5.
The above-mentioned Counties collectively constitute parts of the New York Northern New Jersey Long Island Metropolitan Statistical Area, as defined by the U.S.
Census Bureau. The Territory includes the cities of Jersey City, Newark, Hoboken and
Elizabeth, in New Jersey, as well as many towns along the Jersey Shore such as Union
Beach, Highlands, Monmouth Beach and Ocean Township. The Territory of the
Regional Center is linked by proximity, economic integration and commuting patterns of
its labor force. This is confinned by the Economic Analysis attached at Exhibit 22.

Page 4 of22

248

 4.

Management of U.S. Immigration Fund- FL

Management of Structure ofthe Regional Center
In Exhibit 6 we enclose a diagram of the corporate structure of the Regional
Center. The Company is managed by one Managing Member, USIF. USIF is 100%
owned and controlled by I
I Principal is the Managing Member of

I

I

(b)(4)

By letter dated December 7, 2012, attached in Exhibit 8, USIF confirmed that
Principal is the representative ofUSIF as the Managing Member the Company.
The Company encloses a detailed Operations Plan at Exhibit 12, which provides
a description of the management structure, management personnel and processes that will
be applied in project development for the Regional Center.

Management Team
As stated in the Operations Plan, USIF is the Managing Member of the Company
and will manage daily operations of the Regional Center. USIF employs an experienced
team of professionals who have the expertise and experience necessary to make the
Regional Center a great success. The areas of expertise and operating capability include:
real estate development, finance, marketing, legal and accounting.
USIF will charge a fee for its services to the Company. The Company will pay
for the services delivered by USIF from revenue from the Management Fees described
below. As the Company grows, additional capability will be added to the Company.
USIF' s team of managers and professionals provide similar services to two (2)
other EB-5 regional centers owned or operated by Principal: Florida Regional Center
(RCW 319-10194 I Unique I.D. # 1031910194), and U.S. Immigration Fund NY.
Thus, they are a management team very experienced in the EB-5 program and in real
estate development.

Page 5 of22

249

 The following are key managers and professionals of USIF who will contribute
their time and know-how to the launch and continuing operations of the Regional Center:
Name

Title

Nicholas A. Mastroianni, II /

Manager & Principal

David Finkelstein

Chief Financial Officer

Mark Giresi

General Counsel
/

Nicholas A. Mastroianni, Ill /

IVIaii\Clll I!)

Sandy Albanese

Investor Relations Manager

Biographies of the key managers stated above are enclosed in the Operations Plan
enclosed at Exhibit 12. This team of key managers and professionals has successfully
taken real estate development projects from start-to-finish. They have turned ideas into
designs and plans; negotiated the contracts required for a project; raised the financing;
completed construction, and then brought the project into operations.
The key managers will collectively review new investment projects for the
Regional Center, using analysis of market data; launch budget estimate; cash flow
projections, financial and contract terms, and incorporating the where appropriate the
analysis and advice of the Regional Center's outside advisors. Once a project is
considered viable for the Regional Center, job creation estimates will be obtained from
the economic consultant for the Regional Center, and final project structure will be
determined. Project documents, such a private placement memorandum, will be
developed with the assistance of outside corporate and immigration counsel. If the
project presents novel issues, the Regional Center may avail itself of the opportunity to
present to US CIS of an exemplar I-526 petition.
USIF will retain the services of additional staff as needed to meet the needs of the
Regional Center. All potential new Regional Center team members will be required to
have the proper background, experience and education to fill their roles.
In addition to the team of managers and professionals that work for USIF, the
Regional Center will hire highly qualified outside advisors to assist them in the design,
application and operation of the Regional Center (as described in the Operations Plan):

Lead Securities Law Counsel. Attorney Andrew Kingston will be the lead
Securities Law counsel to the Regional Center. Andrew Kingston has over 15 years of

Page 6 of22

250

 experience in public and private offerings of securities and has successfully advised EB-.S
regional centers on previous private securities offerings.
Economic Analyst. The Regional Center will use the services of Evans, Carroll
& Associates as economic analysts for its job creating projects. Evans, Carroll &

Associates has prepared hundreds of successful economic impact analyses for EB-5
regional center projects throughout the United States. Michael Evans, Ph.D., will be the
lead economist for the Regional Center.
Lead Immigration Counsel. FosterQuan, LLP, an experienced immigration law

firm with extensive experience in EB-5 projects. The expertise of experienced EB-5
attorneys will ensure compliance with USCIS rules and standards in the content of deal
structuring; 1-526 visa petitions, and 1-829 petitions on behalf of the Regional Center.
The lead attorney for FosterQuan, LLP will be Ignacio A. Donoso, Esq.
(b)(4)

Banking Services. The Regional Center will utilize thel

[or all escrow
banking services of the Regional Center (or a similarly reputable bank such as
._I_ __ .

Premises. The operations for the Regional Center will be conducted from its

corporate offices located in 1295 U.S. Highway One, Suite 300, North Palm Beach,
Florida 33408, and Telephone (561) 799-1883. The offices of the EB-5 Regional Center
are located on the main offices ofUSIF, which is providing these offices and personnel as
part of the Management Fee to the Regional Center.

5.

(b)(4)

Start-up Capital and
Operations

Financial Projections of Regional Center

The enclosed Operations Plan describes the start-up capital that has been and is
being dedicated to the development and launch of operations of the Regional Center (see
Exhibit 12). The start-up budget of expenses of the Regional Center was approximately
I
ltrom the start of the project until the I-924 application was filed. Thes~e
expenses, include, without limitation: the legal formation of the Company (U.S.
Immigration Fund- NJ, LLC) and its necessary corporate entities; economic consulting
services related to the economic impact of the Regional Center's first projects;
negotiation of required contracts, and preparing of an application to USCIS for approval
as a Designated Regional Center under the EB-5 Pilot Program. The start-up capital of
the Regional Center was provided (and is being provided) by the Principal, directly, or
indirectly through his company, USIF.

Page 7 of22

251

 (b)(4)

The Regional Center is being provided with cash on-hand by USIF to support the
operations of the Regional Center during its initial launch period. The amount of
...__.....~as been committed by USIF to the Company to be used in the future to pay for
expenses including: initial marketing of the Regional Center; design of a web-page;
further legal advice on securities issues and immigration issues, and hiring attorneys and
economists to prepare the final set of investment documents for the Regional Center's
first two projects. USIF executed a financial commitment letter dated December 7, 2012,
which is enclosed at Exhibit 8. This letter serves to confirm the financial commitment of
USIF to the Company and the Regional Center project, and confirms its significant cash
resources of over I
Ito the development, launch and operation of the
Regional Center. Exhibit 13 includes a copy of the bank account statement of the
operating checking account of USIF confirming a recent balance of ovei
We also enclosed sample invoices paid by USIF for the launch of the Regional Center in
Exhibit 13. Thus, the start-up capital and financial commitment of USIF will be
sufficient to launch operations and see the project through to fruition over the coming
years. The Regional Center therefore has sufficient financing already to pay for its
launch costs, and consequently is not relying on financing from the Administrative Fee
paid by EB-5 Investors in its Projects, or the Management Fee, to pay for the expenses of
initiating operations.

(b)(4)

I

Revenue Projections
The Operations Plan at Exhibit 12 includes the financial projections and budget
expenditures of the Regional Center, which are reproduced below. Revenue projections

(b)(4)

tor the proJected proJects. Based on this timetable and the assumptions described below,
the Operating Budget and Cash Flow Projections for the Regional Center are as follows:

Page 8 of22

252

 (b)(4)
Budget & Cash Flow Projections- USIF-NJ for FY2013 (From Operations Plan)

Operating Budget and Cash Flow Projection Assumptions:
i.

An application fee payable from the Developer is estimated at
approximately
lPer project.

ii.

A Management Fee o0ofthe Loan per annum is estimated for the each
project, payable quarterly while the loans are outstanding.

111.

From the Administrative Fee that each foreign investor pays (not from
their capital investment), a Processing Fee otl
lwill be paid to
the Regional Center.

IV.

The fees for the services ofUSIF are not projected to be paid until the first
1-526 is filed, estimated to occur in the 2nd quarter of2013

v.

The premises of the Company are being provided by USIF as part of the
management services provided by USIF in its capacity as Sole Member

(b)(4)

I

Page 9 of22

253

 (b)(4)

I

and Manager. The rent expense is projected at
~er month
commencing in the 2nd quarter of2013 and will be paid from the revenue
generated by either Project application fees or funding support from USIF.
The sharing of space with other affiliated companies of Nicholas A.
Mastroianni II will keep office expenses to a minimum.
v1.

All expense line items are increased byOannually.

vii.

New projects are expected to begin development during 2014~ hence, the
stream of cash flow to support the Regional Center is expected to continue
for many years to come. In the following example, one new project, the
88 Morgan Street Project, with 110 EB-5 Investors is forecast for the
calendar year commencing January I, 2014. The same fee structure as in
the current projects was used for the projected projects.

**

Jn beginning period represents expenses paid from 7/1112 for RC

._I_ _. .

formation.
(b)(4)

Investor Administrative Fees. Revenues will, in part, be generated by assessing
an Administrative Fee equal to
~ayable by each EB-5 Investor at the time of
their subscription for an investment in one of the Regional Center's projects. The
Administrative Fee will be in addition to each EB-5 Investor's capital investment of
$500,000 or $1,000,000, depending on the TEA designation of each project. The
Administrative Fee may change in the future depending on market conditions.

I

(b)(4)

Management Fee. The Management Fee charged by the Regional Center to the
New Commercial Enterprise (sometimes referred to herein as an "Entity") of each project
will bel
ter annum of the total principal amount outstanding under the
Loan from time to time, cumulative but not compounded, payable quarterly while the
Loan is outstanding. ("Management Fee"). The Management Fee will be charged by the
Regional Center directly or through the General Partner of the Entity, which will be a
company affiliated with USIF and the Principal's group of companies. In the St. Lucie
Project, the General Partner is U.S. Immigration Funds GP- Santa Lucia, LLC. In the Via
Mizner Project, the General Partner is Florida Regional Center, LLC.
The Management Fee will only be paid from profits of the Entity and not from the
EB-5 Investor's Capital Contribution: no EB-5 Investor Capital Contribution will be used
to pay the Management Fee.

Page 10 of22

254

 By letters dated December 7, 2012, USIF and Principal confirm to USCIS that the
Capital Contribution paid by EB-5 Investor will only be used to pay for capital
investment activities of the job-creating project sponsored by the Regional Center (See
Exhibit 13).
In conclusion, the Regional Center will be managed as a "well-capitalized"
company. The operating revenue projections set out above are considered by USIF to be
conservative based on the anticipated activity level. USIF will identify future regional
projects and these will continue to fund the Company and the Regional Center into the
future.
6.

Economic Sectors of the U.S. Immigration Fund - NJ

NAICSCodes
The Regional Center's investment in new projects will focus in the following
industries and economic sectors, which are described according to the North American
Industry Classification System codes and titles (collectively, the "Industry Categories"):
Industry Name

I Commercial and Institutional Real Estate Construction

i

NAICSCode

2362

Residential Real Estate Construction

2361

Lessors of Real Estate

53111

Architectural, Engineering & Related Services

5413

The Industry Categories derive from the two sample projects of the Regional
Center, which are described in the Business Plan. The 88 Morgan Street Project Business
Plan is attached at Exhibit 19. The Industries Categories are designated and applied in
the Economic Analysis that determines the economic impact of each Project. The 88
Morgan Street Project's Economic Analysis is attached at Exhibit 20.

7.

Standard Project Structure for Regional Center

As described in the enclosed Operations Plan, the organizational methodology
and structure of the Regional Center will be to use newly organized New Jersey Limited
Liability Companies (or, on occasion, a new limited partnership) to pool capital from EB5 Investors in exchange for an equity ownership of said Limited Liability Company. Such

Page II of22

255

 Limited Liability Company will be referred to herein as an "Entity". Please see the
Diagram of the Regional Center enclosed at Exhibit 6.
The Company will form a new Entity under New Jersey law for each new project
promoted under the Regional Center. USIF will participate as Manager of each Entity,
either directly or through a wholly-owned subsidiary company whose sole purpose is to
serve as Manager to a specific project's Entity. We enclose a Sample Limited Liability
Company Agreement for the project Entity for the 88 Morgan Street Project at Exhibit
19.
EB-5 Investors will contribute capital directly into one Entity, which will be an
active for-profit enterprise. The Entity will invest the funds from EB-5 Investors in their
entirety into a job creating project by executing for-profit commercial loan facilities to a
real estate developer, which will constitute the job creating entity for the project. Where
commercial loans are used by the Regional Center, each such loan will have a term of not
less than five (5) years from the date of investment, in conformity with USCIS guidance.
A sample of tem1s for a loan facility under the Regional Center is found in Exhibit 22
hereto.
This structure is intended to ensure the stability of the Company as the main
regional center vehicle for the Regional Center. It is also intended to ensure highly
qualified and consistent management of the project entities used by the Company for
each project.

8.

Investment Process for EB-5 Investors

Subscription Documents
EB-5 Investors will be delivered the following documents to review, analyze and,
where appropriate, execute to complete an investment in the Entity sponsored by the
Regional Center, samples of which are attached as Exhibits hereto:
Sample SubscdPtfb~ P~flt
Investor Suitability Evaluation:

14

Subscription Agreement:

15

Escrow Agreement:

16

Limited Liability Agreement of the 88 Morgan Street Project:

17

Sample of Offering Memorandum for 88 Morgan Street Project:

18

Collectively, the sample documents set out at Exhibits 14, 15, 16, 17 and 18 will
be referred to collectively as the "Subscription Documents".
Page 12 of22

256

 These documents are submitted as samples of the forms of the future documents
that will be completed and executed by the EB-5 Investor and the Entity (i.e., the new
commercial enterprise). Some of the Subscription Documents may form part of the
Offering Memorandum. In Exhibit 21 we enclose a Sample Flow Chart of how potential
EB-5 Investors will be considered for a investment in an Entity.

At-Risk Investments
All of the Subscription Documents confirm that the Capital Contribution of the
EB-5 Investor is entirely at-risk, and that the investment involves a business venture with
risk of profit or loss. Moreover, the Regional Center is careful not to offer a guarantee to
potential EB-5 Investors that the investment will be profitable, that their capital will be
returned in whole or in part, or that an immigration benefit will necessarily be obtained
through an investment in the Regional Center.
For example, in the Sample Offering Memorandum for the 88 Morgan Street
Project, the Subscription Agreement, provides, at Section 6.1 O(ii):

(b)(4)

Similar warnings are included in the Risk Factors set out in Sample Offering
Memorandum of the 88 Morgan Street Project. For example, in the Summary of Offering
Tetms, at Page 6 of the Sample Offering Memorandum, it reads:

(b)(4)

Page 13 of22

257

 The Sample Offering Memorandum describes the complete discussion of risks of
the investment in Section XIII.

Escrow
The practice of the Regional Center will be to use unique escrow bank accounts
owned by the Entity opened for each investment project. The escrow bank accounts will
be opened at
land managed by NES Financial (or another similarly
reputable bank such
k'Escrow Agent"). See Sample Escrow Agreement of
the Regional Center at Exhibit 16.

I

a4

(b)(4)

Under the terms of the Sample Escrow Agreement,l

I

Page 14 of22
258

 Investment Procedure and Background Due Diligence on Investors
(b)(4)

The investment procedure for the Regional Center are set out in the Operations
Plan. We summarize investment procedures:

Books, Records and Annual Reporting Duties ofRegional Centers
As described in the enclosed Operations Plan (Exhibit 12), the Regional Center
will implement procedures that will provide it with sufficient information and recordkeeping to maintain compliance with USCIS annual reporting duties for EB-5 Regional
Centers.
The invested funds for each Entity will be accounted for separately and tracked in
a transparent fashion which will permit an independent auditor to verify at any time that
the funds are being expended for capital improvements and development, not for fees and
expenses.
Further, the Regional Center is aware of the USC IS annual reporting requirements
set out in Form I-924A and accompanying USCIS instructions. This information has
been in the enclosed Operations Plan enclosed in Exhibit 12.
The procedures, records and controls set out above will permit the Regional
Center to comply with USCIS annual reporting obligations.

Page 15 of22

259

 9.

Description of First Project of the Regional Center

The Regional Center will undertake real estate development projects by raising
local capital and combining it with capital raised from EB-5 Investors.
The Application includes one (1) sample project that is expected to be initial
project promoted by the Regional Center. This project is enclosed as a sample project,
and is not being submitted as an Exemplar 1-526 at this time:
The business plan of the initial sample project of the Regional Center is attached
at Exhibit 21. Investments made through projects developed by the Regional Center will
increase foreign investment in the Territory; foster economic development, and generate
employment growth locally and nationally.
Summary ofProject I - 88 Morgan Street Project
We provide a short summary of the 88 Morgan Street Project for your
convenience, obtained from the enclosed Business Plan at Exhibit 21.
(b)(4)

al

The 88 Morgan Street Project is
ldollar capital investment project
to build a new 50 story luxury rental apartment building, consisting of 417 rental
apartments, 217 parking spaces, and approximately 4,000 sq.ft. of retail space adjacent to
Trump Plaza I.
The USIF will be administering and sponsoring a capital investment project to
attract
IEB-5 Investors who are each investing 1
..__....,.
(total of up td
Iin the new company, 88 Morgan Street Funding, LLC
("Funding Company"). The Funding Company is the "New Commercial Enterprise'' that
is organized to be in compliance with the USCIS EB-5 Pilot Program. The Funding
Company will make a secured EB-5 loan (the "Loan") of all of the proceeds of each of
the Qualified Investor'sl
fnvestment in the Funding Company to 88 Morgan
Street, LLC (the "Developer") in accordance with the EB-5 Pilot Program's guidelines.

I

(b)(4)

The Developer will use the proceeds of the Loan for the construction of a mixeduse real estate development project known as the 88 Morgan Street Project to be located
at 88 Morgan Street in Jersey City, New Jersey. The 88 Morgan Street Project is located
in the most convenient location in New Jersey for access to Manhattan, residing directly
in the middle of three PATH hubs, and just minutes away from the ferry and the Holland
Tunnel (the "Property"), within the Territory of the USIF.
Page 16 of22

260

 The cost to construct the 88 Morgan Street Project is budgeted to be._l_ _ _ __.
comprised of the following:
Hard Construction Costs
Soft Construction Costs
Land Purchase,
(b)(4)

TOTAL BUDGETED COSTS

The source of funds to complete the construction is summarized as follows:
Owner's Equity
Senior Construction Loan
EB-5 Funds (Loan)
TOTAL FUNDING

The proceeds of the Loan will be used for construction of the Project and the
creation of jobs in accordance with this Business Plan and the Economic Report
discussed below.
The economic job creation analysis of the 88 Morgan Street Project is enclosed at
Exhibit 20. The Economic Analysis establishes that the 88 Morgan Street Project will
create a sufficient number of new jobs so that each EB-5 Investor can be credited with
creating at least 10 new full-time jobs through their investment.
10.

Economic Methodology and Targeted Employment Areas

Job Creation Methodology

All projects accepted by the Regional Center will involve direct and /or indirect
and induced job creation in the Territory of the Regional Center.
Indirect and induced job creation will be determined using RIMS II input-output
methodology to estimate the number of jobs created as a consequence of investments by
EB-5 investors.
RIMS II is a proven statistical and econometric method. RIMS II is widely used
by both governmental and private sector entities. RIMS II offerings the ability to estimate

Page 17 of22

261

 job creation outcomes based on input parameters including capital investment, revenue
generation, location and type of industry.

Targeted Employment Areas
As stated in the enclosed Operations Plan, the Regional Center's investment
projects will be usually be located in geographic areas or political subdivisions that
qualify as a Targeted Employment Area under 8 C.F.R. Section 204.6(e) (i.e., constitute
either a rural area or an area of high unemployment under applicable EB-5 regulations),
in which case the minimum amount of EB-5 capital necessary to make a qualifying
investment in a Targeted Employment Area within the United States is five hundred
thousand dollars (US$500,000) per EB-5 investor. As such, the planning of Regional
Center investment projects will usually assume that EB-5 Investors each contribute the
amount of $500,000 as a Minimum Capital Contribution. Occasionally, the Regional
Center may develop an investment project that does not qualify as Targeted Employment
Areas under 8 C.F.R. Section 204.6(e), in which case the Minimum Capital Contribution
required of each EB-5 Investor will be no less than US$1 ,000,000 per EB-5 investor.
All determinations that an investment will be located in a Targeted Employment
Area will be supported at the time that the EB-5 Investor's I-526 visa petition is filed by
detailed, transparent and reproducible economic evidence. According to USCIS
Memorandum from Donald Neufeld, Acting Associate Director, to the Field Leadership
dated December 9, 2009, HQ 70/6.2 ("12/2009 Neufeld Memo"), USCIS makes its
determination of whether a geographic area or political subdivision qualifies as a
Targeted Employment Area on the date an investor files an 1-526 visa petition and not at
the time that the I-924 Application for Regional Center is filed.
The Regional Center may use Targeted Employment Area determinations made
by State-approved government entities under 8 C.F.R. Section 204.6(i).

Economic Analysis of 88 Morgan Street Project
The economic analysis for the first project of the Regional Center - the 88
Morgan Street Project was prepared by Michael Evans, Ph.D., of Evans, Carroll &
Associates and is enclosed at Exhibit 20, (each, the "Economic Analysis").
The Economic Analysis applies RIMS II economic methodology using final
demand employment multipliers that analyze the employment creation impact of
investment projects in the Territory where investment is made in the Industry Categories.

Page I8 of22
262

 Under USCIS guidance, the Economic Analysis uses direct, indirect and induced job
creation estimates using final demand employment multipliers only.

No Tenant-Occupancy Issue

(b)(4)

The Regional Center has developed Economic Analysis which conforms to
USCIS policy guidance on Tenant-Occupancy issued on February 17, 2012 and May 8,
2012. The Economic Analysis of the 88 Morgan Street Project is designed to avoid the
Tenant-Occupancy issues that may arise. The manner in which the Tenant-Occupancy
issue is avoided in the Economic Analysis is set out below.

Project Capital and Job Creation Requirements

According to the Business Plan and the Economic Analysis, the 88 Morgan Street
Project requires the following amount of capital (based on US$500,000 Minimum Capital
Contributions), numbers ofEB-5 Investors, and new job creation:

·· '·l··l l'>,lyrou!t:!lf~ln~e~!'?rs·tm&x.}
,,,,;·,;.·,·k'

'~ , ~ ~ i:M (~("k<~·~<·~,q;/":~

' i'<<:ti<<.::«<<«'«<<'/f/

t;lj~}~J~;§~i~t::;;;

(b)(4)

Page 19 of22

263

 The Economic Analysis of the job creation impact of the 88 Morgan Street
Project is set out fully in Exhibit 20, and a summary of which from Section 2 (Page 4)
thereof reproduce below for your convenience:
(b)(4)

(b)(4)

Table A of 88 Morgan Street Project Economic Analysis

The Economic Analysis of the 88 Morgan Street Project establishes that it will
cre~new full-time direct, indirect and induced jobs. This i<:Jobs more than
theL_j new jobs required to satisfy the job creation requirement of the maximum
number ofEB-5 Investors in the 88 Morgan Street Project (an excess o Q
The Economic Analysis of the job creation impact of the 88 Morgan Street
Project contains detailed analysis of how the projects will increase key metrics of the
regional economy. We reproduce below the Summary of Economic Impact Measures
(Table C) for the regional economy for each project:
[intentionally left blank]

Page 20 of22

264

 (b)(4)

Table C. Summary Measures of Economic Impact for Construction and Rental
income of 88 Mon!an Street Aoartment Buildim.!

These significant positive effects for the Regional Center's first project will help
overcome severe limitations to access to credit experienced on a national level in the
United States due to the banking crisis of 2008~ 2009, 2010 and which is still on-going.
Thus, Regional Center will serve to: (a) promote investment in the industries targeted by
the Regional Center, and (b) contribute to building new facilities that will have a
significant positive impact on job creation in the Territory.

11.

Conclusion

Based on the foregoing, we are convinced that the Regional Center will
substantially benefit the Territory. It will create much needed jobs and attract capital
investment to the Regional Center's Territory.

Page 21 of22

265

 Therefore, we respectfully request that USCIS favorably adjudicate this
application. Should you have any questions, please do not hesitate to contact
immigration counsel for this matter, Ignacio A. Donoso, Partner of FosterQuan LLP
(idonoso@fosterquan.com), by telephone at (713) 229-8733, by fax at (713) 228-1303.
Sincerely yours,

lADiey
Enclosures (See attached Exhibits)

Page 22 of22

266

 U"-~-NJ

DOCUMENT
Revised Economic Analysis prepared by Evans, Carroll & Associates for the
88 Morgan Street Project dated Aprilll, 2013.

Response to NOID

TAB No.
4.

267

 1

Economic Impact of Developing a Luxury Apartment Building
Located in Jersey City, NJ, for the US Immigration Fund, LLC
and its New EB-5 Regional Center in Northern New Jersey

Prepared for:
The U. S. Immigration Fund

Prepared by:
Michael K. Evans
Evans, Carroll & Associates, Inc.
2785 NW 26th St.
Boca Raton, FL 33434
561-470-9035
mevans@evanscarrollecon.com

Apri111, 2013

268

 2

Table of Contents
1. Executive Summary

3

2. Tabulation of Principal Results

4

3. Introduction and Scope of Work

8

4. Brief Introduction to the RIMS II Model and its Multipliers

9

5. Methodology for Calculating Indirect Jobs

12

6. Economic Parameters for 8 Counties in New Jersey

17

7. Location of Hotel, Maps of Area, and TEA Analysis

32

8. Economic Impact of Construction Activity

36

9. Economic Impact of Rental Income

45

10. Summary Statistics for Entire Project

51

Appendix: Resume of Dr. Michael K. Evans

53

269

 3
1. Executive Summary
• The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space.
• The economic impact results are calculated using the RIMS II inpuUoutput model for
the following 8 counties in New Jersey: Hudson, Essex, Union, Bergan, Passaic,
Morris, Monmouth, and Middlesex. These counties are chosen based on commuting
patterns, as explained later in this report.
(b)(4)

270

 4

2. Tabulation of Principal Results
Table A shows the annual revenue, the final demand multiplier, and the total
number of jobs created by the construction and o erations of the apartment building.
Since the construction will take more than
e economic impact figures for
the hard construction costs and appropriate so cos s mclude direct as well as indirect
and induced jobs. All figures are permanent jobs.
Table A. Summary of Employment and Revenue Estimates
(b)(4)

Table 81 shows the NAICS codes for each type of economic activity.
descriptions are taken from:

The

1Jttp;ft.WWW..:G~O$.!J.$~gQy{ggi:PiD/$.$§<;i/nr:iiG$/!J9iG?IGO?Gh9.It=.:4.Ql2

Table 81. NAICS Codes for Each Type of Activity
2361 Residential Building Construction
2362 Nonresidential Building Construction

4232 Furniture and Home Furnishing Merchant Wholesalers
4234 Professional and Commercial Equipment and Supplies Merchant Wholesalers
4236 Household Appliances and Electrical and Electronic Goods Merchant
Wholesalers
53111 Lessors of Residential Buildings and Dwellings
5413 Architectural, Engineering, and Related Services

Table B-2 shows the print screen of all the RIMS II multipliers used in this study.
Please note that for purchases of FF&E, the multiplier used is the wholesale trade
multiplier excluding direct jobs, calculated as

I

I

(b)(4)

271

 5

Table 82. Print Screen of Multipliers
{3)
(1) (2)

(4)

(5)

(6)

230000 Construction
420000 Wholesale trade

2.0346 0.5600 11.77391.1005 1.80511.9882
1.8451 0.4707 8.4173 1.18911.8173 2.4393

531000 Real estate
541300 Architectural, engineering, and related services

1.4670 0.2244 13.2613 1.0810 1.9496 1.2985
1.9921 0.5483 10.2148 1.2297 1.8728 2.5874

Region Definition Bergen, NJ; Essex, NJ; Hudson, NJ; Middlesex, NJ: Monmouth, NJ; Morris, NJ; Passaic, NJ; Union, NJ
'Includes Government enterprises.
i. Each entry in column 1 represents the total dollar change in output thai occurs in all industries for each additional dollar of output delivered to
final demand by the industry corresponding to the entry.
2. Each entry in column 2 represents the total dollar change in earnings of households employed by all industri&s for each additional dollar of
output delivered to final demand by the industry corresponding to the entry.
3. Each entry in column 3 represents the total change in number of jobs that occurs in a!ltndustries for each additional1 million doOars of output
delivered to final demand by the industry corresponding to the entry. Because the employment multlplrers are based on 2008 data, the output
delivered to final demand should be in 2008 dollars.
4. Each entry in column 4 represents the total dollar change in value added that occurs m all industries for each additional dollar of output
delivered lo final demand by the industry corresponding to the entry.
5. Each entry in column 5 represents the total dollar change in earnings of households employed by all tndustries for each additional dollar of
earnings paid directly to households employed by the industry corresponding to the entry.
6. Each entry IIi column 6 represents the total change in number of jObs in aft industries for each additional job m the industry corresponding to
!he entry.
NOTE.--Multipliers are based on the 2002 Benchmark Input-Output Table lor the Nation and 2008 regional data. Industry List A identifies the
industries corresponding to the entries.
SOURCE.-Regionallnput-Output Modeling System (RIMS II), Regional Product Division, Bureau of Economic Analysis.

Table C shows the annual level of household income, and the output for utilities,
maintenance and repair construction, manufacturing output, and professional and
business support services for the construction and operation of the 88 Morgan Street
apartment building.

(b)(4)

Table C. Summary Measures of Economic Impact for Construction and
Rental income of 88 Morgan Street Apartment Building

272

 6

Household Earnings (Labor Income)

(b)(4)

The jobs created by the project subsequently create new sources of household
income. The household income created within there ional center by the construction of
the 88 Morgan Street apartment buildin is about
with another I
I
I
ltrom the purchases of FF&E and
rom architectural and engineering
services. Household income would also rise about
from the rental income
of the apartments, for a total of about f____..
The details used to calculate these figures are given throughout the report.
Separate tables are provided for the total number of jobs created, the average earnings
per new worker, and the total increase in earnings for construction and operation of the
hotel. In each case, the RIMS II inpuUoutput model has been used to calculate the
number of jobs in each major industrial classification, the average earnings per
employee, and hence total earnings. The number of jobs by industrial classification is
based on calculations imbedded in the RIMS II model for each of the activities as
summarized in Table A and documented in detail throughout this report.
Demand for Business Services, Utilities, Maintenance and Construction, and New
SupplierNendor Relationships Created with Manufacturers

(b)(4)

The total economic impact of the regional center from the supplier purchases and
business relationships for the construction and operation of the hotel will create
approximately I
I in additional economic activity across the region for the
project These suppher purchases are calculated from the indirect increase in output
generated by the RIMS II model. It should be noted that some of these supplier
industries might potentially locate within the regional center, and their economic output
is included in this total.
The estimate of supplier purchases is based on the commodity data in the RIMS
II input-output model. This data specifies the amount and type of commodity input
needed to maintain specific types of business operations. The model estimates the
supplier purchases based on the types of jobs and number of jobs that will be created
within the regional center. In addition, the model allocates the supplier purchases to
businesses within the region, based on trade flow data from the U.S. Bureau of
Economic Analysis.
Utilities include services such as electricity, natural gas, and water and sewer
facilities. The economic impact on utility services total about I
lrespectively.
Most of this represents the use of utilities by occupants of the apartments.
(b)(4)

273

 7

Maintenance and repair services include some building and construction activity
on existing buildings. The regional center would create an economic impact of about
I
I These expenditures represent permanent, ongoing maintenance on the
buildmgs after they are completed; they do not reflect the initial construction costs.
New supplier/vendor relationships with manufacturers would create an economic
impact of about
Most of this output represents purchases of locally
produced materials and parts for the construction of the building; some of these
expenditures are the purchase of locally produced supplies for the hotel.

I

(b)(4)

I

The regional center will also create demand for various types of business
services, including professional and scientific services, management of companies,
administrative services, and buildin su ort and waste management services. The
impact of this activity totals abou
Most of this represents payments to
architects and engineers for the cons rue 1on activities; it also includes outsourcing of
professional service activities for operating the hotel, such as lawyers and accountants.
The figures given in Table C represent only a brief summary of the detailed
calculations that have been undertaken and are reported in tabular format throughout
the report. The figure for utility output, for example, represents the sum of utility output
for each of the categories of economic activity listed in Table A. For repair and
maintenance construction office, this figure represents the amount spent times he
input/output coefficient showing the total amount of output per I
lof construction
expenditures. The same methodology applies to all the other figures given in Table C.
Detailed figures may be found in the tables in Sections (8) and (9), which provide
estimates of indirect jobs by industry category.

274

 8

3. Introduction and Scope of Work
The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space. This report contains the
economic impact results for the construction of the building and apartment rentals,
based on the RIMS II input/output model for the following 8 counties in New Jersey:
Hudson, Essex, Union, Bergan, Passaic, Morris, Monmouth, and Middlesex.
Section (4) contains a brief description of the RIMS II models and its various
multipliers, and Section (5) contains additional information explaining how the indirect
jobs are calculated. Section (6) contains and analyzes the key statistics for the sixcounty area used to calculate the RIMS II multipliers. Tables 6-1, 6-2, 6-3 and 6-4 show
the data for employment by major occupation and industrial classification, income
distribution by deciles, mean and median household and family income, and poverty
rates for the eight counties used to calculate the multipliers for this study, and compares
these figures to the U.S. totals or averages.
Table 6-5 shows key labor market statistics over the past decade for the State of
New Jersey, each of these counties, and the 8-county total. Tables 6-6 and 6-7 show
the level and growth rate of population and personal income for these same areas.
Table 6-8 shows the commuting patterns for Hudson County, and explains how these
figures are used to determine the counties included in the multiplier analysis. Section
(7) contains a map of the location of the building and maps of the area.
Section (8) presents the economic impact tables for the hard construction costs,
EB-5 eligible soft construction costs, and purchases of FF&E. Separate sets of tables
are presented for each category of construction for the increase in employment, output,
and earnings, and the average level of output and earnings per new worker, for the 20
major industrial classifications in the RIMS II input/output model. Section (9) discusses
the number of jobs and revenue estimates for the rental income from the apartments,
retail space, and parking, and presents similar tables for the detailed industry results.
Section (10) summarizes the RIMS II model results.

275

 9

4. Brief Guide to RIMS II Input/Output Model
The following material has been condensed from the RIMS II User Handbook.
Introduction and General Comments
Effective planning for public- and private-sector projects and programs at the
State and local levels requires a systematic analysis of the economic impacts of these
projects and programs on affected regions. In turn, systematic analysis of economic
impacts must account for the inter-industry relationships within regions because these
relationships largely determine how regional economies are likely to respond to project
and program changes. Thus, regional input-output (1-0) multipliers, which account for
inter-industry relationships within regions, are useful tools for conducting regional
economic impact analysis.
In the 1970s, the Bureau of Economic Analysis (BEA) developed a method for
estimating regional 1-0 multipliers known as RIMS (Regional Industrial Multiplier
System), which was based on the work of Garnick and Drake. In the 1980s, BEA
completed an enhancement of RIMS, known as RIMS II (Regional Input-Output
Modeling System), and. published a handbook for RIMS II users.
In 1992, BEA
published a second edition of the handbook in which the multipliers were based on
more recent data and improved methodology. In 1997, BEA published a third edition of
the handbook that provides more detail on the use of the multipliers and the data
sources and methods for estimating them.
RIMS II is based on an accounting framework called an 1-0 table. For each
industry, an 1-0 table shows the industrial distribution of inputs purchased and outputs
sold. A typical 1-0 table in RIMS II is derived mainly from two data sources: BEA's
national 1-0 table, which shows the input and output structure of nearly 500 U.S.
industries, and BEA's regional economic accounts, which are used to adjust the national
1-0 table to show a region's industrial structure and trading patterns.
Using RIMS II for impact analysis has several advantages. RIMS II multipliers
can be estimated for any region composed of one or more counties and for any industry,
or group of industries, in the national 1-0 table. The accessibility of the main data
sources for RIMS II keeps the cost of estimating regional multipliers relatively low.
Empirical tests show that estimates based on relatively expensive surveys and RIMS 11based estimates are similar in magnitude.
BEA's RIMS multipliers can be a cost-effective way for analysts to estimate the
economic impacts of changes in a regional economy. However, it is important to keep in
mind that, like all economic impact models, RIMS provides approximate order-ofmagnitude estimates of impacts. RIMS multipliers are best suited for estimating the
impacts of small changes on a regional economy. For some applications, users may
want to supplement RIMS estimates with information they gather from the region
undergoing the potential change. To use the multipliers for impact analysis effectively,

276

 10
users must provide geographically and industrially detailed information on the initial
changes in output, earnings, or employment that are associated with the project or
program under study. The multipliers can then be used to estimate the total impact of
the project or program on regional output, earnings, and employment.
RIMS II is widely used in both the public and private sector. In the public sector,
for example, the Department of Defense uses RIMS II to estimate the regional impacts
of military base closings. State transportation departments use RIMS II to estimate the
regional impacts of airport construction and expansion. In the private-sector, analysts
and consultants use RIMS II to estimate the regional impacts of a variety of projects,
such as the development of shopping malls and sports stadiums.
RIMS II Methodology
RIMS II uses BEA's benchmark and annual 1-0 tables for the nation. Since a
particular region may not contain all the industries found at the national level, some
direct input requirements cannot be supplied by that region's industries. Input
requirements that are not produced in a study region are identified using BEA's regional
economic accounts.
The RIMS II method for estimating regional 1-0 multipliers can be viewed as a
three-step process. In the first step, the producer portion of the national 1-0 table is
made region-specific by using six-digit NAICS location quotients (LQs). The LQs
estimate the extent to which input requirements are supplied by firms within the region.
RIMS II uses LQs based on two types of data: BEA's personal income data (by place of
residence) are used to calculate LQs in the service industries; and BEA's wage-andsalary data (by place of work) are used to calculate LOs in the non-service industries.
In the second step, the household row and the household column from the
national 1-0 table are made region-specific. The household row coefficients, which are
derived from the value-added row of the national 1-0 table, are adjusted to reflect
regional earnings leakages resulting from individuals working in the region but residing
outside the region. The household column coefficients, which are based on the personal
consumption expenditure column of the national 1-0 table, are adjusted to account for
regional consumption leakages stemming from personal taxes and savings. In the last
step, the Leontief inversion approach is used to estimate multipliers. This inversion
approach produces output, earnings, and employment multipliers, which can be used to
trace the impacts of changes in final demand on and indirectly affected industries.
Advantages of RIMS II
There are numerous advantages to using RIMS II. First, the accessibility of the
main data sources makes it possible to estimate regional multipliers without conducting
relatively expensive surveys. Second, the level of industrial detail used in RIMS II helps
avoid aggregation errors, which often occur when industries are combined. Third, RIMS
II multipliers can be compared across areas because they are based on a consistent set

277

 11
of estimating procedures nationwide. Fourth, RIMS II multipliers are updated to reflect
the most recent local-area wage-and-salary and personal income data.

Overview of Different Multipliers
RIMS II provides users with five types of multipliers: final demand multipliers for
output, for earnings, and for employment; and direct-effect multipliers for earnings and
for employment. These multipliers measure the economic impact of a change in final
demand, in earnings, or in employment on a region's economy.
The final demand multipliers for output are the basic multipliers from which all
other RIMS II multipliers are derived. In this table, each column entry indicates the
change in output in each row industry that results from a $1 change in final demand in
the column industry. The impact on each row industry is calculated by multiplying the
final demand change in the column industry by the multiplier for each row. The total
impact on regional output is calculated by multiplying the final demand change in the
column industry by the sum of all the multipliers for each row except the household row.
RIMS II provides two types of multipliers for estimating the impacts of changes
on earnings: final demand multipliers and direct effect multipliers. These multipliers are
derived from the table of final demand output multipliers.
The final demand multipliers for earnings can be used if data on final demand
changes are available. In the final demand earnings multiplier table, each column entry
indicates the change in earnings in each row industry that results from a $1 change in
final demand in the column industry. The impact on each row industry is calculated by
multiplying the final demand change in the column industry by the multipliers for each
row. The total impact on regional earnings is calculated by multiplying the final demand
change in the column industry by the sum of the multipliers for each row.

Employment Multipliers

(b)(4)

RIMS II provides two types of multipliers for estimating the impacts of changes
on employment: final demand multipliers and direct effect multipliers. These multipliers
are derived from the table of final demand output multipliers.
The final demand multipliers for employment can be used if the data on final
demand changes are available. In the final demand employment multiplier table, each
column entry indicates the change in employment in each row industry that results from
aI
lchange in final demand in the column industry. The impact on each row
industry is calculated by multiplying the final demand change in the column industry by
the multiplier for each row. The total impact on regional employment is calculated by
multiplying the final demand change in the column industry by the sum of the multipliers
for each row.

278

 12

The direct effect multipliers for employment can be used if the data on the initial
changes in employment by industry are available. In the direct effect employment
multiplier table, each entry indicates the total change in employment in the region that
results from a change of one job in the row industry. The total impact on regional
employment is calculated by multiplying the initial change in employment in the row
industry by the multiplier for the row.
Choosing a Multiplier
The choice of multiplier for estimating the impact of a project on output, earnings,
and employment depends on the availability of estimates of the initial changes in final
demand, earnings, and employment. If the estimates of the initial changes in all three
measures are available, the RIMS II user can select any of the RIMS II multipliers. In
theory, all the impact estimates should be consistent. If the available estimates are
limited to initial changes in final demand, the user can select a final demand multiplier
for impact estimation. If the available estimates are limited to initial changes in earnings
or employment, the user can select a direct effect multiplier.

5. Methodology for Calculating Indirect Job Gains

In spite of the explanation of the RIMS II model given directly above, some
USCIS adjudicators have asked for further clarification about how that model is used to
determine the increase in the number of indirect jobs. That is an important issue
because, unlike the direct job count, which can be verified by USCIS from various
payroll and withholding documents, the calculation of indirect jobs cannot be verified
directly but depends on mathematical calculations.
The general concept is based on the coefficients in the input/output model itself
(the same methodology applies to RIMS II, IMPLAN, or any other generally recognized
and accepted input/output model). In any given year, the government calculates how
much input is used for a given production of output. The detailed figures are taken from
the Economic Censuses taken once every five years; the figures are then updated from
various annual supplements.
Basically the process has two steps, each of which is described next in greater
detail. The first is to determine the amount of output, and hence the number of jobs,
required to produce a given amount (say $1 million) of the final product or service.
These are national coefficients. The second is to determine what proportion of those
goods and services are purchased within the local region (the regional purchase
coefficients, or RPCs).
In the case of a manufacturing process, the national coefficients are based on
production functions: how much coke per ton of steel, how much steel per motor
vehicle, how much flour for a loaf of bread, and so on. However, most of the jobs are

279

 13
created in the service sector, where Commerce Department data are used to determine,
for example, how much restaurants spend on laundry services, how much airlines
spend for attorneys, and so on. These figures are based on information contained in
the various Economic Censuses. The national coefficients would also determine, for
example, how many architects and engineers would be hired for a construction project
of a given scope and size, and how many new employees at financial institutions would
be required to handle the additional cash flow generated by the new business. Both of
these are discussed below in greater detail.
Even after these coefficients are determined, however, the regional purchase
coefficients (RPC) must still be estimated. If, for example, a trucking firm spends 1% of
its revenue on accountants, how much of that money is spent on local firms, and how
much is spent outside the region?
That answer depends on various factors. The most important is the amount of
the good or service produced within the region. If a trucking firm, for example, were
located in a small county with no accountants, obviously it would not spend any of that
money locally. That sets a lower limit but is not generally the case. Instead, a
balancing algorithm is used.
Suppose, for example, that all the firms producing, distributing, or selling goods
and services in a given county spent $10 million on accounting services.
Also,
suppose that total billings of all accountants in the county were $20 million. In that
case, local accountants could handle all the local business, plus business from
neighboring counties. If, on the other hand, total accountant billings in the county were
only $5 million, local firms could not spend more than half of the money on local
accountants.
Of course it is possible that there are adequate resources in the county but local
firms choose to use companies outside the county; perhaps prices or service is better.
No input/output model can account for such anomalies. On the other hand, given
transportation costs, it would be highly unusual for a firm to be located in a given
location and not serve the nearby businesses, instead choosing only those clients who
(b)(4) were farther away.
The RIMS II model- and other regional input/output models- assigns regional
purchase coefficients (RPCs) in all cases where the local industry purchases goods and
services from local firms. This matrix could have as many asl....__~~~-~......
elements, although in practice many of them are zero. Large counties with a wide
variety of businesses have more non-zero elements than small counties with relatively
few businesses.
In general, the RPCs tend to be close to zero for most manufactured goods, and
close to unity for most services. While there are many exceptions to this rule, most
firms will use financial, professional, business, and health care services that are located
in that county or contiguous areas.

280

 14
To take just one example of many, consider the number of new jobs created by
architects and engineers for a new construction project of any given size. Most
construction cost manuals, such as those published by R. S. Means, indicate that those
costs are usually about 5% to 9% of the total job. According to the national input/output
file, the figures are 9.2% for commercial construction and 4.5% for industrial
construction.
These figures can be compared with the proportions of architects and engineers
in the specific regional area, based on the RIMS II data that are used to determine the
economic multipliers in the specific county group. For this 8-county group, the
input/output model shows proportions of 8.4% for commercial and 4.3% for industrial
construction, indicating that 91% of the architects and engineers for commercial jobs
and 95% for industrial jobs are hired locally. These figures are fairly typical of other
locations and regions; except for "signature" buildings designed by famous names, most
architects and engineers live in the same region as the buildings that are being
constructed.
To summarize to this point, the number of indirect jobs as a proportion of direct
jobs depends on (a) the national relationships, and (b) the regional purchase
coefficients. In our presentation for the businesses in this report, we provide further
discussion of those industries with the largest number of indirect jobs. However, there
are a few industries that produce relatively large numbers of jobs in almost all cases,
and these can be generally discussed at this stage in order to avoid repeating this
information several times. The industries discussed here include banking, real estate,
legal and accounting, architects and engineers, other professional services,
employment services, other business services, restaurants, and government. In all of
these cases, the vast majority of workers are hired locally. Our comments for the rest of
this section are based on the assumption of a $10 million investment; the results are
linear.
Banking and credit: On an aggregate basis, for every $10 million in deposits,
very broadly defined (M3), there is about 1 new banking employee. As a rough rule of
thumb, the size of M3 is roughly equal to the size of GDP. Hence we would expect
about 1 new banking employee for every $10 million increase in output, as calculated
from the RIMS II model.
Real estate: Additional real estate employees are based on two factors. One is
the leasing activity of the new building, and the other is the increase in residential real
estate activity as people get new jobs, either within the area or by moving into the area.
On a lease basis, a $10 million investment is likely to result in a building of 80,000
square
feet. If it leases fort:::)uare foot, that would be $3.2 million in annual lease
(b)(4)
payments, and with a 6% commission would generate $192,000 in revenues, which
would account for about 2 new real estate employees (the figure would be less for
industrial buildings). The increase in employment would also result in some real estate
activity as workers moved into better housing in the same location, or moved in from
other areas. In a normal year, there are about 7 million sales of new and existing
homes for a labor force of about 140 rnJlllac, or 5%. Hence if the total increase in
employment werel
that would impiYL_Jeal estate transactions; if they average

281

 (b)(4)

15
$200,000 at a 6% commission, that would be $12,000 per home or a total of $120,000,
which would support approximately 1 new real estate job.
Legal & Accounting: Each of~ accounts for about 1% of total employment;
so if there were a total increase ofLJbs, we would expect an average ooew
employees in this classification.
Architects & Engineers: almost all of these jobs stem from the new construction
activity. This category has already been discussed above; for a $10 million construction
project, which would create about ~ew construction jobs, we would expect aboutO
new jobs in architects and enginee~r a commercial project andc::Jew jobs for an
industrial project.
Other professional services: This category includes employees in consulting,
scientific research and development, advertising, and management, as well as several
other smaller, specialized categories. In general, consulting, management, and the all
other category each account for about 1% of total employment, and R&D and
advertising account for about Y2% of total employment, for a total of about 4% of total
employment. This figure will vary widely depending on the degree to which consultants
and R&D are used by the new business.
Employment services: On a national average basis, 1 out of every 45 people is
employed by this industry. Here again, the figures will vary widely depending on (a) the
proportion of people who are hired through employment agencies, and (b) the
proportion of the work that is outsourced to employment services.
Business support services include office management, travel arrangement,
security, credit bureaus, telemarketing, and back-office jobs that are outsourced, such
as direct mail, copying, and duplicating services. The back-office services would vary
widely depending on the type of new business; retail stores, for example, would print
and distribute more advertising brochures than a manufacturing operation. On a
national average basis, these jobs account for about 2% of total employment.
Building support services, which includes janitorial services, lawn maintenance,
and waste management. For an office building of 80,000 square feet, the cost would be
approximately $2/sq ft per year for maintenance, or $160,000, which would support
about new jobs; here again, the figure would be lower for industrial buildings.

~estaurants:

This category reflects business meals. Of course the number of
business meals depends greatly on the type of business; lawyers, accountants, and
consultants will have more business meals than manufacturing plants or water
treatment facilities. On a national average basis, Commerce Department figures show
that total restaurant sales in 2007 were $580 billion, while consumer expenditures at
restaurants were $500 billion. However, that figure also includes tips, which are not
included in restaurant sales. After subtracting 15% for tips, that indicates about $425
billion in food and beverage purchases by consumers, indicating about $155 billion for
business expenses. With a labor force o~ximately 140 million, that is equivalent
to about $1,100 per employee. Hence ifJ.__Jew jobs were created, business meal
(b)(4)

282

 16
expenses would rise an average of $221 ,000, which would imply about 4.5 new indirect
jobs in the restaurant industry. These figures are likely to be somewhat higher when
direct jobs are created for office buildings and hotels.
Government: The increase in public sector employees represents the amount
funded by increased real estate taxes. For a construction project with $10 million in
hard costs, the total value is likely to be between $15 and $20 million when one includes
furniture, fixtures, equipment, and land values. Using a national aver~erty tax
rate of 1%, that would raise $150,000 to $200,000, which would createL__j1ew jobs
in the public sector.
(b)(4)

283

 17

6. Economic Parameters for Hudson, Essex, Union, Bergen, Passaic,
Morris, Middlesex, and Monmouth Counties
This section is organized as follows. Tables 6~1, 6~2, 6-3 and 6~4 show the data
for employment by major occupation and industrial classification, income distribution by
deciles, mean and median household and family income, and poverty rates for the eight
counties used to calculate the multipliers for this study, and compares these figures to
the U.S. totals or averages. Table 6~5 shows key labor market statistics over the past
decade for the State of New Jersey, each of these counties, and the 8-county total.
Tables 6-6 and 6~ 7 show the level and growth rate of population and personal income
for these same areas. Table 6~8 shows the commuting patterns for Hudson County,
and explains how these figures are used to determine the counties included in the
multiplier analysis.

Table 6-1. Key Economic Statistics for Hudson and Counties Compared to the U.
S. Economy, 2010 Data
Essex

%

Hudson

%

u.s.

%

612,565
400,523
344,146
56,377
247
211,795

100.0%
65.4%
65.4%
56.2%
9.2%
0.0%
34.6%

520,559
359,487
359,408
312,480
46,928
79
161,072

100.0%
69.1%
69.0%
60.0%
9.0%
0.0%
30.9%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

OCCUPATION
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production & transportation

344,146
128,336
70,110
83,284
24,850
37,566

100.0%
37.3%
20.4%
24.2%
7.2%
10.9%

312,480
118,514
54,500
75,993
22,231
41,242

100.0%
37.9%
17.4%
24.3%
7.1%
13.2%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs

344,146
839
19,412
21,063
8,192
33,180
24,477
11,875
31,756
44,064
89,318
25,779

100.0%
0.2%
5.6%
6.1%
2.4%
9.6%
7.1%
3.5%
9.2%
12.8%
26.0%
7.5%

312,480
88
17,452
25,036
12,919
31,641
24,887
10,909
34,463
42,737
60,295
23,187

100.0%
0.0%
5.6%
8.0%
4.1%
10.1%
8.0%
3.5%
11.0%
13.7%
19.3%
7.4%

139,033,928
2,646,975
8,686,813
14,439,691
' 3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%

Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

400,770

284

 18
Other private services
Public administration
INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)
Families
Less than $10,000
r---$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)
Mean family income (dollars)
Per capita income (dollars)

17,380
16,811

5.1%
4.9%

16,461
12,405

5.3%
4.0%

6,913,449
7,187,193

5.0%
5.2%

275,417 100.0%
28,243
10.3%
6.0%
16,478
28,288
10.3%
25,719
9.3%
32,635
11.8%
44,176
16.0%
31,262
11.4%
32,280
11.7%
14,778
5.4%
21,558
7.8%
52,394 104.7%
80,167 117.4%

238,692
19,411
14,462
24,152
20,533
29,768
44,776
26,814
31,304
11,757
15,715
54,817
76,339

100.0%
8.1%
6.1%
10.1%
8.6%
12.5%
18.8%
11.2%
13.1%
4.9%
6.6%
109.5%
111.8%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

175,731 100.0%
12,211
6.9%
6,627
3.8%
15,282
8.7%
15,561
8.9%
19,250
11.0%
26,811
15.3%
21,661
12.3%
25,935
14.8%
13,439
7.6%
18,954
10.8%
66,439 109.6%
97,237 122.6%
29,674 113.9%

147,709
8,382
7,409
14,311
12,795
20,209
27,360
16,708
21,969
8,032
10,534
57,978
81,559
29,798

100.0%
5.7%
5.0%
9.7%
8.7%
13.7%
18.5%
11.3%
14.9%
5.4%
7.1%
95.7%
102.8%
114.3%

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609
79,338
26,059

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

Median earnings for workers
Median earnings for male full-time
Median earnings for female full-time

32,961
49,597
41,317

114.1%
106.7%
113.0%

35,677
50,563
41,173

123.5%
108.7%
112.6%

28,899
46,500
36,551

PERCENTAGE BELOW POVERTY LEVEL
All families
All people

13.9%
16.7%

123.0%
109.2%

13.7%
16.5%

121.2%
107.8%

11.3%
15.3%

Please note that in these tables, the percentage figures in regular type refer to the overall category in
that column, while the figures in red are relative to the U.S. average figures

The income distributions in Essex and Hudson Counties can best be described
as "fat-tailed", with greater than average percentages in the highest and lowest income
brackets. To elaborate, 11% of families in each of the two counties earn less than
$15,000 a year, compared to 8% nationally- while 11% of Essex families and 7% of
Hudson families earn $200,000 or more, compared to 5% for the U.S. This dichotomy
can also be seen in the high mean household incomes ($80K in Essex and $76K in

285

 19
Hudson, versus $68K for the U.S.) and large share of families living in poverty (14% in
each county, versus 11% for the nation).
Turning to the occupation data, both counties have lower than average shares in
manufacturing as well as the arts, entertainment, hotel, and food service industries and higher than average shares in transportation and finance. The counties differ in the
mix of workers in the education and health care industries, as Essex (26%) has a higher
proportion than average and Hudson has a lower proportion at 19% - the smallest of
the five counties.

Table 6-2. Key Economic Statistics for Union and Bergen Counties Compared to
the U.S. Economy
Category

Union

%

Bergen

%

EMPLOYMENT STATUS

u.s.

%

2010
420,828

100.0%

727,196

100.0%

243,832,923

100.0%

291,604

69.3%

478,944

65.9%

156,966,769

64.4%

291,560

69.3%

478,892

65.9%

155,917,013

63.9%

255,497

60.7%

438,302

60.3%

139,033,928

57.0%

36,063

8.6%

40,590

5.6%

16,883,085

6.9%

0.0%

52

0.0%

1,049,756

0.4%

129,224

30.7%

248,252

34.1%

86,866,154

35.6%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

Management & professional

90,913

35.6%

201,513

46.0%

49,975,620

35.9%

Service occupations

43,165

16.9%

55,159

12.6%

25,059,153

18.0%

Sales and office occupations

62,273

24.4%

114,453

26.1%

34,711,455

25.0%

Construction, maintenance, repair

22,283

8.7%

28,908

6.6%

12,697,304

9.1%

Production & transportation

36,863

14.4%

38,269

8.7%

16,590,396

11.9%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

0.1%

919

0.2%

2,646,975

1.9%

6.9%

24,897

5.7%

8,686,813

6.2%

9.1%

14,439,691

10.4%

Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

44

OCCUPATION
Civilian employed population 16+

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction

177
17,557

Manufacturing

24,870

9.7%

40,015

Wholesale trade

10,869

4.3%

19,216

4.4%

3,941,066

2.8%

Retail trade

25,990

10.2%.

47,458

10.8%

16,203,408

11.7%

Transportation & utilities

18,211

7.1%

22,703

5.2%

6,843,579

4.9%

7,394

2.9%

16,169

3.7%

3,015,521

2.2%

Information

286

 20
Finance, insurance, & real estate
Professional & administrative

21,793
29,021

8.5%

45,159

10.3%

9,275,465

6.7%

11.4%

58,730

13.4%

14,710,089

10.6%

22.6%

32,311,107

23.2%

Educational services & health care

53,596

21.0%

99,084

Arts, entertain, hotel, food svcs

19,342

7.6%

28,699

6.5%

12,859,572

9.2%

Other private services

13,531

5.3%

20,540

4.7%

6,913,449

5.0%

Public administration

13,146

5.1%

14,713

3.4%

7,187,193

5.2%

183,882

100.0%

333,002

100.0%

114,567,419

100.0%

5.8%

15,136

4.5%

8,757,190

7.6%

3.3%

12,370

3.7%

6,668,865

5.8%

7.4%

13,165,380

11.5%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999

10,740
6,138

$15,000 to $24,999

15,300

8.3%

24,587

$25,000 to $34,999

14,321

7.8%

23,753

7.1%

12,323,322

10.8%

$35,000 to $49,999

23,549

12.8%

33,430

10.0%

16,312,385

14.2%

$50,000 to $74,999

31,943

17.4%

53,157

16.0%

20,940,859

18.3%

$75,000 to $99,999

21,678

11.8%

40,999

12.3%

13,526,500

11.8%

$100,000 to $149,999

31,378

17.1%

56,634

17.0%

13,544,839

11.8%

$150,000 to $199,999

11,796

6.4%

34,456

10.3%

4,809,998

4.2%

9.3%

38,480

11.6%

4,518,081

3.9%

133.2%

77,389

154.6%

50,046

94,659

138.7%

105,488

154.5%

68,259

131,811

100.0%

236,574

100.0%

76,089,045

100.0%

Less than $10,000

6,001

4.6%

6,237

2.6%

3,824,251

5.0%

$10,000 to $14,999

2,973

2.3%

4,959

2.1%

2,660,781

3.5%

$15,000 to $24,999

8,903

6.8%

11,365

4.8%

6,770,812

8.9%

$25,000 to $34,999

8,224

6.2%

12,914

5.5%

7,332,318

9.6%

11.7%

19,255

8.1%

10,578,051

13.9%

17.6%

36,079

15.3%

14,990,631

19.7%

12.0%

29,860

12.6%

10,638,931

14.0%

19.4%

49,242

20.8%

11,261,766

14.8%

7.9%

31,650

13.4%

4,130,868

5.4%

11.6%

35,013

14.8%

3,900,636

5.1%

127.6%

97,394

160.7%

60,609

107,812

135.9%

123,384

155.5%

79,338

Per capita income (dollars)

33,267

127.7%

39,409

151.2%

26,059

Median earnings for workers

35,214

121.9%

44,350

153.5%

28,899

Median earnings for male full-time

51,195

110.1'%

63,074

135.6%

46,500

Median earnings for female full-time

43,496

119.0%

51,103

139.8%

36,551

$200,000 or more
Median household income (dollars)
Mean household income (dollars)

Families

$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)
Mean family income (dollars)

17,039
66,665

15,365
23,157
15,838
25,630
10,400
15,320
77,361

·-·····

287

 21

PERCENTAGE BELOW POVERTY LEVEL
All families
All people

8.70%
11.10%

77.0%

5.6%

49.6%

11.30%

72.5%

6.8%

44.4%

15.30%

Union County is mixed, with many high-income suburban areas but also lowincome areas by the railroad tracks. As a result it has a high proportion of households
and families at the upper end of the income scale, but almost a proportional amount at
the lower end of the scale. As a result, while the median and mean income levels are
above average and the poverty levels are below average, these figures are smaller than
would be expected from a typical suburban county, and well below Bergen County. By
comparison, Bergen County has about three times the national average in the top
income bracket, and only about half in the bottom bracket. As a result, median family
income for Union County is 128% of the national average, while the figure for Bergen
County is 161% of the average. Similarly, the poverty rate for all families is 77% of the
national average for Union County, but only 50% for Bergen County.
In terms of employment distribution by occupation, both counties have a fairly
robust manufacturing base, only slightly below the national average. Most of the other
sectors are also close to those averages, with slightly higher proportions for financial
and professional services.

Table 6-3. Key Economic Statistics for Morris and Passaic Counties Compared to
the U.S. Economy
Category

Morris

%

Passaic

%

EMPLOYMENT STATUS

u.s.

%

2010
389,318

100.0%

392,154

100.0%

243,832,923

100.0%

265,835

68.3%

251,834

64.2%

156,966,769

64.4%

265,835

68.3%

251,834

64.2%

155,917,013

63.9%

242,762

62.4%

223,928

57.1%

139,033,928

57.0%

Unemployed

23,073

5.9%

27,906

7.1%

16,883,085

6.9%

Armed Forces

0

0.0%

0

0.0%

1,049,756

0.4%

123,483

31.7%

140,320

35.8%

86,866,154

35.6%

242,762

100.0%

223,928

100.0%

139,033,928

100.0%

117,011

48.2%

72,732

32.5%

49,975,620

35.9%

Service occupations

31,488

13.0%

41,066

18.3%

25,059,153

18.0%

Sales and office occupations

61,530

25.3%

55,173

24.6%

34,711,455

25.0%

Construction, maintenance, repair

13,971

5.8%

15,773

7.0%

12,697,304

9.1%

Production & transportation

18,762

7.7%

39,184

17.5%

16,590,396

11.9%

Population 16 years and over
In labor force
Civilian labor force
Employed

Not in labor force

OCCUPATION
Civilian employed population 16+
Management & professional

288

 22

INDUSTRY
242,762

100.0%

605

Construction
Manufacturing

223,928

100.0%

139,033,928

100.0%

0.2%

106

0.0%

2,646,975

1.9%

13,025

5.4%

12,406

5.5%

8,686,813

6.2%

29,462

12.1%

30,737

13.7%

14,439,691

10.4%

8,531

3.5%

9,361

4.2%

3,941,066

2.8%

Retail trade

24,489

10.1%

27,233

12.2%

16,203,408

11.7%

Transportation & utilities

11,615

4.8%

10,168

4.5%

6,843,579

4.9%

Information

10,352

4.3%

5,816

2.6%

3,015,521

2.2%

Finance, insurance, & real estate

26,164

10.8%

17,055

7.6%

9,275,465

6.7%

Professional & administrative

33,295

13.7%

25,463

11.4%

14,710,089

10.6%

Educational services & health care

55,177

22.7%

50,431

22.5%

32,311,107

23.2%

Arts, entertain, hotel, food svcs

12,728

5.2%

16,915

7.6%

12,859,572

9.2%

Other private services

8,589

3.5%

11,461

5.1%

6,913,449

5.0%

Public administration

8,730

3.6%

6,776

3.0%

7,187,193

5.2%

Total households

177,786

100.0%

161,527

100.0%

114567,419

100.0%

Less than $10,000

5,141

2.9%

14,538

9.0%

8,757,190

7.6%

$10,000 to $14,999

3,562

2.0%

7,604

4.7%

6,668,865

5.8%

$15,000 to $24,999

10,598

6.0%

17,286

10.7%

13,165,380

11.5%

$25,000 to $34,999

10,446

5.9%

17,003

10.5%

12,323,322

10.8%

$35,000 to $49,999

15,265

8.6%

19,142

11.9%

16,312,385

14.2%

$50,000 to ~~74,999

27,277

15.3%

26,057

16.1%

20,940,859

18.3%

$75,000 to ~~99,999

25,266

14.2%

17,637

10.9%

13,526,500

11.8%

$100,000 to $149,999

33,587

18.9%

24)27

14.9%

13,544,839

11.8%

$150,000 to $199,999

20,542

11.6%

10,658

6.6%

4,809,998

4.2%

$200,000 or more

26,102

14.7%

7,475

4.6%

4,518,081

3.9%

Median household income (dollars)

91,469

182.8'}{,

53,993

107.9%

50,046

121,784

178.4%

73,618

107.9%

68,259

128,754

100.0%

113,041

100.0%

76,089,045

100.0%

Less than $10,000

1,983

1.5%

7,061

6.2%

3,824,251

5.0%

$10,000 to $14,999

1,149

0.9%

2,987

2.6%

2,660,781

3.5%

$15,000 to ~)24,999

4,287

3.3%

10,418

9.2%

6,770,812

8.9%

$25,000 to ~)34,999

5,257

4.1%

10,897

9.6%

7,332,318

9.6%

$35,000 to S49,999

9,063

7.0%

11,966

10.6%

10,578,051

13.9%

$50,000 to ~)74,999

18,910

14.7%

19,967

17.7%

14,990,631

19.7%

$75,000 to ~)99,999

18,470

14.3%

13,043

11.5%

10,638,931

14.0%

Civilian employed population 16+
Agriculture & mining

Wholesale trade

INCOME AND BENEFITS
-·-·-·~----.

Mean housE!hold income (dollars)

Families

289

 23
$100,000 to $149,999

27,700

21.5%

20,577

18.2%

11,261,766

14.8%

$150,000 to $199,999

18,007

14.0%

9,254

8.2%

4,130,868

5.4%

$200,000 or more

23,928

18.6%

6,871

6.1%

3,900,636

5.1%

Median family income (dollars)

107,639

177.6%

65,248

107.7%

60,609

Mean family income (dollars)

141,174

177.9%

84,767

106.8%

79,338

Per capita income (dollars)

44,393

170.4%

25,244

96.9%

26,059

Median earnings for workers

48,157

166.6%

30,444

105.3%

28,899

Median earnings for male full-time

77,163

165.9%

46,945

101.0%

46,500

Median earnings for female full-time

55,422

151.6%

37,130

101.6%

36,551

All families

3.7%

32.7%

12.5%

110.6%

11.30%

All people

6.0%

39.2%

15.7%

102.6%

15.30%

PERCENTAGE BELOW POVERTY LEVEL

Morris County is a typical upscale suburban county; Passaic County is mixed,
somewhat like Union County, with pockets of poverty as well as islands of affluence. In
Morris County, median family income is 178% of the national average, similar to but
even higher than Bergen County, while Passaic is only 108% of the average, similar to
but lower than Union County. The poverty levels reflect this difference in income; for all
families, the rate is only 1/3 of the national average for Morris County, but 110% of that
average for Passaic County.
Both counties have a higher than average proportion of the workforce in
manufacturing, at 12.1% for Morris County and 13.7% for Passaic County, compared to
10.4% nationally. Both counties also have a higher than average proportion of workers
in financial and professional services, although the increment is much smaller for
Passaic County. Offsetting these bulges, both counties have a much smaller than
average proportion of workers in arts, entertainment, leisure, hotels, and restaurants.
Table 6-4. Economic Profile of Middlesex and Monmouth Counties and
Comparison with the U.S., 2010 Data
Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

Middlesex
647,766
436,439
436,344
392,654
43,690
95
211,327

% Monmouth
100.0%
67.4%
67.4%
60.6%
6.7%
0.0%
32.6%

499,682
334,514
334,163
305,172
28,991
351
165,168

%

u.s.

%

100.0%
66.9%
66.9%
61.1%
5.8%
0.1%
33.1%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

OCCUPATION

290

 24
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production & transportation

392,654
170,323
55,446
99,238
25,049
42,598

100.0%
43.4%
14.1%
25.3%
6.4%
10.8%

305,172
131,997
46,342
81,326
21,803
23,704

100.0%
43.3%
15.2%
26.6%
7.1%
7.8%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs
Other private services
Public administration

392,654
628
18,052
39,615
17,826
43,951
26,800
12,486
36,177
52,832
83,080
29,705
15,450
16,052

100.0%
0.2%
4.6%
10.1%
4.5%
11.2%
6.8%
3.2%
9.2%
13.5%
21.2%
7.6%
3.9%
4.1%

305,172
1,043
16,060
20,781
10,399
33,644
14,981
13,058
33,142
39,280
70,468
24,158
11,999
16,159

100.0%
0.3%
5.3%
6.8%
3.4%
11.0%
4.9%
4.3%
10.9%
12.9%
23.1%
7.9%
3.9%
5.3%

139,033,928
2,646,975
8,686,813
14,439,691
3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572
6,913,449
7,187,193

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%
5.0%
5.2%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)

278,877 100.0%
9,344
3.4%
8,634
3.1%
20,963
7.5%
17,484
6.3%
28,013
10.0%
52,023
18.7%
41,574
14.9%
59,641
21.4%
23,338
8.4%
17,863
6.4%
76,443 152.7%
91,077 133.4%

234,582
8,749
7,916
20,280
16,779
21,105
34,504
30,287
43,322
23,299
28,341
80,816
109,907

100.0%
3.7%
3.4%
8.6%
7.2%
9.0%
14.7%
12.9%
18.5%
9.9%
12.1%
161.5%
161.0%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

Families
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)

203,542
3,425
3,594
10,298
10,039
18,530
36,692
32,490
51,013
21,178
16,283
88,678

159,264
3,542
2,250
7,999
8,157
11,826
20,099
23,504
36,806
19,441
25,640
101,714

100.0%
2.2%
1.4%
5.0%
5.1%
7.4%
12.6%
14.8%
23.1%
12.2%
16.1%

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

100.0%
1.7%
1.8%
5.1%
4.9%
9.1%
18.0%
16.0%
25.1%
10.4%
8.0%
146.3%

167.8%

291

 25
Mean family income (dollars)
Per capita income (dollars)

--

102,733
32,017

122.9%

132,616
41,434

167.2%
159.0%

79,338
26,059

Median earnings for workers
Median earnings for male full-time
Median earnings for female full-time

40,270
61,557
47,101

139.3%
132.4%
128.9%

42,266
71,576
52,072

146.3%
153.9%
142.5%

28,899
46,500
36,551

PERCENTAGE BELOW POVERTY LEVEL
All families
All people

5.1%
7.7%

45.1%
50.3%

5.0%
6.6%

44.2%
43.1%

11.3%
15.3%

129.5%

Middlesex and Monmouth Counties are prototypical wealthy suburbs, with
median household incomes more than 50% higher than the U.S. figures and poverty
rates half of the national averages or less. Monmouth County has an especially high
share of the wealthy, with 12% of households earning $200,000 or more - compared to
4% for the U.S.
Consistent with their high-income profiles, both counties have high percentages
of white-collar workers - 43% in each county, compared to 36% nationally. Similar to
the other counties in the region, Middlesex (9%) and Monmouth (11 %) have high shares
of workers in the finance and insurance industries - compared to 7% for the U.S.
Unlike Middlesex County, Monmouth County has a lower than average proportion of its
workforce in manufacturing, at 7%.
Table 6-5. Labor Market Statistics for 8 Counties in Northern New Jersey, 20022011 Data
Labor Force

Employed

Unemployed

Un Rate,%

New Jersey
2002

4,370,809

4,117,265

253,544

5.8

2003

4,363,896

4,108,397

255,499

5.9

2004
2005

4,358,908
4,404,451

4,144,223
4,207,738

214,685
196,713

4.9
4.5

2006

4,465,067

4,257,899

207,168

4.6

2007

4,456,306

4,264,617

191,689

4.3

2008

4,262,281

246,829

2009

4,509,110
4,546,443

4,138,364

408,079

5.5
9.0

2010

4,554,076

4,116,640

437,436

9.6

4,556,186

4,131,832

424,354

9.3

2011

Bergen
2002

466,326

442,760

23,566

5.1

2003

465,115

441,480

23,635

5.1

2004

462,702

443,247

19,455

4.2

292

 26
2005

467,206

449,791

17,415

3.7

2006

473,275

455,022

18,253

3.9

2007

472,991

456,594

16,397

3.5

2008

478,584

457,046

21,538

4.5

2009

480,720

443,620

37,100

7.7

2010

476,243

436,522

39,721

8.3

2011

479,131

441,277

37,854

7.9

2002

371,383

344,532

26,851

7.2

2003

369,164

342,304

26,860

7.3

2004

363,454

340,905

22,549

6.2

2005

361,843

341,544

20,299

5.6

2006

364,175

343,012

21,163

5.8

2007

362,785

343,281

19,504

5.4

2008

366,007

341,853

24,154

6.6

2009

367,125

329,526

37,599

10.2

2010

370,372

329,355

41,017

11.1

2011

370,417

330,337

40,080

10.8

2002

296,200

273,503

22,697

7.7

2003

292,204

270,633

21,571

7.4

2004

287,381

269,725

17,656

6.1

2005

288,312

272,630

15,682

5.4

2006

290,204

274,266

15,938

5.5

2007

290,990

276,383

14,607

5.0

2008

294,408

275,666

18,742

6.4

2009

299,839

268,570

31,269

10.4

2010

310,845

277,281

33,564

10.8

2011

312,467

280,302

32,165

10.3

2002

Middlesex
413,685

390,439

23,246

5.6

2003

411,128

388,372

22,756

5.5

2004

410,464

391,663

18,801

4.6

2005

415,943

398,420

17,523

4.2

2006

421,868

403,617

18,251

4.3

2007

421,754

405,387

16,367

3.9

2008

425,916

404,463

21,453

5.0

2009

427,408

391,354

36,054

8.4

2010

436,381

398,449

37,932

8.7

2011

436,228

399,546

36,682

8.4

Essex

Hudson

293

 27

Monmouth
2002

325,726

308,550

17,176

5.3

2003

323,789

306,191

17,598

5.4

2004

322,012

307,448

14,564

4.5

2005

324,105

310,869

13,236

4.1

2006

329,093

315,612

13,481

4.1
3.8

2007

332,191

319,687

12,504

2008

335,353

318,975

16,378

4.9

2009

336,577

308,793

27,784

8.3

2010

329,433

300,427

29,006

8.8

2011

329,571

301,254

28,317

8.6

2002

265,499

253,291

12,208

4.6

2003

266,068

253,862

12,206

4.6

2004

265,376

255,660

9,716

3.7

2005

267,813

259,088

8,725

3.3

2006

272,237

263,196

9,041

3.3

2007

272,580

264,282

8,298

3.0

2008

275,584

264,528

11,056

4.0

2009

275,118

255,839

19,279

7.0

2010

272,994

252,965

20,029

7.3

2011

272,849

253,719

19,130

7.0

2002

236,848

220,154

16,694

7.0

2003

236,729

219,363

17,366

7.3

2004

233,946

219,516

14,430

6.2

2005

235,518

222,610

12,908

5.5

2006

237,194

223,944

13,250

5.6

2007

237,294

224,527

12,767

5.4

2008

240,836

224,443

16,393

6.8

2009

244,838

218,118

26,720

10.9

2010

244,764

216,367

28,397

11.6

2011

246,012

218,724

27,288

11.1

2002

269,672

252,547

17,125

6.4

2003

268,107

251,137

16,970

6.3

2004

265,034

250,970

14,064

5.3

2005

265,654

252,991

12,663

4.8

2006

268,521

255,487

13,034

4.9

Morris

Passaic

Union

294

 28
2007

267,960

255,865

12,095

4.5

2008

271,553

255,902

15,651

5.8

2009

273,728

248,504

25,224

9.2

2010

275,137

248,502

26,635

9.7

2011

275,886

249,244

26,642

9.7

8 counties
2002

2,645,339

2,485,776

159,563

6.0

2003

2,632,304

2,473,342

158,962

6.0

2004

2,610,369

2,479,134

131,235

5.0

2005

2,626,394

2,507,943

118,451

4.5

2006

2,656,567

2,534,156

122,411

4.6

2007

2,658,545

2,546,006

112,539

4.2

2008

2,688,241

2,542,876

145,365

5.4

2009

2,705,353

2,464,324

241,029

8.9

2010

2,716,169

2,459,868

256,301

9.4

2011

2,722,561

2,474,403

248,158

9.1

The unemployment rate for this part of New Jersey is very similar to the profile
for the overall U. S., although the figures in 2010 and 2011 are marginally lower. By
individual county, Hudson, Essex, Union, and Passaic counties have rates that are
above the 8.9% level for 2011, while Bergen, Middlesex, Morris, and Monmouth are
below average. According to BLS statistics as of December 1, 2012, there were almost
250,000 unemployed people in this 8-county region in 2011.

Table 6-6. Level and Growth Rate of Population, State of New Jersey, 8 Counties
in the Northern New Jersey, and the Total of these Counties
(Table is divided into Sections A and B for easier viewing)
New Jersey

Bergen

Essex

Hudson

Union

Middlesex

2011

8,821,155

911,004

785,137

641,224

539,494

814,217

2010

8,799,593

906,184

784,099

634,979

537,475

810,747

2009

8,755,602

900,319

781,943

628,572

532,434

805,204

2008

8,711,090

895,328

778,165

619,533

527,528

799,191

2007

8,677,885

890,817

778,996

613,637

524,960

792,137

2006

8,661,679

889,406

781,027

613,577

525,153

786,890

2005

8,651,974

891,446

786,341

614,664

526,161

787,329

2004

8,634,561

893,378

791,305

614,607

526,916

781,582

2003

8,601,402

892,214

795,167

614,813

527,611

775,973

2002

8,552,643

890,647

795,625

615,554

527,625

769,280

2011/10

0.25%

0.53%

0.13%

0.98%

0.38%

0.43%

2010/09

0.50%

0.65%

0.28%

1.02%

0.95%

0.69%

2009/08

0.51%

0.56%

0.49%

1.46%

0.93%

0.75%

295

 29
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

0.38%
0.19%
0.11%
0.20%
0.39%
0.57%

0.51%
0.16%
-0.23%
-0.22%

2011/02

0.34%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02
2011/02

Middlesex
814,217
810,747
805,204
799,191
792,137
786,890
787,329
781,582
775,973
769,280
0.43%

0.13%
0.18%

-0.11%
-0.26%
-0.68%
-0.63%
-0.49%
-0.06%

0.96%
0.01%
-0.18%
0.01%
-0.03%
-0.12%

0.49%
-0.04%
-0.19%
-0.14%
-0.13%
0.00%

0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

0.25%

-0.15%

0.45%

0.25%

0.63%

Morris
494,976
492,681
490,779
489,743
488,355
487,486
485,472
483,997

Passaic
502,007
501,606
498,641
494,904
492,886
492,730
493,600
493,981

8 counties
5,319,079
5,298,691
5,266,561
5,231,740

481,000
477,234

494,915
494,571

5,209,106
5,195,068

Monmouth
631,020

630,920
628,669
627,348
626,644
626,934
627,838
628,605
627,413
624,532

5,208,432
5,203,203
5,212,851
5,214,371

0.47%

0.08%

0.69%
0.75%
0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

0.02%
0.36%
0.21%
0.11%
-0.05%
-0.14%
-0.12%
0.19%
0.46%

0.39%
0.21%
0.28%
0.18%
0.41%
0.30%
0.62%
0.79%

0.59%
0.76%
0.41%
0.03%
-0.18%
-0.08%
-0.19%
0.07%

0.38%
0.61%
0.67%
0.45%
0.10%
-0.19%
-0.03%
0.10%
0.27%

0.63%

0.11%

0.41%

0.17%

0.26%

Population growth in this 8-county area was not only well below the 1% rate for
the U.S, but was less than half the rate in New Jersey; since that is the figure for the
entire state, the growth rate was only about 1/5 of that for the other 9 counties in New
Jersey. The pattern reversed course at mid-decade, with an actual decline from 2004
through 2007 being followed by an average growth rate of 0.5% from 2008 to 2011.

Table 6-7. Level and Growth Rate of Personal Income, Billions of Dollars, State of
New Jersey, 8 Counties in Northern New Jersey, and the Total of these Counties

2011

New Jersey
462.49

Bergen
60.21

Essex
41.58

Hudson
30.38

Union
27.98

296

 30
26.63

2010

443.74

57.44

40.01

28.75

2009

430.96

56.36

37.98

26.82

25.76
27.59

2008

454.21

61.09

40.20

26.57

2007

436.12

60.04

38.83

24.21

26.64

2006

411.43

55.78

36.93

22.69

25.54

2005

379.65

50.55

33.99

21.15

23.28

2004

365.26

48.66

32.77

19.99

22.54

2003

347.69

45.62

30.81

19.24

21.87

2002

341.56

46.24

30.14

19.00

21.51

2011/10

4.23%

4.83%

3.91%

5.66%

5.08%

2010/09

2.97%

1.91%

5.34%

7.20%

3.35%

2009/08

-5.12%

-7.73%

-5.53%

0.96%

-6.63%

2008/07

4.15%

1.75%

3.53%

9.76%

3.57%

2007/06

6.00%

7.63%

5.14%

6.69%

4.31%
9.72%

2006/05

8.37%

10.34%

8.65%

7.26%

2005/04

3.94%

3.90%

3.73%

5.81%

3.29%

2004/03

5.05%

6.65%

6.37%

3.88%

3.06%

2003/02

1.80%

-1.33%

2.21%

1.30%

1.70%

2011/02

3.42%

2.98%

3.63%

5.35%

2.96%

Middlesex

Monmouth

Morris

Passaic

8 counties

2011

40.06

36.82

35.50

21.69

294.23

2010

38.34

35.59

34.18

20.64

281.58

2009

37.58

34.79

32.98

20.03

272.31

20.57

289.02

2008

39.53

37.22

36.25

2007

37.22

36.15

34.77

19.83

277.68

2006

34.78

33.68

33.11

18.66

261.17

2005

32.14

30.87

30.55

17.41

239.95

2004

31.00

29.78

29.42

16.48

230.64
218.81

2003

30.07

27.75

27.32

16.13

2002

29.55

27.36

26.93

15.92

216.63

2011/10

4.50%

3.45%

3.87%

5.09%

4.49%

2010/09

2.02%

2.31%

3.65%

3.04%

3.41%

2009/08

-4.95%

-6.53%

-9.04%

-2.60%

-5.78%

2008/07

6.20%

2.97%

4.28%

3.74%

4.08%

2007/06

7.01%

7.35%

5.01%

6.26%

6.32%

2006/05

8.22%

9.09%

8.37%

7.17%

8.84%

2005/04

3.70%

3.66%

3.85%

5.61%

4.04%

2004/03

3.10%

7.32%

7.67%

2.22%

5.41%

2003/02

1.76%

1.43%

1.47%

1.28%

1.00%

297

 31

3.44%

2011/02

3.35%

3.12%

3.49%

3.46%

The growth in personal income over the decade for this 8-county region was the
same as the rest of New Jersey, and about 0.3% per year lower than the U.S. economy.
The decline in 2009 was obviously tied to the financial markets, but was not nearly as
severe as the swings in Manhattan and the suburban counties in New York State. Of
particular interest is that income actually continued to rise in Hudson County in 2009 in
spite of the increasing concentration of financial institutions who have moved across the
river from New York City; it was the only county in this group where income did not
decline in 2009. The rebound in 2010 and 2011 for the entire region continued to be
close to the national average; for Hudson County, the increase was well above average.
Finally, we turn to the commuting patterns. In determining the economic impact
of new job creation, it is necessary to choose the counties that form the relevant area
for analysis. The economic multipliers will be higher as the number of counties included
in the area increases. If the proportion of the workforce covered rises above 95%, that
would include too many jobs that are not directly related to the new project. If that
proportion falls below 90%, the multipliers would probably be understated. Hence the
commuting patterns of the workforce data from the 2000 Census are used to determine
the optimal mix of counties to be included in the multiplier calculations. These
commuters spend most of their paychecks in the counties where they live, so the
economic impact of the new project creates some new induced jobs in bordering
counties. Also, some of the goods and services purchased by the new businesses are
produced or purchased from establishments in neighboring counties.
Table 6-8 can be interpreted as follows. In 2000, there were 223,225 people in
the Hudson County workforce. Of these, 121 ,352 lived in Hudson County, 25,444 lived
in Bergen County, and so on. We have included counties that accounted for 84.1% of
the total Hudson County workforce, which is below the usual level because many of the
commuters live in far-flung counties that have few links with Hudson County.
Table 6-8. Commuting Patterns for Hudson County, NJ
Total Hudson County Workforce
Living in these counties:

223,225

Hudson Co. NJ

121,352

Bergen Co. NJ

25,444

Essex Co. NJ

16,193

Middlesex Co. NJ

8,706

Union Co. NJ

8,251

Passaic Co. NJ

6,468

Monmouth Co. NJ

6,165

Morris Co. NJ

4,806

Total these 8 counties
% in these 8 counties

197,835
84.1%

298

 32

7. Location of Building, Maps of Area, and TEA Analysis
Figure 7-1. Location of 88 Morgan Street, Jersey City

2"'1 S!
~

~

2"'1$!

>

l;;
I

£
fru~ Jf

<?

"

~

t

l>t $t

'!>\l<:t!C~O~~"<~f

Bily$1

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J

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0

~~.."" 1St

4~¢

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lf!Jr

l

,.

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q

fl:J~

Gra~st

,.

l

!;

l
225 a~$t\d

Jr"

li

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z

Gra"'1S!

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299

 33
Figure 7-2. Location of Building in the 8-County Area

""•

,tiiil•wilre
tWa!erGap
,,~//"'

Washington

Reading

110 mi

20~m

·1j
1

I''

300

 34

Figure 7-3. County Map of New Jersey

  
  

?22/11? 
mm

   
 
 

   

 

mafia gunman





        
    
  

   
 

     
   
  

.
434% .


  

   

 

            
    

   
 



     

  


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301

35
TEA Analysis
A TEA can be formed from CTs 3,4,5,6,7,8,11, 12,01,12.02, 15, 22,23, 25, 26,
30, 31, 32 33, 44, 45,46,50, 51, 52, 53, and 55; the locations of these CTs are shown in
Figure 7-4. The Property is located in CT 26. A letter of certification is expected from
the New Jersey Department of Labor.

Figure 7-4. Census Tract Map of Jersey City

302

 36

8. Economic Impact of Construction Expenditures

I

Table 8-1 shows the total development budget of
Of this
amount, about
lis EB-5 eligible hard construction costsl
lis
architectural, engmeenng, and related fees, and
s purchases of furniture,
fixtures, and equipment (FF&E). The remainin
consists rimaril of land
costs, interest costs, contingencies, and fees. The total
in EB-5
eligible hard construction costs used in the RIMS II calculation expressly excludes, the
ll · f ures stated in the Detailed Construction Budget set out in Table 8-2: (i)
n Construction Contingency; (ii}l
for Bond Completion, and (iii)
or Jersey City Police.

I

(b)(4)

U

Table 8-1. Sources and Uses of Funds

(b)(4)

The details of the budget are given in Table 8-2. We have subtracted certain
items from the Hard Cost figure given in Table 8-1 that are not EB-5 eligible; the
remaining amount includes building, parking, and site preparation. EB-5 eligible soft
costs are architectural, engineering, and surveying fees. The line items included in the
hard cost are the buildrg costsl of'
land the parking garage costs of
I
lfor a total of
mil1on.
(b)(4)

Table 8-2. Detailed Construction Budget

303

 37

(b)(4)

USCIS has requested that these figures be related to industry standards.
According to R. S. Means, Square Foot Costs, 34th Annual Edition (2013), the average
construction cost per square foot for an apartment building on a national average basis
is '•
These
1 lhe average cost for an underground parking garage is $72.73.
figures should be multiplied by the rrgjonal caeffident for Jersey City, NJ, which is 1.1 0,
hence raising these figures to about
~spectively. These numbers can
(b)(4)
304

 38

I
(b)(4)

be compared with the cost per square foot given in the above table of I
I and
I The figure for the apartment building is below industry standards; the figure
for the parking garage is above industry standards, but the weighted average of these

tw(:,:::,~:fs of the building it

o
fe

lompared to the R. S. Means average figure

he additional cost of the parking garage reflects is attributable to design
d to the land being near the water and within a flood zone.

In general, USCIS has indicated that current-dollar numbers should be deflated
to the year in which the input/output coefficients were calculated, which in this case is
2008. For construction expenditures, however, prices have actually dropped since then,
as shown in the Turner construction index.
The estimated values used in the impact analysis are as follows: 2012, 829;
2013, 845, and 2014, 862 (a 2% annual growth rate). For projects being constructed in
2013 and 2014, the average level would be 854, which is well below the 908 level
reached in 2008.
index
3rd Quarter 2012

832

0.73

2nd Quarter 201.2
1st Quarter 2012
4th Quarter 2011

826
821
818

0.61
0.37
0.49

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000
1999

812
799
832
908
854
793
717
655
621
619
613
595
570

1.6
-4.0
-8..4
6.3
7.7
10.6
9.5
5.4
0.3
1.0
3.0
4.4
3..8

Turner has prepared the construction cost forecast for more than 80 years. Used
widely by the construction industry and Federal and State governments, the building
costs and price trends tracked by The Turner Building Cost Index may or may not reflect

305

 39
regional conditions in any given quarter. The Cost Index is determined by several
factors considered on a nationwide basis, including labor rates and productivity, material
prices and the competitive condition of the marketplace. This index does not necessarily
conform to other published indices because others do not generally take all of these
factors into account. Further information about this index is available at:
http ://yyw.w.~t.qrn~IGQO§tf\J.GJl9.D~GQffi/99.§l:i.IJQ~X

The next six tables show the economic impact of (a) hard construction costs, (b)
EB-5 eligible soft costs, and (c) purchases of FF&E. In all cases, the tables show the
impact for the 20 major industrial classifications in the RIMS II inpuUoutput model; in all
cases, only indirect and induced impacts are included. Please note that in these and
succeeding tables, output and earnings are given in thousands of dollars.

(b)(4)

Table 8-3. Increase in Employment, Output, and Earnings for Hard Construction
Costs of 88 Morgan Street

306

 40

(b)(4)

D

Table 8-3 shows there will be a total of
jobs created from the hard
construction costs of the 88 Morgan Street building. Output would rise about I
I
I
Iwhile household earnings would increase b about
Table 8-4
shows the average output per new worker is about
while average earnings
are aboutl
I
Table 8-4. Output and Earnings Per New Worker, Hard Construction Costs for 88
Morgan Street

(b)(4)

For equipment purchases, USCIS has agreed to count jobs indirectly created
outside the geographical boundaries of a Regional Center (RC) in determining whether
the RC's business plan complies with EB-5 regulations. The policy change was
expressed in a December 3, 2010, letter from USC IS Director Alejandro Mayorkas in
response to a letter from Senator Patrick Leahy, Chairman of the Senate Judiciary
Committee.
Mayorkas wrote: "USC IS interprets the law to require that a regional center focus
its EB-5 capital investment activities on a single, contiguous area within the defined
geographic jurisdiction requested by the regional center. Nevertheless, we agree that

307

 41
the law does not further mandate that all indirect job creation attributable to a regional
center take place within that jurisdiction. I will, therefore, ensure that USCIS policy
reflects this understanding of the law."
The regulations include the following language: "The regulation at 8 CFR
204.6.(m) provides [that] ... Each regional center ... shall submit a proposal, which ...
Contains a detailed prediction regarding the manner in which the regional center will
have a positive impact on the regional or national economy in general as reflected by
such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the regional
center" (emphasis added).
The FF&E are probably not produced in the Jersey City region, but they are
purchased there. Hence the indirect and induced jobs from wholesale trade can be
included in these calculations
(b)(4)

Table 8-5. Increase in Employment, Output, and Earnings, Purchases of FF&E
for 88 Morgan Street , Indirect and Induced Effects Only

308

 42

(b)(4)

Table 8-5 shows there will be a total of 10 indirect and induced jobs created from
the pqrchas;s of FF&E for the 88 Morgan Street building. O~:~t would iise about
while household earnings would increase by about
Table 86 shows tie avera)e output per new worker is about
1e average earnings
are about

I

I

Iii

Table 8-6. Output and Earnings Per New Worker, Purchases of FF&E for 88
Morgan Street , Indirect and Induced Effects Only

(b)(4)

In terms of what soft costs are EB-5 eligible, we rely on the information given in
the NAICS coding manual, which is summarize as follows:
541310 Architectural Services
This industry comprises establishments primarily engaged in planning and designing residential,
institutional, leisure, commercial, and industrial buildings and structures by applying knowledge of design,
construction procedures, zoning regulations, building codes, and building materials.

541330 Engineering Services

309

 43
This industry comprises establishments primarily engaged in applying physical laws and principles of
engineering in the design, development, and utilization of machines, materials, instruments, structures,
processes, and systems. The assignments undertaken by these establishments may involve any of the
following activities: provision of advice, preparation of feasibility studies, preparation of preliminary and
final plans and designs, provision of technical services during the construction or installation phase,
inspection and evaluation of engineering projects, and related services.

236220 Nonresidential Building Construction
This industry comprises establishments primarily responsible for the construction (including new work,
additions, alterations, maintenance, and repairs) of commercial and institutional buildings and related
structures, such as stadiums, grain elevators, and indoor swimming facilities. This industry includes
establishments responsible for the on-site assembly of modular or prefabricated commercial and
institutional buildings. Included in this industry are commercial and institutional building general
contractors, commercial and institutional building operative builders, commercial and institutional building
design-build firms, and commercial and institutional building project construction management firms.

Table 8-7. Increase in Employment, Output, and Earnings for EB-5 Eligible Soft
Construction Costs of 88 Morgan Street Project
(b)(4)

310

 44

(b)(4)

Table 8-7 shows there will be a total Q b s created from the EB-5 eligible soft
I constr~ction costs of the 88 Morgan Street building. Output would rise about
while household earnings would increase by about I
I Table 8-8
shows thf averagj output per new worker is about!
I while average earnings
are abou

D

Table 8-8. Output and Earnings Per New Worker for EB-5 Eligible Soft
Construction Costs of 88 Morgan Street Project
(b)(4)

9. Economic Impact of Rental Income for Apartments, Retail Space,
and Parking Space

c

The building at 88 Morgan Street will be primarily residential, containing 417
apartments, 214 parking spaces, and about 4,000 square feet of retail space.
According to the developer, the Jersey City market place is one of the
rental
markets in New Jersey. Re~s at crmparable developments are well ov
It and
occupancies hover in the hi
The operating assumptions are shown 1n a le 9-1.

(b)(4)

311

 45

Table 9-1. Operating Assumptions for 88 Morgan Street, Jersey City, NJ
>perating Assumptions
(b)(4)

The monthly rentals for comparable apartment buildings in Jersey City are shown
in Table 9-2.

312

 46
Table 9-2. Comparable Monthly Rents in Jersey City

Rent Growth
(b)(4)

Soun-es: '1 REIS SubTrt.,...d Futures: Apa.rtn:~nt· 3Q 2011. Metro:
1
~~Y~ Submarb!t: HudS()rt County '

mN.ew

12

313

 47

The total annual rental income entered into the RIMS II model is hence
calculated as follows, based on the operating projections provided by the developer.
The figures for "Year 4", which is the first full year of occupancy, are used for these
calculations.
Table 9-3. Operating Projections, first 4 Years, for 88 Morgan Street Building
Detailed Operating Projections

(b)(4)

18

In the first full year of operation, gross potential rent would be "'f~~""!""'-~.....
however that figure must be reduced by an expected 3% vacancy rate, 0.5% loss for
bad debts, and first-year rent concessions (essentially one free month) that amount to
anothe1
Hence total apartment rentals after subtracting these items
equals
This figure is then boosted by the expected revenue for retail
income, and other fees. Retail space of 4,000 square feet is expected to rent foc:::J
per square foot, which is well below t~age for comparable locations. Finally, fees
from other income are expected to bL...Jper month per occupied unit, with the firstyear adjustment for one month of free rent. Summing all these factors indicates total
annual rental income~
lfor the first full year of operation. Parking revenue
has been excluded from the rental revenue estimate.

I

(b)(4)

(b)(4)
314

 48

This figure is in 2016 dollars, while the input/output coefficients are based on
(b)(4)
2008 dollars, so it must be deflated. The CPI for rental; income medium-sized cities
rose 1.6% per year from 2008 to 2012, as shown in Table 9-4, so continuing that rate
forward to 2016, the deflator would be 1.134, indicating rental income o1
in 2008 dollars.
.....__ _ _ _..,..
Table 9-4. CPI for Primary Rental Income, Medium-Sized Cities
Area:

Size Class B/C (between 50,000 and

1,500,000)
Item:
Rent of primary residence
Base Period: DECEMBER 1997=100

(b)(4)

The detailed industry results for ~
tn rental income are shown in the
next two tables.
.....__ _ _...

Table 9-5. Increase in Employment, Output, and Earnings, Rental Income for 88
Morgan Street Building, 2008 Dollars

315

 49
(b)(4)

Table 9-5 shows there would be an increase ofnpermanent new jobs from the
rental income of the 88 Morgan Street building.
To'ra'routRut would rise about I
I
r l and household earnings would increase by about~
Table 9-6

's!ioiiis'rteut eer rw worker would be about!
(b)(4)

I wit

I

average annual earnings

ofabou
Table 9-6. Output and Earnings Per New Worker, Rental Income for 88 Morgan
Street Building, 2008 Dollars

316

 50

 

 

 

 

317

51

10. Summary Statistics for the Construction and Rental Income for
the 88 Morgan Street Building
Tables 10-1 and 10-2 show the combined economic impact of constructing and
rental income for the 88 Morgan Street Building. These results are the summation of
the data given in Sections (8) and (9), so the individual cells simply represent the sum
(or average) of these figures in the previous two sections.

(b)(4)

(b)(4)

Table 10-1. Increase in Employment, Output, and Earnings for Construction and
Operation of the 88 Mor~

Table 10-1 shows that rlpermanent new jobs would be created by the
construction and rental income fO"i11i'e 88 Morgan Street building. Output would rise by
aboutl
I and household earnings would increase by aboutl
]
Table 10-2 shows that the average output per new worker would be ab~o--u~t1====~1
while average annual earnings would be abou!
I

318

 52

(b)(4)

Table 10-2. Output and Earnings Per New Worker for Construction and Operation
of 88 Morgan Street Building

319

 53

Appendix: Resume of Dr. Michael K. Evans

CURRENT AND PREVIOUS POSITIONS
• Chairman, Evans, Carroll & Associates, Inc., 1980-present
Economics)

(previously Evans

Economic consulting firm specializing in EB-5 immigration analysis, economic
impact studies of development projects and new construction, models of state and local
tax receipts, impact of current and proposed government legislation, and construction of
econometric models for individual industries and companies.
• Chief Economist, American Economics Group, 2000-2008.
Built a comprehensive state modeling system that provides economic analysis for
a variety of consulting projects (see below).
• Clinical Professor of Economics, Department of Managerial Economics and Decision
Sciences (MEDS), Kellogg Graduate School of Management, Northwestern University,
1996-99.
Taught courses in macroeconomics and business forecasting. Wrote textbooks
for both courses.
• Winner of Blue Chip Economic Indicator Award for most accurate macroeconomic
forecasts during the past four years, November 1999
• Founder and President, Chase Econometric Associates, 1970-1980
• Assistant and Associate Professor of Economics, Wharton School, University of
Pennsylvania, 1964-69. Co-developer of the original Wharton Model.
• Visiting Professor, Radford University, (Radford, VA), 1987
Chairman of Institute for International Economic Competitiveness
• Visiting Lecturer, Hebrew University (Jerusalem), 1966-67
Built econometric model of the Israeli economy
• Ph. D. in Economics, Brown University. Dissertation, "A Postwar Quarterly Model of
the United States Economy, 1948-1962". A. B. in Mathematical Economics, Brown
University

320

 54

PREVIOUS ACTIVIT/ES AND EDUCATION
• Contributing Editor, Industry Week
Wrote a column in each issue on economic and financial trends as they impact
the manufacturing sector.
• Editor, The Evans Report
Weekly newsletter discussing economic trends and financial markets. Pioneered
the concept of the Monthly Tracking Model to incorporate recent economic releases into
the overall economic forecast, including methods to predict these economic data.
• Consultant, National Printing Equipment and Supply Association
Prepared quarterly forecasts of shipments of printing equipment and graphic arts
supplies by product line, based on an econometric model constructed for NPES. Also
prepares analysis and forecasts of exports and imports by principal product line.
• Consultant, APICS -- The Educational Society for Resource Management,
Designed and developed the APICS Business Outlook Index, which used survey
data collected by the Evans Group to measure current production, production plans,
shipments, employment, new orders, unfilled orders, inventory stocks, and the
comparison of the actual to desired inventory/sales ratio to predict short-term changes
in manufacturing sector activity. The results of this survey appeared every month in
APICS: The Performance Advantage
• Consultant, American Hardware Manufacturing Association
Wrote a separate weekly edition of the Evans Report analyzing recent trends in
the hardware and housing industries, including forecasts of the hardware industry based
on an econometric model developed for AHMA.
• Board of Economists, Los Angeles Times
Wrote column every 6 weeks (5 other economists on the Board)
• Columnist, United Press International
Wrote twice-weekly column, "Dollars and Trends"
• Consultant, Senate Finance Committee,

321

 55
Built the first large-scale supply-side model of the U.S. economy
• Consultant, Environmental Protection Agency and Council on Environmental Quality
Estimated inflationary impact of government regulations
• Consultant, National Aeronautics and Space Administration
Estimate impact of R&D spending on productivity growth
• Consultant, U. S. Treasury
Estimated impact of investment tax credit and accelerated depreciation on capital
spending by industry
• Consultant, U. S. Department of Agriculture
Built large-scale econometric model of agricultural sector of U. S. economy
• Consultant, Organization of Economic Cooperation and Development
Built econometric model of the French economy

SAMPLE OF RECENT CONSULTING PROJECTS
A. Economic Impact of EB-5 Immigrant Investor Programs and New Markets Tax
Credits
For more information on these projects, see w~~~Y~D$E:!RQ~9Qffi
Key to symbols: N, new regional center, E, extension of existing center
List is current as of November 5, 2010. Totals to date are 136 new regional centers, 72
extensions, and 7 new markets tax credits, for a total of 215 projects
N• Calculated the economic impact of the construction and operation of an assisted
living center in Santa Ana, CA
N• Calculated the economic impact of the construction and operation of several BBQ
restaurants in South Florida.
N• Calculated the economic impact of the drilling oil wells in 8 counties in Texas and
Louisiana.

322

 56
N• Calculated the economic impact of operating coal mines for metallurgical coal in
West Virginia.
N• Calculated the economic impact of operating gold mines in Alaska.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Flushing, NY
N• Calculated the economic impact of constructing and operating two hotels, one in
downtown San Diego, and one in Escondido, CA
N• Calculated the economic impact of expanding and operating an auto racing track in
Palm Beach, FL
N• Calculated the economic impact of building and operating mobile housing villages
for disaster relief.
N• Calculated the economic impact of operating an "incubator" for research on medical
devices, preparations, and services in Houston, TX.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Denver, CO.
N• Calculated the economic impact of constructing and operating a charter school in
Miami/Dade County, FL
E• Calculated the economic impact of constructing and operating a hotel in Manhattan,
NY
N• Calculated the economic impact of constructing and operating hotels, assisted living
centers, and mixed-use commercial buildings in 8 counties in Southern California
N• Calculated the economic impact of constructing and operating a charter school in
Broward County, FL
N• Calculated the economic impact of renovating a former public housing project in
Chicago, IL
N• Calculated the economic impact of starting a high-tech company for optical displays
in Orlando and Gainesville, FL
N• Calculated the economic impact of constructing and operating luxury hotels in four
Southern California counties
E• Calculated the economic impact of expanding a manufacturing company in Ann
Arbor, Ml

323

 57
N• Calculated the economic impact of reconverting an old mill building into offices and
other commercial uses in Bristol County, MA
N• Calculated the economic impact of a film and TV production studio in Los Angeles,
CA
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings in 35 Texas counties.
N• Calculated the economic impact of constructing and operating the world's tallest
residential structure in Chicago, IL
N• Calculated the economic impact of constructing and operating a mixed-use
commercial and residential building in Seattle, WA
N• Calculated the economic impact of constructing and operating a hotel in Cleveland,
OH
N• Calculated the economic impact of a research facility in Jupiter, FL
N• Calculated the economic impact of constructing and operating an assisted living
center in Harry County, SC
N• Calculated the economic impact of constructing and operating a chain pharmacy in
Chicago, IL
E• Calculated the economic impact of constructing and operating a high-end hotel and
resort in Aspen, CO
N• Calculated the economic impact of constructing and operating an assisted living
center in Dallas, TX
E• Calculated the economic impact of constructing and operating an medical
assistance company in Bronx, NY
E• Calculated the economic impact of constructing and operating a mixed-use
commercial building in Queens, NY
E• Calculated the economic impact of operating a livery service in Queens, NY
N• Calculated the economic impact of constructing and operating residential properties
in Southern California
N• Calculated the economic impact of operating a film and TV production studio in Los
Angeles, CA
N• Calculated the economic impact of drilling oil wells in Montana

324

 58

N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for 43 counties in Texas
E• Calculated the economic impact of constructing and operating a restaurant and
dinner theater in Guam
N• Constructed an input/output model for the Commonwealth of the Northern Mariana
Islands, and used it to calculated the economic impact of constructing and operating a
restaurant in Saipan.
E• Calculated the economic impact of constructing and operating a new hotel in Miami,
FL
E• Calculated the economic impact of constructing and operating a resort and wellness
center in South Florida
N• Calculated the economic impact of expanding and operating a ski resort in
Vermont.
N• Calculated the economic impact of constructing and operating residential and
commercial buildings in 20 counties in South Central Texas
N• Calculated the economic impact of constructing and operating a hotel near the
Newark, NJ airport
E• Calculated the economic impact of constructing and operating a company to
process health insurance benefits in South Florida
E• Calculated the economic impact of constructing and operating a veterinary hospital
in Palm Beach County, FL
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for all counties in MA, CT, Rl, and NH
N• Calculated the economic impact of constructing and operating a residential
construction company in Maryland
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for the entire state of Oklahoma
N• Calculated the economic impact of constructing and operating a company for
manufacturing dental implants in Cuyahoga County, OH
N• Calculated the economic impact of constructing and operating a mixed-use
commercial facility in Brooklyn, NY

325

 59
N• Calculated the economic impact of constructing and operating an office building for
financial services in downtown Manhattan, NY
N• Calculated the economic impact of constructing and operating a mixed·use facility
in Southern California
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a mixed·use
commercial building in Seattle, WA
N• Calculated the economic impact of constructing and operating a charter school in
Arizona
N• Calculated the economic impact of constructing and operating a resort in
northeastern Utah
N• Calculated the economic impact of operating an online video game company
N• Calculated the economic impact of constructing and operating a hotel in New York
City
N• Calculated the economic impact of constructing and operating a fashion mall in
South Florida
E• Calculated the economic impact of construction and operation of a new automobile
assembly plant in Petersburg, VA
N• Calculated the economic impact of operating a call center for the U.S. government
in Muskogee, OK
N• Calculated the economic impact of developing a mixed-use commercial and
residential center in Scottsdale, AZ
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in New Jersey to process waste material on a pollution·free basis.
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in Washington State to process waste material on a pollution·free basis.
E• Calculated the economic impact of constructing and operating a new hotel in Coral
Gables, FL

326

 60

E• Calculated the economic impact of developing a new residential community in
Brevard County, and retail stores and restaurants in St. Lucie County, FL
N • Calculated the economic impact of a new business to store and process field crops
in Madison, MS
N• Calculated the economic impact of operating food service establishments and
assisted living centers in 40 counties in Texas.
E• Calculated the economic impact of developing a mixed-use commercial center in
Miami, FL
N• Calculated the economic impact of renovating a theater in New York City to show
film highlights of previous Broadway hits.
N• Calculated the economic impact of renovating and operating distressed buildings in
the San Francisco Bay area.
E• Calculated the economic impact of a mixed-use commercial center in Montgomery
County, TX
E• Calculated the economic impact of expanding a manufacturing facility to produce
more energy-efficient lighting in Sarasota, FL
N• Calculated the economic impact of developing facilities for amateur sporting events
in northern GA
N• Calculated the economic impact of developing a mixed-use commercial center in
Missoula, MT
N• Calculated the economic impact of operating call centers in Las Vegas, NV, and
other western Nevada counties
E• Calculated the economic impact of constructing and operating a proton cancer
treatment center in Boca Raton, FL
E• Calculated the economic impact of constructing and operating a "Green Box" facility
in Detroit to process waste material on a pollution-free basis.
E• Calculated the economic impact of renovating and expanding commercial property
in Lower Manhattan
N• Calculated the economic impact of constructing student housing and retail stores in
Davie, FL

327

 61
E• Calculated the economic impact of constructing residential housing near Harvard
University
E• Calculated the economic impact of developing mixed-use commercial centers in
Broward County, FL
E• Calculated the economic impact of renovating a Dallas apartment building
E• Calculated the economic impact of renovating and operating a nursing home in Las
Vegas, NV
E• Calculated the economic impact of constructing a hotel and shopping center in
Miami, FL
E• Calculated the economic impact of developing a design center in Miami/Dade
county, FL
E• Calculated the economic impact of developing and operating a chain of children's
playrooms and party facilities in South Florida
E• Calculated the economic impact of developing a new stadium for the Nets
basketball team, to be located in Brooklyn, NY
E• Calculated the economic impact of developing a Marriott hotel in Washington, D.C.
E• Calculated the economic impact of developing and operating a casino for foreign
patrons in Las Vegas, NV
E• Calculated the economic impact of operating a series of yogurt fast-food restaurants
in South Florida
E• Calculated the economic impact of constructing steel homes and commercial
buildings in South Florida
N• Calculated the economic impact of construction and operation of a farm
distillery in Vermont
N• Calculated the economic impact of purchase and renovation of deeply discounted
residential properties in South Florida
N• Calculated the economic impact of a hotel to be built near LaGuardia Airport in
Queens, NY
N• Calculated the economic impact for several mixed-use commercial and residential
properties for a regional center covering southern Wisconsin and northern Illinois.

328

 62
N• Calculated the economic impact for mixed-use commercial project in Flushing, NY
E• Calculated the economic impact for major new hotel near the Washington, D. C.
conference center
N• Calculated the economic impact of an assisted living center in suburban Atlanta,
GA
N• Calculated the economic impact of an office tower in mid-town Manhattan for the
diamond trade
N• Calculated the economic impact of three mixed-use commercial and residential
projects in Santa Clara County, CA
N• Calculated the economic impact of six mixed-use commercial and residential
projects in Los Angeles, Orange, Riverside, and San Bernardino counties
N• Calculated the economic impact of operating a chain of pizza restaurants in
southern Florida.
N• Calculated the economic impact of constructing and operating an assisted living
facility in Atlanta, GA
E• Calculated the economic impact of constructing and operating an expansion of
University Hospital in Cleveland, OH
E• Calculated the economic impact of a wastewater treatment plant in Victorville, CA
N• Calculated the economic impact of drilling for geothermal energy and constructing
and operating power plants in several counties in Nevada
E• Calculated the economic impact of a vacation club operation in Orlando, FL
E• Calculated the economic impact of constructing and operating an extended-stay
hotel in Boston, MA
E• Calculated the economic impact of constructing and operating an assisted living
facility in Walton County, FL
N• Calculated the economic impact of manufacturing and constructing residential and
commercial steel modular buildings in Lee County, FL
E• Calculated the economic impact of a chain of yogurt and juice stores and
restaurants in southern Florida

329

 63
E• Calculated the economic impact of two mixed-use commercial developments in
Orange County, CA.
E• Calculated a Targeted Employment Area by census tracts for six counties in the
Houston, TX metropolitan area
E• Calculated the expansion of new hybrid car manufacturing facility from Mississippi
to Tennessee and Virginia.
E• Calculated the economic impact of construction and operation of a skilled nursing
facility in Las Vegas, NV.
N• Calculated the economic impact of construction and operation of a proton cancer
treatment center and medical offices buildings in Los Angeles County, CA.
E• Determined the economic impact of improving facilities at the Port of Baltimore in
order to attract more shipping from the Panama Canal when the locks are widened.
N• Calculated the economic impact of a major hotel and resort area in Ft. Lauderdale,
FL.
N• Calculated the economic impact of building steel homes in South Florida, including
the local manufacture of steel fabricated parts.
E• Calculated the economic impact of constructing and operating a hotel at Times
Square in New York City.
N• Calculated the economic impact of a mixed-used residential and commercial project
in Atlanta, GA.
E• Calculated the economic impact of expanding and opening new restaurants in
Dallas, TX. In a separate project, calculated the economic impact of renovating,
refurbishing, and operating a boutique hotel in Dallas, TX.
E• Calculated the economic impact of building and operating low-income housing in
Boston, MA.
N• Calculated the economic impact of constructing and operating assisted living
facilities in eight rural Texas counties.
N• Calculated the economic impact of a mixed-use commercial project in Riverside
County, CA.
E• Calculated the economic impact of opening a manufacturing plant for "green" motor
vehicles in the Detroit, Ml area.

330

 64
E• Calculated the economic impact of constructing and operating hotels and
restaurants in Columbus, MS.
E• Calculated the economic impact of operating restaurants in the Hotel Win
Hollywood, CA.
N• Calculated the economic impact of a mixed-use commercial project in McCook, IL
(suburban Chicago).
N• Calculated the economic impact of constructing and operating a water-based
amusement facility in San Diego, CA.
N• Calculated the economic impact of a mixed-use commercial facility in suburban
Cincinnati, OH (project is in KY).
E• Calculated the economic impact of constructing and operating a casino, hotel, and
restaurant in Las Vegas, NV.
N• Calculated the economic impact of a new academic institution for alternative energy
in Santa Clarita, CA.
N• Calculated the economic impact of several mixed-used projects in San Francisco,
Alameda County, Santa Clara County, and Fresno County.
N• Calculated the economic impact of a super energy store and solar farm in Riverside
County, CA.
N• Calculated the economic impact of a prostate cancer treatment center in South
Carolina.
E• Calculated the economic impact of refurbishing and expanding retail space at the
George Washington Bridge in New York City.
E• Calculated the economic impact of building Atlantic Yards, new stadium for the New
York Nets, in Brooklyn, NY
N• Calculated the economic impact of an assisted living center and several mixed-use
commercial facilities in the Reno, NV area.
E• Calculated the economic impact of buying residential properties at deep discount
prices, refurbishing and selling them, in South Florida.
N· Calculated the economic impact for a fractional-ownership marina in Port Charlotte,
FL, plus office space, retail stores, restaurants, and a home brokerage office.
N• Calculated the economic impact of construction and operation of four retirement
homes in Vermont.

331

 65

E• Calculated the economic impact of an upscale retail shopping center in Vail, CO.
and a medical office building in Edwards, CO (both in Eagle County).
E· Calculated economic impact of a wind turbine manufacturing plant in Larimer
County, CO
N• Calculated economic impact of a hotel, retail stores, restaurants, office buildings,
and bank facilities in Pasadena, CA
N• Calculated economic impact of a luxury hotel and condominiums in Destin, FL
N• Calculated economic impact of constructing and operating a mixed-use commercial
project in Jupiter, FL
E• Determined whether 17 possible restaurant locations in Miami/Dade and Broward
Counties qualified as Targeted Employment Areas.
E• Determined the economic impact of opening and operating a slot-machine casino in
Hanover, MD, as part of a proposed EB-5 regional center for the Baltimore metropolitan
area.
N• Calculated the economic impact of renovating and expanding a restaurant on
Martha's Vineyard, MA, as part of an EB-5 regional center in that state.
N• Determined the economic impact of assembling and installing solar panels for
residences in the state of LA.
E• Determined a Targeted Employment Area for Dallas, TX as part of a proposed EB-5
regional center for the Dallas area.
N• Calculated the economic impact for various mixed used projects for a proposed
regional center for the entire State of Texas, including shopping centers, office buildings,
restaurants, assisted living centers, medical technology facilities, and other personal
and business services.
N· Calculated the economic impact for the construction and operation of several fastfood restaurants in 10 counties in central California.
N• Calculated the economic impact for the renovation and expansion of a shopping
mall in Greenville, SC.
E• Calculated the economic impact of buying existing apartment buildings at deep
discount prices, renovating and operating them, in 21 counties in FL.
N· Calculated the economic impact of building and operating an institute for proton
cancer therapy for a proposed EB-5 regional center in Brooklyn, NY.

332

 66
N• Calculated the economic impact of building and operating a mixed-use facility with
medical offices, hotels, and apartments for a proposed EB-5 regional center in Queens,
NY.
E• Determined a Targeted Employment Area for Philadelphia, PA as part of a proposed
EB-5 regional center for the Philadelphia area.
N• Calculated the economic impact of a proposed office building and mixed-use facility
for an EB-5 regional center in Dallas, Texas
N• Calculated the economic impact for various mixed-use projects for a proposed EB-5
regional center in the greater New York City area, including an extended stay hotel,
urgent care center, financial lending firm for alternative assets, retail stores, apartments,
office space, warehouses, industrial "flex" space, entertainment centers, restaurants,
conference and convention centers, nursing home and assisted living facilities, medical
offices, medical technology facilities, and high-tech manufacturing.
N• Calculated the economic impact of "green" hotels in 10 counties in Central California.
N• Calculated the economic impact of generic projects in manufacturing, financial
services, health services, hotels, and restaurants for a proposed regional center for the
state of Florida.
E• Calculated the economic impact of 12 different types of economic activity for an
expansion of the Palm Beach Regional Center to five contiguous counties.
N• Calculated the economic impact of a new auto parts plant in Alabama to supply
parts to Kia automobiles.
N• Calculated the economic impact of opening fast-food restaurants in Miami/Dade and
Broward counties in FL.
N• Calculated the economic impact of a mixed-use commercial center in Flushing,
Queens County, NY.
E• Calculated the economic impact of revitalizing and renovating part of the Brooklyn
Navy Yard for "green" manufacturing facilities.
E• Calculated the economic impact of 12 different types of economic activity for various
counties in Charlotte and Sarasota counties, FL
E· Calculated the economic impact of four new manufacturing and distribution
companies in Palm Beach County, FL.
N• Calculated the economic impact of developing a resort area and building residences
in rural Tennessee.

333

 67

N• Calculated the economic impact of developing and operating a resort area in
Southern Arizona.
N· Calculated the economic impact of revitalizing the depressed East Side of
Cleveland, Ohio, with new commercial and industrial buildings.
N• Determined the nationwide economic impact of a $1 billion investment in
Mississippi for a new hybrid motor vehicle plant.
N·
Determined the economic impact of expanding a shipyard in Southeastern
Louisiana.
N•
Calculated the economic impact of a new shopping center in Buena Vista,
California, and two other generic shopping centers in Los Angeles and San Bernardino
counties.
E• Calculated the economic impact of enhancing resort areas in eight rural counties in
Colorado.
N• Calculated the economic impact of the rehabilitation of Fitzsimons Village in Aurora,
Colorado, by adding an office building with medical labs, hotel, shopping center, and
residences.
E• Determined the economic impact of a mixed-use commercial center for the Kansas
City metropolitan area.
N· Calculated the number of jobs created for a film production company in New York
City.
N• Calculated economic impact of small-scale rooftop solar panels in various counties
in California.
N•
Calculated economic impact of 7 different types of proposed businesses for a
proposed regional center in the Bay Area of California.
N• Determined the economic impact of a new biological research park, office building,
and logistics center in Wooster, Ohio.
E• Calculated the economic effect of a mixed-use urban renewal project in Cleveland,
Ohio.
N• Calculated economic impact of dairy farm and cheese processing plant in Northern
California.

334

 68
N·
Determined economic impact of a shipyard, food processing plant, and
semiconductor plant for a proposed regional center in Louisiana and Mississippi.
N• Calculated the economic impact of a new gaming casino in Natchez, Mississippi.
N· Developed an Input/output Model for Guam, which was then used to calculate the
economic impact of several generic projects.
N•
Calculated the economic impact of a retail shopping center in suburban Los
Angeles County.
N• Prepared an economic impact analysis for the "timber to homes" project for a
proposed regional center in Colorado.
N•
Calculated the economic impact for a proposed regional center in Baltimore,
Maryland that would include the rebuilding of depressed areas in East Baltimore and
along the riverfront.
N· Prepared the economic analysis for a proposed EB-5 regional center for the entire
state of Florida that included impact calculations for 14 different types of industries.
N• Prepared the economic analysis for a proposed EB-5 regional center in the San
Francisco Bay area that included calculations for 10 different types of industries.
N• Prepared economic impact calculations for proposed EB-5 regional centers in New
York City and Northeastern New Jersey.
• Calculated the economic impact of a rehabilitated office building in Albuquerque, New
Mexico, including the increase in high quality jobs. NEW MARKETS
• Calculated the economic impact of a rehabilitated skilled nursing center in East Los
Angeles, California, including the impact on nearby census tracts. NEW MARKETS
N• Calculated the economic impact of development of warehouse and light industrial
manufacturing space in Las Vegas, Nevada.
N• Calculated the economic impact of rehabilitation and expansion of a vacation and
health spa in Sharon Springs, New York
N• Calculated economic impact of revitalizing an old resort hotel and adding new
facilities for Lake Geneva, WI.
• Calculated the employment and tax effects for a portfolio of projects undertaken under
the New Market capital program. NEW MARKETS

335

 69
E· Calculated generic employment changes for proposed EB-5 project for an Inland
Port in Palm Beach County, FL
N• Calculated the economic impact of construction of El Monte Village in El Monte, CA.
• Calculated the economic impact of moving the Social Security Administration building
in Birmingham, AL, and revitalizing the surrounding neighborhood. NEW MARKETS
• Calculated the economic impact of rehabbing and expanding the Everett Mall in
Everett, WA. NEW MARKETS
• Determined the economic impact of building a new medical center in Charleston, SC
NEW MARKETS
N• Calculated economic impact of expanding Sugarbush resort in VT. Study included
expansion of existing facilities and addition of new facilities.
• Calculated economic impact for new market tax credit program in Portsmouth, N.H.
Study included both overall economic impact, and the increase in employment and
income and the decrease in the unemployment rate and incidence of poverty in
individual census tracts. NEW MARKETS
N• Calculated the economic benefits of EB-5 programs for foreign investors for a
mixed-use construction project, including a hotel, retail stores, apartments, and a sports
stadium in the Washington, D. C. metropolitan area
N• Calculated the economic benefits of EB-5 programs for a mixed-used retail shopping
center in the New York City metropolitan area.
N• Calculated the economic benefits of EB-5 programs for foreign investors for
proposed shopping centers in five separate counties in Southern California, including
differential impacts of building the shopping centers in different counties.

B. Projects for State and Local Governments

• Constructed an econometric model for the State of New York and determined the
change in employment, labor income, and tax revenues for 43 different tax changes
proposed by the Governor's office.
• Constructed a detailed econometric model for the State of Pennsylvania to determine
the economic impact of the complete panoply of state taxes levied; the model contains
over 1,000 equations. In cooperation with American Economics Group, the model was

336

 70
developed to simulate the effect of changes in any state tax rate on households and
businesses by income deciles, household status, age of individuals, size of households,
and many other demographic variables. The change in business taxes can also be
simulated for detailed industry classifications.
• Determined whether the Washington, D.C. water and sewer authority should accept a
high bid for a new waste disposal system. Decision to reject has saved the authority
over $200 million, as construction prices turned down sharply as predicted.
• Built an econometric model to determine the "tax gap" caused by Internet sales for the
state of Minnesota.
• Determined appropriate levels of shelter grants individual counties in New York State,
and for utility allowances in New York City. Reviewed and prepared testimony in
ongoing court cases in these areas.
Calculated the economic impact of the revitalization of downtown Milwaukee,
Wisconsin.

C. Economic Impact of Casino Gaming

• Built an econometric model to predict the growth of the gaming industry over the next
decade, and the economic impact of that industry on employment and tax revenues at
the Federal and state levels.
• Estimated the economic impact of Indian casino gaming nationally and for the State of
Wisconsin.
• Determined the economic impact of the Oneida Indian gaming casino on the Green
Bay metropolitan area.
• Estimated the negative economic impact on the Milwaukee area if a new Indian
gaming casino were to be built in Kenosha, Wisconsin.
D. Economic Impact of Smoking Bans and Higher Taxes

• Testified on economic impact of smoking bans in Canada; certified as an expert
witness by the Court.
• Examined the impact of smoking bans on restaurant sales in several different
locations in the U.S. to determine how much sales changed when these bans were
imposed, and the differential effects depending on whether these bans were partial or
total.

337

 71

• Determined the cross-border effects on retail sales from differential rates in cigarette,
gasoline, and alcohol excise taxes
• Determined the economic impact of higher cigarette taxes on minority group
employment.
• Estimated the economic impact and loss of Federal and state tax revenues when
higher cigarette prices lead to increased smuggling.
E. Consulting Projects for Travel and Tourism
• Built an econometric model to predict tourism trips and revenues for the major regions
of the U.S. economy.
• Constructed econometric models to predict tourism in Las Vegas and Orlando.
• Using the IMPLAN model, predicted economic impact of tourism and travel
expenditures for all counties in Pennsylvania.

F. Other Private Sector Consulting Projects
Calculated the revenue gain at the Federal, state and local level generated by
domestic manufacturing of Airbus parts and equipment.
• Calculated the economic impact of proposed EPA bans on fluoropolymer production.
• Estimated the size and economic importance of the fluoropolymer industry, and
calculated economic impact of shutting down domestic production.
• Built an econometric model to examine how U.S. tax and regulatory policies help
determine whether the gold mining industry would invest in the U.S. or other countries.
Testified before Congress to help defeat legislation inimical to the mining industry.
• Built an econometric model to predict consumer bankruptcies, based on recent growth
in consumer credit outstanding, the overall economic environment, and recent changes
in credit regulations
• Estimated the economic impact of the ethanol subsidy on the U.S. economy and
Farm Belt States, including the impact on the balance of payments, employment, and
tax receipts. Testified before Congress to help pass legislation to extent subsidies to
the ethanol industry.

338

 72
• Built an econometric model to determine the impact of updating and improving the
system of locks on the Upper Mississippi River on corn prices and exports, farm
income, and the overall economy.

BOOKS PUBLISHED
Macroeconomics for Managers, Blackwell, 2003
Practical Business Forecasting, Blackwell, 2002
Economic Impact of the Demand for Ethanol, Diane Publishing Company, 1998
How to Make Your Shrinking Salary Support You in Style for the Rest of Your Life,
Random House, 1991
The Truth About Supply-Side Economics. Basic Books, 1983.
A Supply-Side Model of the U. S. Economy, mimeo (prepared for Senate Finance
Committee), 1980.
An Econometric Model of the French Economy:
O.E.C.D, March 1969.

A Short-Term Forecasting Model.

Econometric Gaming (with L. R. Klein and M. J. Hartley). Random House, 1969.
Macroeconomic Activity: Theory, Forecasting and Control. Harper & Row, 1969.
The Wharton Econometric Forecasting Model (with L.R. Klein), Economics Research
Unit, Wharton School: University of Pennsylvania Press, 1967. Enlarged edition, 1968.
Over 30 articles in major academic journals and publications (list on request)

339

 I

I

Expedited Processing Requested
For 1-924
To Attract Investment To
Devastated Counties in
New Jersey

340

 EXHIBIT LIST
1-924 APPLICATION FOR REGIONAL CENTER
U.S. IMMIGRATION FUND-NJ
EXHIBIT NAME

TAB
NUMBER

Formation of Applicant, U.S. IMMIGRATION FUND-NJ, LLC
Atiicles of Formation of the U.S. Immigration Fund-NJ, LLC registered with
the Secretary of State for Delaware on December 7, 2012.

1.

Minutes of the Action of the Sole Member of U.S. Immigration Fund-NJ,
LLC, in Lieu of Organization Meeting, dated December 7, 2012.

2.

Company Agreement of U.S. Immigration Fund -NJ, LLC, executed by the
Sole Member, dated December 6, 2012.

3.

Certificate of Membership Interest No. 1 of U.S. Immigration Fund-NJ,
LLC, duly executed on December 7, 2012.

4.

Maps Outlining the Territory of the U.S. Immigration Fund-NJ.

5.

Diagram of the Corporate Structure of the U.S. Immigration Fund-NJ.

6.

Letter dated December 7, 2012 from U.S. Immigration Fund-NJ, LLC,
requesting designation as an EB-5 Regional Center, and confirming that all
funds raised from EB-5 foreign investors will be used entirely for expenses
of the job creating project activities.

7.

Financial Commitment Letter dated December 12, 2012, issued by U.S.
Immigration Fund, LLC to U.S. Immigration Fund-NJ, LLC, with copy of
the bank account statement of the operating checking account of U.S.
Immigration Fund, LLC confirming a recent balance of over US$1 ,000,000.

8.

Written statement dated December 7, 2012, of the principal of U.S.
Immigration Fund-NJ, LLC confirming that all funds raised from EB-5
foreign investors will be used entirely for expenses of the job creating project
activities.

9.

341

 Formation of the Manager of U.S. Immigration Fund-NJ
Certificate of Formation of U.S. Immigration Fund, LLC, issued by the
Secretary of State for Delaware dated July 25,2012.

10.

Entity Details web page report issued by the Secretary of State for Delaware
(Division of Corporations) for U.S. Immigration Fund, LLC.

11.

Operations & Financing of U.S. Immigration Fund-NJ
Operations Plan of the U.S. Immigration Fund- NJ

12.

Sample paid invoices by U.S. Immigration Fund, LLC for the expenses of
applying for USCIS regional center designation for U.S. Immigration
Fund-NJ, LLC.

13.

Sample Subscription Documents for Investors
Sample Investor Suitability Evaluation.

14.

Sample Subscription Agreement.

15.

Sample Escrow Agreement.

16.

Sample Limited Liability Company Agreement of 88 Morgan Street Project.

17.

Sample Offering Memorandum of 88 Morgan Street Project.

18.

Project Business Plans & Economic Analysis
Business Plan of 88 Morgan Street Project.

19.

Economic Analysis of Job Creation of the 88 Morgan Street Project by
Evans, Carroll & Associates dated December 7, 2012 (RIMS II
methodology).

20.

Sample Investor Flow Chart.

21.

Sample Loan Terms.

22.

Evidence for Request for Expedited Processing
Memorandum Supporting Expedited Processing Request

23.

U.S. Government Evidence of the Devastation from Hurricane Sandy

24.

•

•

President Obama's Executive Order Declaring Disaster Area for New
Jersey Counties that form part of the Regional Center's Territory,
dated October 30, 2012.
President Obama's Executive Order Creating the Hurricane Sandy
Rebuilding Task Force dated December 7, 2012.

342

 •

President Obama's Appropriations Request to the House of
Representatives for Hurricane Sandy Relief, dated December 7, 2012.
• U.S. Department of Labor, Bureau of Labor Statistics, "Hurricane
Sandy: A Pre-Storm Look at Affected Areas," dated November,
2012.
•

U.S. Department of Labor, "Employment Losses After Hurricane",
dated December 5, 2012. Analysis on the impact of Hurricanes
confirming the negative impact of the storm on employment and
household earnings.

Newspaper articles of the impact of Hurricane Sandy

25.

Maps of the areas in New Jersey impacted by Hurricane Sandy showing the
impact in Middlesex, Essex, Union and Hudson Counties (which form part of
the Territory).

26.

Photographs of the devastation wrought by Hurricane Sandy in cities located
within the Territory including Jersey City; Union City & Elizabeth.

27.

343

 EXHIBIT NAME

TAB
NUMBER

Formation of Applicant, U.S. IMMIGRATION FUND-NJ, LLC

Articles of Formation of the U.S. Immigration Fund-NJ, LLC registered with
the Secretary of State for Delaware on December 7, 2012.

1.

344

 'lJJefaware

PAGE

1

%e Jirst State
I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT
COPY OF THE CERTIFICATE OF FORMATION OF "U.S. IMMIGRATION FUND NJ, LLC", FILED IN THIS OFFICE ON THE SEVENTH DAY OF DECEMBER,
A.D. 2012, AT 4:52 O'CLOCK P.M.

Jeffrey 'N Bullock, Secretary of State

5254960

8100

121311998

C TION: 0047507
DATE: 12-07-12

verify this certificate online
delaware.gov/authver.shtml

345

 State or Delaware
Secretary or State
Division o£ Corporations
Delivered 05:38 PM 12/07/2012
FILED 04 ~52 PM 12/07/2012
SRV 121311998 - 5254960 FILE

STATEn/DELAWARE
LIMITED LIABILITY COMPANY
CERTIFICATE ofFORl\tATION

First: The name of the limited liability company is ..;;c;...c- - - - - - - - - ~J.S.

Immigration Fund - NJ, LLC

Second: The address of its registered office in the State of Delaware
:2711

Centerville Road, Suite 400

Zip code _1..;..98..;..08
_ _ _ _ __
Corporation Service Company

in the City of Wilmington

---"'------

The name of its Registered agent at such address is

Third: (Use this paragraph only if the company is to have a specific effective date of
dissolution: "The latest date on which the limited liability company is to dissolve is
")

_______

.

Fourth: (Insert any other matters the members determine to include herein.)

ln Witness Whereof. the undersigned have executed this Certificate of Formation this
'7th

day of December

2012

By: fst Nicholas A. Mastroianni II
Authorized Person (s)
Name: Nicholas A. Mastroianni II

346

 ~i,~
'fiS.l:.

IRS DEPl\RTMENT
OF THE TREASURY
INTERNAL REVENUE SERVICE
'·

CINCINNATI

OH

45999-0023
Date of this notice:

(b )(3)

I

12-11-2012

Employer Identification Number:

I

Form:

SS-4

Number of this notice:

U.S IMMIGRATION FUND - NJ LLC
NICHOLAS A MASTROIANNI II SOLE MBR
1295 US HIGHNAY 1
N PALM BEACH, FL 33408

CP 575 G

For assistance you may call us at:
1·800-829-4933

IF YOU vJRITE, ATTACH THE
STIJB AT THE END OF THIS NOTICE.

(b)(3)

l>IE

ASSIGNED YOU AN

EMPLOYER

IDENTIFICATION NUMBER

Thapk you ior applying for an Employer Identification Number (EIN). We assigned you
EINI
This EIN will identify you, your business accounts, tax returns, and
Please keep tbis not.ice j n your permanent
documents, even if you have no
records.
\<Jhen
tax documents, payments, and related correspondence, it is very important
t.hat you use your EIN and complete name and address exactly as sho11m above. Any variation
may cause a delay in processing, result in incorrect infonnation in your account, or even
cause you to be
more than one EIN. If the information is not correct as shown
above,
make
correction
the attached tear off stub and return it to us.
A limited liability company (LLC) may file Form 8832, Entity Classification Election,
and elect to be classified as an association taxable as a corporation. If the LLC is
to be treated as a corporation that meets certain tests and it will be
S
corporation status, it must timely file Form 2553, Election by a Smal.!. Bus}ness
The LLC wiJJ be treated as a
as of the effective date of the 8
election and does not need to file Form 8832.
To obtain tax forms and publications, including those referenced in this notice,
<.rJsit our f'i1eb site at www.i:cs.gov. If you do not have access to the Internet, call
1 800 829-3676 (TTY/TDD 1-800-829-4059) or visit your local IRS office.
IMPORTANT REMINDERS:

*

Keep a copy of this notice in your permanent records. This notice is issued only
one time and the IRS will not be able to generate a duplicate copy for you.

*

Use this EIN and your name
your federal tax forms.

as

appear at the top of this notice on al.l

* Refer to this EJN on your tax-related correspondence and documents.
If you have questions about your EIN, you can call us at the phone number or write to
us at the address shown at the top of this notice. If you write, please tear off the stub
at the bottom of thh1 notice and send it along with your letter. If you do not need to
write us, do not complete and return the stub. Thank you for your cooperation.

347

 EXHIBIT NAME
Minutes of the Action of the Sole Member of U.S. Immigration Fund-NJ,
LLC, in Lieu of Organization Meeting, dated December 7, 2012.

TAB
NUMBER
2.

348

 RESOLUTION OF THE SOLE MEMBER IN LIEU OF THE ORGANIZATIONAL
MEETING OF THE MEMBERS
OF
U.S. IMMIGRATION FUND- NJ, LLC

(b)(4)

l

349

 (b)(4)

Approved by the Sole Member as of December 7, 2012:
U.S. IMMIGRATION FUND- NJ, LLC, a FLorida limited liability company
By:

U.S. IMMIGRA.1ION FUND, LLC,
a Dttla~re li~ited liability company, Sole Member
,_/

I
~

(b)(4)

2

350

 EXHIBIT NAME
Company Agreement of U.S. Immigration Fund -NJ, LLC, executed by the
Sole Member, dated December 7, 2012.

TAB
NUMBER

3.

351

 LIMITED LIABILITY COMPANY AGREEMENT
OF
U.S. FUND - NJ, LLC

 

 

 

 

352



 

 

 

 

 

353

(b)(4)

SOLE MEMBER:

U.S. Itymigration Fund
, LLC, a
Delaw,are limited liability company
(b)(4)

s A. Mastroianni, II
naging Member

354

 Schedule A

 

 

 

 

 

 

355

EXHIBIT NAME
Certificate of Membership Interest No. 1 of U.S. Immigration Fund-NJ,
LLC. duly executed on December 7, 2012.

TAB
NUMBER

4.

356

 CERTIFICATE OF MEMBERSHIP INTEREST No. 1
U.S.IMMIGRATION FUND· NJ, LLC

(b)(4)

ALimited Liability Company Organized Under the Laws of the State ofDelaware

This document certifies that U.S. IMMIGRATION FUND, LLC is the owner D
units of the issued and outstanding membership units of U.S. IMMIGRATION FUND-NJ,
LLC, alimited liability company organized under the laws of the state of Delaware, and shall
have the right of the Members established under the State Law, the Formation Documents
and the Operating Agreement. Units of said Company are transferable only on the books of
the Company, subject to any restrictions set forth in State Law; the Formation Documents,
and the Operating Agreement, by the holder of this certificate in person or by authorized
agent, properly endorsed.
U.S. IMMIGRATION FUND- NJ, LLC has caused this certificate to signed and
issued by its duly authorized representatives. This Certificate is dated December 7, 2012

357

 TAB

EXHIBIT NAME NUMBER

Maps Outlining the Territory of the US Immigration Fund-NJ. 5.

358

(

.NTY MAP OF NEW JERSEY SHOWE

BOUNDARY OF

USIF-NJ TERRITORY

OORUNGTON

lild o:TLORlD/\ REGIONAL CENTER LLC/US Immigration Fund- New Jersey/Maps/Map ofNew Jersey Counties.gif112/10/2012 7:45:02 PM]

359

 County Map- State of New Jersey
Perimeter of Territory of
U.S. Immigration Fund-NJ, LLC Regional Center
Shown In RED

26
360

 MAP OF METROPOLITAN STATISTICAL AREAS
IN THE TERRITORY OF THE
U.S. IMMIGRATION FUND-NJ REGIONAL CENTER

OLYI

361

 EXHIBIT NAME

Diagram of the Corporate Structure of the U.S. Immigration Fund-NJ.

TAB
NUMBER

6.

362

 Diagram of Corporate Structure of
U.S. Immigration Fund - NJ

>J~:ltctt<nas A.

Mastr<lianni; 'U

Managing Member

(b)(4)

363

 EXHIBIT NAME
Letter dated December 7, 2012 from U.S. Immigration Fund-NJ, LLC,
requesting designation as an EB-5 Regional Center, and confirming that all
funds raised from EB-5 foreign investors will be used entirely for expenses
of the job creating project activities.

TAB
NUMBER

7.

364

 ······'

'''•••••''!

U.S IMMIGRATION FUND-NJ, LLC
1298 US HIGHWAY 1
NORTH PALM BEACH, NJ 33408

December 7, 2012, 2012
Attention: EB-5 RC Proposal
U.S. Citizenship & Immigration Services
California Service Center
24000 Avila Road, 2nd NJoor
Laguna Niguel, CA 92607

Rc:

Written Statement of Principal of U.S. Immigration Fund-NJ, LLC ("USIF-N.J")

To Whom It May Concern:
I am writing in reference to the 1~924 Application tiled by the USIF-NJ for Regional
Center designation in my capacity as its Managing Member. I hereby certify the following:

l.

I hereby acknowledge, authorize and confirm that USIF-NJ is applying to the U.S.
Citizenship & Immigration Services for initial designation of the USIF-NJ as a Regional
Center under the EB-5 Pilot Program, on the terms set out in the enclosed Form 1-924, its
attached exhibits and in the attorney letter from our legal counsel, FostcrQuan, LLP.

2.

USIF-NJ is wholly owned by U.S. Immigration Fund, LLC ("USIF"). And both these
companies are indirectly owned and controlled by me, Nicholas A. Mastroianni, II.

3.

All funds raised from EB-5 foreign investors for projects of the USIF-NJ shall be entirely
used to pay for costs related to job creating capital project activities and shall not be
reimbursed or be reimbursable to EB-5 investors during the conditional residency period.

365

 Please do not hesitate to contact the undersigned regarding this letter.
Sincerely,
U.S.

Immig~~ion

Fund-NJ, LLC

l"'
\

.

"~
--

i

I

caging Member, U.S. Immigration Fund, LLC
By its authorized representative: Nicholas A. Mastroianni, fi

2

366

 TAB
NUMBER

EXHIBIT NAME
Financial Commitment Letter dated December 12, 2012, issued by U.S.
Immigration Fund, LLC to U.S. Immigration Fund-NJ, LLC, with copy of
the bank account statement of the operating checking accoun,.t.o...f.-u. . s
•.,____..,.
Immigration Fund, LLC confirming a recent balance of oveJ.._ _ _ _ _....,.

8.

(b)(4)

367

 U.S IMMIGRATION FUND, LLC
1295 US HIGHWAY 1
NORTH PALM BEACH, NJ 33408

December 7, 2012
Attention: EB-5 RC Proposal
U.S. Citizenship & Immigration Services
California Service Center
24000 Avila Road, 211 d NJoor
Laguna Niguel, CA 92607

Re:

U.S. Immigration F'und- NJ, LLC ("USIF-NJ")

The purpose of this letter is to provide assurances to the United States Citizenship &
Immigration Services ("USC IS") of the financial stren~:,Jth and wherewithal ofUSIF-NJ in
connection with the 1-924 Application f1led with the USC IS for Regional Center designation
in the territory of South Florida. USIF-NJ is a wholly-owned subsidiary of U.S. Immigration
Fund, LLC ("USIF'') in which I am the principal owner and Managing Member.
USIF has sufficient resources to financially support the EB-5 Pilot Program projects
it will sponsor.
USIF has already paid approximatelyr---bf expenses on behalf of the USIF-NJ
related to the start-up of operations. USIF is c~to continue funding USIF-NJ's
obligations up tol
ler year for the next
fwith a limit of up t1
~er
month). USIF will pay those expenses and provide OSJf with the required capttal to continue
paying its obligations on a continuous basis and achieve full operational status.

(b)(4)

USIF is financially sound and has working capital in excess oft
In cash.
Enclosed as Exhibit B, hereto is a copy of the bank account statement ofUSIF as of
November 14, 2012 which shows cash deposits o~

I

368

 Please do not hesitate to contact the undersigned regarding this letter and thank you tor
your cooperation in this matter.

Sincerely,
U.S. Immigration Fund-NJ, LLC

,_

aging Member, U.S. Immigration Fund, LLC

"·--By its authorized representative: Nicholas A.
Mastroianni, II

2

369

 EXHIBIT NAME
Written statement dated December 7, 2012, of the principal of U.S.
Immigration Fund-NJ, LLC confirming that all funds raised from EB-5
foreign investors will be used entirely for expenses of the job creating project
activities.

TAB
NUMBER

9.

372

 •••••••
,,,,•••
,,,!!
U.S IMMIGRATION FUND-NJ, LLC
1298 US HIGHWAY l
NORTH PALM BEACH, NJ 33408

December 7, 2012, 2012
Attention: EB-5 RC Proposal
U.S. Citizenship & Immigration Services
California Service Center
24000 Avila Road, 2"d NJoor
Laguna Niguel, CA 92607

Re:

Written Statement of U.S. Immigration Fund-NJ,LLC ("USIF-NJ")
regarding Funds Raised from EB-5 Investors

To Whom It May Concern:
USIF-NJ, hereby certifies the following:

(b)(4)

l.

Except for processing or administration fees ofl
lall funds raised from EB-5
investors for projects of USIF-NJ regional center shall be used entirely in capital
investment activities of the job creating project sponsored by the regional center. Capital
investments trom EB-5 foreign investors shall not be reimbursed or be reimbursable
during the conditional residency period. A profit from operations may be paid, in
compliance with applicable EB-5 rules.

2.

All of the subscription documents of the USIF- NJ will make evident to EB-5 investors
that their investments are fully aHisk, with no redemption rights for the EB-5 investors.

373

 Sincerely,

US. Immigratiog Fund-NMang?g EMembcr, U.S. Immigration Fund, LLC

 


in
By  authorized representative: Nicholas A. Mastroianni, II

374

EXHIBIT NAME

TAB
NUMBER

Formation of the Manager of U.S. Immigration Fund-NJ
Certificate of Formation of U.S. Immigration Fund, LLC, issued by the
Secretary of State for Delaware dated July 25,2012.

10.

375

 State o£

l.lela~

Sec:.ret.a.t:v o£ State
lliv:i.sion of ~t:.ic:ms

Delivered OJ:ll

~

07/25/2012

FIIZD 03:10PM 07/25/2012
SRV 120811615 - 5189111 FII.Z.

STATE ofDELAWARE
LIMITED LIABILITY COMPANY
CERTIFICATE ofFORMATION

First: The name of the limited liability company i s - - - - - - - - - -

u.s.

Immigration Fund, LLC

Second: The address of its registered office in the State of Delaware is One Commerce
Center - 1201 Orange St. f600
in theCityofWilmington
Zip code 1 989 9

, The name of its Registered agent at such address is

Incorp Services, lnc.
Third: (Use this paragraph only if the company is to have a. specific effective date of
dissolution: ''The latest date on which the limited liability company is to dissolve is

---------------------.-n)
Fourth: (lnsert any other matters the members determine to include herein.)

In Witness Whereof, the undersigned have executed this Certificate of Fonnation this
20th
day of July
2012

376

 EXHIBIT NAME

Entity Details web page report issued by the Secretary of State for Delaware
(Division of Corporations) for U.S.lmmigration Fund, LLC.

TAB
NUMBER

11.

377

 Division of Corporations ·- Online Services

12/l/12 10:47 AM

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Entity Details
THIS IS NOT A STATEMENT OF GOOD STANDING

lncorooratlon Date/ 07/25/2012
Formation Date: (mm/dd/yyyy)

File Number

5189171

Entity Name:

U.S. IMMIGRATION FUND, LLC

Entity Kind:

LIMITED
LIABILITY
COMPANY
(LLC)

Entitv Type:

Residency:

DOMESTIC

State:

GENERAL

DE

REGISTERED AGENT INFORMATION

Name:

INCORP SERVICES, INC.

Address:

1201 ORANGE ST STE 600 ONE COMMERCE CENTER

City:

WILMINGTON

State:

DE

Phone:

(800)246-2677

County:
Postal Code:

NEW CASTLE
19899

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Page 1 of 1

378

 EXHIBIT NAME

TAB
NUMBER

Operations & Financing of U.S. Immigration Fund-NJ

Operations Plan of the U.S. Immigration Fund NJ

12.

379

 U.S.IMMIGRATION FUND-NJ, LLC

OPERATIONS PLAN
FOR
USCIS REGIONAL CENTER DESIGNATION

DECEMBER 4, 2012

380

 Table of Contents
I. INTRODUCTION: ........................................................................................................................................3
II. USIF GOALS AND OBJECTIVE$: ..................................................................................................................3
Ill. REGIONAL CENTER TERRITORY: ...............................................................................................................4
IV. ORGANIZATIONAl STRUCTURE: ...............................................................................................................S
V. MANAGEMENT: .........................................................................................................................................6
VI.

TARGETED INDUSTRIES & ECONOMETRIC METHODOLOGY: .......................................................... 10

VII. OPERATIONS: ........................................................................................................................................11
Project Evaluation ...............................................................................................................................11
Project Company Structure .................................................................................................................12
Project Management ...........................................................................................................................13
VIII. FINANCIAL$: ........................................................................................................................................14
IX. UStF SAMPLE PROJECT: .........................................................................................................................16
X. INVESTMENT PROCESS & INVESTOR DUE DIUGENCE: ........................................................................... 17
II

Accredited Investor" Verification ......................................................................................................17

Due Diligence .......................................................................................................................................17
Source of Funds ...................................................................................................................................17
Investor Relations ................................................................................................................................l8
XI. MARKETING: ..........................................................................................................................................21
XII.

REPORTING ......................................................................................................................................22

XIII.

CONTACT INFORMATION ............................................................................................................. 25

2
381

 U.S. IMMIGRATION NEE LLC

Operaticm Plan

 

 

 

 

382

 

 

 

 

383

ORGANIZATIONAL STRUCTURE:
USIF has been formed as a limited liability company. The ownership structure is depicted below
in the following chart:

Managing Member

100%
(b)(4)

100%

Sole Manager

Services

100%

U.S. hnmigration Fund-NJ, LLC

(b)(4)

5
384

 Nicholas A. Mastroianni, II, is also the principal owner of a successful operating EB-5 Regional
Center, the Florida Regional Center (RCW 319~ 10194 I Unique I.D. # 103191 0194 ).

MANAGEMENT:
USIF will be managed by USIF~DEL which employs an experienced team of professionals who
have the expertise and experience necessary to make the Regional Center a great success. The
areas of expertise and operating capability include: real estate development, finance, marketing,
legal and accounting.
USIF~DEL

will provide all of the expertise and services to its wholly-owned subsidiary, USIF.
USIF-DEL will charge a fee for its services to USIF. USIF will pay for the services delivered by
USIF-DEL from revenue from the Management Fees described in Section IV below. As USIF
grows, additional capability will be added to the company.
Key members of management are as follows:
1) Manager: Nicholas A. Mastroianni, II
Job Duties:
•

•

•

•

•

Provide the necessary leadership to assure that the Regional Center
successfully performs its company objectives as overseer of the
performance of Regional Center projects, especially assuring compliance
with USCIS EB-5 standards and objectives;
Develop and maintain a current list of the principal official and point of
contact for the management and administration of approved projects and
maintain company policies, procedures and processes to assure the
Regional Center operates effectively and in accordance with the law;
Hire and maintain competent and productive staff who are well trained in
the USCIS policies and procedures, including all reporting responsibilities
pursuant to USCIS regulations;
Lead in the development and attraction of quality projects into the
Regional Center.
These will be businesses that conform to USCIS
standards, objectives and policies. In particular, this role will assure that
Regional Center capital investment projects create the requisite number of
jobs and that the projects are well managed to assure that immigrant
investors receive their permanent green cards within the required
timeframe.
Ensure that all books and records are maintained relative to:
o The name, date of birth, nationality, and alien registration number for
each foreign investor who makes a capital investment and files an I526 petition with USCIS, specifying whether the petition was
approved, denied or withdrawn by the petitioner,

6
385

 o The capital invested by investors in new commercial enterprises,
o Current list of approved methodologies to evaluate and track job
creation that result from an approved business enterprise of each
foreign investor's investment capital,
o Current list by U.S. municipality and state of residence of each alien
investor who makes an investment and files an 1-526 petition with
USCIS
o The amount of alien investor capital and the amounts of other capital
that have been invested in each job creating commercial enterprise,
distinguishing the separate totals for each,
Resume:

(b)(6)

2) Chief Financial Officer- David Finkelstein
Job Duties:

• Oversee all financial matters of the Regional Center (accounting,
budgeting, banking).
• Manage tracking of all funds from EB-5 Investors deposited into
designated escrow bank accounts for EB-5 Projects. Manage tracking and
reconciliation of funds released from escrow to the new commercial
enterprise and then to the EB-5 Project under a loan.
• Manage EB-5 Immigrant tracking system to assure such information is
readily available to meet the requirements of the USC IS guidelines.

7
386

 •

Manage preparation of quarterly and annual financial documents for all
USIF EB-5 projects and USIF operations, including review of pro-forma
financial statements and supervision of all outside accountants.

Resume:

3) Marketing: Nicholas A. Mastroianni, III
Job Duties:
•

Oversee all marketing initiates of the Regional Center, including
managing the relationships with foreign agents and finders who introduce
prospective foreign investors to the capital investment projects.
• Develop and manage all marketing materials to deliver to foreign agents.
Resume:

•
(b)(6)

•

4) Paralegal & Administration - Sandy Albanese
Job Duties:
•
•

•
•
•
•

Oversee all paralegal and supporting functions.
Work with Finance and assist in the management of the EB-5 Immigrant
tracking system to assure such information is readily available to meet the
requirements of the USCIS guidelines.
Report the total aggregate number of approved EB-5 alien investor 1-526
petitions per Federal Fiscal Year made through the Regional Center
Report the total number of approved alien investor 1-829 petitions per
Federal Fiscal year to date made through the Regional Center
Manage all communications with foreign agents and investors in the jobcreating new commercial enterprise.
Ensure that all foreign investors complete and sign all appropriate legal
documents, including questionnaires to ensure that the alien investor is a

8
387

 sophisticated "accredited investor" and that the person's source of funds
satisfies USCIS requirements and applicable law.
Resume:

•
(b)(6)

•

5) USIF-DEL Legal Counsel- Mark Giresi
Job Duties:

• Ensure compliance with all applicable laws and regulations, including
immigration laws and regulations, securities laws, and USCIS policy.
• Oversee and manage all legal matters on behalf ofUSIF-NJ.
• Work in concert with the USIF-NJ "preferred'' Form 1-526 immigration
attorneys to ensure accuracy of petitions prior to filing with the USC IS.
• Ensure that all foreign investors complete and sign all appropriate legal
documents, including questionnaires to ensure that the alien investor is a
sophisticated "accredited investor" and that the person's source of funds
satisfies USCIS requirements and applicable law Licensed Attorney at
Law of the State of New Jersey- 1983 to present.
• Burger King Corporation: Senior Vice President and General Counsel
1993-1998 and Senior Vice President, U.S. Franchise Operations and
Development 1998-2000.
• Limited Brands, Inc. - Executive Vice President, Retail Operations 20002008.
6) Lead Securities Law Counsel - Attorney Andrew Kingston

• Andrew Kingston will be the lead Securities Law counsel to the Regional
Center. Andrew Kingston has over 15 years of experience in public and
private offerings of securities and has successfully advised EB-5 regional
centers on previous private securities offerings.
7) Lead Immigration Counsel - FosterQuan, LLP

• An experienced immigration law firm with extensive experience in EB-5
projects. The expertise of experienced EB-5 attorneys will ensure
compliance with USCIS rules and standards in the content of deal

9
388

 structuring; 1-526 visa petitions, and 1-829 petitions on behalf of the
Regional Center. The lead attorney for FosterQuan, LLP will be Ignacio
A. Donoso, Esq.
8) Economic Analyst - Evans, Carroll & Associates

•

Evans, Carroll & Associates has prepared hundreds of successful
economic impact analyses for EB-5 regional center projects throughout
the United States. Michael Evans, Ph.D., will be the lead economist for
the Regional Center.
• Dr. Evans is highly experienced in conducting job creation analysis for
EB-5 Projects using RIMS II econometric methodology.
• Dr. Evans has developed clear guidance for the USIF on compliance with
the USCIS Tenant-Occupancy guidance issued on February 17, 2012 and
May 8, 2012 (Operational Guidance on EB-5 Adjudications Involving the
Tenant-Occupancy Methodology, OG-602.06-001 ).

TARGETED INDUSTRIES & ECONOMETRIC METHODOLOGY:
NAICS Codes

USIF investment in new EB-5 projects will focus in the following industries and economic
sectors, which are described according to the North American Industry Classification System
(NAICS) codes and titles:
Industry Name

NAICS Code

Commercial and Institutional Real Estate Construction

2362

Residential Real Estate Construction

!

2361

Lessors of Real Estate

53111

Architectural, Engineering & Related Services

5413

In the future, additional NAICS codes will be added through possible 1-924 Amendments of the
USIF, based on qualifying EB-5 Projects and economic analysis of job creation based on USCIS
approved methodology
RIMS II Econometric Methodology

USIF will estimate job creation from an EB-5 Project based on eligible investments in the
Targeted Industries using RIMS II econometric methodology. Direct, indirect and induced jobs
creation analysis will conform to USCIS guidance on job creation estimates, including
compliance with the Tenant-Occupancy guidance issued by USCIS in February 17, 2012 and
10
389

 May 8, 2012 (Operational Guidance on EB-5 Adjudications Involving the Tenant-Occupancy
Methodology, OG-602.06-001 ).

OPERATIONS:
Project Evaluation

USIF will evaluate potential EB-5 Projects to ensure compliance with the USCIS regional center
designation and the objectives ofUSIF. USIF will give priority to projects in which commercial
loans are made for the construction and operation of mixed-use real estate development that will
prove profitable and successful investments for foreign investors. In addition to the two EB-5
projects, which are now scheduled to be developed (described below in Section VII), a pipeline
of future projects will be created.
USIF will have a project evaluation committee to analyze potential EB-5 Projects before USIF
agrees to sponsor such a project for EB-5 Investors. The project evaluation committee is
comprised of seasoned professionals with backgrounds in transactions, investment management,
construction, development, operations, marketing, and economic development. The project
evaluation committee will initially include the following individuals:
•
•
•
•

Nicholas A. Mastroianni, II, Chair and Principal ofUSIF-DEL.
David Finkelstein, CFO ofUSIF-DEL.
Mark Giresi, Chief Counsel ofUSIF-DEL.
Nicholas A. Mastroianni, III, Marketing.

Additionally, advice will be sought from key outside consultants and advisors such as:
• Michael Evans, Ph.D., Economic Consulting on job creation.
• Ignacio A. Donoso, Esq., of the law firm of Foster Quan, LLP- immigration legal advice
and counsel on EB-5 visa requirements.

The process for deal flow is shown below:
• The Chair and Principal ofUSIF facilitates deal Flow and works to ensure that USIF
evaluates and accepts only high-quality real estate development projects.
• Deals are submitted for evaluation (from all sources) to the CFO and General Counsel
• Deals will be screened and analyzed based on multiple criteria, including:
0

(b)(4)

0
0

0

11
390

 (b)(4)

0
0
0

0

• If a tr·a~n~s~a~ct~io~n~m~ee~t~s~th~e"!in~i~ti~al~s~c~re~e~n~in~g"".'c~n!'!"te~r~Ia~,"!'tth~<e.,C~h;a~Ir~a~n.,.,dC"''"'"'l'r,U~p~er~t~o~rm~'!"'a~
a~et"'!!';aw~e"!"'!!a!I"'-.J
review of the proposed transaction 1and provide a report showing merits and risks of
each deal.
• Project evaluation committee meets monthly (or more frequently depending on deal
Flow) to evaluate projects.
• Once proposed transactions are approved by the project review committee, the Chair and
General Counsel structure transaction with the counterparty

Project Company Structure
(b)(4)

12
391

 This structure is intended to ensure the stability of USIF and that highly qualified and consistent
management of the EB-5 Project is adopted for each project.

lJSU"
1% Ownership

EB-5 Investors
(99% Ownership)
$500,000 investment i
Administrative Fee eac~h_ _...,

(b)(4)
(b)(4)

Limited Liability Company
New Commercial Enterprise I Lender

$Loan

Developer I Borrower

Use of Loan to
Build the Project

KABR!Kushner Group
88 Morgan Street, LLC

Project Management

USIF will manage the Entity, which will be the new commercial enterprise for an EB-5 Project.
As manager or general partner of the new Entity, USIF will directly manage the day-to-day
operations of the Entity. USIF may also indirectly manage the new Entity through a subsidiary
or affiliate company that will serve as Manager or General Partner of the new Entity. Reporting
will be required of the developer/borrower under the loan contract to obtain required EB-5
Project information from the developer/ borrower. This structure ensures that financial and job
creation targets are met.

13
392

  . . .
WK WNANCIALS:

 

 

 

 

14

393

Revenue Projections

(b)(4)

In the following example, one new project with0nvestors was forecast for each year
commencing 2014. The same fee structure as in the current project was used for the
projected projects. Based on the aforementioned timetable and assumptions, the
Operating Budget and Cash flow Projections for the Regional Center are as follows:

(b)(4)

(b)(4)

..__ __.Jn beginning period represents expenses paid from 711112 for RC formation.
In conclusion, USIF RC will be managed as a "well~capitalized" company. The operating
projection is believed to be conservative based on the anticipated activity level. USIF will
identify future regional projects and these will continue to fund the USIF Regional Center into
the future.

15
394

 USIF SAMPLE PROJECT:
We have prepared one ( 1) sample project of the type of real estate development projects that the
USIF will sponsor as EB-5 Projects. This sample project is more fully described in the Business
Plan. The project, 88 Morgan Street, is a mixed-use real estate development project in which
EB-5 investment funds are pooled in a newly formed limited partnership. The Entity loans the
proceeds of the EB-5 capital investment funds to the developer to be used for the construction of
the buildings and other improvements that comprise the project. The project is located in the
Territory of the USIF.
Project: 88 Morgan Street

88 Morgan Street is a mixed-use real estate development project located in Jersey City, NJ in the
County of Hudson an area projected to qualify as a Targeted Employment Area. The EB-5
Project will include the construction of a 50 story rental apartment Tower, consisting of 417
rental apartments, 217 parking spaces, and approximately 4,000 sq.ft. of retail space adjacent to
Trump Plaza I.
The cost to construct the Project is budgeted to be J

Icomprised of the following:

...._-;::::::::::!...----.
Hard Construction Costs
Soft Construction Costs
Land Purchase,
TOTAL BUDGETED COSTS

(b)(4)

The source of funds to complete the construction is summarized as follows:
Owner's Equity
Senior Construction Loan
EB-5 Funds (Loan)
TOTAL FUNDING
The EB-5 Funds for 88 Morgan Street EB-5 Project is expected to beL.I......t=-=llllliu_,siF would
therefore need to attraci
IEB-5 investors each investinJ
I (b)(4)
The Economic Report prepared by Michael Evans, Ph.D. evaluates the financial and other data
set forth in this Business Plan. The Economic Report uses RIMS II econometric methodology.
The Economic Report concludes that the Project will create a total oil
!permanent new jobs
in the construction of the buildings and related improvements on the Property and the operations
of the new business activities owned by the Owner that are being created in the Project. This is
comprised of the following:

16
395

 The projected total of job creation isDnew jobs.

As such, the Economic Report concludes that up to
the Project.

I

(b)(4)

Iof EB-5 funds can be invested in
DILIGENCE:

"Accredited Investor" Verification

USIF will follow U.S. Securities and Exchange Act ("SEC Act") and all SEC Commission rules
for classifying an EB-5 Investor as an "Accredited Investor" according to the definitions
contained in Rule 501 of Regulation D. Two applicable definitions, either of which must be met
by potential EB-5 Investors, are as follows:
•

A natural person who has individual net worth, or joint net worth with the person's
spouse, that exceeds $1 million at the time of the investment (excluding their
principal residence).

• A natural person with income exceeding $200,000 in each of the two most recent
years or joint income with a spouse exceeding $300,000 for those years and a
reasonable expectation of the same income level in the current year.
Due Diligence

USIF will require each prospective EB-5 Investor to complete an Investor Suitability Evaluation
which requests detailed information on: (1) the EB-5 Investor's identity; (2) the EB-5 Investor's
Source of Funds and (3) the EB-5 Investor's immigration history in the U.S. The prospective
EB-5 Investor will also be required to provide adequate supporting information to verify
compliance with their eligibility as an Accredited Investor and their source of funds. A copy of
the questionnaire is attached to this Operations Plan at Exhibit E.
Source of Funds

USIF will adhere to all USCIS rules and regulations relating to confirming the legal source of
funds used for investments in EB-5 Projects. USIF will require that our lead immigration
attorneys, FosterQuan, LLP, provide training on USC IS Source of Funds rules to our Manager of
Investor Relations and personnel managing investor contacts. These rules include basic
requirements of8 CFR Sec. 204.60)(3) such as:

17
396

 • Obtaining evidence of salary earnings.
• Obtaining evidence of tax payments on salary, including 5 years of personal income tax
returns whenever they are available.
• Obtaining bank statements for amounts deposited in a bank.
• Obtaining evidence of bank transfers and foreign exchange transactions.
• Obtaining evidence of assets of the EB-5 Investor, such as real estate, and obtaining
evidence of how that asset became owned by the EB-5 investor.
Further, our lead immigration attorneys will provide advice and analysis of 1-526 visa petitions
whenever an issue of source of funds arises.
In sum, USIF is confident that these procedures will enable it to verify that funds from an EB-5
Investor have been lawfully obtained.
USIF's escrow bank will also comply with 31 U.S.C. 5318(i), "Due Diligence for United States
Private Banking and Correspondent Bank Accounts Involving Foreign Persons".
Investor Relations

USIF's Manager of Investor Relations will be in charge on building relationships with USIF
investors to assure reporting, communication and follow up. This will help with recruitment, as
we know that word of mouth and referrals will be instrumental in USIF recruitment success.
Investment Procedures

The USIF has developed the following outline of procedures to safeguard its compliance with
USCIS, U.S. Treasury and U.S. Securities and Exchange Commission regulations, and also to
ensure its success in managing assets and sponsoring successful projects that qualify under the
EB-5 Pilot Program ..

Step 1 - Registration
The potential EB-5 investor will first register with the USIF. Registration will be completed by
completing and signing the USIF Investor Suitability Evaluation.
As part of the registration, the Investor will provide their biographic information; copy of official
identification with photograph (e.g., a passport or driver's license);
Registration requires that the Investor disclose in detail the key sources of funds to be used in
their EB-5 investment.

18
397

 Step 2- Review of Investor's Initial Information
Upon receipt of a completed Investor Suitability Evaluation, the USIF will engage in due
diligence screening of the investor to avoid allowing someone to invest who (a) is not an
··accredited investor" pursuant to Rule 501 of Regulation D of the SEC Act, (b) does not comply
with requirements for exemption from U.S. securities registration; (c) may have criminal issues
in their background; or (d) cannot reasonably prove lawful source of funds in conformity with
USCIS rules, or has prior immigration violations. USIF will inspect and make a determination
as to the investor's:
• Source of funds
• Residency
• Treasury compliance OF AC Specially Designated Nationals List.
• Identity
• Criminal and General Background Search - to be completed using service provider: e.g.,
lnfoCubic or similar service.
Where necessary, USIF will request supporting documentation evidencing lawful source of
funds. This shall typically include such items as: introductory informational documents
regarding the investor; the investor's financial documents; the petitioner's investments; the
petitioner's business documents; the petitioner's real estate holdings; the petitioner's
employment history and relevant documents; and documents relating to other relevant sources of
the petitioner's income and/or capital such as gifts, loans, gambling winnings, inheritances, etc.
The Investor Suitability Evaluation completed by a potential EB-5 Investor will be maintained in
an internal USIF database and sent to legal counsel for registration and analysis. Counsel will
review immigration-critical questions; OF AC Specially Designated Nationals List, as well as
source of funds requirements of USCIS based on the responses to the Investor Suitability
Evaluation. Where necessary, additional documents & evidence of investor income,
employment, business profits and taxes paid.

Step 3- Subscription Documents
After the Investor Suitability Questionnaire is reviewed and the potential EB-5 Investor is
authorized by USIF, the EB-5 investor will be provided with copies of the Escrow Agreement,
Subscription Agreement, Private Placement Memorandum, Limited Partnership Agreement
(collectively, the "Subscription Documents"), and any relevant financial information of the USIF
and its EB-5 Project(s).
The potential EB-5 investor will be provided with an opportunity to review the Subscription
Documents and an opportunity to ask questions to foreign migration agents about the project,
and to conduct their own due diligence on USIF and the project.

19
398

 Step 4- Subscription

(b)(4)

Should the potential EB-5 Investor decide to proceed with his or her investment, the investor will
be required to deliver to the USIF duly executed Subscription Documents evidencing their
investment in the newly formed Entity. In addition, the EB-5 investor must also deposit the
entire amount of the capital {i.e., $500,000 or $1,000,000 as the case may be) and the additional
Administrative Fee
~o the escrow bank account of the new Entity in
immediately available funds. The instructions for such payments are found in the Subscription
Agreement, Escrow Agreement and Private Placement Memorandum that comprise the off-shore
Offering to the investor.

I

Step 5- Final Approval

(b)(4)

At the time that the potential investor delivers the signed Subscription Documents and the
Capital Contribution ($500,000 or $1,000,000, as the case may be) and Administrative Fee
I
L USIF has the right and sole discretion, under the Subscription Agreement, to accept
or reject the investor's subscription. This provision is intended to give USIF the right to reject
any investor who does not comply with being an accredited investor, or who cannot properly
document their source of funds, or, indeed for any other reason related to the investor's
background.
If the investor's application is accepted, the investor will be provided with the Subscription
Documents countersigned by USIF and supporting evidence for the investor's eventual 1-526
Immigrant Petition for Alien Entrepreneur. If the investor's application is rejected, then the
newly formed Entity and USIF will instruct the escrow bank, as escrow agent, to return to
escrowed capital contribution and escrowed administrative fee to the investor.

Step 6- Immigration Petition
Source of funds due diligence will also be conducted at the preparation of each form 1-526
petition filed by investors. An immigration attorney experience in EB-5 visa petitions will
prepare the I-526 petitions on behalf of the investor. USIF has retained the services of the highly
reputable firm, FosterQuan, LLP, as the preferred immigration counsel to the USIF to ensure
accurate review of source of funds documentation, and consistency and quality of each 1-526
Immigrant Petition for Alien Entrepreneur filed by investors in the USIF. FosterQuan, LLP will
either prepare or review each I-526 immigrant visa petition by individual EB-5 investors in the
US IF before each is filed with USCIS.

20
399

 XI. MARKETING:
The Partnerships have created an extensive marketing program to attract Qualified Investors. All
marketing activities will be conducted exclusively outside the United States and in compliance
with Rule 502(c) of the SEC Act. An affiliated approved Regional Center, the New Jersey
Regional Center ("FRC") has previously executed successful marketing plans to foreign finders
and migration agents under the EB·5 Pilot Program.
The Program to attract the Investment from Qualified Investors is summarized as follows:

(b)(4)

21
400

 (b)(4)

REPORTING
USIF, with the advice and support oflegal counsel FosterQuan, LLP, will oversee the reporting
to the USCIS. The USIF will require reports on a monthly basis to be notified of compliance
with the USC IS requirements, and review of monthly reports will be made and entered into the
company's records. Records will be maintained using electronic software and specialized
project management software.
USIF will ensure consistent management and oversight.
The invested funds for each new Entity will be accounted for separately and tracked in a
transparent fashion which will permit an independent auditor to verify at any time that the funds
are being expended for capital improvements and development, not for fees and expenses.

22
401

 Each potential EB-5 Investor will be tracked through the registration system mentioned above.
Names and identification documents will be required for each investor, and these will be
registered in a list of each such registrant maintained for each year. This registration and record
keeping will permit the USIF to control who has contacted it as a potential investor. Investors
who decide to invest in the Regional Center will be tracked through two means: (1) internal list
of potential EB-5 Investors and the progress of their cases, from the date the Investor Suitability
Evaluation was completed to the date the I-526 visa petition of an EB-5 Investor was filed, to the
date a decision is issued by USCIS; (2) Foster Quan, LLP will be the immigration attorneys for
the USIF and it uses the well-known software "Immigration Tracker" software to maintain a
database of all immigrant petitions filed under the auspices of the USIF. This will permit the
USIF to request reports on the status of petitions, and the obtain USC IS receipt numbers for all
cases, control deadlines for filing 1-829 petitions.
Further, USIF understands the USCIS annual reporting requirements set out in Form I-924A
and accompanying USC IS instructions. This information has been provided by FosterQuan, LLP
and USIF has the staff necessary to comply with the reporting requirements.
According to Form I-924 Supplement A, an approved EB-5 Regional Center must report on the
following matters:
A

The aggregate amount of EB-5 alien capital invested
through USIF. [Form I-924Supplement, Part 3, No. 1]

B.

The aggregate number of new direct and/or indirect jobs created by EB-5
investors through USIF. [Form I-924 Supplement, Part 3, No. 1]

C.

The aggregate number of jobs "maintained" jobs by EB-5 capital
investments into a "troubled business" through USIF, if applicable. [Form
1-924 Supplement, Part 3, No. 1]

D.

The industry(s) that have been the focus of EB-5 capital investments
sponsored through USIF and the resulting aggregate EB-5 capital
Investment and job creation. (Note: Separately identify jobs maintained
through investments in "troubled businesses".) [Form 1-924 Supplement,
Part 3, No. 2]

E.

The names, addresses, and industry category title of each job creating
commercial enterprise located within the geographic scope of USIF that
has received alien investor capital. Also, provide the aggregate amount of
EB-5 capital investment, the aggregate number of new direct and/or
indirect jobs created by EB-5 investors, and if applicable, the aggregate
number of jobs that have been "maintained" through EB-5 capital
investments into a "troubled business", for each commercial enterprise
located within the geographic scope of USIF. [Form 1-924 Supplement,
Part 3, No. 3]

23
402

 F.

If the EB-5 commercial enterprise( s) serve as a vehicle for investment into
other business entities that have or will create or maintain jobs for EB-5
purposes, then identify the names, addresses, amount of EB-5 capital
investment, and the number of jobs created or maintained by the actual job
creating businesses through EB-5 investments. [Form 1-924 Supplement,
Part 3, No. 3]

G.

The total number of approved, denied or revoked filed by EB-5 alien
investor 1-526 petitions for capital investments sponsored through the
USIF EB-5 Regional Center. [Form I-924 Supplement, Part 3, No.4]

H.

The total number of approved, denied or revoked filed by EB-5 alien
investor 1-829 petitions for capital investments sponsored through USIF.
[Form 1-924 Supplement, Part 3, No.5]

In addition to these requirements, USIF has been given legal counsel about certain internal
management subject areas that must be governed by the USIF, and regularly reported to USCIS,
are the following:
•

Principal officer and point of contact of the Regional Center.

•
•

Address of the principal offices of the Regional Center.
Description of due diligence screening of potential investors to ascertain their
lawful source of capital and the alien's ability to fully invest the requisite amount
of capital.
The Regional Center's evaluation and oversight practices on projects promoted
under its auspices.
The name, date of birth, Alien Registration Number of each foreign investor who
makes an investment and files and 1-526 Immigrant Visa Petition and I-829 with
USC IS, and a description of whether the petition was approved, denied or remains
pending.
The country of nationality of each investor who makes an investment with the
Regional Center and for whom an 1-526 Immigrant Visa Petition is filed.
The U.S. city and state of residence of each alien investor who makes an
investment and files an I-526 Immigrant Visa Petition and I-829 with USCIS.
Detailed description of each company and venture that has received money raised
from EB-5 investors.
The name and location of each job creating commercial enterprise that has
received money raised from EB-5 investors.

•
•

•
•

•
•

The total amount of EB-5 capital raised from alien investors in the last Federal
Fiscal Year.
The total amount of domestic capital raised from domestic investors in the last
Federal Fiscal Year.

24
403

 •
•

The total aggregate amount of EB-5 capital raised from alien investors since the
date of approval of the Regional Center.
For any Federal Fiscal Year in which the Regional Center does not have alien
investors to report, provide an explanation for the inactivity along with a specific
plan describing in detail the timeline and steps to be taken to actively promote the
Regional Center.

The procedures, records and controls set out above will permit the USIF to comply with USCIS
annual reporting obligations. Moreover, mechanisms are set out to ensure the management of
projects is directed towards their success, and that funds received from projects investors are
handled accurately and in compliance with all ethical and all obligations before the Securities
and Exchange Commission and the USCIS.

XIII. CONTACT INFORMATION
l.

lMivllGRA TION FUND NJ, LLC

Attention: Nicholas A. Mastroianni, II
1245 U.S. Highway One, Suite 300
Nmih Palm Beach, FL 33408
Phone: (561) 799-0050
Fax (561) 799-0061
!nf(i/.l;NJregionalcentcr.com

25
404

 County Map- State of New Jersey
Perimeter of Territory of
U.S. Immigration Fund-NJ, LLC Regional Center
Shown In

26
405

 EXHIBIT NAME

fample paid invoices by U.S. Immiwation Fund, LLC for the expenses ofl

TAB
NUMBER

13.

(b)(4)

406

 600 Travis Street
Suite 2000
Houston. TX 77002
713.229.8733 office
713.228.1303 fax
www.fosterquan.com

HE CO!v1f'P.EHEN$1VE iMMICR.ATION LAW FIRM

INVOICE

Nicholas A. Mastroianni, II
Principal
U.S. Immigration Fund, LLC
1295 U.S. Highway One
North Palm Beach) Florida 33408
(b)(6)
Email:l

DATE:
CLIENT NAME:
ATTY:

December 20,2012
U.S. Immigration Fund - NJ
Ignacio A. Donoso

I

FILE NUMBER: 410523.

(b)(4)

PAID IN FULL

407

 (b)(6)
(b)(4)

I
ATTN~ I
We Credited Your Acc:Qunt Per Incoming Fedwire

\.Vl h!l( PAV!\11\NT

11-

11--

11-

408

 EXHIBIT NAME

TAB
NUMBER

Sample Subscription Documents for Investors

Sample Investor Suitability Evaluation.

14.

409

 429/. 

gum?:
Min-um!?



U.S. IMMIGRATION FUND

INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL

 

 

 

 

410

EB-S SUITABILITY EVALUATION
PERSONAL 
Page 2

 

 

 

 

411

 INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL
Page 3

 

 

 

 

412

EB-S INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL
Page 4

 

 

 

 

413

 INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL
Page 5

 

 

 

 

414

?"19 

INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL
Page 6

 

 

 

 

415

 INVESTOR SUITABILITY EVALUATION
PERSONAL CONFIDENTIAL
Page 7

 

 

 

 

416

(b)(4)

EB-SINVESTOR SUITABILITY EVALUATION
PERSONAL & CONFIDENTIAL
Page 8

~

www.USIFUND.com

~

A 129S US Highway One- North Palm Beach- Florida- 33408- USA- P: 001.561.799.1883- F: 001.561.799.0061 ~

417

 TAB
EXHIBIT NAME NUMBER

Sample Subscription Agreement. 15.

418

Draft v. 112/20/2012

THIS AGREEMENT HAS BEEN INITIALLY WRITTEN IN THE ENGLISH LANGUAGE; IN
THE EVENT OF ANY CONFLICT BETWEEN THE ORIGINAL ENGLISH VERSION AND
ANY TRANSLATIONS INTO OTHER LANGUAGES, THE ORIGINAL ENGLISH VERSION
SHALL CONTROL

(b)(4)

88 MORGAN STREET FUNDING, LLC
SUBSCRIPTION AGREEMENT

419

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420

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430

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Subscription Agreement- USIF-NJ

IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the day and year
written below.
SUBSCRIPTION:
Number of Units subscribed for:
Total Amount:
Number of Units x (Subscription Amount $500,000
+Administrative Fee
$_ _ _ _ _ _ _ _ __

1

SUBSCRIBER:

I

(b)(4)

Signature

Street Address

Print or Type Name of Subscriber

City

Date

State or Country

Facsimile: _ _ _ _ _ _ _ _ _ _ __

Email:. _ _ _ _ _ _ _ _ _ _ _ __

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431

 ',,

Draft v. 112/20/2012

Subscription Agreement- USIF-NJ

PARTNERSHIP:
88 MORGAN STREET FUNDING, LLC
By U.S. Immigration Fund GP-88 Morgan Street, LLC, its
Management Company

By: ___________________________
Name:
Its:

ACCEPTED SUBSCRIPTION:
ACCEPTED AS OF
2013, AS TO
THE ABOVE SUBSCRIBED UNIT(S) UNLESS
OTHERWISE INDICATED BELOW:

Number of Units Accepted: _ _ _ _ __
Total Amount Accepted:

Subscriber's Designation (select one only):

D Phase I Subscriber
D Phase II Subscriber

D Phase III Subscriber

14

432

 TAB

EXHIBIT NAME NUMBER

Sample Escrow Agreement. 16.

433

Draft v.112/20/2012
SUBSCRIPTION AND ADMINISTRATIVE FEE ESCROW AGREEMENT
U.S. Immigration Fund-NJ

(b)(4)

434

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IN WITNESS WHEREOF, the Parties hereto have executed this Subscription and Administrative Fee
Escrow Agreement on the day and year first above written.

"FUNDING COMPANY "
(b)(4)

By: ____________________________
Name:
Title:

"SUBSCRIBER REPRESENTATIVE"
U.S. Immigration Fund-NJ, LLC

By: ____________________________
Name:
Title:

"ADMINISTRATIVE AGENT''

(b)(4)

By: ____________________________
Name:
Title:
"ESCROW AGENT''

By: ____________________________
Name:
Title:

9
442

 Draft v.112/20/2012

EXHIBIT A-1
Certificate of Incumbency
(List of Authorized Representatives)
Client Name: 88 Morgan Street Funding, LLC
As an Authorized Officer of the above referenced entity, I hereby certifY that the each person listed below
is an authorized signor for such entity, and that the title and signature appearing beside each name is true
and correct.

Name

Title

Signature

Contact Number

IN WITNESS WHEREOF, this certificate has been executed by a duly authorized officer by:

Date---------------Title:

----------------------

10

443

 Draft v.112/20/2012

EXHIBIT A-2
Certificate of Incumbency
(List of Authorized Representatives)
Client Name: U.S. Immigration Fund-NJ, LLC
As an Authorized Officer of the above referenced entity, I hereby certify that the each person listed below
is an authorized signor for such entity, and that the title and signature appearing beside each name is true
and correct.
Name

Title

Signature

Contact Number

IN WITNESS WHEREOF, this certificate has been executed by a duly authorized officer by:

Date~~~~~~~-

Title:

-----------------

11
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 Draft v.112/20/2012

EXHIBITB

. ._____...Ias Escrow Agent
(b)(4)

88 Morgan Street Funding, LLC._I_ _ _ _ _ ___,

Schedule of Fees & Expenses

12
445

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Exhibit C
Form of Written Direction

(b)(4)

88 Morgan Street Funding, LLC

13
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14

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Draft v. 112/20/2012

(b)(4)

ESCROW ADMINISTRATION SERVICES AGREEMENT
U.S. Immigration Fund-NJ

449

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This Escrow Administrative Services Agreement is effective as of the Effective Date.

Administrative Agent:
(b)(4)

By:
Name: ------------------------Title:

Subscriber Representative:

U.S. Immigration Fund-NJ, LLC, a New Jersey limited
liability company

By:
Name: -------------------------

Title:

454

 Schedule to Escrow Administration Services Agreement

Execution

 

 

 

 

455

EXHIBIT NAME
Sample Limited Liability Company Agreement of 88 Morgan Street Project.

TAB
NUMBER
17.

456

 Draft v.112/20/2012

LIMITED LIABILITY COMPANY

OPERATING AGREEMENT

88 MORGAN STREET FUNDING, LLC

[DATE]

457

 Draft v.112/20/2012

TABLE OF CONTENTS
PAGE
I. DEFINITIONS ...................................................................................................... 2

:2. FORMATION ....................................................................................................... 8
3. NAME AND PLACE OF BUSINESS .................................................................. 8
4. PURPOSE AND SCOPE OF COMPANY.......................................................... 8
5. TITLE .................................................................................................................... 9
6. COMMENCEMENT, TERM .............................................................................. 9
7. CAPITAL CONTRIBUTIONS ............................................................................ 9
8. RIGHTS AND DUTIES OF THE MANAGING MEMBER. .......................... 12
9. SALARIES AND EXPENSES............................................................................ 17
10. PROFITS, LOSSES, DISTRIBUTIONS AND JOB CREATION
ALLOCATION ................................................................................................... 18
11. SALE, DISSOLUTION AND LIQUIDATION................................................. 23
12. INVESTING MEMBERS ................................................................................... 24
13. RESTRICTIONS ON TRANSFER OF MEMBERSHIP INTERESTS......... 26
14. MISCELLANEOUS FINANCIAL AND ACCOUNTING MATTERS .......... 27
15. AMENDMENTS................................................................................................. 29
16. POWER OF ATTORNEY.................................................................................. 30
17. MEETINGS; MEANS OF VOTING ................................................................. 30
18. WITHDRAWALS ............................................................................................... 31
19. REPRESENT ATI 0 NS 0 F THE MEMBERS .................................................. 31
20. MISCELLANEOUS ........................................................................................... 34

2

458

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OPERATING AGREEMENT
OF

88 MORGAN STREET FUNDING, LLC

 

 

 

 

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IN WITNESS WHEREOF, the parties hereto have entered into this Agreement as of the
date first above written.
88 MORGAN STREET FUNDING, LLC,
a New Jersey limited liability company
By: U.S. IMMIGRATION FUND GP- 88 MORGAN
STREET, LLC,
a limited liability company
its Managing Member
By:
Name: ------------------------------Title:
Dated: -------------------------------

40
496

 Draft v.112/20/2012

88 MORGAN STREET FUNDING, LLC
OPERATING AGREEMENT
SUBSCRIBER SIGNATURE PAGE

(Signature)
Print Name:
Address:
Telephone:
Tax I.D. or Social Security#: _ _ _ _ _ _ _ __
Number of Units:
Email Address:

41
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SCHEDULE 1

LIST OF INVESTING MEMBERS

42

498

EXHIBIT NAME
Sample Template of Offering Memorandum of 88 Morgan Street Project.

TAB
NUMBER
18.

499

 Draft v.112/20/2012

Number: _ _ _ _ __

Date Issued: _ _ _ _ _ _ _ __

CONFIDENTIAL PRIVATE OFFERING MEMORANDUM
88 MORGAN STREET FUNDING, LLC

(b)(4)

500

 OFFERING SUMMARY

Draft v.1 12/20/2012

 

 

 

 

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TAB

EXHIBIT NAME NUMBER

Sample Investor Flow Chart. 21.

524

Immigration Procedures

This overview is for general infom1ational purposes only and shall not be constmed as legal advice.
Prospective investors must consult a qualified immigration attorney prior to commencing the procedures
set forth below.

t/;o.ur immigration attorney submits
I-526 Petition to USCIS.

y~:"''\

J

----------ep------~--~/

Upon approval of your 1-526 Petition, you may apply for Lawful Permanent Residence
via Consular Processing (if you are outside the United States) or Adjustment of Status (if
you are in the United States with valid non-immigrant status). Adjustment of Status is
not available in some instances, such as when you entered the United States pursuant to
the Visa WaiverPr()gram.

Consular Processing
Approval of your 1-526 Petition is forwarded to the
National Visa Center (NVC) for processing. The NVC
will contact you with information, forms and
documentary requirements for completion prior to
the scheduling of a visa interview at. the U.S.
Consulate.

Adjustment of Status
You must submit an 1-485 application to USCIS.
Your immigration attorney will assist with the
required forms and documentary evidence.
Separate applications must be submitted for each
qualifYing family member (spouse and children
urider21).

Once the NVC notifies you that an interview has
been scheduled, you will undergo a medical
examination, the results of which must be presented
at the interview. Review U.S. Consulate interview

While your 1-485 application is pending, you may
obtain employment and travel authorization from
US CIS. Subject to few exceptions, you must receive
advance permission to return to the United States

guidelines and ensure that all necessary original

if you travel outside the United States. Failure to

documents will be available at the time of the
interview.

do so will constitute abandonment of your 1·485
application.

Upon approval of your 1-485 application, you will
receive a Welcome Notice, and shortly thereafter,
a Lawful Permanent Residence card as evidence of
your status as conditional residents of the United
States. You will proceed to Phase 3 below at the

Conditional residence is usually granted at the time of
interview. Following visa approval, you and your
qualifying family members must enter the United
States in order to receive a Lawful Permanent
Residence card. You will proceed to Phase 3 below at
the appropr:iate•··.tim.e:

appropriate time.

C-2

525

 Investment Procedures

 

(W4) PHASE 1: SUBSCRIPTION

 

 

 

 

526

PHASE 2: [-626 PETITION

 

 

 

 

CW4

527

PHASE 3: 1?829 PETITION

 

 

 

 

C-5

528

EXHIBIT NAME

TAB
NUMBER

Project Business Plans & Economic Analysis
Business Plan of 88 Morgan Street Project.

19.

529

 88 Morgan
Street Funding,
LLC

November 23,

2012

An Investment opportunity in a thriving market, located in Jersey City,
New Jersey.

88 Morgan
Street Funding,
LLC Submission
of Business
Plan

In support for EB-5 Designation under the USCIS Pilot Program for._l_ _ _....,.lusD Dollars
I in EB-5 Funding

(USDI

(b)(4)

530

 Table of Contents
I.

EXECUTIVE SUMMARY .............................................................................................................. 3

II.

THE PROJECT ................................................................................................................................ 4
A.

B.
B.

c.

III.
B.
C.
D.

E.
D.

IV

OVERVIEW ....................................................................................................................................... 4
THE PROPERTY ................................................................................................................................ 6
JOB CREATION ................................................................................................................................. 7
SuMMARY ........................................................................................................................................
EB-5 INVESTMENT ........................................................................................................................ 8
INVESTMENT STRUCTURE .............................................................................................................. lO
MANAGEMENT ............................................................................................................................... 10
INVESTMENT TERMS AND CONDITIONS ......................................................................................... 11
LOAN STRUCTURE ......................................................................................................................... 14
Exrr STRATEGY ............................................................................................................................. 15

s

LOCATION- JERSEY CITY, NJ- HUDSON COUNTY ........................................................ 16

METROPOLITAN STATISTICAL AREAS OF NEW JERSEY ....................................................... 18
GEOGRAPHY ........................................................................................................................................... 19
HISTORY ................................................................................................................................................. 19
Public schools .................................................................................................................................... 22
Private schools ................................................................................................................................... 23
J1useums and libraries ....................................................................................................................... 23
COMMERCE ............................................................................................................................................. 24
MEDIA .................................................................................................................................................... 24
NOTABLE LANDMARKS .......................................................................................................................... 24

V.

PROJECT FEASIBILITY ............................................................................................................. 26

VI. FINANCIAL INFORMATION ..................................................................................................... 34
A. SOURCES AND USES ....................................................................................................................... 34
B. BUDGETS AND CONSTRUCTION TIMELINE .................................................................................... 35
Construction Time/ine .............................................................................. .......................................... 35
VII. INVESTJ\<IENT STRUCTURE ...................................................................................................... 38
A. DESCRIPTION ................................................................................................................................. 38
B. DEVELOPMENT TEAM .................................................................................................................... 38
VIII.
IX.
A.

X.

XII.

REGIONAL CENTER ............................................................................................................... 39
MARKETING PLAN TO ATTRACT IMMIGRANT INVESTORS ........................................ 40
MARKETING PROGRAM ............................................................................................................... 40
ECONOMIC IMPACT OF DEVELOPING A LUXURY RESIDENTIAL TOWER AS PART
OF THE US IMMIGRATION FUND-NJ, LLC, AN EB-5 REGIONAL CENTER, IN THE
NEW JERSEY METROPOLITAN AREA .................................................................................. 41
CONTACT INFORMATION ........................................................................................... 43

2

531

 BUSINESS PLAN
88 Morgan Street Funding, LLC
I.

(b)(4)

Executive Summary
The U.S. Immigration Fund-NJ, LLC (''USIF") as an approved United States Citizenship and
Immigration Services ("USCIS") regional center, will be administering and sponsoring a capital
investment ro'ect ursuant to the Immigrant Investor EB-5 Pilot Program (the "EB-5 Pilot
,.....iooooiooiiiil. . .iiiiioooi..._________,...ualified Investors (defined below) are each investing
·n the Funding Company Units of 88 Morgan Street
...,.,L-m.,c"'"m-g-,""""""""'!"!'t""e~""'""un~I..n-g~o-m_p_a.....
ny"). The Funding Company is the "New Commercial
Enterprise" that is organized to be in compliance with the USCIS EB-5 Pilot Program. The
Funding Company will make a secured EB5 loan (the "Loan") of all of the proceeds of each of
the Qualified Investor'4
hnvestment in the Funding Company to 88 Morgan Street,
LLC (the "Owner") in accordance with the EB-5 Pilot Program's guidelines.
The Owner will use the proceeds of the Loan for the construction of a mixed-use real estate
development project known as 88 Morgan Street Project to be located at 88 Morgan Street (the
"Project"), located in the most convenient location in New Jersey for access to Manhattan,
residing directly in the middle of three PATH hubs, and just minutes away from the ferry and the
Holland Tunnel (the "Property"), within the Territory of the USIF. The Project will consist of
the construction of a 50 story rental apartment building, consisting of 417 rental apmtments, 217
parking spaces, and approximately 4,000sqfl of retail space adjacent to Trump Plaza I.
Based on the Economic Report dated December 7, 2012 prepared by Michael K. Evans, Ph.D.
("Economic Report") a copy of which is attached as Exhibit (A), the Project is expected to
create at least 10 qualified permanent jobs for each Qualified Investor.

l ___...,.lcomprised of the following:

The cost to eonstmct the Project is budgeted to be ..
Hard Construction Costs
Soft Constmction Costs
Land Purchase,
TOTAL BUDGETED COSTS

The source of funds to complete the construction is summarized as follows:

(b)(4)

Owner's Equity
Senior Construction Loan
EB-5 Funds (Loan)
TOTAL FUNDING

The proceeds of the Loan will be used for constmction of the Project and the creation of jobs in
accordance with this Business Plan and the Economic Repmi discussed below. The proceeds of
the Senior Constmction Loan plus the Owner's Equity o1
will be used to purchase

I

3

532

 (b)(4)

the Propetiy and the balance for construction costs to complete the Project. The I
I
cost of the land is comprised of the costs of obtaining all governmental approvals and
entitlements to build the Project.

H.

The Project

(b)(4)

The Project is a
~ollar capital investment project that features a 50 story rental
apartment building, consisting of 417 rental apartments, 217 parking spaces, and approximately
4,000sqft of retail space adjacent to Trump Plaza I. The Loan from the Funding Company
provides the Owner with the additional funding to complete the construction of the Project and
create the jobs in accordance with the Economic Report prepared by Dr. Michael Evans below.

I

The Project has residential and commercial components and will be built simultaneously. Once
complete, the Project will consist of the following:

Amenities & Services
• An existing easement agreement allows residents of Phase II to gain access to all
of Phase l's luxurious amenities (which have already been constmcted), including
• Over 41,000 square feet of extravagant indoor and outdoor lifestyle amenities
• Gracious outdoor terrace featuring a heated swimming pool surrounded by
luxurious cabanas and landscaped lawn
4

533

 • State-of-the-art fitness center fully equipped with cardiovascular and weightlifting machines, private training and yoga room
• Golf simulator offering access to the world's most famous courses without
leaving the building
• Billiard and Game Room
• Lavishly appointed spa complete with walk-in rainfall shower, men's and
women s steam and treatment rooms
• Roman-style Aqua Grotto featuring an enclosed 26' heated thermal bath, coed
steam and sauna. And walk-in shower
• Screening room featuring an oversized flat screen television
• Private dining room complete with a full kitchen
• Social room with a fireplace and a flat screen television
• Business center offering Internet access
• Children's activity room and outdoor play area
• Indoor Basketball Court and Swimming Pool
Monthly Garage Parking is available
• Access to retail and dining
Services include: 24 hour Concierge and Doorman, BMW zip cars, Valet
Parking, Porter and Maid service, Tailoring and Dry Cleaning, and so much
more ...

5

534

 • The Project at 88 Morgan St. is located in one of the most desirable areas of Jersey City,
just 2 blocks from the water front and will have panoramic views of the New York City
skyline. The Project is considered one of the most "shovel ready" residential development
projects in Jersey City.
• The development site is approved for the constmction of a 50 story residential tower
consisting of 417 rental apartments, 217 parking spaces, and approximately
4,000 sq. ft. of retail space adjacent to Tmmp Plaza I.
• The land at 88 Morgan St. is considerably more valuable than other parcels of its size
given its location and current status.
• Located on an approximately 12,000 sq. ft., graded, constmction-ready parcel of land,
Phase II will encompass both the corner of Greene Street and Bay Street, as well as that
of Greene Street and Morgan Street.
• Included in the 12,000 sq. ft. empty lot are the air rights over the existing single
story retail space adjacent to Phase I of Trump Plaza.
• The air rights allow for a five story parking garage to be constmcted over the existing
retail space. In doing so, Phase ll will both tie into and add on to the existing 7th
story amenity space of Phase I.

The 88 Morgan Street address is synonymous with high-class living, and its central location
offers convenient access to all points in Manhattan.

6

535

 Property Zoning & Approvals: The development site is approved for the
construction of a 50 story residential tower consisting of 417 rental apartments, 217
parking spaces, and approximately 4,000 sq. ft. of retail space adjacent to Trump
Plaza I.
2. Targeted Employment Area: The Property is located in a Census Tract that is
considered by the State of New Jersey to qualify as a high unemployment area
under the provisions of the EB-5 Pilot Program as a Targeted Employment Area
("TEA") with unemployment rate that is in excess of 150% of the U.S. National
average. The 88 Morgan Street Project will be located The Project at 88 Morgan
St. is located in one of the most desirable areas of Jersey City, just 2 blocks from
the water front and will have panoramic views of the New York City skyline. The
Project is considered one of the most "shovel ready" residential development
projects in Jersey City.

1.

The USIF has requested a letter from the New Jersey Department of Labor that will confirm that
the Property is located in Census Tracts within the TEA designated by the New Jersey
Department of Labor ("TEA Letter"). The USIF is aware that USC IS guidance establishes that
the detem1ination of whether a geographic area qualifies as a TEA is decided by USCIS at the
time that an EB-5 investor's 1-526 visa petition is filed with USCIS, instead of the date when an
I-924 Application for Regional Center is filed. USIF expects that the TEA Letter will confirm
that this Census Tract in New Jersey meets the requirements to qualify as a TEA. The 2011
annual unemployment rate for this tract was t4. 7%, which was more than 150% greater than the
U.S. National annual unemployment rate. Accordingly, the USIF has made its plans based on
the requirement that Qualified Investors are each investing $500,000 in the New Commercial
Enterprise (the Funding Company) to qualify their investments under the EB-5 Pilot Program.

The Economic Report prepared by Michael Evans, Ph.D. evaluates the financial and other data
set forth in this Business Plan. The Economic Report uses RIMS II econometric methodology.
The Economic Report concludes that the Project will create a total ofL:}ermanent new jobs
in the construction of the buildings and related improvements on the Property and the operations
of the new business activities owned by the Owner that are being created in the Project. This is
comprised ofthe following:

(b)(4)

(l~1ew jobs created from construction activities.
(.2
new jobs from architectural and engineering services.
(3
ew jobs from the purchase of FF&E.
(4)0new jobs from the first year of full operations of the Project.
The projected total of job creation isDnew jobs.
(b)(4)

t1

tf

As such, the Economic Report concludes that up
EB-5 funds can be invested in
the Project.
....._ _...,.

7

536

 I

The Funding Company 1s making a
toan to the Owner.
requirements of al
~oan to the Owner are t e following:
(b)(4)

Amount of
EB-5 Loan ($)

I

Total No.
EB-5 Investors

Capital
Contribution
Per EB-5
Investor

Minimum New
Jobs Required

Total Jobs
Created per
Economic Study

The job creation

Excess Number
of Jobs

(10 per Investor)

As confirmed by the foregoing table, the Project has been designed to provide a cushion o O
Iequating tcr-lxcess jobs (31%), orc:Jobs per investor. USIF intends to only use
the jobs from EB-~ble constmction expenditures, architectural and engineering services,
FF &E and apartment rental operations for purposes of meeting the I0 jobs per Investor minimum
requirement of the EB-5 Pilot Program.
(b)(4)

Summary
All components of the Development (rental apartments and retail) will contribute substantially to
the economics of 88 Morgan Street. The Project is expected to bring a total ofOennanent
new direct, indirect and/or induced jobs. The Property is located within a TEA, as previously
stated.

HI.

EB-5 Investment
'\.

EB-5 Pilot Program

The Funding Company was formed to make equity and/or debt investments pursuant to and in
accordance with the EB-5 Pilot Program, which grants lawful permanent resident status in the
United States to those who make qualifying investments under the provisions of the U.S.
Immigration and Nationality Act (see 8 U.S.C. § 1153(b)(5)(A)(i)-(iii) and (C)). The Funding
Company will offer and sell units of the Funding Company interest ("Units") outside the
United States to Qualified Investors in a private placement exempt from registration under the
Securities Act of 1933, as amended (the "Securities Act") and in compliance with the
requirements of the EB-5 Pilot Program (the "Securities Offering"). In order to invest into the
Funding Company, a potential Qualified Investor must meet criteria set fm1h in the Securities
Offering Materials, follow the required subscription procedures, and complete all required U.S.
and foreign immigration procedures. The Funding Company Agreement dated [_,] 2013 (the
''Funding Company Agreement'') will govern the rights and obligations of each Qualified
Investor in the Funding Company.

(b)(4)

The amount of the OtTering will be up to
Dollars. Each of
thc:::Jjualified Investors will invest
in capital plus a I
ladministrative fee
(each an ''Investment") in the Fundmg ompany. The $500,000 capital Investment in the
Funding Company qualifies under the EB-5 Program because the Project is located in a TEA.

8

537

 (b)(4)

U.S. Immigration Fund GP-88 Morgan Street, LLC (the "Management Company") will
manage the Funding Company. These management responsibilities will include the collection of
funds from the Qualified Investors and making the Loan to the Owner by means of a promissory
note or notes and other related documents ("'Loan Documents"). Other responsibilities of the
Management Company and USIF will include assuring the Qualified Investors and USCIS
ofticials that the Project is being built and the funds are being used in accordance with the
approved development budget. Finally, the Management Company will monitor the payment of
the Loan to the Owner. The Management Company and USIF have entered into an agreement
under which the USIF agrees to oversee the activities of the Management Company to ensure
compliance with all requirements of the EB-5 Pilot Program.

(b)(4)

As stated above, the Project will be completed with a total
The
Investments from the Qualified Investors will be up to a total o•----'.ii
otQnvestors and will supplement the Owner's equity o,..__ _ _.......
financing o
to complete the constmction. In the Economic Report, Dr. Evans
states that there ar
projected nnw p;manent jobs calculated in accordance with USCIS
requirements. This creates a surplus o
xcess jobs, which is approximatelQnore jobs
than are needed for the maximum number of Qualified Investors.
The source of funds to complete the constmction is summarized as follows:
Owner's Equity
Senior Construction Loan
EB-5 Funds (Loan)
TOTAL FUNDING

(b)(4)

There is no guarantee that the EB-5 Loan will be repaid by the Owner or that the proceeds from
the foreclosure of any of the security in the Property will be sufficient to cover any non-payment
of the Loan. For this reason, the Investment is deemed fully at risk. No distribution to the
Qualified Inv!ls in the Funding Company will be made until the maturity date of the Loan
which will b
ears from Loan being funded, but not earlier than the end of the conditional
residency peno and approval of the Qualified Investor's I-829 petition.

c·

(b)(4)

Based on the Owner's tinancial projections and the analysis of the independent feasibility
repot1s,
tation of the Funding Company that the Owner will be able to pay off the
Loan of
plus accmed interest in full at its maturity dateOyears from the date
flmding 1e oan. e potential sources of repayment are from the sale and/or refinancing of all
or a portion of the Property (see Sec Ill B 2·"Revenue & Sales Projections").

9

538

 (b)(4)

Investment Structure

lof

Up to'

the funding for the construction of the
Projec wHI Be m the fonn of one or more promissory notes delivered in one (I) and up to three
(3) Phases from the Funding Company to the Owner (i.e., the Loan). The ownership of the
Funding Company and the Loan structure is depicted in the following diagram:
(b)(4)
-LENDER88 Morgan Street Funding, LLC

EB-5 Investors
(The Partners - 99% Ownership)

U.S. Immigration Fund GP-88
Morgan Street, LLC
(Management Company- 1%
()wnf't·~hin)

-BORROWER-

88 Morgan Street, LLC

C

Management
10

539

 The Funding Company was fanned in the state of New Jersey [on
,] 2013. The
Management Company will serve as Manager and will manage the activities of the Funding
Company. The Funding Company is the entity into which the Qualified Investors will each
make their Investments. The Funding Company will make the Loan of the proceeds of the
respective $500,000 Investments to the Owner for use in the constmction of the Project.
USIF was organized on December 7, 2012. It has petitioned the USCIS for approval as a
regional center. USIF will be the holder of the USCIS approved regional center rights to sponsor
and administer qualified projects under the Pilot Program in Bergen, Essex, Hudson, Middlesex,
Monmouth, Monis, Passaic and Union Counties in New Jersey (the ''Territory") in which the
Project is located. USIF will oversee the Project and perfonn the responsibilities of the USCIS
regional center as set forth in Section III A. The approval of a regional center means USCIS
recognizes the economic entity as a designated participant in the Pilot Program. Designated
Industries include:
• Residential Building Constmction (NAICS 2361)
• Non-Residential Building Constmction (NAICS 2362)
• Lessors of Residential Buildings & Dwellings (NAICS 53111)
• Architectural and Engineering Services (NAICS 5413)
Management Company will conduct the day-to-day management of the Funding Company and
shall have the following authority to act on behalf of the Funding Company:
(I) to employ attorneys, agents, consultants, accountants and other independent
contractors to perfonn services on behalf of the Funding Company, including affiliates
of the Management Company; provided that such services are reasonably necessary or
advisable and the compensation therefore is reasonable;
(2) to bring or defend legal actions in the name of the Funding Company, pay,
collect, compromise, arbitrate, or otherwise adjust or settle claims or demands of
or against the Funding Company or its agents;
(3) to perfonn or cause to be performed all of the Funding Company's obligations under
any agreement to which the Funding Company is a party;
(4)

to cause the Funding Company to make the Loan to the Owner;

(5) to cooperate with the USIF in all matters relating to the Project, the Qualified Investors,
the Petitions to be filed with USC IS and the effective management of the investments
made by the Qualified Investors;
(6) to execute, acknowledge and deliver any and all instmments necessary to effectuate any
of the loregoing.

Investment Terms and Conditions
A summary of the tenns and conditions of the Investment include, but may not be limited to the
following:
11

540

  

 

 

 

12

541

 

 

 

 

13

542

 

 

 

 



Eff; Liam Si?i?jtur?

 

 

 

 

14

543

(b)(4)

In accordance with the guidelines of USCIS, relating to investments within an approved EB-5
Pilot Program project, the investment by the Qualified Investors in the Funding Company shall
be "fully at risk." There is no guarantee that the Loan will be repaid by the Owner or that the
proceeds from the foreclosure of any of the security in the Property will be sufficient to cover
any non-payment of the Loan. For this reason, the Investment is deemed fully at risk.
(b)(4)

15

544

 Projected Revenue
ProJect Component

(b)(4)

IV

I

Amount

Location- Jersey City, NJ- Hudson County

Skyline of Downtown Jersey City

16

545

 :Seal

Location ol'k1·sey City within Hudson County. h1>et: Location of Hudson County highlighted within the
state of New Jerst'Y·

Census Bureau map of .Jersey City, New Jersey

Country

United States
New Jersey

Jersey City is the seat of Hudson County, New Jersey, United States. As of the 2010 United
States Census, the population of Jersey City was 247,597, making it the second-most populous
city in New Jersey.

17

546

 Metropolitan Statistical Areas of New Jersey

Part of the New York City metropolitan area, Jersey City lies across from Lower Manhattan
between the Hudson River and Upper New York Bay and the Hackensack River and Newark
Bay. A port of entry, with 11 miles ( 18 km) of waterfront and significant rail connections, Jersey
City is an impmiant transportation terminus and distribution and manufacturing center for the
Port of New York and New Jersey. Service industries have played a prominent role in the
redevelopment of its waterfront and the creation of one of the nation's largest downtowns.
•

After a peak population of316,715 measured in the 1930 Census, the city's population
saw a half-century long decline to a low of 223,532 in the 1980 Census, but since then
the city's population has grown, with the 2010 population reflecting an increase of 7,542
(+3.1%) from the 240,055 counted in the 2000 Census, which had in turn increased by
1L518 (+5.0%) from the 228,537 counted in the 1990 Cetl§.li§..

18

547

 Jersey City is bordered to the east by the Hudson River, to the north by Secaucus, North Bergen,
Union City and Hoboken, to the west, across the Hackensack, by Keamy and Newark, and to the
south by Bayonne. Given its proximity to Manhattan, Jersey City and Hudson County are
sometimes referred to as New York City's sixth borough. r221 rnu 241

Image of Jersey City taken by NASA. (The red line demarcates the municipal boundaries of
Jersey City.)

Jersey City at the end of the 19th century.
Among the oldest surviving houses in Jersey City is the stone Van Wagenen House of 1742.
During the American Revolutionary War the area was in the hands of the British who controlled
New York. Paulus Hook was attacked by Major Light Horse Harry Lee on August 19, 1779.
After the war Alexander Hamilton and other prominent New Yorkers and New Jerseyeans
attempted to develop the area that would become historic downtown Jersey City and laid out the
city squares and streets that still characterize the neighborhood, giving them names also seen in
Lower Manhattan or after war heroes (Grove, Varick, Mercer, Wayne, Monmouth, and
Montgomery among them). During the 19th century, 60,000 fonner slaves reached Jersey City
on one of the four routes of the Underground Railroad that led to the city.ll2.l

19

548

 The old ferry docks at the CRRNJ tenninal in Liberty State Park in 2011
The City of Jersey was incorporated by an Act of the New Jersey Legislature on January 28,
1820, from portions of Bergen Township, while the area was still a part of Bergen County. The
city was reincorporated on January 23, 1829, and again on February 22, 1838, at which time it
became completely independent of North Bergen and was given its present name. On February
22, 1840, it became part of the newly created Hudson County.llill

Jersey City and Hoboken in 1886
Soon after the Civil War, the idea arose of uniting all of the towns of Hudson County east of the
Hackensack River into one municipality. A bill was approved by the State legislature on April 2,
1869, with a special election to be held October 5, 1869. An element of the bill provide that only
contiguous towns could be consolidated. While a majority of the voters across the county
approved the merger, the only municipalities that had approved the consolidation plan and that
adjoined Jersey City were Hudson City and Bergen City.Lill The consolidation began on March
17, 1870, taking effect on May 3, 1870.Llli Three years later the present outline of Jersey City
was completed when Greenville agreed to merge into the Greater Jersey City.
20th century
Jersey City was a dock and manufacturing town for much of the 19th and 20th centuries. Much
like New York City, Jersey City has always been a destination for new immigrants to the United
States. In its heyday before World War II, German, Irish, and Italian immigrants found work at
~~olgate, Chloro or Dixon Ticonderoga. However, the largest employers at the time were the
railroads, whose national networks tenninated on the Hudson River at Pavonia Tenninal,
Exchange Place and Communipaw. ln 1908, the first pennanent, drinking water disinfection
system in the U.S. was installed on the water supply for the City by John L. Leal.Llil The Hudson
Tubes opened in 1911, allowing passengers to take the train to Manhattan as an alternative to the
extensive ferry system. The Black Tom explosion occurred on July 30, 1916, as an act of
sabotage on American ammunition supplies by German agents to prevent the materials from
being used by the Allies in World War I.

From 1917 to 1947, Jersey City was governed by Mayor Frank Hague. Originally elected as a
refonn candidate, the Jersey City History Web Site says his name is "synonymous with the early
20

549

 twentieth century urban American blend of political favoritism and social welfare known as
bossism." Hague ran the city with an iron t1st while, at the same time, molding governors,
United States senators, and judges to his whims. Boss Hague was known to be loud and vulgar,
but dressed in a stylish manner earning him the nickname "King Hanky-Panky".llil In his later
years in office, Hague would often dismiss his enemies as "reds" or "commies". Hague lived like
a millionaire, despite having an annual salary that never exceeded $8,500. He was able to
maintain a fourteen-room duplex apartment in Jersey City, a suite at the Plaza Hotel in
Manhattan, and a palatial summer home in Deal, and travel to Europe yearly in the royal suites
of the best liners.
After Hague's retirement from politics, a series of mayors including John V. Kenny, Thomas J.
Whelan and Thomas F. X. Smith attempted to take control of Hague's organization, usually
under the mantle of political reforn1. None were able to duplicate the level of power held by
llague,Lllil but the city and the county remained notorious for political corruption for
years. r39 H40lf 41l By the 1970s, the city experienced a period of urban decline that saw many of its
wealthy residents leave for the suburbs, rising crime, civil unrest, political cmruption, and
economic hardship. From 1950 to 1980, Jersey City lost 75,000 residents, and from 1975 to
1982, it lost 5,000 jobs, or 9% of its workforce.
Beginning in the 1980s, development of the waterfront in an area previously occupied by rail
yards and factories helped to stir the beginnings of a renaissance for Jersey City. The rapid
construction of numerous high-rise buildings increased the population and led to the
development of the Exchange Place financial district, also known as 'Wall Street West', one of
the largest banking centers in the United States. Large financial institutions such as UBS,
Cioldrnan Sachs, Chase Bank, Citibank and Merrill Lynch occupy prominent buildings on the
Jersey City waterfront, some of which are among the tallest buildings in New Jersey.
Simultaneous to this building boom, the light-rail network was developed.Hll With 18,000,000
square feet (1 ,700,000 m2) of office space, it has the nation's 12th largest downtown.

Education

J "c

s.J •

The Yanitelli Center on the campus of Saint Peter's College.
21

550

 Jersey City is home to the New Jersey City University (NJCU) and Saint Peter's College, both of
which are located in the city's West Side district. It is also home to Hudson County Community
College, which is located in Journal Square. The University of Phoenix has a small location at
Newport, and Rutgers University offers MBA classes at Harborside Center. Hudson County
Community College, a junior college located in the Journal Square area offering courses to
heLLC the transition into a larger university, is praised for the culinary department and
program.LL!ll

Public schools

Dr. Ronald E. McNair Academic High School
The Jersey City Public Schools serve students threeyears and older from Pre-K 3 through twelfth
grade. The district is one of 31 Abbott districts statewide,~ which are now referred to as "SDA
Districts" based on the requirement for the state to cover all costs for school building and
renovation projects in these districts under the supervision of the New Jersey Schools
Development Authority.I
Dr. Ronald E. McNair Academic High School was the second-ranked public high school in New
Jersey out of 322 schools statewide, in New Jersey Monthlv magazine's September 2010 cover
story on the state's "Top Public High Schools", after being ranked second in 2008 out of 316
schools.illlJ. and was selected as 41st best high school in the United States in News~veek
magazine's national 2011 survey.Lilll William L. Dickinson High School is the oldest high
school in the city and one of the largest schools in Hudson County in terms of student
population. Opened in 1906 as the Jersey City High School it is one of the oldest school sites in
the city, its a four-story Beaux-Arts building located on a hilltop facing the Hudson River.illll
Liberty High School (New Jersey) is also one of the top schools in the Heights and the only high
school that focuses on all academics. Other public high schools in Jersey City are James J. Ferris
Lincoln High School, and Henry Snyder High School. The !.:!1!~:!lJdlill!!!Y
Schools of Technology (which also has campuses in North Bergen and Secaucus) has a campus
in Jersey City, which includes County Prep High School.

22

551

 Among Jersey City's elementary and middle schools is Academy I Middle School and Frank R.
Conwell Middle School #4, which is part of the Academic Enrichment Program for Gifted
Students. Another school is Alexander D. Sullivan P.S. #30, an ESL magnet school in the
Greenville district, which services nearly 800 Pre-k through 5th grade students.
Jersey City also has 12 charter schools, which are run under a special charter granted by the
Commissioner of the New Jersey Department of Education, including the Mathematics,
Engineering, Technology and Science Charter School (for grades 6 - 12) and the Dr. Lena
Edwards Charter School (for K-8), which were approved in January 20 ll.l..JlQl

a)

Catholic schools

The Roman Catholic Archdiocese of Newark maintains a network of elementary and secondary
Catholic schools serve every area of Jersey City. High schools administered by the Archdiocese
arc Hudson Catholic Regional High School, St. Anthony High School, Saint Dominic Academy
and St. Peter's Preparatory SchooJ.Ulil St. Mary High School - Closed in June 2011 due to
declining enrollment[
Catholic grade schools include Our Lady of Mercy Academy, Our Lady of Czestochowa School,
Resunection School, Sacred Heart School, St. Aloysius Elementary Academy, St. Anne School,
St. Joseph School and St. Nicholas School.

b)

Other private schools

Other private high schools in Jersey City include First Christian Pentecostal Academyr 1301 and
Stevens Cooperative School.Llill Kel1111are High School is operated through the York Street
Project as part of an effort to reduce rates of poverty in households headed by women, through a
program that offers small class sizes, individualized learning and development oflife skills.LI.ill
A number of other charter and private schools are also available. Genesis Educational CenteP
is a private Christian school located in downtown Jersey City for ages newborn through 8th
grade. The Jersey City Ati School is a private art school located in downtown Jersey City for all
ages.

'T'he Jersey City Free Public Library has five regional branches, some of which have permanent
collections and host exhibitions. At the Main Library, the New Jersey Room contains historical
archives and photos. The Miller Branch is home to the Afro-American Historical and Cultural
Society Museum. The Five Comers Branch specializes in works related to music and the tine
atis, and is a gallery space. The library system also supports a bookmobile and five
neighborhood libraries.
Liberty State Park is home to Central Railroad of New Jersey Tenninal, the Interpretive Center,
and Liberty Science Center, an interactive science and learning center. The center, which first
opened in 1993 as New Jersey's first major state science museum, has science exhibits, the
23

552

 world's largest IMAX Dome theater. numerous educational resources, and the original
Hoberman sphereJ 1361 From the park, ferries travel to both Ellis Island and the Immigration
Museum and Liberty Island, site of The Statue of Liberty.
The Museum of Russian Art specializes in Soviet Nonconformist Art.
The Jersey City Museum closed in December 2010 and is not expected to reopen. It showed
contemporary work and sponsored community-oriented projects.
Some stations of the Hudson Bergen Light Rail feature public art exhibitions, including those at
Exchange Place, Danforth Avenuer 140 and Martin Luther King Drive station.ll::1:.1JI.l.m
J

Commerce
Jersey City has several shopping districts, some of which are traditional main streets for their
respective neighborhoods, such as Central, Danforth, and West Side Avenues. Journal Square is
a major commercial district. Newport Mall is a regional shopping area.llill Portions of the city
are part of an Urban Enterprise Zone. In addition to other benefits to encourage employment
within the Zone, shoppers can take advantage of a reduced 312°/c) sales tax rate (versus the 7%
rate charged statewide) at eligible merchants.
Jersey City is home to the headquarters of Verisk Analvticsl 145 J and Lord Abbett, a privately held
money management firm.Ll±Ql Companies such as Computershare, ICAP, ADP, and Fidelity
Investments also conduct operations in the city.LL:lll Goya Foods, which is headquartered in
adjacent Secaucus, announced plans in 2011 to open a 500,000-square-foot distribution center in
Jersey City.

Media
Jersey City is located within the New York media market, most of its daily papers available for
sale or delivery. The daily newspaper The Jersev Journal, located at its namesake Journal
Square. covers Hudson County, its morning daily, Hudson Dispatch now defunct.lli2l The Jersev
City Reporter is part of the Hudson Reporter group of local weeklies. The Jersey City
Independent is a web-only news outlet that covers politics and culture in the city. 11501 The River
Vie~v Observer is another weekly published in the city and distributed throughout the county.
Another countywide weekly, El Especialito, also serves the city.illli The Dailv News maintains
extensive publishing and distribution facilities at Liberty Industrial Park.
WFMU 91.lFM (WMFU 90.1FM in the Hudson Valley), the longest nmning freeform radio
station in the US, moved to Jersey City in 1998.Lllli WSNR-620 AM is also licensed in the city.
Jersey City is the filming location for the 2012 reality television series Snooki & JWoww, a
spinoff of Jersev Shore that stars Nicole "Snooki" Polizzi and Jetmifer "JWoww" Farley living at
a former firehouse at 38 Mercer Street at Grove Street in Downtown Jersey City.

Notable landmarks
• See List o(Registered Historic Places in Hudson County. New Jersev

24

553

 • Statue of Liberty National Monument, Ellis Island and Liberty Island
• Liberty Science Center
• The Katyil Memorial by well-known Polish-American artist Andrzej Pitynski on
Exchange Place is the first memorial of its kind to be raised on American soil to honor
the dead of the Katyt1 Forest Massacre.
• The Colgate Clock, promoted by Colgate-Palmolive as the largest in the world, sits in
Jersey City and faces Lower New York Bay and Lower Manhattan (it is clearly visible
from Battery Park in lower Manhattan). The clock, which is 50 feet (15m) in diameter
with a minute hand weighing 2,200 pounds, was erected in 1924 to replace a smaller one
that was relocated to a plant in Jeffersonville, Indiana.
• The Landmark Loew's Jersey Theatre, one of the five Loew's Wonder Theatres
constructed in the 1920s and the only one located outside ofNew York City, is located in
Journal Square. Currently presenting classic films, live perfonnances, and events while
the theatre undergoes restoration by volunteers.

• With the waterfront, the PATH and the light rail only steps away, as well as readily available
ZIP cars on-site, the property is conveniently positioned for travel.
• Phase II is located between three mass transit PATH hubs (Grove, Exchange Place, and
Newport/Pavonia). The PATH (Port Authority Trans Hudson) system links Jersey City to
Hoboken, Harrison, Newark and to both Downtown and Midtown in New York City within
minutes.

• The PATH is both reliable and efficient; businesses at Jersey City's Exchange Place say that
25

554

 they

are "across the street" from Manhattan's Wall Street.

• The Light Rail, which connects Jersey City with Bayonne, Hoboken, and Weehawken is an
award-winning, nationally recognized, innovative transit system. Its electric powered modem
trolleys are both environmentally friendly as well as very heLLCful in decongesting New YorkNew Jersey traffic.
• Jersey City is in close proximity to the Holland Tunnel, providing cars and buses with a
simple, direct access to Manhattan.
• A number of ferry lines go from Jersey City to Manhattan:
NY Waterway provides several routes out of Jersey City and considered the largest
concentration of service offered.
• Since Jersey City is at the center of this major highway system, it's extremely easy for
employees and goods to stream both in and out of the project location.

Project Feasibility

V.

The owners financial assumptions are based on their many years of experience in the Real Estate
market relating to ownership, management and development of similar projects. They have
confim1ed the demand for luxury apartments in the area and the low level of recent or future
planned development. They are projecting a rental income between I
lfor a studio
apartment up to ~er month for a 3 bedrooms. In the examples below for similar
properties in the ~cation the monthly rentals start
a studio apartment and
up to
a 3 bedroom.]

I

for

ad

lor

(b)(4)

26

555

 Neighborhood- Jersey City Powerhouse District

Proposed Phase II

• The Powerhouse District is a veritable hot bed of arts and culture, making this one of
Jersey City's most desirable and blossoming neighborhoods.
• Only minutes away from Manhattan, Jersey City attracts many young families and single
workers, helping to make Jersey City a hub for nightlife, theater, art-galleries, Parks,
museums and a thriving waterfront.
• Jersey City boasts the largest mall in Hudson County, the Newport Mall, which has 3
levels and is anchored by Macy's, Sears, and JC Penney.
• Jersey City has a modern medical center and is the seat of Jersey City State College and
St. Peter's College. Liberty State Park, on the waterfront, is the site of the science
museum and provides an excellent view of New York Harbor.

27

556

 (W4)

Rental Comparables

 

 

 

 

28

557

 

 

 

 

29

558

(Why-

 

 

 

 

3]

559

 

 

 

 

32

560

 

 

 

 

561

Financial Information

The Project has a total projected cost of ..
l ___....,l This is comprised of the following:

(b)(4)

•

I

tor the purchase of the Property which includes all the cost of obtaining the
necessary governmental approvals, other entitlements, all pre-development costs and;

•
approximatell

lm

ro'ected costs to complete the construction, which includes
of projected "hard" construction costs, and approximately
proJected "soft" construction costs, FF&E, financing expenses and other

costs.
•

(b)(4)

bf

The Owner is securing approximate!~
seijm corstmct;on debt the "Senior
Construction Loans"). The Owner's equity investment oq
) and the..._-.-~~~
Loan to be provided by the Funding Company (the proceeds of which are derived from the EB-5
Investor) will be used solely for project construction hard costs or qualified soft costs.

All EB-5 Investor capital investment ($500,000 for each individual) will be used as part of the
Loan to pay for "hard" constmction costs and other qualified development expenses in
accordance with the EB-5 Pilot Program guidelines.

The following chart summarizes the projected Source and Use of funds, and shows the
percentage participation in the Project for each funding source.

Source of Funds (in millions)

I

Use of Funds (in millions)

I

(b)(4)

34

562

 Construction
The following budget represents the total costs to complete the construction of the Project on the
Property. This includes projected construction costs to be funded with proceeds from the Senior
Construction Loan together with the proceeds of the Loan from the Funding Company. As
noted above, the Owner previously acquired the Property and paid for the costs related to
obtaining the entitlements on the Property all represented by the total Land Costs in the budget
below. All the Hard and Soft costs represented in the following budget are the projected future
costs. The budget has been prepared by the joint effort of the owners who have many years
experience in real estate development of similar projects. The cost used are based on current
local costs provided by industry suppliers, i.e steel, cement, plumbing, electric etc.

Construction Timeline
Based on the construction timetable provided by the Owners and Triton Construction, it will take
approximately 26 months for the Developer to complete the construction of the Building and
obtain a final Cetiificate of Occupancy. Important construction milestones include the
completion of the following:
•
•
•
•
•
•
•

Excavation~

February/March 2013
Concrete Foundation and Waterproofing -April20 13
Tower Building Construction begins April20 13
Tower Building Construction completed November 2013
Roofing and Tower Crane Areas February 2014
Interior Finishes- January 2015
Mechanicals, Electrical, Plumbing and Sprinkler Systems
February
2015
• Punch List and Temporary Certificate of Occupancy items April 2015
Funding will be provided by the Funding Company in one (1) Phase and up to three (3) Phases.

35

563

 Development Budget

 

 

 

 

36

564

Operating Assumptions

 

 

 

 

565

 Detailed Operating Projections

 

 

 

 

566

VII. Investment Structure
Description
The Project Ownership and Management a Joint Ownership between the KABR Group and Kushner
Companies (the "Owner") was formed in February 2012 for the purpose of acquiring and
developing the Project. The Management Company of the Owner is structured as follows:

88 Morgan Street, LLC

KABRGroup
Kushner Comoanies

Development Team
In Febmary of 2012, the KABR Group and Kushner Companies (the "Ownership") established a
Joint Venture to manage the entitlement, development, and operation of a 50 story rental apartment
building, consisting of 417 rental apartments, 217 parking spaces, and approximately 4,000sqft of
retail space adjacent to Trump Plaza I.
(b)(4)

Kushner Companies is a diversified real estate organization headquartered in New York with
extensive experience in the ownership, management, development, and redevelopment of
properties, owning over 13,000 multi-family apartments nationwide. Historically, the company has
developed, acquired and successfully managed over 30,000 apartments, half of which was sold to
AIG in 2007 fori

I

KABR Group is a diversified real estate investment company dedicated to the timely and
opportunistic purchase of real estate assets in the New York metro region. The group currently
owns and operates a diverse portfolio of properties in several states

38

567

 Regional Center
USlf as an approved EB-5 regional center within Bergen, Essex, Hudson, Middlesex, Monmouth,
Morris, Passaic and Union Counties in New Jersey will sponsor the project located within its
Territory.
The USIF will manage and oversee all operations and Project activities to ensure compliance with
all requirements through the design and execution of a database and reporting system that will
provide the following information on an annual basis to USCIS:
•

•

•

•
•

•

•

•
•
•

•

Maintain a current listing of the officials and point of contact for the management and
administration of the Project. This will include the USIF, the Management Company, the
Funding Company and the Owner.
Maintain a current list of approved methodologies to evaluate and track job creation in the
Project that resulted from the Loan and the use of the proceeds from the Qualified Investors
investment in the Funding Company.
Maintain an inventory of the name, date of birth, and alien registration number of each
Qualified Investor who makes an investment in the Funding Company and who files an EB5 Pilot Program I-526 Petition with USCIS, specifying whether the petition was approved,
denied, or withdrawn by the Qualified Investor/petitioner.
Maintain a current list of the country of nationality of each Qualified Investor who makes an
investment in the Funding Company and files an I-526 Petition with USCIS.
Maintain a current list of the U.S. municipality and state of residence of each Qualified
lnvestor who makes an investment in the funding Company and files an 1-526 Petition with
USC IS.
Maintain a listing of the categories of approved business activity within the geographic
Territory of the USIF that have received the Qualified Investor's capital, and in what
amounts.
Repmi the amounts invested by Qualified Investors and the amounts of other domestic
capital that have been invested together in each job created by virtue of the Loan from the
Funding Company to the Owner and distinguish between the separate totals for each.
Report to USCIS the aggregate number of approved EB-5 alien investor I-526 Petitions per
Federal Fiscal Year to date made through the USIF.
Report the aggregate number of approved EB-5 alien investor I-829 petitions per Federal
Fiscal Year to date through the USIF.
Report the aggregate EB-5 alien capital amount invested through the USIF with respect to
the Project for each Federal Fiscal Year to date since the approval and designation of the
USIF as a regional center.
Provide the combined aggregate of "new" direct and/or indirect jobs created by the Project
and the use of the capital invested by the Qualified Investors for each Federal Fiscal Year to
date since the approval and designation of the USIF as a regional center.

39

568

 IX.

I\larketing Plan to Attract Immigrant Investors

The Funding Company has created an extensive marketing program to attract Qualified
Investors. All marketing activities will be conducted exclusively outside the United States and
in compliance with Rule 502(c) of the Securities Act. USlF has previously executed successful
marketing plans to foreign immigrant investors under the EB-5 Pilot Program.
The Program to attract the Investment from Qualified Investors is summarized as follows:

(b)(4)

40

569

 (b)(4)

Economic Impact of Developing a Luxury Residential Tower as Part of the US
Immigration Fund-NJ, LLC, an EB-5 Regional Center, in the New Jersey
l\1etropolitan Area
Dr. Michael K. Evans, Ph. D. of Evans, Carroll & Associates, Inc. was engaged to calculate the
economic impact of this Project. The purpose of the Economic Report is to detennine the economic
benefit of the Project within the community of Hudson County and the USIF' s approved Territory.
·rhe Economic Report measures the economic impact of the 88 Morgan Street Project in tenns of:
•
•
•
•
•
•

Job Creation
Household Income
Demand for Business Services
Demand for Utility Services
Maintenance and Repair Construction
New Supplier/Vendor Relationships Created with Manufacturers
41

570

 ...

(b)(4)

XI.

As stated in the Economic Report, Dr. Evans uses the RIMS II input-output model to calculate job
creation for each categoty of economic activity. This model has been successfully used by Dr.
Evans in over 100 studies and has been approved in many earlier applications by USCIS. The
Economic Report contains the relevant information and analysis to establish that the Project will
crcaterlnew permanent jobs, which is greater than the minimum number of jobs required under
thcE~gram.

Summary and Conclusion
Based on the extensive data and research contained in this Business Plan, it is recommended that the
Project, located in the USIF's approved Territory, be approved as a USCIS EB-5 Pilot Program
Project. Recommendation for this approval is based on the following strengths:

•

The 88 Morgan Street Project creates the required number of permanent jobs. The
Economic Report uses construction spending to rea liz~
new direct, indirect and
induced jobs from construction and operations of the Project.

•

The Project is located within a Targeted Employment Area so conditional and (b)(4)
permanent residency can be pursued with an investment of $500,000 rather than
$1,000,000.

•

The Loan is intended to be repaid within years, subject to USC IS restrictions that
may delay repayment based upon the finalization of the I-829 petition process for the
Qualified Investors. The investment by each Qualified Investor is fully at risk.

•

The Funding Company will have a Secured Lien on all the 88 Morgan Street
Property and improvements junior only to the senior bank financing.

•

In closing, it is clear that the Project to be constructed in Jersey City, New Jersey, strongly
promotes economic growth, improves regional productivity, creates a significant level of
jobs and will attract increased domestic and foreign capital into the area it serves. For these
reasons, the Project will make a quality USCIS EB-5 Pilot Program Project.

I

0

42

571

 I.

Contact Information
Attention: Nicholas A. Mastroianni, II
U.S. Immigration Fund GP- 88 Morgan Street, LLC
U.S. Immigration Fund- NJ, LLC
I 295 US Highway One, Suite 300
No11h Palm Beach, Florida 33408
Phonc:(561)799-1883
Fax: (561) 799-0061
lnfo@USIFund.com

43

572

 EXHIBIT NAME
Economic Analysis of Job Creation of the 88 Morgan Street Project by
Evans, Carroll & Associates dated December 7, 2012 (RIMS II
methodology).

TAB
NUMBER
20.

573

 1

Economic Impact of Developing a Luxury Apartment Building
Located in Jersey City, NJ, for the US Immigration Fund, LLC
and its New EB-5 Regional Center in Northern New Jersey

Prepared for:
The U. S. Immigration Fund

Prepared by:
Michael K. Evans
Evans, Carroll & Associates, Inc.
2785 NW 26th St.
Boca Raton, FL 33434
561-470-9035
mevans@evanscarrollecon.com

December 7, 2012

574

 2

Table of Contents
1. Executive Summary

3

2. Tabulation of Principal Results

4

3. Introduction and Scope of Work

8

4. Brief Introduction to the RIMS II Model and its Multipliers

9

5. Methodology for Calculating Indirect Jobs

12

6. Economic Parameters for 8 Counties in New Jersey

17

7. Location of Hotel, Maps of Area, and TEA Analysis

32

8. Economic Impact of Construction Activity

36

9. Economic Impact of Rental Income

45

10. Summary Statistics for Entire Project

51

Appendix: Resume of Dr. Michael K. Evans

53

575

 3

1. Executive Summary
• The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space.

(b)(4)

• The economic impact results are calculated using the RIMS II input/output model for
the following 8 counties in New Jersey: Hudson, Essex, Union, Bergan, Passaic,
Morris, Monmouth, and Middlesex. These counties are chosen based on commuting
patterns, as explained later in this report.

576

 4

2. Tabulation of Principal Results
Table A shows the annual revenue, the final demand multiplier, and the total
number of jobs created by the construction and operations of the apartment building.
Since the construction will take more than two years, the economic impact figures for
the hard construction costs and appropriate soft costs include direct as well as indirect
and induced jobs. All figures are permanent jobs.
(b)(4)

Table A. Summary of Employment and Revenue Estimates

Table 81 shows the NAICS codes for each type of economic activity.
descriptions are taken from:
htJ:P :1/www. census .govleg i-bi n/sssd/naics/naicsrch?chart=20 12

The

Table B1. NAICS Codes for Each Type of Activity
2362 _Nonresidential Building Construction
2361_Residential Building Construction
53111_Lessors of Residential Buildings and Dwellings
5413_Architectural, Engineering, and Related Services

Table B-2 shows the print screen of all the RIMS II multipliers used in this study.
Please note that for purchases of FF&E, the multiplier used is the construction multiplier
excluding direct jobs, calculated asl
I
(b)(4)

577

 5
Table 82. Print Screen of Multipliers

(1)

230000 Construction
531000 Real estate
541300 Architectural, engineering, and related services
812900 Other personal services

(2)

(5) (6)
(4)
2.0346 0.5600 11.7739 1.1005 1.80511.9882
1.4670 0.2244 13.2613 1.0810 1.9496 1.2985
1.9921 0.5483 10.2148 1.2297 1.8728 2.5874
1.8509 0.3285 9.0272 1.09512.8866 2.7787
(3)

Region Defimtion Befgen, NJ; Essex, NJ; Hudson. NJ; MiddleseJI:, NJ; Monmouth, NJ; Morris, NJ: Passaic, NJ; Umon, NJ
·lndudes Government enterprises.
1. Each entry in column 1 represents the total dollar change in output that occurs m all mdustries lor each additional doiJar of output delivered to
!mal demand by the 1ndustry corresponding to the ent!)'
2. Each entry 111 column 2 represents the total dollar change in earnings of households employed by all induslrtes for each additional doHar of
delivered to fmal demand b')t the industry corresponding to the entry
entry m column 3 represents the total change 111 number of JObs that occurs m a!! industnes lor each addil!onal1 million dollars of output
3
delivered to ftrml demand by the mduslry corresponding to the entry. Because the employment multipliers are based on 2008 data, the output
delivered to final demand should be in 2008 dollars
.+. Each entry in column 4 represents the total dollar change in value added that occurs in all industries for each additional dollar of output
delivered to final demand by the industry corresponding to the en!!)'.
5. Each entry 1r1 column 5 represents the total dollar change tn earnings of households employed by ali industries for each additional dollar of
paid d1rect!y to households employed by the mdustry corresponding to the entry
entry 10 column 6 represents the total change in number of Jobs 1r1 all mdustnes for each addrtiooaljob in the rndustry correspond111g to
6
the entr;
NOTE.--Mult1pliers are based on the 2002 Benchmark lnpu!-Oulput Table for the Nation and 2008 regional data. Industry list A identifies the
rndustnes correspondmg to the enlnes.
SOURCE.-Regionallnput-Output Modelmg System (RIMS II), Regional Product Div1sion, Bureau of Econom1c Analysis

Table C shows the annual level of household income, and the output for utilities,
maintenance and repair construction, manufacturing output, and professional and
business support services for the construction and operation of the 88 Morgan Street
apartment building.
(b)(4)

Table C. Summary Measures of Economic Impact for Construction and
Rental income of 88 Morgan Street Apartment Building

578

 6

Household Earnings (Labor Income)

The jobs created by the project subsequently create new sources of household
income. The household income created within the re ional center by the construction of
the 88 Morgan Street apartment buildin ·
with another I
I
from the purchases of FF&E and
rom architectural and engineering
services. Household income would a so nse a outl
Ifrom the rental income
of the apartments, for a total of aboutl
I

(b)(4)

The details used to calculate these figures are given throughout the report.
Separate tables are provided for the total number of jobs created, the average earnings
per new worker, and the total increase in earnings for construction and operation of the
hotel. In each case, the RIMS II input/output model has been used to calculate the
number of jobs in each major industrial classification, the average earnings per
employee, and hence total earnings. The number of jobs by industrial classification is
based on calculations imbedded in the RIMS II model for each of the activities as
summarized in Table A and documented in detail throughout this report.
Demand for Business Services, Utilities, Maintenance and Construction, and New
SupplierNendor Relationships Created with Manufacturers

(b)(4)

The total economic impact of the regional center from the supplier purchases and
business relationships for the construction and operation of the hotel will create
approximately I
lin additional economic activity across the region for the
project. These supplier purchases are calculated from the indirect increase in output
generated by the RIMS II model. It should be noted that some of these supplier
industries might potentially locate within the regional center, and their economic output
is included in this total.
The estimate of supplier purchases is based on the commodity data in the RIMS
II input-output model. This data specifies the amount and type of commodity input
needed to maintain specific types of business operations. The model estimates the
supplier purchases based on the types of jobs and number of jobs that will be created
within the regional center. In addition, the model allocates the supplier purchases to
businesses within the region, based on trade flow data from the U.S. Bureau of
Economic Analysis.
Utilities include services such as electricity, natural gas, and water and sewer
facilities. The economic impact on utility services total abo uti
respectively.
Most of this represents the use of utilities by occupants of the apartments.
(b)(4)

I

Maintenance and repair services include some building and construction activity
uildings. The regional center would create an economic impact of about
These expenditures represent permanent, ongoing maintenance on the
g
r they are completed; they do not reflect the initial construction costs.

579

 7

New supplier/vendor relationships with manufacturers would create an economic
impact of about
Most of this output represents purchases of locally
produced materials and parts for the construction of the building; some of these
expenditures are the purchase of locally produced supplies for the hotel.

I

(b)(4)

I

The regional center will also create demand for various types of business
services, including professional and scientific services, management of companies,
administrative services, and building support and waste management services. The
impact of this activity totals about
Most of this represents payments to
architects and engineers for the construction activities; it also includes outsourcing of
professional service activities for operating the hotel, such as lawyers and accountants.

I

I

The figures given in Table C represent only a brief summary of the detailed
calculations that have been undertaken and are reported in tabular format throughout
the report. The figure for utility output, for example, represents the sum of utility output
for each of the categories of economic activity listed in Table A. For repair and
maintenance construction office, this figure represents the l;mount s~ent times he
input/output coefficient showing the total amount of output per
f construction
expenditures. The same methodology applies to all the other 1gures g1ven in Table C.
Detailed figures may be found in the tables in Sections (8) and (9), which provide
estimates of indirect jobs by industry category.

580

 8

3. Introduction and Scope of Work
The U.S. Immigration Fund, LLC plans to open a new EB-5 regional center in
northern New Jersey. The first project will be a luxury apartment building located at 88
Morgan Street in Jersey City, NJ. The building will have 417 apartment units, 214
parking spaces, and about 4,000 square feet of retail space. This report contains the
economic impact results for the construction of the building and apartment rentals,
based on the RIMS II input/output model for the following 8 counties in New Jersey:
Hudson, Essex, Union, Bergan, Passaic, Morris, Monmouth, and Middlesex.
Section (4) contains a brief description of the RIMS II models and its various
multipliers, and Section (5) contains additional information explaining how the indirect
jobs are calculated. Section (6) contains and analyzes the key statistics for the sixcounty area used to calculate the RIMS II multipliers. Tables 6-1, 6-2, 6-3 and 6-4 show
the data for employment by major occupation and industrial classification, income
distribution by deciles, mean and median household and family income, and poverty
rates for the eight counties used to calculate the multipliers for this study, and compares
these figures to the U.S. totals or averages.
Table 6-5 shows key labor market statistics over the past decade for the State of
New Jersey, each of these counties, and the 8-county total. Tables 6-6 and 6-7 show
the level and growth rate of population and personal income for these same areas.
Table 6-8 shows the commuting patterns for Hudson County, and explains how these
figures are used to determine the counties included in the multiplier analysis. Section
(7) contains a map of the location of the building and maps of the area.
Section (8) presents the economic impact tables for the hard construction costs,
EB-5 eligible soft construction costs, and purchases of FF&E. Separate sets of tables
are presented for each category of construction for the increase in employment, output,
and earnings, and the average level of output and earnings per new worker, for the 20
major industrial classifications in the RIMS II input/output model. Section (9) discusses
the number of jobs and revenue estimates for the rental income from the apartments,
retail space, and parking, and presents similar tables for the detailed industry results.
Section (10) summarizes the RIMS II model results.

581

 9

4. Brief Guide to RIMS II Input/Output Model
The following material has been condensed from the RIMS II User Handbook.
Introduction and General Comments

Effective planning for public- and private-sector projects and programs at the
State and local levels requires a systematic analysis of the economic impacts of these
projects and programs on affected regions. In turn, systematic analysis of economic
impacts must account for the inter-industry relationships within regions because these
relationships largely determine how regional economies are likely to respond to project
and program changes. Thus, regional input-output (1-0) multipliers, which account for
inter-industry relationships within regions, are useful tools for conducting regional
economic impact analysis.
In the 1970s, the Bureau of Economic Analysis (BEA) developed a method for
estimating regional 1-0 multipliers known as RIMS (Regional Industrial Multiplier
System), which was based on the work of Garnick and Drake. In the 1980s, BEA
completed an enhancement of RIMS, known as RIMS II (Regional Input-Output
Modeling System), and published a handbook for RIMS II users.
In 1992, BEA
published a second edition of the handbook in which the multipliers were based on
more recent data and improved methodology. In 1997, BEA published a third edition of
the handbook that provides more detail on the use of the multipliers and the data
sources and methods for estimating them.
RIMS II is based on an accounting framework called an 1-0 table. For each
industry, an 1-0 table shows the industrial distribution of inputs purchased and outputs
sold. A typical 1-0 table in RIMS II is derived mainly from two data sources: BEA's
national 1-0 table, which shows the input and output structure of nearly 500 U.S.
industries, and BEA's regional economic accounts, which are used to adjust the national
1-0 table to show a region's industrial structure and trading patterns.
Using RIMS II for impact analysis has several advantages. RIMS II multipliers
can be estimated for any region composed of one or more counties and for any industry,
or group of industries, in the national 1-0 table. The accessibility of the main data
sources for RIMS II keeps the cost of estimating regional multipliers relatively low.
Empirical tests show that estimates based on relatively expensive surveys and RIMS 11based estimates are similar in magnitude.
BEA's RIMS multipliers can be a cost-effective way for analysts to estimate the
economic impacts of changes in a regional economy. However, it is important to keep in
mind that, like all economic impact models, RIMS provides approximate order-ofmagnitude estimates of impacts. RIMS multipliers are best suited for estimating the
impacts of small changes on a regional economy. For some applications, users may
want to supplement RIMS estimates with information they gather from the region
undergoing the potential change. To use the multipliers for impact analysis effectively,

582

 10
users must provide geographically and industrially detailed information on the initial
changes in output, earnings, or employment that are associated with the project or
program under study. The multipliers can then be used to estimate the total impact of
the project or program on regional output, earnings, and employment.
RIMS II is widely used in both the public and private sector. In the public sector,
for example, the Department of Defense uses RIMS II to estimate the regional impacts
of military base closings. State transportation departments use RIMS II to estimate the
regional impacts of airport construction and expansion. In the private-sector, analysts
and consultants use RIMS II to estimate the regional impacts of a variety of projects,
such as the development of shopping malls and sports stadiums.

RIMS II Methodology
RIMS II uses SEA's benchmark and annual 1-0 tables for the nation. Since a
particular region may not contain all the industries found at the national level, some
direct input requirements cannot be supplied by that region's industries. Input
requirements that are not produced in a study region are identified using SEA's regional
economic accounts.
The RIMS II method for estimating regional 1-0 multipliers can be viewed as a
three-step process. In the first step, the producer portion of the national 1-0 table is
made region-specific by using six-digit NAICS location quotients (LQs). The LQs
estimate the extent to which input requirements are supplied by firms within the region.
RIMS II uses LQs based on two types of data: SEA's personal income data (by place of
residence) are used to calculate LQs in the service industries; and SEA's wage-andsalary data (by place of work) are used to calculate LQs in the non-service industries.
In the second step, the household row and the household column from the
national 1-0 table are made region-specific. The household row coefficients, which are
derived from the value-added row of the national 1-0 table, are adjusted to reflect
regional earnings leakages resulting from individuals working in the region but residing
outside the region. The household column coefficients, which are based on the personal
consumption expenditure column of the national 1-0 table, are adjusted to account for
regional consumption leakages stemming from personal taxes and savings. In the last
step, the Leontief inversion approach is used to estimate multipliers. This inversion
approach produces output, earnings, and employment multipliers, which can be used to
trace the impacts of changes in final demand on and indirectly affected industries.

Advantages of RIMS II
There are numerous advantages to using RIMS II. First, the accessibility of the
main data sources makes it possible to estimate regional multipliers without conducting
relatively expensive surveys. Second, the level of industrial detail used in RIMS II helps
avoid aggregation errors, which often occur when industries are combined. Third, RIMS
II multipliers can be compared across areas because they are based on a consistent set

583

 11
of estimating procedures nationwide. Fourth, RIMS II multipliers are updated to reflect
the most recent local-area wage-and-salary and personal income data.

Overview of Different Multipliers
RIMS II provides users with five types of multipliers: final demand multipliers for
output, for earnings, and for employment; and direct-effect multipliers for earnings and
for employment. These multipliers measure the economic impact of a change in final
demand, in earnings, or in employment on a region's economy.
The final demand multipliers for output are the basic multipliers from which all
other RIMS II multipliers are derived. In this table, each column entry indicates the
change in output in each row industry that results from a $1 change in final demand in
the column industry. The impact on each row industry is calculated by multiplying the
final demand change in the column industry by the multiplier for each row. The total
impact on regional output is calculated by multiplying the final demand change in the
column industry by the sum of all the multipliers for each row except the household row.
RIMS II provides two types of multipliers for estimating the impacts of changes
on earnings: final demand multipliers and direct effect multipliers. These multipliers are
derived from the table of final demand output multipliers.
The final demand multipliers for earnings can be used if data on final demand
changes are available. In the final demand earnings multiplier table, each column entry
indicates the change in earnings in each row industry that results from a $1 change in
final demand in the column industry. The impact on each row industry is calculated by
multiplying the final demand change in the column industry by the multipliers for each
row. The total impact on regional earnings is calculated by multiplying the final demand
change in the column industry by the sum of the multipliers for each row.

Employment Multipliers
RIMS II provides two types of multipliers for estimating the impacts of changes
on employment: final demand multipliers and direct effect multipliers. These multipliers
are derived from the table of final demand output multipliers.

(b)(4)

The final demand multipliers for employment can be used if the data on final
demand changes are available. In the final demand employment multiplier table, each
column entry indicates the change in employment in each row industry that results from
~
l;hange in final demand in the column industry. The impact on each row
industry is calculated by multiplying the final demand change in the column industry by
the multiplier for each row. The total impact on regional employment is calculated by
multiplying the final demand change in the column industry by the sum of the multipliers
for each row.

584

 12

The direct effect multipliers for employment can be used if the data on the initial
changes in employment by industry are available. In the direct effect employment
multiplier table, each entry indicates the total change in employment in the region that
results from a change of one job in the row industry. The total impact on regional
employment is calculated by multiplying the initial change in employment in the row
industry by the multiplier for the row.

Choosing a Multiplier
The choice of multiplier for estimating the impact of a project on output, earnings,
and employment depends on the availability of estimates of the initial changes in final
demand, earnings, and employment. If the estimates of the initial changes in all three
measures are available, the RIMS II user can select any of the RIMS II multipliers. In
theory, all the impact estimates should be consistent. If the available estimates are
limited to initial changes in final demand, the user can select a final demand multiplier
for impact estimation. If the available estimates are limited to initial changes in earnings
or employment, the user can select a direct effect multiplier.

5. Methodology for Calculating Indirect Job Gains

In spite of the explanation of the RIMS II model given directly above, some
USC IS adjudicators have asked for further clarification about how that model is used to
determine the increase in the number of indirect jobs. That is an important issue
because, unlike the direct job count, which can be verified by USCIS from various
payroll and withholding documents, the calculation of indirect jobs cannot be verified
directly but depends on mathematical calculations.
The general concept is based on the coefficients in the input/output model itself
(the same methodology applies to RIMS II, IMPLAN, or any other generally recognized
and accepted input/output model). In any given year, the government calculates how
much input is used for a given production of output. The detailed figures are taken from
the Economic Censuses taken once every five years; the figures are then updated from
various annual supplements.
Basically the process has two steps, each of which is described next in greater
detail. The first is to determine the amount of output, and hence the number of jobs,
required to produce a given amount (say $1 million) of the final product or service.
These are national coefficients. The second is to determine what proportion of those
goods and services are purchased within the local region (the regional purchase
coefficients, or RPCs).
In the case of a manufacturing process, the national coefficients are based on
production functions: how much coke per ton of steel, how much steel per motor
vehicle, how much flour for a loaf of bread, and so on. However, most of the jobs are

585

 13
created in the service sector, where Commerce Department data are used to determine,
for example, how much restaurants spend on laundry services, how much airlines
spend for attorneys, and so on. These figures are based on information contained in
the various Economic Censuses. The national coefficients would also determine, for
example, how many architects and engineers would be hired for a construction project
of a given scope and size, and how many new employees at financial institutions would
be required to handle the additional cash flow generated by the new business. Both of
these are discussed below in greater detail.
Even after these coefficients are determined, however, the regional purchase
coefficients (RPC) must still be estimated. If, for example, a trucking firm spends 1% of
its revenue on accountants, how much of that money is spent on local firms, and how
much is spent outside the region?
That answer depends on various factors. The most important is the amount of
the good or service produced within the region. If a trucking firm, for example, were
located in a small county with no accountants, obviously it would not spend any of that
money locally. That sets a lower limit but is not generally the case. Instead, a
balancing algorithm is used.
Suppose, for example, that all the firms producing, distributing, or selling goods
and services in a given county spent $10 million on accounting services.
Also,
suppose that total billings of all accountants in the county were $20 million. In that
case, local accountants could handle all the local business, plus business from
neighboring counties. If, on the other hand, total accountant billings in the county were
only $5 million, local firms could not spend more than half of the money on local
accountants.
Of course it is possible that there are adequate resources in the county but local
firms choose to use companies outside the county; perhaps prices or service is better.
No input/output model can account for such anomalies. On the other hand, given
transportation costs, it would be highly unusual for a firm to be located in a given
location and not serve the nearby businesses, instead choosing only those clients who
were farther away.
The RIMS II model- and other regional input/output models- assigns regional
purchase coefficients (RPCs) in all cases where the local industry purchases goods and
services from local firms. This matrix could have as many as 406 * 406 = 164,836
elements, although in practice many of them are zero. Large counties with a wide
variety of businesses have more non-zero elements than small counties with relatively
few businesses.
In general, the RPCs tend to be close to zero for most manufactured goods, and
close to unity for most services. While there are many exceptions to this rule, most
firms will use financial, professional, business, and health care services that are located
in that county or contiguous areas.

586

 14
To take just one example of many, consider the number of new jobs created by
architects and engineers for a new construction project of any given size. Most
construction cost manuals, such as those published by R. S. Means, indicate that those
costs are usually about 5% to 9% of the total job. According to the national input/output
file, the figures are 9.2% for commercial construction and 4.5% for industrial
construction.
These figures can be compared with the proportions of architects and engineers
in the specific regional area, based on the RIMS II data that are used to determine the
economic multipliers in the specific county group. For this 8-county group, the
input/output model shows proportions of 8.4% for commercial and 4.3% for industrial
construction, indicating that 91% of the architects and engineers for commercial jobs
and 95% for industrial jobs are hired locally. These figures are fairly typical of other
locations and regions; except for "signature" buildings designed by famous names, most
architects and engineers live in the same region as the buildings that are being
constructed.
To summarize to this point, the number of indirect jobs as a proportion of direct
jobs depends on (a) the national relationships, and (b) the regional purchase
coefficients. In our presentation for the businesses in this report, we provide further
discussion of those industries with the largest number of indirect jobs. However, there
are a few industries that produce relatively large numbers of jobs in almost all cases,
and these can be generally discussed at this stage in order to avoid repeating this
information several times. The industries discussed here include banking, real estate,
legal and accounting, architects and engineers, other professional services,
employment services, other business services, restaurants, and government. In all of
these cases, the vast majority of workers are hired locally. Our comments for the rest of
this section are based on the assumption of a $10 million investment; the results are
linear.
Banking and credit: On an aggregate basis, for every $10 million in deposits,
very broadly defined (M3), there is about 1 new banking employee. As a rough rule of
thumb, the size of M3 is roughly equal to the size of GOP. Hence we would expect
about 1 new banking employee for every $10 million increase in output, as calculated
from the RIMS II model.

(b)(4)

Real estate: Additional real estate employees are based on two factors. One is
the leasing activity of the new building, and the other is the increase in residential real
estate activity as people get new jobs, either within the area or by moving into the area.
On a lease basis, a $10 million investment is likely to result in a building of 80,000
square feet. If it leases for $40/square foot, that would be $3.2 million in annual lease
payments, and with a 6% commission would generate $192,000 in revenues, which
would account for about 2 new real estate employees (the figure would be less for
industrial buildings). The increase in employment would also result in some real estate
activity as workers moved into better housing in the same location, or moved in from
other areas. In a normal year, there are about 7 million sales of new and existing
homes for a labo~ of about 140 million, or 5%. Hence if the total increase in
employment wert__Jthat would implyOal estate transactions; if they average

587

 (b)(4)

15

$200,000 at a 6% commission, that would be $12,000 per home or a total of $120,000,
which would support approximately 1 new real estate job.
Legal & Accounting: Each of these accounts for about 1% of total employment;
so if there were a total increase Qobs, we would expect an average of[}ew
employees in this classification.
Architects & Engineers: almost all of these jobs stem from the new construction
activity. This category has alrea~y been discussed above; for a $10 million construction
project, which would create abo
w construction jobs, we would expect abon
new jobs in architects and engineers for a commercial project and
Jw jobs for~
industrial project.

I

I

Other professional services: This category includes employees in consulting,
scientific research and development, advertising, and management, as well as several
other smaller, specialized categories. In general, consulting, management, and the all
other category each account for about 1% of total employment, and R&D and
advertising account for about %% of total employment, for a total of about 4% of total
employment. This figure will vary widely depending on the degree to which consultants
and R&D are used by the new business.
Employment services: On a national average basis, 1 out of every 45 people is
employed by this industry. Here again, the figures will vary widely depending on (a) the
proportion of people who are hired through employment agencies, and (b) the
proportion of the work that is outsourced to employment services.
Business support services include office management, travel arrangement,
security, credit bureaus, telemarketing, and back-office jobs that are outsourced, such
as direct mail, copying, and duplicating services. The back-office services would vary
widely depending on the type of new business; retail stores, for example, would print
and distribute more advertising brochures than a manufacturing operation. On a
national average basis, these jobs account for about 2% of total employment.
Building support services, which includes janitorial services, lawn maintenance,
and waste management. For an office building of 80,000 square feet, the cost would be
approximately $2/sq ft per year for maintenance, or $160,000, which would support
about 4 new jobs; here again, the figure would be lower for industrial buildings.
Restaurants: This category reflects business meals. Of course the number of
business meals depends greatly on the type of business; lawyers, accountants, and
consultants will have more business meals than manufacturing plants or water
treatment facilities. On a national average basis, Commerce Department figures show
that total restaurant sales in 2007 were $580 billion, while consumer expenditures at
restaurants were $500 billion. However, that figure also includes tips, which are not
included in restaurant sales. After subtracting 15% for tips, that indicates about $425
billion in food and beverage purchases by consumers, indicating about $155 billion for
business expenses. With a labor force of approximately 140 million, that is equivalent
to about $1,100 per employee. Hence if 200 new jobs were created, business meal

588

 16

expenses would rise an average of $221,000, which would imply about 4.5 new indirect
jobs in the restaurant industry. These figures are likely to be somewhat higher when
direct jobs are created for office buildings and hotels.
Government: The increase in public sector employees represents the amount
funded by increased real estate taxes. For a construction project with $10 million in
hard costs, the total value is likely to be between $15 and $20 million when one includes
furniture, fixtures, equipment, and land values. Using a national average property tax
~ate of 1%; that would raise $150,000 to $20o,oqg}(~hich would createc:J new jobs
m the public sector.

589

 17

6. Economic Parameters for Hudson, Essex, Union, Bergen, Passaic,
Morris, Middlesex, and Monmouth Counties
This section is organized as follows. Tables 6-1, 6-2, 6-3 and 6-4 show the data
for employment by major occupation and industrial classification, income distribution by
deciles, mean and median household and family income, and poverty rates for the eight
counties used to calculate the multipliers for this study, and compares these figures to
the U.S. totals or averages. Table 6-5 shows key labor market statistics over the past
decade for the State of New Jersey, each of these counties, and the 8-county total.
Tables 6-6 and 6-7 show the level and growth rate of population and personal income
for these same areas. Table 6-8 shows the commuting patterns for Hudson County,
and explains how these figures are used to determine the counties included in the
multiplier analysis.
Table 6-1. Key Economic Statistics for Hudson and Counties Compared to the U.
S. Economy, 2010 Data
Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
1--Unemployed
Armed Forces
Not in labor force

Essex

%

Hudson

%

u.s.

%
100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

612,565
400,770
400,523
344,146
56,377
247
211,795

100.0%
65.4%
65.4%
56.2%
9.2%
0.0%
34.6%

520,559
359,487
359,408
312,480
46,928
79
161,072

100.0%
69.1%
69.0%
60.0%
9.0%
0.0%
30.9%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

OCCUPATION
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production & transportation

344,146
128,336
70,110
83,284
24,850
37,566

100.0%
37.3%
20.4%
24.2%
7.2%
10.9%

312,480
118,514
54,500
75,993
22,231
41,242

100.0%
37.9%
17.4%
24.3%
7.1%
13.2%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs

344,146
839
19,412
21,063
8,192
33,180
24,477
11,875
31,756
44,064
89,318
25,779

100.0%
0.2%
5.6%
6.1%
2.4%
9.6%
7.1%
3.5%
9.2%
12.8%
26.0%
7.5%

312,480
88
17,452
25,036
12,919
31,641
24,887
10,909
34,463
42,737
60,295
23,187

100.0%
0.0%
5.6%
8.0%
4.1%
10.1%
8.0%
3.5%
11.0%
13.7%
19.3%
7.4%

139,033,928
2,646,975
8,686,813
14,439,691
3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%

590

 18
Other private services
Public administration

17,380
16,811

5.1%
4.9%

16,461
12,405

5.3%
4.0%

6,913,449
7,187,193

5.0%
5.2%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)

275,417
28,243
16,478
28,288
25,719
32,635
44,176
31,262
32,280
14,778
21,558
52,394
80,167

100.0%
10.3%
6.0%
10.3%
9.3%
11.8%
16.0%
11.4%
11.7%
5.4%
7.8%

238,692
19,411
14,462
24,152
20,533
29,768
44,776
26,814
31,304
11,757
15,715
54,817
76,339

100.0%
8.1%
6.1%
10.1%
8.6%
12.5%
18.8%
11.2%
13.1%
4.9%
6.6%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

Families
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)
Mean family income (dollars)
Per capita income (dollars)

175,731
12,211
6,627
15,282
15,561
19,250
26,811
21,661
25,935
13,439
18,954
66,439
97,237
29,674

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609
79,338
26,059

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

Median earnings for workers
Median earnings for male full-time
Median earnings for female full-time

32,961
49,597
41,317

104.7%
117.4%

100.0%
6.9%
3.8%
8.7%
8.9%
11.0%
15.3%
12.3%
14.8%
7.6%
10.8%
109.6'/(,
122J.i%

113.9%
114.1%

106.791)
113.0%

147,709
8,382
7,409
14,311
12,795
20,209
27,360
16,708
21,969
8,032
10,534
57,978
81,559
29,798
35,677
50,563
41,173

109,5%
111.8%

100.0%
5.7%
5.0%
9.7%
8.7%
13.7%
18.5%
11.3%
14.9%
5.4%
7.1%
95.7%
102-8%
114.3%
123.5~'{

108.7%
112,6~1)

28,899
46,500
36,551

PERCENTAGE BELOW POVERTY LEVEL
13.9% 1230%
13.7% 12Uo/.
11.3%
All families
15.3%
16.7% l()ZU%
16.5% 107.8%
All people
Please note that in these tables, the percentage figures in regular type refer to the overall category in
that column, while the figures in
are relative to the U.S. average figures

The income distributions in Essex and Hudson Counties can best be described
as "fat.tailed", with greater than average percentages in the highest and lowest income
brackets. To elaborate, 11% of families in each of the two counties earn less than
$15,000 a year, compared to 8% nationally - while 11% of Essex families and 7% of
Hudson families earn $200,000 or more, compared to 5% for the U.S. This dichotomy
can also be seen in the high mean household incomes ($80K in Essex and $76K in

591

 19
Hudson, versus $68K for the U.S.) and large share of families living in poverty (14% in
each county, versus 11% for the nation).
Turning to the occupation data, both counties have lower than average shares in
manufacturing as well as the arts, entertainment, hotel, and food service industries and higher than average shares in transportation and finance. The counties differ in the
mix of workers in the education and health care industries, as Essex (26%) has a higher
proportion than average and Hudson has a lower proportion at 19% - the smallest of
the five counties.

Table 6-2. Key Economic Statistics for Union and Bergen Counties Compared to
the U. 5. Economy
Category

Union

u.s.

%

Bergen

%

420,828

100.0%

727,196

100.0%

243,832,923

100.0%

291,604

69.3%

478,944

65.9%

156,966,769

64.4%

291,560

69.3%

478,892

65.9%

155,917,013

63.9%

255,497

60.7%

438,302

60.3%

139,033,928

57.0%

Unemployed

36,063

8.6%

40,590

5.6%

16,883,085

6.9%

Armed Forces

44

0.0%

52

0.0%

1,049,756

0.4%

129,224

30.7%

248,252

34.1%

86,866,154

35.6%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

Management & professional

90,913

35.6%

201,513

46.0%

49,975,620

35.9%

Service occupations

43,165

16.9%

55,159

12.6%

25,059,153

18.0%

Sales and office occupations

62,273

24.4%

114,453

26.1%

34,711,455

25.0%

Construction, maintenance, repair

22,283

8.7%

28,908

6.6%

12,697,304

9.1%

Production & transportation

36,863

14.4%

38,269

8.7%

16,590,396

11.9%

255,497

100.0%

438,302

100.0%

139,033,928

100.0%

177

0.1%

919

0.2%

2,646,975

1.9%

8,686,813

6.2%

EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed

Not in labor force

%

2010

OCCUPATION
Civilian employed population 16+

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction

17,557

6.9%

24,897

5.7%

Manufacturing

24,870

9.7%

40,015

9.1%

14,439,691

10.4%

Wholesale trade

10,869

4.3%

19,216

4.4%

3,941,066

2.8%

Retail trade

25,990

10.2%

47,458

10.8%

16,203,408

11.7%

Transportation & utilities

18,211

7.1%

22,703

5.2%

6,843,579

4.9%

7,394

2.9%

16,169

3.7%

3,015,521

2.2%

Information

592

 20
Finance, insurance, & real estate

21,793

8.5%

45,159

10.3%

9,275,465

6.7%

Professional & administrative

29,021

11.4%

58,730

13.4%

14,710,089

10.6%

Educational services & health care

53,596

21.0%

99,084

22.6%

32,311,107

23.2%

6.5%

12,859,572

9.2%

Arts, entertain, hotel, food svcs

19,342

7.6%

28,699

Other private services

13,531

5.3%

20,540

4.7%

6,913,449

5.0%

Public administration

13,146

5.1%

14,713

3.4%

7,187,193

5.2%

Total households

183,882

100.0%

333,002

100.0%

114,567,419

100.0%

Less than $10,000

10,740

5.8%

15,136

4.5%

8,757,190

7.6%

$10,000 to $14,999

6,138

3.3%

12,370

3.7%

6,668,865

5.8%

$15,000 to $24,999

15,300

8.3%

24,587

7.4%

13,165,380

11.5%

$25,000 to $34,999

14,321

7.8%

23,753

7.1%

12,323,322

10.8%

10.0%

16,312,385

14.2%

INCOME AND BENEFITS

$35,000 to $49,999

23,549

12.8%

33,430

$50,000 to $74,999

31,943

17.4%

53,157

16.0%

20,940,859

18.3%

$75,000 to $99,999

21,678

11.8%

40,999

12.3%

13,526,500

11.8%

$100,000 to $149,999

31,378

17.1%

56,634

17.0%

13,544,839

11.8%

$150,000 to $199,999

11,796

6.4%

34,456

10.3%

4,809,998

4.2%

$200,000 or more

17,039

9.3%

38,480

11.6%

4,518,081

3.9%

Median household income (dollars)

66,665

133.2%

77,389

154.6%

50,046

94,659

138 . 731,

105,488

131,811

100.0%

236,574

100.0%

76,089,045

100.0%

6,001

4.6%

6,237

2.6%

3,824,251

5.0%

2.1%

2,660,781

3.5%

Mean household income (dollars)

Families
Less than $10,000

68,259

$10,000 to $14,999

2,973

2.3%

4,959

$15,000 to $24,999

8,903

6.8%

11,365

4.8%

6,770,812

8.9%

$25,000 to $34,999

8,224

6.2%

12,914

5.5%

7,332,318

9.6%

$35,000 to $49,999

15,365

11.7%

19,255

8.1%

10,578,051

13.9%

$50,000 to $74,999

23,157

17.6%

36,079

15.3%

14,990,631

19.7%

$75,000 to $99,999

15,838

12.0%

29,860

12.6%

10,638,931

14.0%

$100,000 to $149,999

25,630

19.4%

49,242

20.8%

11,261,766

14.8%

$150,000 to $199,999

10,400

7.9%

31,650

13.4%

4,130,868

5.4%

$200,000 or more

15,320

11.6%

35,013

14.8%

3,900,636

5.1%

Median family income (dollars)

77,361

127.6%

97,394

160.7%

60,609

107,812

135.9'7~

123,384

155.5%

79,338

Per capita income (dollars)

33,267

12/.J'/i,

39,409

1512')1;

26,059

Median earnings for workers

35,214

121.9%

44,350

1.53.5 1?~

28,899

Median earnings for male full-time

51,195

110.1%

63,074

1356%)

46,500

Median earnings for female full-time

43,496

119.0'){

51,103

139.1:\%

36,551

Mean family income (dollars)

593

 21

PERCENTAGE BELOW POVERTY LEVEL
All families

8.70%

77,0%

5.6%

49,6'%

11.30%

All people

11.10%

77
CC''
'..;,.,,,.;}<.)

6.8%

44.4%,

15.30%

Union County is mixed, with many high-income suburban areas but also lowincome areas by the railroad tracks. As a result it has a high proportion of households
and families at the upper end of the income scale, but almost a proportional amount at
the lower end of the scale. As a result, while the median and mean income levels are
above average and the poverty levels are below average, these figures are smaller than
would be expected from a typical suburban county, and well below Bergen County. By
comparison, Bergen County has about three times the national average in the top
income bracket, and only about half in the bottom bracket. As a result, median family
income for Union County is 128% of the national average, while the figure for Bergen
County is 161% of the average. Similarly, the poverty rate for all families is 77% of the
national average for Union County, but only 50% for Bergen County.
In terms of employment distribution by occupation, both counties have a fairly
robust manufacturing base, only slightly below the national average. Most of the other
sectors are also close to those averages, with slightly higher proportions for financial
and professional services.

Table 6-3. Key Economic Statistics for Morris and Passaic Counties Compared to
the U. 5. Economy
Category

Morris

%

Passaic

%

EMPLOYMENT STATUS

u.s.

%

2010
389,318

100.0%

392,154

100.0%

243,832,923

100.0%

265,835

68.3%

251,834

64.2%

156,966,769

64.4%

265,835

68.3%

251,834

64.2%

155,917,013

63.9%

242,762

62.4%

223,928

57.1%

139,033,928

57.0%

Unemployed

23,073

5.9%

27,906

7.1%

16,883,085

6.9%

Armed Forces

0

0.0%

0

0.0%

1,049,756

0.4%

123,483

31.7%

140,320

35.8%

86,866,154

35.6%

242,762

100.0%

223,928

100.0%

139,033,928

100.0%

117,011

48.2%

72,732

32.5%

49,975,620

35.9%

Service occupations

31,488

13.0%

41,066

18.3%

25,059,153

18.0%

Sales and office occupations

61,530

25.3%

55,173

24.6%

34,711,455

25.0%

Construction, maintenance, repair

13,971

5.8%

15,773

7.0%

12,697,304

9.1%

Production &transportation

18,762

7.7%

39,184

17.5%

16,590,396

11.9%

Population 16 years and over
In labor force
Civilian labor force
Employed

Not in labor force

OCCUPATION
Civilian employed population 16+
Management & professional

594

 22

INDUSTRY
242,762

100.0%

223,928

100.0%

139,033,928

100.0%

605

0.2%

106

0.0%

2,646,975

1.9%

Construction

13,025

5.4%

12,406

5.5%

8,686,813

6.2%

Manufacturing

29,462

12.1%

30,737

13.7%

14,439,691

10.4%

Wholesale trade

8,531

3.5%

9,361

4.2%

3,941,066

2.8%

Retail trade

24,489

10.1%

27,233

12.2%

16,203,408

11.7%

Transportation & utilities

11,615

4.8%

10,168

4.5%

6,843,579

4.9%

Information

10,352

4.3%

5,816

2.6%

3,015,521

2.2%

Finance, insurance, & real estate

26,164

10.8%

17,055

7.6%

9,275,465

6.7%

Professional & administrative

33,295

13.7%

25,463

11.4%

14,710,089

10.6%

Educational services & health care

55,177

22.7%

50,431

22.5%

32,311,107

23.2%

Arts, entertain, hotel, food svcs

12,728

5.2%

16,915

7.6%

12,859,572

9.2%

Other private services

8,589

3.5%

11,461

5.1%

6,913,449

5.0%

Public administration

8,730

3.6%

6,776

3.0%

7,187,193

5.2%

Total households

177,786

100.0%

161,527

100.0%

114,567,419

100.0%

Less than $10,000

5,141

2.9%

14,538

9.0%

8,757,190

7.6%

$10,000 to $14,999

3,562

2.0%

7,604

4.7%

6,668,865

5.8%

$15,000 to $24,999

10,598

6.0%

17,286

10.7%

13,165,380

11.5%

$25,000 to $34,999

10,446

5.9%

17,003

10.5%

12,323,322

10.8%

$35,000 to $49,999

15,265

8.6%

19,142

11.9%

16,312,385

14.2%

$50,000 to $74,999

27,277

15.3%

26,057

16.1%

20,940,859

18.3%

$75,000 to $99,999

25,266

14.2%

17,637

10.9%

13,526,500

11.8%

$100,000 to $149,999

33,587

18.9%

24,127

14.9%

13,544,839

11.8%

$150,000 to $199,999

20,542

11.6%

10,658

6.6%

4,809,998

4.2%

$200,000 or more

26,102

14.7%

7,475

4.6%

4,518,081

3.9%

Median household income (dollars)

91,469

53,993

107.9%

50,046

1()7

68,259

Civilian employed population 16+
Agriculture & mining

INCOME AND BENEFITS

121,784

178.4%

73,618

128,754

100.0%

113,041

100.0%

76,089,045

100.0%

Less than $10,000

1,983

1.5%

7,061

6.2%

3,824,251

5.0%

$10,000 to $14,999

1,149

0.9%

2,987

2.6%

2,660,781

3.5%

$15,000 to $24,999

4,287

3.3%

10,418

9.2%

6,770,812

8.9%

$25,000 to $34,999

5,257

4.1%

10,897

9.6%

7,332,318

9.6%

$35,000 to $49,999

9,063

7.0%

11,966

10.6%

10,578,051

13.9%

$50,000 to $74,999

18,910

14.7%

19,967

17.7%

14,990,631

19.7%

$75,000 to $99,999

18,470

14.3%

13,043

11.5%

10,638,931

14.0%

Mean household income (dollars)
Families

595

 23
$100,000 to $149,999

27,700

21.5%

20,577

18.2%

11,261,766

14.8%

$150,000 to $199,999

18,007

14.0%

9,254

8.2%

4,130,868

5.4%

$200,000 or more

23,928

18.6%

6,871

6.1%

3,900,636

5.1%

Median family income (dollars)

107,639

177.6%

65,248

107.7'%

60,609

Mean family income (dollars)

141,174

177.9%

84,767

106.8%

79,338

Per capita income (dollars)

44,393

170,4%

25,244

96.9';<,

26,059

Median earnings for workers

48,157

30,444

105.3%

28,899

Median earnings for male full-time

77,163

165.9\?;;

46,945

lOU)%

46,500

Median earnings for female full-time

55,422

1.51..6%

37,130

101.6%

36,551

All families

3.7%

7%

12.5%

11.0.6'%

11.30%

All people

6.0%

39,27~>

15.7%

102 6%,

15.30%

PERCENTAGE BELOW POVERTY LEVEL

Morris County is a typical upscale suburban county; Passaic County is mixed,
somewhat like Union County, with pockets of poverty as well as islands of affluence. In
Morris County, median family income is 178% of the national average, similar to but
even higher than Bergen County, while Passaic is only 108% of the average, similar to
but lower than Union County. The poverty levels reflect this difference in income; for all
families, the rate is only 1/3 of the national average for Morris County, but 110% of that
average for Passaic County.
Both counties have a higher than average proportion of the workforce in
manufacturing, at 12.1% for Morris County and 13.7% for Passaic County, compared to
10.4% nationally. Both counties also have a higher than average proportion of workers
in financial and professional services, although the increment is much smaller for
Passaic County. Offsetting these bulges, both counties have a much smaller than
average proportion of workers in arts, entertainment, leisure, hotels, and restaurants.

Table 6-4. Economic Profile of Middlesex and Monmouth Counties and
Comparison with the U.S., 2010 Data
Category
EMPLOYMENT STATUS
Population 16 years and over
In labor force
Civilian labor force
Employed
Unemployed
Armed Forces
Not in labor force

Middlesex
647,766
436,439
436,344
392,654
43,690
95
211,327

% Monmouth
100.0%
67.4%
67.4%
60.6%
6.7%
0.0%
32.6%

499,682
334,514
334,163
305,172
28,991
351
165,168

%

u.s.

%

100.0%
66.9%
66.9%
61.1%
5.8%
0.1%
33.1%

2010
243,832,923
156,966,769
155,917,013
139,033,928
16,883,085
1,049,756
86,866,154

100.0%
64.4%
63.9%
57.0%
6.9%
0.4%
35.6%

OCCUPATION

596

 24
Civilian employed population 16+
Management & professional
Service occupations
Sales and office occupations
Construction, maintenance, repair
Production &transportation

392,654
170,323
55,446
99,238
25,049
42,598

100.0%
43.4%
14.1%
25.3%
6.4%
10.8%

305,172
131,997
46,342
81,326
21,803
23,704

100.0%
43.3%
15.2%
26.6%
7.1%
7.8%

139,033,928
49,975,620
25,059,153
34,711,455
12,697,304
16,590,396

100.0%
35.9%
18.0%
25.0%
9.1%
11.9%

INDUSTRY
Civilian employed population 16+
Agriculture & mining
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation & utilities
Information
Finance, insurance, & real estate
Professional & administrative
Educational services & health care
Arts, entertain, hotel, food svcs
Other private services
Public administration

392,654
628
18,052
39,615
17,826
43,951
26,800
12,486
36,177
52,832
83,080
29,705
15,450
16,052

100.0%
0.2%
4.6%
10.1%
4.5%
11.2%
6.8%
3.2%
9.2%
13.5%
21.2%
7.6%
3.9%
4.1%

305,172
1,043
16,060
20,781
10,399
33,644
14,981
13,058
33,142
39,280
70,468
24,158
11,999
16,159

100.0%
0.3%
5.3%
6.8%
3.4%
11.0%
4.9%
4.3%
10.9%
12.9%
23.1%
7.9%
3.9%
5.3%

139,033,928
2,646,975
8,686,813
14,439,691
3,941,066
16,203,408
6,843,579
3,015,521
9,275,465
14,710,089
32,311,107
12,859,572
6,913,449
7,187,193

100.0%
1.9%
6.2%
10.4%
2.8%
11.7%
4.9%
2.2%
6.7%
10.6%
23.2%
9.2%
5.0%
5.2%

INCOME AND BENEFITS
Total households
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median household income (dollars)
Mean household income (dollars)

278,877
9,344
8,634
20,963
17,484
28,013
52,023
41,574
59,641
23,338
17,863
76,443
91,077

100.0%
3.4%
3.1%
7.5%
6.3%
10.0%
18.7%
14.9%
21.4%
8.4%
6.4%

234,582
8,749
7,916
20,280
16,779
21,105
34,504
30,287
43,322
23,299
28,341
80,816
109,907

100.0%
3.7%
3.4%
8.6%
7.2%
9.0%
14.7%
12.9%
18.5%
9.9%
12.1%

114,567,419
8,757,190
6,668,865
13,165,380
12,323,322
16,312,385
20,940,859
13,526,500
13,544,839
4,809,998
4,518,081
50,046
68,259

100.0%
7.6%
5.8%
11.5%
10.8%
14.2%
18.3%
11.8%
11.8%
4.2%
3.9%

76,089,045
3,824,251
2,660,781
6,770,812
7,332,318
10,578,051
14,990,631
10,638,931
11,261,766
4,130,868
3,900,636
60,609

100.0%
5.0%
3.5%
8.9%
9.6%
13.9%
19.7%
14.0%
14.8%
5.4%
5.1%

--

Families
Less than $10,000
$10,000 to $14,999
$15,000 to $24,999
$25,000 to $34,999
$35,000 to $49,999
$50,000 to $74,999
$75,000 to $99,999
$100,000 to $149,999
$150,000 to $199,999
$200,000 or more
Median family income (dollars)

203,542
3,425
3,594
10,298
10,039
18,530
36,692
32,490
51,013
21,178
16,283
88,678

152,7(:1>
133.4%

100.0%
1.7%
1.8%
5.1%
4.9%
9.1%
18.0%
16.0%
25.1%
10.4%
8.0%
1463%

159,264
3,542
2,250
7,999
8,157
11,826
20,099
23,504
36,806
19,441
25,640
101,714

161.5'/r.,
161.0%

100.0%
2.2%
1.4%
5.0%
5.1%
7.4%
12.6%
14.8%
23.1%
12.2%
16.1%
167.8'X)

597

 25
Mean family income (dollars)
Per capita income (dollars)

102,733
32,017

Median earnings for workers
Median earnings for male full-time
Median earnings for female full-time
PERCENTAGE BELOW POVERTY LEVEL
All families
All people

129.5%

122.9%

40,270
61,557
47,101

139.3%

5.1%
7.7%

45.1%

132.4'}{,

128.9'%

50.3%

132,616
41,434

167 ,21).;,

159.0%
1.46.3'Yo

42,266
71,576
52,072

1425%

5.0%
6.6%

43J.%

153.9%

44.2.%

79,338
26,059
28,899
46,500
36,551

11.3%
15.3%

Middlesex and Monmouth Counties are prototypical wealthy suburbs, with
median household incomes more than 50% higher than the U.S. figures and poverty
rates half of the national averages or less. Monmouth County has an especially high
share of the wealthy, with 12% of households earning $200,000 or more- compared to
4% for the U.S.
Consistent with their high-income profiles, both counties have high percentages
of white-collar workers - 43% in each county, compared to 36% nationally. Similar to
the other counties in the region, Middlesex (9%) and Monmouth (11 %) have high shares
of workers in the finance and insurance industries - compared to 7% for the U.S.
Unlike Middlesex County, Monmouth County has a lower than average proportion of its
workforce in manufacturing, at 7%.
Table 6-5. Labor Market Statistics for 8 Counties in Northern New Jersey, 20022011 Data
Labor Force

2002
2003
2004

New Jersey
4,370,809
4,363,896

Employed

Unemployed

Un Rate,%

4,117,265

253,544

5.8

4,108,397
4,144,223

255,499

5.9

4,207,738

214,685
196,713

4.9
4.5

2005

4,358,908
4,404,451

2006

4,465,067

4,257,899

207,168

4.6

2007

4,456,306

4,264,617

191,689

4.3

2008

4,509,110

4,262,281

246,829

5.5

2009

4,546,443

4,138,364

408,079

9.0

2010

4,554,076

4,116,640

437,436

9.6

2011

4,556,186

4,131,832

424,354

9.3

Bergen
2002

466,326

442,760

23,566

5.1

2003

465,115

441,480

23,635

5.1

2004

462,702

443,247

19,455

4.2

598

 26
2005

467,206

449,791

17,415

3.7

2006

473,275

455,022

18,253

3.9

2007

472,991

456,594

16,397

3.5

2008

478,584

457,046

21,538

4.5

2009

480,720

443,620

37,100

7.7

2010

476,243

436,522

39,721

8.3

2011

479,131

441,277

37,854

7.9

2002

371,383

344,532

26,851

7.2

2003

369,164

342,304

26,860

7.3

2004

363,454

340,905

22,549

6.2

2005

361,843

341,544

20,299

5.6

2006

364,175

343,012

21,163

5.8

2007

362,785

343,281

19,504

5.4

2008

366,007

341,853

24,154

6.6

2009

367,125

329,526

37,599

10.2

2010

370,372

329,355

41,017

11.1

2011

370,417

330,337

40,080

10.8

2002

296,200

273,503

22,697

7.7

2003

292,204

270,633

21,571

7.4

2004

287,381

269,725

17,656

6.1

2005

288,312

272,630

15,682

5.4

2006

290,204

274,266

15,938

5.5

2007

290,990

276,383

14,607

5.0

2008

294,408

275,666

18,742

6.4

2009

299,839

268,570

31,269

10.4

2010
2011

310,845
312,467

277,281
280,302

33,564
32,165

10.8
10.3

2002

Middlesex
413,685

390,439

23,246

5.6

2003

411,128

388,372

22,756

5.5

2004

410,464

391,663

18,801

4.6

2005

415,943

398,420

17,523

4.2

2006

421,868

403,617

18,251

4.3

2007

421,754

405,387

16,367

3.9

2008

425,916

404,463

21,453

5.0

2009

427,408

391,354

36,054

8.4

2010

436,381

398,449

37,932

8.7

2011

436,228

399,546

36,682

8.4

Essex

Hudson

599

 27

2002

Monmouth
325,726

308,550

17,176

5.3

2003

323,789

306,191

17,598

5.4

2004

322,012

307,448

14,564

4.5

2005

324,105

310,869

13,236

4.1

2006

329,093

315,612

13,481

4.1

2007

332,191

319,687

12,504

3.8

2008

335,353

318,975

16,378

4.9

2009

336,577

308,793

27,784

8.3

2010

329,433

300,427

29,006

8.8

2011

329,571

301,254

28,317

8.6

2002

265,499

253,291

12,208

4.6

2003

266,068

253,862

12,206

4.6

2004

265,376

255,660

9,716

3.7

2005

267,813

259,088

8,725

3.3

2006

272,237

263,196

9,041

3.3

2007

272,580

264,282

8,298

3.0

2008

275,584

264,528

11,056

4.0

2009

275,118

255,839

19,279

7.0

2010

272,994

252,965

20,029

7.3

2011

272,849

253,719

19,130

7.0

2002

236,848

220,154

16,694

7.0

2003

236,729

219,363

17,366

7.3

2004

233,946

219,516

14,430

6.2

2005
2006

222,610
223,944
224,527

12,908
13,250
12,767

5.5
5.6

2007

235,518
237,194
237,294

2008
2009

240,836
244,838

224,443

16,393

218,118

26,720

6.8
10.9

2010

244,764

216,367

28,397

11.6

2011

246,012

218,724

27,288

11.1

2002

269,672

252,547

17,125

6.4

2003

268,107

251,137

16,970

6.3

2004

265,034

250,970

14,064

5.3

2005

265,654

252,991

12,663

4.8

2006

268,521

255,487

13,034

4.9

Morris

Passaic

5.4

Union

600

 28
2007

267,960

255,865

12,095

4.5

2008
2009

271,553

255,902

15,651

5.8

273,728

248,504

25,224

9.2

2010

275,137

248,502

26,635

9.7

2011

275,886

249,244

26,642

9.7

8 counties
2002

2,645,339

2,485,776

159,563

6.0

2003

2,632,304

2,473,342

158,962

6.0

2004

2,610,369

2,479,134

131,235

5.0

2005

2,626,394

2,507,943

118,451

4.5

2006

2,656,567

2,534,156

122,411

4.6

2007

2,658,545

2,546,006

112,539

4.2

2008

2,688,241

2,542,876

145,365

5.4

2009

2,705,353

2,464,324

241,029

8.9

2010

2,716,169

2,459,868

256,301

9.4

2011

2,722,561

2,474,403

248,158

9.1

The unemployment rate for this part of New Jersey is very similar to the profile
for the overall U. S., although the figures in 2010 and 2011 are marginally lower. By
individual county, Hudson, Essex, Union, and Passaic counties have rates that are
above the 8.9% level for 2011, while Bergen, Middlesex, Morris, and Monmouth are
below average. According to BLS statistics as of December 1, 2012, there were almost
250,000 unemployed people in this 8-county region in 2011.

Table 6-6. Level and Growth Rate of Population, State of New Jersey, 8 Counties
in the Northern New Jersey, and the Total of these Counties
(Table is divided into Sections A and B for easier viewing)
New Jersey

Bergen

Essex

2011
2010

8,821,155
8,799,593

911,004
906,184

785,137
784,099

2009

8,755,602

900,319

2008

8,711,090

2007

Hudson

Union

Middlesex

781,943

641,224
634,979
628,572

539,494
537,475
532,434

805,204

895,328

778,165

619,533

527,528

799,191

8,677,885

890,817

778,996

613,637

524,960

792,137

2006

8,661,679

889,406

781,027

613,577

525,153

786,890

2005

8,651,974

891,446

786,341

614,664

526,161

787,329

2004

8,634,561

893,378

791,305

614,607

526,916

781,582

2003

8,601,402

892,214

795,167

614,813

527,611

775,973

2002

8,552,643

890,647

795,625

615,554

527,625

769,280

2011/10

0.25%

0.53%

0.13%

0.98%

0.38%

0.43%

2010/09

0.50%

0.65%

0.28%

1.02%

0.95%

0.69%

2009/08

0.51%

0.56%

0.49%

1.46%

0.93%

0.75%

814,217
810,747

601

 29
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

0.38%
0.19%
0.11%
0.20%
0.39%
0.57%

0.51%
0.16%
-0.23%
-0.22%
0.13%
0.18%

-0.11%
-0.26%
-0.68%
-0.63%
-0.49%
-0.06%

0.96%
0.01%
-0.18%
0.01%
-0.03%
-0.12%

0.49%
-0.04%
-0.19%
-0.14%
-0.13%
0.00%

0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

2011/02

0.34%

0.25%

-0.15%

0.45%

0.25%

0.63%

Middlesex
814,217
810,747
805,204
799,191
792,137
786,890
787,329
781,582
775,973
769,280

Monmouth
631,020
630,920
628,669
627,348
626,644
626,934
627,838
628,605
627,413
624,532

Morris
494,976
492,681
490,779
489,743
488,355
487,486
485,472
483,997
481,000
477,234

Passaic
502,007
501,606
498,641
494,904
492,886
492,730
493,600
493,981
494,915
494,571

8 counties
5,319,079
5,298,691
5,266,561
5,231,740
5,208,432
5,203,203
5,212,851
5,214,371
5,209,106
5,195,068

2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

0.43%
0.69%
0.75%
0.89%
0.67%
-0.06%
0.74%
0.72%
0.87%

0.02%
0.36%
0.21%
0.11%
-0.05%
-0.14%
-0.12%
0.19%
0.46%

0.47%
0.39%
0.21%
0.28%
0.18%
0.41%
0.30%
0.62%
0.79%

0.08%
0.59%
0.76%
0.41%
0.03%
-0.18%
-0.08%
-0.19%
0.07%

0.38%
0.61%
0.67%
0.45%
0.10%
-0.19%
-0.03%
0.10%
0.27%

2011/02

0.63%

0.11%

0.41%

0.17%

0.26%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002

Population growth in this 8-county area was not only well below the 1% rate for
the U.S, but was less than half the rate in New Jersey; since that is the figure for the
entire state, the growth rate was only about 1/5 of that for the other 9 counties in New
Jersey. The pattern reversed course at mid-decade, with an actual decline from 2004
through 2007 being followed by an average growth rate of 0.5% from 2008 to 2011.

Table 6-7. Level and Growth Rate of Personal Income, Billions of Dollars, State of
New Jersey, 8 Counties in Northern New Jersey, and the Total of these Counties

2011

New Jersey
462.49

Bergen
60.21

Essex
41.58

Hudson
30.38

Union
27.98

602

 30
2010
2009
2008
2007
2006
2005
2004
2003
2002

443.74
430.96
454.21
436.12
411.43
379.65
365.26
347.69
341.56

57.44
56.36
61.09
60.04
55.78
50.55
48.66
45.62
46.24

40.01
37.98
40.20
38.83
36.93
33.99
32.77
30.81
30.14

28.75
26.82
26.57
24.21
22.69
21.15
19.99
19.24
19.00

26.63
25.76
27.59
26.64
25.54
23.28
22.54
21.87
21.51

2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

4.23%
2.97%
-5.12%
4.15%
6.00%
8.37%
3.94%
5.05%
1.80%

4.83%
1.91%
-7.73%
1.75%
7.63%
10.34%
3.90%
6.65%
-1.33%

3.91%
5.34%
-5.53%
3.53%
5.14%
8.65%
3.73%
6.37%
2.21%

5.66%
7.20%
0.96%
9.76%
6.69%
7.26%
5.81%
3.88%
1.30%

5.08%
3.35%
-6.63%
3.57%
4.31%
9.72%
3.29%
3.06%
1.70%

2011/02

3.42%

2.98%

3.63%

5.35%

2.96%

Middlesex
40.06
38.34
37.58
39.53
37.22
34.78
32.14
31.00
30.07
29.55

Monmouth
36.82
35.59
34.79
37.22
36.15
33.68
30.87
29.78
27.75
27.36

Morris
35.50
34.18
32.98
36.25
34.77
33.11
30.55
29.42
27.32
26.93

Passaic
21.69
20.64
20.03
20.57
19.83
18.66
17.41
16.48
16.13
15.92

8 counties
294.23
281.58
272.31
289.02
277.68
261.17
239.95
230.64
218.81
216.63

4.50%
2.02%
-4.95%
6.20%
7.01%
8.22%
3.70%
3.10%
1.76%

3.45%
2.31%
-6.53%
2.97%
7.35%
9.09%
3.66%
7.32%
1.43%

3.87%
3.65%
-9.04%
4.28%
5.01%
8.37%
3.85%
7.67%
1.47%

5.09%
3.04%
-2.60%
3.74%
6.26%
7.17%
5.61%
2.22%
1.28%

4.49%
3.41%
-5.78%
4.08%
6.32%
8.84%
4.04%
5.41%
1.00%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2011/10
2010/09
2009/08
2008/07
2007/06
2006/05
2005/04
2004/03
2003/02

603

 31

2011/02

3.44%

3.35%

3.12%

3.49%

3.46%

The growth in personal income over the decade for this 8-county region was the
same as the rest of New Jersey, and about 0.3% per year lower than the U.S. economy.
The decline in 2009 was obviously tied to the financial markets, but was not nearly as
severe as the swings in Manhattan and the suburban counties in New York State. Of
particular interest is that income actually continued to rise in Hudson County in 2009 in
spite of the increasing concentration of financial institutions who have moved across the
river from New York City; it was the only county in this group where income did not
decline in 2009. The rebound in 2010 and 2011 for the entire region continued to be
close to the national average; for Hudson County, the increase was well above average.
Finally, we turn to the commuting patterns. In determining the economic impact
of new job creation, it is necessary to choose the counties that form the relevant area
for analysis. The economic multipliers will be higher as the number of counties included
in the area increases. If the proportion of the workforce covered rises above 95%, that
would include too many jobs that are not directly related to the new project. If that
proportion falls below 90%, the multipliers would probably be understated. Hence the
commuting patterns of the workforce data from the 2000 Census are used to determine
the optimal mix of counties to be included in the multiplier calculations. These
commuters spend most of their paychecks in the counties where they live, so the
economic impact of the new project creates some new induced jobs in bordering
counties. Also, some of the goods and services purchased by the new businesses are
produced or purchased from establishments in neighboring counties.
Table 6-8 can be interpreted as follows. In 2000, there were 223,225 people in
the Hudson County workforce. Of these, 121,352 lived in Hudson County, 25,444 lived
in Bergen County, and so on. We have included counties that accounted for 84.1% of
the total Hudson County workforce, which is below the usual level because many of the
commuters live in far-flung counties that have few links with Hudson County.
Table 6-8. Commuting Patterns for Hudson County, NJ
Total Hudson County Workforce
Living in these counties:
Hudson Co. NJ
Bergen Co. NJ
Essex Co. NJ
Middlesex Co. NJ

223,225
121,352
25,444
16)93
8,706

Union Co. NJ

8)51

Passaic Co. NJ

6,468

Monmouth Co. NJ

6,165

Morris Co. NJ

4,806

Total these 8 counties
% in these 8 counties

197,835
84.1%

604

 32

7. Location of Building, Maps of Area, and TEA Analysis
Figure 7-1. Location of 88 Morgan Street, Jersey City

.

-<1"'1'

.Sr

l

4:

g

3m S!

E

~

:;:

4th St

1

.~.

2t!c .sr

$
.;;
e,,y:;;!

\1

;;"

i5

];

m

"'
'~

:.

~

i2

"'c

Q

~

!!'

!:

1

~t S:

Morgan St

11
'(

605

 33
Figure 7-2. Location of Building in the 8-County Area
Port ,Jervis

O!a Forge

Vernon

Tob}"1a1~kl

Fr<~nkforct

CN!SOO

Stroudsburg

P,aterson
Bangor

Allentown

Ouaf:ertcwn

Pnntetor.
Souoorton

Lawrence

lovms111p
Warmmster

11C mr
2C

tf

Trenton

Freehold
Townsh;p

".Nil'ow
Ph,coerux>>~l!e Nomstown

Gro-..e

Hr:

606

 34

Figure 7~3. County Map of New Jersey

       

 

Ht mmw?



       
  

   
   


\a
may, wax/MW

 
    



 

 

607

35

TEA Analysis
A TEA can be formed from CTs 3,4,5,6,7,8,11, 12,01,12.02, 15, 22,23, 25, 26,
30, 31, 32 33, 44, 45,46,50, 51, 52, 53, and 55; the locations of these CTs are shown in
Figure 7-4. The Property is located in CT 26. A letter of certification is expected from
the New Jersey Department of Labor.

Figure 7-4. Census Tract Map of Jersey City

608

 36

8. Economic Impact of Construction Expenditures

(b)(4)

Table 8-1 shows the total development budget ofl
m 'lis
amount, aboutl
lis EB~5 eligible hard construction c o s t s J i s
architectural, engineering, and related fees, and
lis purchases of furniture,
fixtures, and equipment (FF&E). The remaining.
_consists primarily of land
costs, interest costs, contingencies, and fees.

I

Table 8-1. Sources and Uses of Funds

(b)(4)

The details of the budget are given in Table 8~2. We have subtracted certain
items from the Hard Cost figure given in Table 8~1 that are not EB~5 eligible; the
remaining amount includes building, parking, and site preparation. EB~5 eligible soft
costs are architectural, engineering, and surveying fees.

609

 37

Table 8-2. Detailed Construction Budget

(b)(4)

Development Budget

In general, USCIS has indicated that current-dollar numbers should be deflated
to the year in which the input/output coefficients were calculated, which in this case is
2008. For construction expenditures, however, prices have actually dropped since then,
as shown in the Turner construction index.
The estimated values used in the impact analysis are as follows: 2012, 829;
2013, 845, and 2014, 862 (a 2% annual growth rate). For projects being constructed in
2013 and 2014, the average level would be 854, which is well below the 908 level
reached in 2008.

610

 38

Quarter

Index

A%

3rd Quarter 2012

832

0.73

2nd Quarter 2012
1st Quarter 2012
4th Quarter 2011

826
821
818

0.61
0.37
0.49

Year

Avtrag~ Co®~

6.%

2011
2010
2009
2008
2007
2006
2005
2004
2003
2002
2001
2000

812
799
832
908
854
793
717
655
621
619
613
595
570

1.6
-4.0
-8.4
6.3

1999

7.7

10.6
9.5
5.4
0.3
1.0
3.0
4.4
3.8

Turner has prepared the construction cost forecast for more than 80 years. Used
widely by the construction industry and Federal and State governments, the building
costs and price trends tracked by The Turner Building Cost Index may or may not reflect
regional conditions in any given quarter. The Cost Index is determined by several
factors considered on a nationwide basis, including labor rates and productivity, material
prices and the competitive condition of the marketplace. This index does not necessarily
conform to other published indices because others do not generally take all of these

factors into account. Further information about this index is available at:
http://www.turnerconstruction.com/cost-index
The next six tables show the economic impact of (a) hard construction costs, (b)
EB-5 eligible soft costs, and (c) purchases of FF&E. In all cases, the tables show the
impact for the 20 major industrial classifications in the RIMS II input/output model; in all
cases, only indirect and induced impacts are included. Please note that in these and
succeeding tables, output and earnings are given in thousands of dollars.

611

 39

(b)(4)

Table 8-3. Increase in Employment, Output, and Earnings for Hard Construction
Costs of 88 Morgan Street

D

Table 8-3 shows there will be a total of
jobs created from the hard
construction costs of the 88 Morgan Street building. Outpu w I ri
bout
million, while household earnings would increase b abou
Table 8-4
shows thj averagel output per new worker is about
while average earnings
are about

I

I
(b)(4)

Table 8-4. Output and Earnings Per New Worker, Hard Construction Costs for 88
Morgan Street

(b)(4)

612

 (b)(4)

40

For equipment purchases, USCIS has agreed to count jobs indirectly created
outside the geographical boundaries of a Regional Center (RC) in determining whether
the RC's business plan complies with EB-5 regulations. The policy change was
expressed in a December 3, 2010, letter from USC IS Director Alejandro Mayorkas in
response to a letter from Senator Patrick Leahy, Chairman of the Senate Judiciary
Committee.
Mayorkas wrote: "USCIS interprets the law to require that a regional center focus
its EB-5 capital investment activities on a single, contiguous area within the defined
geographic jurisdiction requested by the regional center. Nevertheless, we agree that
the law does not further mandate that all indirect job creation attributable to a regional
center take place within that jurisdiction. I will, therefore, ensure that USCIS policy
reflects this understanding of the law."
The regulations include the following language: "The regulation at 8 CFR
204.6.(m) provides [that] ... Each regional center ... shall submit a proposal, which ...
Contains a detailed prediction regarding the manner in which the regional center will
have a positive impact on the regional or national economy in general as reflected by
such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the regional
center" (emphasis added).
It is highly unlikely that the FF&E is manufactured in the NYC area, and we are
not making that claim. One possibility is to use the indirect and induced jobs created by
the production of the FF&E outside the regional center. The justification for this
approach is as follows:

613

 41

The regulations include the following language: "The regulation at 8 CFR
204.6.(m) provides [that] ... Each regional center ... shall submit a proposal, which ...
Contains a detailed prediction regarding the manner in which the regional center will
have a positive impact on the regional or national economy in general as reflected by
such factors as increased household earnings, greater demand for business services,
utilities, maintenance and repair, and construction both within and without the regional
center" (emphasis added).
The drawback to that approach, however, is that in general no information is
available indicating the jurisdiction where the FF&E was produced, so we do not know
which set of multipliers to use. Hence we have used an alternative approach, which is
to claim that the indirect and induced jobs created by the installation of the FF&E in the
NYC area can be legitimately included in the EB-5 job count.
These jobs would include all of the activities that occur within the region:
transportation and distribution of the FF&E to the hotel site, purchasing margins at the
wholesale and possibly retail level, and most importantly, the construction jobs that are
used in the installation of the FF&E. This generally involves substantial construction
activity in terms of installing bathroom fixtures, electronic equipment,
telecommunications systems, and other construction jobs associated with preparing the
hotel rooms for clients. For this reason, then, the FF&E calculations are based on the
indirect and induced final demand and employment multipliers for the
construction sector.

(b)(4)

Table 8-5. Increase in Employment, Output, and Earnings, Purchases of FF&E
for 88 Morgan Street, Indirect and Induced Effects Only

614

 (b)(4)

(b)(4)

42

Table 8-5 shows there will be a total of Oindirect and induced jobs created from
the purchases of FF&E for the 88 Morgan Street building. Out ut would rise about
I
twhile household earnings would increase by about
Table 8-6
shows the average output per new worker is aboutl
Iw 1 e average earnings
are abou~
I
Table 8-6. Output and Earnings Per New Worker, Purchases of FF&E for 88
Morgan Street, Indirect and Induced Effects Only

(b)(4)

615

 43

In terms of what soft costs are EB-5 eligible, we rely on the information given in
the NAICS coding manual, which is summarize as follows:
541310 Architectural Services
This industry comprises establishments primarily engaged in planning and designing residential,
institutional, leisure, commercial, and industrial buildings and structures by applying knowledge of design,
construction procedures, zoning regulations, building codes, and building materials.

541330 Engineering Services
This industry comprises establishments primarily engaged in applying physical laws and principles of
engineering in the design, development, and utilization of machines, materials, instruments, structures.
processes, and systems. The assignments undertaken by these establishments may involve any of the
following activities: provision of advice, preparation of feasibility studies, preparation of preliminary and
final plans and designs, provision of technical services during the construction or installation phase,
Inspection and evaluation of engineering projects, and related services.

236220 Nonresidential Building Construction
This industry comprises establishments primarily responsible for the construction (including new work,
additions, alterations, maintenance, and repairs) of commercial and institutional buildings and related
structures. such as stadiums, grain elevators, and indoor swimming facilities. This industry includes
establishments responsible for the on-site assembly of modular or prefabricated commercial and
institutional buildings. Included in this industry are commercial and institutional building general
contractors, commercial and institutional building operative builders, commercial and institutional building
design-build firms, and commercial and institutional building project construction management firms.

(b)(4)

Table 8M7. Increase in Employment, Output, and Earnings for EBMS Eligible Soft
Construction Costs of 88 Moraan Street Project

616

 44

(b)(4)

Table 8-7 shows there will be a total oObs created from the EB-5 eligible soft
construction costs of the 88 Morgan Street building. Output would rise aboutr-1
while household earnings would increase by about
Table-a:B"
'srimvs'thj averagj output per new worker is about
while average earnings
are abou

rl

(b)(4)

Table 8-8. Output and Earnings Per New Worker for EB-5 Eligible Soft
-······················ _____
C_o_ns~t~uction Costs of 88 Morgan Street Project
(b)(4)

617

 45

9. Economic Impact of Rental Income for Apartments, Retail Space,
and Parking Space
The building at 88 Morgan Street will be primarily residential, containing 417
apartments, 214 parking spaces, and about 4,000 square feet of retail space.
According to the developer, the Jersey City market place is one of the strf"~tst rental
markets in New Jersey. Rents at comparable developments are well over
q ft and
occupancies hover in the high 90s. The operating assumptions are shown in able 9-1.

(b)(4)

Table 9-1. Operating Assumptions for 88 Morgan Street, Jersey City, NJ
Jp~r.1ting

Assumptions

(b)(4)

The monthly rentals for comparable apartment buildings in Jersey City are shown
in Table 9-2.

618

 46

Table 9-2. Comparable Rents in Jersey City

 

 

Rent 

 

 

lawmnm


619

47
The total annual rental income entered into the RIMS II model is hence
calculated as follows, based on the operating projections provided by the developer.
The figures for "Year 4", which is the first full year of occupancy, are used for these
calculations.

Table 9-3. Operating Projections, first 4 Years, for 88 Morgan Street Building
Detailed Operating Projections
(b)(4)

(b)(4)

In the first full year of operation, gross potential rent would be I
I
however that figure must be reduced by an expected 3% vacancy rate, 0.5% loss for
bad debts, and first-year rent concessions (essentially one free month) that amount to
anothe1
Hence total apartment rentals after subtracting these items
equals
This figure is then boosted by the expected revenue for
parking spaces, retail 1ncome, and other fees. There are 214 parking spaces and an
average monthly fee of I
lnonth, adjusted for the 3% vacancy rate and 0.5% loss for
bad debts. Retail space of 4,000 square feet is expected to rent forOper square
foot, which is well below the yerar for comparable locations. Finally, fees from other
income are expected to be
per month per occupied unit, with the first-year

620

 48

(b)(4)

adjustment for one month of free rent. Summing all these factors indicates total annual
rental income of I
tnillion for the first full year of operation.
This figure is in 2016 dollars, while the input/output coefficients are based on
2008 dollars, so it must be deflated. The CPI for rental; income medium-sized cities
rose 1.6% per year from 2008 to 2012, as shown in Table 9-4, so continuing that rate
forward to 2016, the deflator would be 1.134, indicating rental income oq
in 2008 dollars.
.....__ _ _.....,.
(b)(4)

Table 9-4. CPI for Primary Rental Income, Medium-Sized Cities

The detailed industry results for._l_.....,.lmillion in rental income are shown in the
next two tables.

(b)(4)

Table 9-5. Increase in Employment, Output, and Earnings, Rental Income for 88
Morgan Street Building, 2008 Dollars

621

 49
(b)(4)

Table 9-5 shows there would be an increase otrlpermanent new jobs from the
(b)(4)

I

T~utput woul~l rise about!

rental income of the 88 Morgan Street building.

I

land household earnings would increase by about
Table 9-6 shows
output per new worker would be about
with average annua earnings of about

I

I

I

I

Table 9-6. Output and Earnings Per New Worker, Rental Income for 88 Morgan
Street Building, 2008 Dollars

(b)(4)

622

 50

 

 

 

623

 

51

10. Summary Statistics for the Construction and Rental Income for
the 88 Morgan Street Building
Tables 10-1 and 10-2 show the combined economic impact of constructing and
rental income for the 88 Morgan Street Building. These results are the summation of
the data given in Sections (8) and (9), so the individual cells simply represent the sum
(or average) of these figures in the previous two sections.
Table 10-1. Increase in Employment, Output, and Earnings for Construction and
Operation of the 88 Morgan Street Building
(b)(4)

Table 10-1 shows that c::Jpermanent new jobs would be created by the
construction and rental income for the 88 Morgan Street building. Output would rise by
about I
land household earnings would increase by about I
I
Table 10-2 shows that the average output per new worker would be aboutl
I
while average annual earnings would be about

I

I

(b)(4)

624

 52
(b)(4)

Table 10-2. Output and Earnings Per New Worker for Construction and Operation
of 88 Morgan Street Building

625

 53

Appendix: Resume of Dr. Michael K. Evans
mevans@evanscarrollecon.com

CURRENT AND PREVIOUS POSITIONS
Chairman, Evans, Carroll & Associates, Inc., 1980-present
Economics)

(previously Evans

Economic consulting firm specializing in EB-5 immigration analysis, economic
impact studies of development projects and new construction, models of state and local
tax receipts, impact of current and proposed government legislation, and construction of
econometric models for individual industries and companies.
• Chief Economist, American Economics Group, 2000-2008.
Built a comprehensive state modeling system that provides economic analysis for
a variety of consulting projects (see below).
• Clinical Professor of Economics, Department of Managerial Economics and Decision
Sciences (MEDS), Kellogg Graduate School of Management, Northwestern University,
1996-99.
Taught courses in macroeconomics and business forecasting. Wrote textbooks
for both courses.
• Winner of Blue Chip Economic Indicator Award for most accurate macroeconomic
forecasts during the past four years, November 1999
• Founder and President, Chase Econometric Associates, 1970-1980
• Assistant and Associate Professor of Economics, Wharton School, University of
Pennsylvania, 1964-69. Co-developer of the original Wharton Model.
• Visiting Professor, Radford University, (Radford, VA), 1987
Chairman of Institute for International Economic Competitiveness
• Visiting Lecturer, Hebrew University (Jerusalem), 1966-67
Built econometric model of the Israeli economy
• Ph. D. in Economics, Brown University. Dissertation, "A Postwar Quarterly Model of
the United States Economy, 1948-1962". A. B. in Mathematical Economics, Brown
University

626

 54

PREVIOUS ACTIVITIES AND EDUCATION
• Contributing Editor, Industry Week
Wrote a column in each issue on economic and financial trends as they impact
the manufacturing sector.
• Editor, The Evans Report
Weekly newsletter discussing economic trends and financial markets. Pioneered
the concept of the Monthly Tracking Model to incorporate recent economic releases into
the overall economic forecast, including methods to predict these economic data.
• Consultant, National Printing Equipment and Supply Association
Prepared quarterly forecasts of shipments of printing equipment and graphic arts
supplies by product line, based on an econometric model constructed for NPES. Also
prepares analysis and forecasts of exports and imports by principal product line.
• Consultant, APICS -- The Educational Society for Resource Management,
Designed and developed the APJCS Business Outlook Index, which used survey
data collected by the Evans Group to measure current production, production plans,
shipments, employment, new orders, unfilled orders, inventory stocks, and the
comparison of the actual to desired inventory/sales ratio to predict short-term changes
in manufacturing sector activity. The results of this survey appeared every month in
APICS: The Performance Advantage
• Consultant, American Hardware Manufacturing Association
Wrote a separate weekly edition of the Evans Report analyzing recent trends in
the hardware and housing industries, including forecasts of the hardware industry based
on an econometric model developed for AHMA.
• Board of Economists, Los Angeles Times
Wrote column every 6 weeks (5 other economists on the Board)
• Columnist, United Press International
11

Wrote twice-weekly column, 0ollars and Trends"
• Consultant, Senate Finance Committee,

627

 55
Built the first large-scale supply-side model of the U. S. economy
• Consultant, Environmental Protection Agency and Council on Environmental Quality
Estimated inflationary impact of government regulations
• Consultant, National Aeronautics and Space Administration
Estimate impact of R&D spending on productivity growth
• Consultant, U. S. Treasury
Estimated impact of investment tax credit and accelerated depreciation on capital
spending by industry
• Consultant, U. S. Department of Agriculture
Built large-scale econometric model of agricultural sector of U.S. economy
• Consultant, Organization of Economic Cooperation and Development
Built econometric model of the French economy

SAMPLE OF RECENT CONSULTING PROJECTS
A. Economic Impact of EB-5 Immigrant Investor Programs and New Markets Tax
Credits

For more information on these projects, see www.evanseb5.com
Key to symbols: N, new regional center, E, extension of existing center
List is current as of November 5, 2010. Totals to date are 136 new regional centers, 72
extensions, and 7 new markets tax credits, for a total of 215 projects
N• Calculated the economic impact of the construction and operation of an assisted
living center in Santa Ana, CA
N• Calculated the economic impact of the construction and operation of several BBQ
restaurants in South Florida.
N• Calculated the economic impact of the drilling oil wells in 8 counties in Texas and
Louisiana.

628

 56

N• Calculated the economic impact of operating coal mines for metallurgical coal in
West Virginia.
N• Calculated the economic impact of operating gold mines in Alaska.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Flushing, NY
N• Calculated the economic impact of constructing and operating two hotels, one in
downtown San Diego, and one in Escondido, CA
N• Calculated the economic impact of expanding and operating an auto racing track in
Palm Beach, FL
N• Calculated the economic impact of building and operating mobile housing villages
for disaster relief.
N• Calculated the economic impact of operating an "incubator" for research on medical
devices, preparations, and services in Houston, TX.
N• Calculated the economic impact of constructing and operating a mixed-use
commercial center in Denver, CO.
N• Calculated the economic impact of constructing and operating a charter school in
Miami/Dade County, FL
E• Calculated the economic impact of constructing and operating a hotel in Manhattan,
NY
N• Calculated the economic impact of constructing and operating hotels, assisted living
centers, and mixed-use commercial buildings in 8 counties in Southern California
N• Calculated the economic impact of constructing and operating a charter school in
Broward County, FL
N• Calculated the economic impact of renovating a former public housing project in
Chicago, IL
N• Calculated the economic impact of starting a high-tech company for optical displays
in Orlando and Gainesville, FL
N• Calculated the economic impact of constructing and operating luxury hotels in four
Southern California counties
E• Calculated the economic impact of expanding a manufacturing company in Ann
Arbor, Ml

629

 57
N• Calculated the economic impact of reconverting an old mill building into offices and
other commercial uses in Bristol County, MA

N• Calculated the economic impact of a film and TV production studio in Los Angeles,
CA
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings in 35 Texas counties.
N• Calculated the economic impact of constructing and operating the world's tallest
residential structure in Chicago, IL

N• Calculated the economic impact of constructing and operating a mixed-use
commercial and residential building in Seattle, WA
N• Calculated the economic impact of constructing and operating a hotel in Cleveland,
OH

N• Calculated the economic impact of a research facility in Jupiter, FL
N• Calculated the economic impact of constructing and operating an assisted living
center in Horry County, SC
N• Calculated the economic impact of constructing and operating a chain pharmacy in
Chicago, IL
E• Calculated the economic impact of constructing and operating a high-end hotel and
resort in Aspen, CO
N• Calculated the economic impact of constructing and operating an assisted living
center in Dallas, TX
E• Calculated the economic impact of constructing and operating an medical
assistance company in Bronx, NY
E• Calculated the economic impact of constructing and operating a mixed-use
commercial building in Queens, NY
E• Calculated the economic impact of operating a livery service in Queens, NY
N• Calculated the economic impact of constructing and operating residential properties
in Southern California
N• Calculated the economic impact of operating a film and TV production studio in Los
Angeles, CA
N• Calculated the economic impact of drilling oil wells in Montana

630

 58

N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for 43 counties in Texas
E• Calculated the economic impact of constructing and operating a restaurant and
dinner theater in Guam

N• Constructed an input/output model for the Commonwealth of the Northern Mariana
Islands, and used it to calculated the economic impact of constructing and operating a
restaurant in Saipan.
E• Calculated the economic impact of constructing and operating a new hotel in Miami,
FL

E• Calculated the economic impact of constructing and operating a resort and wellness
center in South Florida
N• Calculated the economic impact of expanding and operating a ski resort in
Vermont.
N• Calculated the economic impact of constructing and operating residential and
commercial buildings in 20 counties in South Central Texas
N• Calculated the economic impact of constructing and operating a hotel near the
Newark, NJ airport
E• Calculated the economic impact of constructing and operating a company to
process health insurance benefits in South Florida
E• Calculated the economic impact of constructing and operating a veterinary hospital
in Palm Beach County, FL
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for all counties in MA, CT, Rl, and NH
N• Calculated the economic impact of constructing and operating a residential
construction company in Maryland
N• Calculated the economic impact of constructing and operating various residential
and commercial buildings for the entire state of Oklahoma
N• Calculated the economic impact of constructing and operating a company for
manufacturing dental implants in Cuyahoga County, OH
N• Calculated the economic impact of constructing and operating a mixed-use
commercial facility in Brooklyn, NY

631

 59
N• Calculated the economic impact of constructing and operating an office building for
financial services in downtown Manhattan, NY
N• Calculated the economic impact of constructing and operating a mixed-use facility
in Southern California
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a retail shopping
center in Tampa, FL
N• Calculated the economic impact of constructing and operating a mixed-use
commercial building in Seattle, WA
N• Calculated the economic impact of constructing and operating a charter school in
Arizona
N• Calculated the economic impact of constructing and operating a resort in
northeastern Utah
N• Calculated the economic impact of operating an online video game company
N• Calculated the economic impact of constructing and operating a hotel in New York
City
N• Calculated the economic impact of constructing and operating a fashion mall in
South Florida
E• Calculated the economic impact of construction and operation of a new automobile
assembly plant in Petersburg, VA
N• Calculated the economic impact of operating a call center for the U.S. government
in Muskogee, OK
N• Calculated the economic impact of developing a mixed-use commercial and
residential center in Scottsdale, AZ
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in New Jersey to process waste material on a pollution-free basis.
N• Calculated the economic impact of constructing and operating a "Green Box" facility
in Washington State to process waste material on a pollution-free basis.
E• Calculated the economic impact of constructing and operating a new hotel in Coral
Gables, FL

632

 60

E• Calculated the economic impact of developing a new residential community in
Brevard County, and retail stores and restaurants in St. Lucie County, FL
N • Calculated the economic impact of a new business to store and process field crops
in Madison, MS
N• Calculated the economic impact of operating food service establishments and
assisted living centers in 40 counties in Texas.
E• Calculated the economic impact of developing a mixed-use commercial center in
Miami, FL
N• Calculated the economic impact of renovating a theater in New York City to show
film highlights of previous Broadway hits.
N• Calculated the economic impact of renovating and operating distressed buildings in
the San Francisco Bay area.
E• Calculated the economic impact of a mixed-use commercial center in Montgomery
County, TX
E• Calculated the economic impact of expanding a manufacturing facility to produce
more energy-efficient lighting in Sarasota, FL
N• Calculated the economic impact of developing facilities for amateur sporting events
in northern GA
N• Calculated the economic impact of developing a mixed-use commercial center in
Missoula, MT
N• Calculated the economic impact of operating call centers in Las Vegas, NV, and
other western Nevada counties
E• Calculated the economic impact of constructing and operating a proton cancer
treatment center in Boca Raton, FL
E• Calculated the economic impact of constructing and operating a "Green Box" facility
in Detroit to process waste material on a pollution-free basis.
E• Calculated the economic impact of renovating and expanding commercial property
in Lower Manhattan
N• Calculated the economic impact of constructing student housing and retail stores in
Davie, FL

633

 61
E• Calculated the economic impact of constructing residential housing near Harvard
University
E• Calculated the economic impact of developing mixed-use commercial centers in
Broward County, FL
E• Calculated the economic impact of renovating a Dallas apartment building
E• Calculated the economic impact of renovating and operating a nursing home in Las
Vegas, NV
E• Calculated the economic impact of constructing a hotel and shopping center in
Miami, FL
E• Calculated the economic impact of developing a design center in Miami/Dade
county, FL
E• Calculated the economic impact of developing and operating a chain of children's
playrooms and party facilities in South Florida
E• Calculated the economic impact of developing a new stadium for the Nets
basketball team, to be located in Brooklyn, NY
E• Calculated the economic impact of developing a Marriott hotel in Washington, D.C.
E• Calculated the economic impact of developing and operating a casino for foreign
patrons in Las Vegas, NV
E• Calculated the economic impact of operating a series of yogurt fast-food restaurants
in South Florida
E• Calculated the economic impact of constructing steel homes and commercial
buildings in South Florida
N• Calculated the economic impact of construction and operation of a farm
distillery in Vermont
N• Calculated the economic impact of purchase and renovation of deeply discounted
residential properties in South Florida
N• Calculated the economic impact of a hotel to be built near LaGuardia Airport in
Queens, NY
N• Calculated the economic impact for several mixed-use commercial and residential
properties for a regional center covering southern Wisconsin and northern Illinois.

634

 62
N• Calculated the economic impact for mixed-use commercial project in Flushing, NY
E• Calculated the economic impact for major new hotel near the Washington, D. C.
conference center
N• Calculated the economic impact of an assisted living center in suburban Atlanta,
GA
N• Calculated the economic impact of an office tower in mid-town Manhattan for the
diamond trade
N• Calculated the economic impact of three mixed-use commercial and residential
projects in Santa Clara County, CA
N• Calculated the economic impact of six mixed-use commercial and residential
projects in Los Angeles, Orange, Riverside, and San Bernardino counties
N• Calculated the economic impact of operating a chain of pizza restaurants in
southern Florida.
N• Calculated the economic impact of constructing and operating an assisted living
facility in Atlanta, GA
E• Calculated the economic impact of constructing and operating an expansion of
University Hospital in Cleveland, OH
E• Calculated the economic impact of a wastewater treatment plant in Victorville, CA
N• Calculated the economic impact of drilling for geothermal energy and constructing
and operating power plants in several counties in Nevada
E• Calculated the economic impact of a vacation club operation in Orlando, FL
E• Calculated the economic impact of constructing and operating an extended-stay
hotel in Boston, MA
E• Calculated the economic impact of constructing and operating an assisted living
facility in Walton County, FL
N• Calculated the economic impact of manufacturing and constructing residential and
commercial steel modular buildings in Lee County, FL
E• Calculated the economic impact of a chain of yogurt and juice stores and
restaurants in southern Florida

635

 63
E• Calculated the economic impact of two mixed-use commercial developments in
Orange County, CA.
E• Calculated a Targeted Employment Area by census tracts for six counties in the
Houston, TX metropolitan area
E• Calculated the expansion of new hybrid car manufacturing facility from Mississippi
to Tennessee and Virginia.
E• Calculated the economic impact of construction and operation of a skilled nursing
facility in Las Vegas, NV.
N• Calculated the economic impact of construction and operation of a proton cancer
treatment center and medical offices buildings in Los Angeles County, CA.
E• Determined the economic impact of improving facilities at the Port of Baltimore in
order to attract more shipping from the Panama Canal when the locks are widened.
N• Calculated the economic impact of a major hotel and resort area in Ft. Lauderdale,
FL.
N• Calculated the economic impact of building steel homes in South Florida, including
the local manufacture of steel fabricated parts.
E• Calculated the economic impact of constructing and operating a hotel at Times
Square in New York City.
N• Calculated the economic impact of a mixed-used residential and commercial project
in Atlanta, GA.
E• Calculated the economic impact of expanding and opening new restaurants in
Dallas, TX. In a separate project, calculated the economic impact of renovating,
refurbishing, and operating a boutique hotel in Dallas, TX.
E• Calculated the economic impact of building and operating low-income housing in
Boston, MA.
N• Calculated the economic impact of constructing and operating assisted living
facilities in eight rural Texas counties.
N• Calculated the economic impact of a mixed-use commercial project in Riverside
County, CA.
E• Calculated the economic impact of opening a manufacturing plant for "green" motor
vehicles in the Detroit, Ml area.

636

 64
E• Calculated the economic impact of constructing and operating hotels and
restaurants in Columbus, MS.
E• Calculated the economic impact of operating restaurants in the Hotel Win
Hollywood, CA.
N• Calculated the economic impact of a mixed-use commercial project in McCook, IL
(suburban Chicago).
N• Calculated the economic impact of constructing and operating a water-based
amusement facility in San Diego, CA.
N• Calculated the economic impact of a mixed-use commercial facility in suburban
Cincinnati, OH (project is in KY).
E• Calculated the economic impact of constructing and operating a casino, hotel, and
restaurant in Las Vegas, NV.
N• Calculated the economic impact of a new academic institution for alternative energy
in Santa Clarita, CA.
N• Calculated the economic impact of several mixed-used projects in San Francisco,
Alameda County, Santa Clara County, and Fresno County.
N• Calculated the economic impact of a super energy store and solar farm in Riverside
County, CA.
N• Calculated the economic impact of a prostate cancer treatment center in South
Carolina.
E• Calculated the economic impact of refurbishing and expanding retail space at the
George Washington Bridge in New York City.
E• Calculated the economic impact of building Atlantic Yards, new stadium for the New
York Nets, in Brooklyn, NY
N• Calculated the economic impact of an assisted living center and several mixed-use
commercial facilities in the Reno, NV area.
E• Calculated the economic impact of buying residential properties at deep discount
prices, refurbishing and selling them, in South Florida.
N• Calculated the economic impact for a fractional-ownership marina in Port Charlotte,
FL, plus office space, retail stores, restaurants, and a home brokerage office.
N• Calculated the economic impact of construction and operation of four retirement
homes in Vermont.

637

 65

E• Calculated the economic impact of an upscale retail shopping center in Vail, CO.
and a medical office building in Edwards, CO (both in Eagle County).
E• Calculated economic impact of a wind turbine manufacturing plant in Larimer
County, CO
N• Calculated economic impact of a hotel, retail stores, restaurants, office buildings,
and bank facilities in Pasadena, CA
N• Calculated economic impact of a luxury hotel and condominiums in Destin, FL
N• Calculated economic impact of constructing and operating a mixed-use commercial
project in Jupiter, FL
E• Determined whether 17 possible restaurant locations in Miami/Dade and Broward
Counties qualified as Targeted Employment Areas.
E• Determined the economic impact of opening and operating a slot-machine casino in
Hanover, MD, as part of a proposed EB-5 regional center for the Baltimore metropolitan
area.
N• Calculated the economic impact of renovating and expanding a restaurant on
Martha's Vineyard, MA, as part of an EB-5 regional center in that state.
N• Determined the economic impact of assembling and installing solar panels for
residences in the state of LA.
E• Determined a Targeted Employment Area for Dallas, TX as part of a proposed EB-5
regional center for the Dallas area.
N• Calculated the economic impact for various mixed used projects for a proposed
regional center for the entire State of Texas, including shopping centers, office buildings,
restaurants, assisted living centers, medical technology facilities, and other personal
and business services.
N· Calculated the economic impact for the construction and operation of several fastfood restaurants in 10 counties in central California.
N• Calculated the economic impact for the renovation and expansion of a shopping
mall in Greenville, SC.
E• Calculated the economic impact of buying existing apartment buildings at deep
discount prices, renovating and operating them, in 21 counties in FL.
N• Calculated the economic impact of building and operating an institute for proton
cancer therapy for a proposed EB-5 regional center in Brooklyn, NY.

638

 66

N• Calculated the economic impact of building and operating a mixed-use facility with
medical offices, hotels, and apartments for a proposed EB-5 regional center in Queens,
NY.
E• Determined a Targeted Employment Area for Philadelphia, PA as part of a proposed
EB-5 regional center for the Philadelphia area.
N• Calculated the economic impact of a proposed office building and mixed-use facility
for an EB-5 regional center in Dallas, Texas
N· Calculated the economic impact for various mixed-use projects for a proposed EB-5
regional center in the greater New York City area, including an extended stay hotel,
urgent care center, financial lending firm for alternative assets, retail stores, apartments,
office space, warehouses, industrial "flex" space, entertainment centers, restaurants,
conference and convention centers, nursing home and assisted living facilities, medical
offices, medical technology facilities, and high-tech manufacturing.
N· Calculated the economic impact of "green" hotels in 10 counties in Central California.
N• Calculated the economic impact of generic projects in manufacturing, financial
services, health services, hotels, and restaurants for a proposed regional center for the
state of Florida.
E• Calculated the economic impact of 12 different types of economic activity for an
expansion of the Palm Beach Regional Center to five contiguous counties.
N• Calculated the economic impact of a new auto parts plant in Alabama to supply
parts to Kia automobiles.
N• Calculated the economic impact of opening fast-food restaurants in Miami/Dade and
Broward counties in FL.
N• Calculated the economic impact of a mixed-use commercial center in Flushing,
Queens County, NY.
E• Calculated the economic impact of revitalizing and renovating part of the Brooklyn
Navy Yard for "green" manufacturing facilities.
E· Calculated the economic impact of 12 different types of economic activity for various
counties in Charlotte and Sarasota counties, FL
E• Calculated the economic impact of four new manufacturing and distribution
companies in Palm Beach County, FL.
N• Calculated the economic impact of developing a resort area and building residences
in rural Tennessee.

639

 67
N• Calculated the economic impact of developing and operating a resort area in
Southern Arizona.
N• Calculated the economic impact of revitalizing the depressed East Side of
Cleveland, Ohio, with new commercial and industrial buildings.
N• Determined the nationwide economic impact of a $1 billion investment in
Mississippi for a new hybrid motor vehicle plant.
N·
Determined the economic impact of expanding a shipyard in Southeastern
Louisiana.
N·
Calculated the economic impact of a new shopping center in Buena Vista,
California, and two other generic shopping centers in Los Angeles and San Bernardino
counties.
E• Calculated the economic impact of enhancing resort areas in eight rural counties in
Colorado.
N• Calculated the economic impact of the rehabilitation of Fitzsimons Village in Aurora,
Colorado, by adding an office building with medical labs, hotel, shopping center, and
residences.
E• Determined the economic impact of a mixed-use commercial center for the Kansas
City metropolitan area.
N• Calculated the number of jobs created for a film production company in New York
City.
N• Calculated economic impact of small-scale rooftop solar panels in various counties
in California.
N•
Calculated economic impact of 7 different types of proposed businesses for a
proposed regional center in the Bay Area of California.
N• Determined the economic impact of a new biological research park, office building,
and logistics center in Wooster, Ohio.
E• Calculated the economic effect of a mixed-use urban renewal project in Cleveland,
Ohio.
N• Calculated economic impact of dairy farm and cheese processing plant in Northern
California.

640

 68
N•
Determined economic impact of a shipyard, food processing plant, and
semiconductor plant for a proposed regional center in Louisiana and Mississippi.
N• Calculated the economic impact of a new gaming casino in Natchez, Mississippi.
N• Developed an Input/output Model for Guam, which was then used to calculate the
economic impact of several generic projects.
N•
Calculated the economic impact of a retail shopping center in suburban Los
Angeles County.
N· Prepared an economic impact analysis for the "timber to homes" project for a
proposed regional center in Colorado.
N•
Calculated the economic impact for a proposed regional center in Baltimore,
Maryland that would include the rebuilding of depressed areas in East Baltimore and
along the riverfront.
N· Prepared the economic analysis for a proposed EB-5 regional center for the entire
state of Florida that included impact calculations for 14 different types of industries.
N• Prepared the economic analysis for a proposed EB-5 regional center in the San
Francisco Bay area that included calculations for 10 different types of industries.
N• Prepared economic impact calculations for proposed EB-5 regional centers in New
York City and Northeastern New Jersey.
• Calculated the economic impact of a rehabilitated office building in Albuquerque, New
Mexico, including the increase in high quality jobs.
• Calculated the economic impact of a rehabilitated skilled nursing center in East Los
Angeles, California, including the impact on nearby census tracts.
MARKETS
N• Calculated the economic impact of development of warehouse and light industrial
manufacturing space in Las Vegas, Nevada.
N· Calculated the economic impact of rehabilitation and expansion of a vacation and
health spa in Sharon Springs, New York
N• Calculated economic impact of revitalizing an old resort hotel and adding new
facilities for Lake Geneva, WI.
• Calculated the employment and tax effects for a portfolio of projects undertaken under
the New Market capital program.

641

 69
E• Calculated generic employment changes for proposed EB-5 project for an Inland
Port in Palm Beach County, FL
N· Calculated the economic impact of construction of El Monte Village in El Monte, CA.
• Calculated the economic impact of moving the Social Security Administration building
in Birmingham, AL, and revitalizing the surrounding neighborhood.
• Calculated the economic impact of rehabbing and expanding the Everett Mall in
Everett, WA.
• Determined the economic impact of building a new medical center in Charleston, SC

N• Calculated economic impact of expanding Sugarbush resort in VT. Study included
expansion of existing facilities and addition of new facilities.
• Calculated economic impact for new market tax credit program in Portsmouth, N.H.
Study included both overall economic impact, and the increase in employment and
income and the decrease in the unemployment rate and incidence of poverty in
individual census tracts. NEW 1\IIMKI'\.
N• Calculated the economic benefits of EB-5 programs for foreign investors for a
mixed-use construction project, including a hotel, retail stores, apartments, and a sports
stadium in the Washington, D. C. metropolitan area
N· Calculated the economic benefits of EB-5 programs for a mixed-used retail shopping
center in the New York City metropolitan area.
N• Calculated the economic benefits of EB-5 programs for foreign investors for
proposed shopping centers in five separate counties in Southern California, including
differential impacts of building the shopping centers in different counties.

B. Projects for State and Local Governments

• Constructed an econometric model for the State of New York and determined the
change in employment, labor income, and tax revenues for 43 different tax changes
proposed by the Governor's office.
• Constructed a detailed econometric model for the State of Pennsylvania to determine
the economic impact of the complete panoply of state taxes levied; the model contains
over 1,000 equations. In cooperation with American Economics Group, the model was

642

 70
developed to simulate the effect of changes in any state tax rate on households and
businesses by income deciles, household status, age of individuals, size of households,
and many other demographic variables. The change in business taxes can also be
simulated for detailed industry classifications.
• Determined whether the Washington, D.C. water and sewer authority should accept a
high bid for a new waste disposal system. Decision to reject has saved the authority
over $200 million, as construction prices turned down sharply as predicted.
• Built an econometric model to determine the "tax gap" caused by Internet sales for the
state of Minnesota.
• Determined appropriate levels of shelter grants individual counties in New York State,
and for utility allowances in New York City. Reviewed and prepared testimony in
ongoing court cases in these areas.
Calculated the economic impact of the revitalization of downtown Milwaukee,
Wisconsin.

C. Economic Impact of Casino Gaming

• Built an econometric model to predict the growth of the gaming industry over the next
decade, and the economic impact of that industry on employment and tax revenues at
the Federal and state levels.
• Estimated the economic impact of Indian casino gaming nationally and for the State of
Wisconsin.
• Determined the economic impact of the Oneida Indian gaming casino on the Green
Bay metropolitan area.
• Estimated the negative economic impact on the Milwaukee area if a new Indian
gaming casino were to be built in Kenosha, Wisconsin.
D. Economic Impact of Smoking Bans and Higher Taxes

• Testified on economic impact of smoking bans in Canada; certified as an expert
witness by the Court.
• Examined the impact of smoking bans on restaurant sales in several different
locations in the U.S. to determine how much sales changed when these bans were
imposed, and the differential effects depending on whether these bans were partial or
total.

643

 71

• Determined the cross-border effects on retail sales from differential rates in cigarette,
gasoline, and alcohol excise taxes
Determined the economic impact of higher cigarette taxes on minority group
employment.
• Estimated the economic impact and loss of Federal and state tax revenues when
higher cigarette prices lead to increased smuggling.

E. Consulting Projects for Travel and Tourism
• Built an econometric model to predict tourism trips and revenues for the major regions
of the U.S. economy.
• Constructed econometric models to predict tourism in Las Vegas and Orlando.
• Using the IMPLAN model, predicted economic impact of tourism and travel
expenditures for all counties in Pennsylvania.

F. Other Private Sector Consulting Projects
Calculated the revenue gain at the Federal, state and local level generated by
domestic manufacturing of Airbus parts and equipment.
• Calculated the economic impact of proposed EPA bans on fluoropolymer production.
• Estimated the size and economic importance of the fluoropolymer industry, and
calculated economic impact of shutting down domestic production.
• Built an econometric model to examine how U.S. tax and regulatory policies help
determine whether the gold mining industry would invest in the U.S. or other countries.
Testified before Congress to help defeat legislation inimical to the mining industry.
• Built an econometric model to predict consumer bankruptcies, based on recent growth
in consumer credit outstanding, the overall economic environment, and recent changes
in credit regulations
• Estimated the economic impact of the ethanol subsidy on the U.S. economy and
Farm Belt States, including the impact on the balance of payments, employment, and
tax receipts. Testified before Congress to help pass legislation to extent subsidies to
the ethanol industry.

644

 72
• Built an econometric model to determine the impact of updating and improving the
system of locks on the Upper Mississippi River on corn prices and exports, farm
income, and the overall economy.

BOOKS PUBLISHED
Macroeconomics for Managers, Blackwell, 2003
Practical Business Forecasting, Blackwell, 2002
Economic Impact of the Demand for Ethanol, Diane Publishing Company, 1998
How to Make Your Shrinking Salary Support You in Style for the Rest of Your Life,
Random House, 1991
The Truth About Supply-Side Economics. Basic Books, 1983.
A Supply-Side Model of the U. S. Economy, mimeo (prepared for Senate Finance
Committee), 1980.
An Econometric Model of the French Economy:
O.E.C.D, March 1969.

A Short-Term Forecasting Model.

Econometric Gaming (with L. R. Klein and M. J. Hartley). Random House, 1969.
Macroeconomic Activity: Theory, Forecasting and Control. Harper & Row, 1969.
The Wharton Econometric Forecasting Model (with L.R. Klein), Economics Research
Unit, Wharton School: University of Pennsylvania Press, 1967. Enlarged edition, 1968.
Over 30 articles in major academic journals and publications (list on request)

645

 TAB

EXHIBIT NAME NUMBER

Sample Loan Terms. 22.

646

' ";Jft v.112/20/2012

(b)(4)

FORM OF LOAN COMMITMENT
88 Morgan Street Funding, LLC
1295 U.S. Highway One, Suite 300
North Palm Beach, FL 33048
[date], 2013

647

  

aft v.1 12/20/2012

 

 

 

 

648

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649

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650

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v.112/20/2012

Accepted and Agreed as of the date set forth above:

88 Morgan Street, LLC
A limited liability company

Name:
Title:

651

 1 

EXHIBIT 1

FUNDING 

652

EXHIBIT NAME

TAB
NUMBER

Evidence for Request for Expedited Processing
Memorandum Supporting Expedited Processing Request

23.

653

 N,LLP
THF

COMPREHE~JSiVE

IMMIGRATION I;\W FIRM

Memorandum
To:

U.S. Citizenship & Immigration Services, EB-5 Visa Unit

From: U.S. Immigration Fund-NJ, LLC
Re:

Request for Expedited Processing ofl-924 Application for Regional Center

Date: December 12, 2012

The U.S. Immigration Fund -NJ, LLC ("USIF-NJ") is requesting Expedited Processing
of this I-924 Application for Regional Center because of the urgent need to attract investment to
the areas of New Jersey devastated by Hurricane Sandy following its landfall on October 29,
2012.
The USCIS Expedite Processing Request criteria are satisfied in this case due to the
Extreme Emergent and Humanitarian Situation of the destruction caused by Hurricane
Sandy.

Hurricane Sandy
According to the White House, Hurricane Sandis landfall on October 29, 2012 caused
·'major flooding, extensive structural damage, and significant loss of life. A dangerous nor' easter
followed 9 days later causing additional damage and undermining the recovery effort. As a result
of these events, thousands of individuals were displaced and millions lost power, some for an
extended period of time. Over 1,600 stores were closed, and fuel distribution was severely
disrupted, further complicating the recovery effort. New York and New Jersey -- two of the
Nation's most populous States-- were especially hard hit by these storms". See Executive Order
of December 7, 2012, appointing Hurricane Sandy Rebuilding Task Force at Exhibit 23.
According to the U.S. Department of Labor, Hurricane Sandy brought "[h]igh winds and
flooding [that] caused dozens of deaths and massive damage to homes, businesses, power
systems, transportation systems, and other property in many states, especially New Jersey and

654

 N,L
THE

COMPREHEt'~S!VE

IMMIC;RATION L;\W FIRJv\

the New York metropolitan area. Sandy's reach placed it among the largest Atlantic tropical
cyclones on record." See Exhibit 23.
Hurricane Sandy is the 2nd largest Atlantic storm by size, covering an area twice the size
of the State of Texas at it made landfall on the Jersey Shore on October 29, 2012. It had the
lowest barometric pressure of any hurricane or storm on record (meaning that it packed the most
force of any recorded storm) and made landfall with winds over 100 miles per hour. It brought a
storm surge measured at 13 feet in New York, and the highest ever recorded wave was measured
in New York Harbor, at over 32 feet. See news reports enclosed at Exhibit 24.
After its passing over New Jersey and New York, over 7.1 million persons were without
electricity, flooding was reported throughout the area, entire communities on the Jersey Shore
had been wiped off the map, Jersey City was flooded by several feet of water, and lower
Manhattan had experienced its worst t1ooding in a nearly a century. See news reports enclosed
at Exhibit 24.
The area struck by Hurricane Sandy includes some of the most populous counties in the
United States, such as Hudson County. As observed by the Department of Labor: "Hurricane
Sandy struck at the most densely populated region of the United States. Four of the five counties
with the highest number of labor force participants per square mile in 2011 were among those
hardest hit by Sandy. All 26 of the counties designated as major disaster areas are among the top
10 percent of U.S. counties in terms of labor force densiti' (See Department of Labor report at
Exhibit 23).
The severity of the devastation of these areas made news around the world. We enclose
at Exhibit 25 news photographs of the severe devastation in areas from important t1ooding in
Jersey City, in Hudson County, to total destruction of boardwalks and homes in Union County,
Monmouth County and Middlesex County.
On October 30, 2012, President Barak Obama ordered the U.S. federal government to
declare federal disaster areas in New Jersey. In response, the Federal Emergency Management
Agency (FEMA) issued a Major Disaster Declaration (DR-4086). The New Jersey action by
President Obama and FEMA declares Disaster Areas in the following New Jersey counties:
Atlantic, Cape May, Essex, Hudson, Middlesex, Monmouth, Ocean and Union. The Counties of
Hudson, Middlesex, Monmouth, Ocean and Union are precisely within the Territory of the
USIF-NJ. We enclose a copy of the FEMA Disaster Declaration in Exhibit 23.
2
655

 LL
THE COt/,PRFHFNSiVE IMMI(;RATION

L;~W

FIRM

On December 7, 2012, President Obama created a special task force to address the urgent
need to assist in rebuilding and recovery efforts ofNew Jersey and New York. According to the
White House, "A disaster of Hurricane Sandy's magnitude merits a comprehensive and
collaborative approach to the long-term rebuilding plans for this critical region and its
infrastructure. Rebuilding efforts must address economic conditions and the region's aged
infrastructure -- including its public housing, transportation systems, and utilities -- and identify
the requirements and resources necessary to bring these systems to a more resilient condition
given both current and future risks."
Territory of the USIF-NJ Covers the Devastated Areas of New Jersey

The operating Territory the USIF-NJ includes the northern Jersey Shore area in Hudson
County, Union County, Ocean County, Essex County, Monmouth County and Middlesex
County.
Attracting Investment to Devastated Region

Initial news reports projected that the total dollar amount of the damage caused by
Hurricane Sandy would range from $20 Billion to $30 Billion. Sadly, even these high estimates
were below the actual need for the devastated areas in New Jersey and New York. On December
7, 2012, President Obama wrote to the Hon. John Boehner, Speaker of the House of
Representatives, to request a financial aid package for New Jersey and New York of $60 Billion
dollars. See Exhibit 24. The devastation from Hurricane Sandy in New Jersey is still being
calculated, and is projected to be in excess of $60 Billion.
Foreign investment attracted by the USIF-NJ will contribute to alleviating the burden on
federal and State government assistance by spurring construction in the devastated areas.
Reducing Unemployment

Hurricane Sandy caused a significant spike in unemployment in New Jersey. Data from
weekly unemployment claims in New Jersey for November show a 300% increase in
unemployment claims compared to the previous year's claims in November of 2011. See
Exhibit 25. The long-term effects of unemployment add to the heavy human toll, as well as the
projected recovery costs of Hurricane Sandy.
3

656

 THE COMPREHFNSIVE IMMIGRATION LAW FIRM

Investments to the devastated areas in New Jersey will contribute significantly to
alleviating the spike in unemployment caused by Hurricane Sandy.
(b)(4)

The initial project of the USIF-NJ is named 88 Morgan Street and is planned for the
federally designated disaster area of Hudson County. The 88 Morgan Street project is projected
to initiate excavation in March of 2013, and will createc:Jnew jobs in its construction and
operations over the course of its build. These are critically important jobs that will alleviate the
emergent unemployment situation in the devastated areas ofNew Jersey.
Conclusion

Based on the foregoing, we firmly believe that there is ample evidence to support the
request by USIF-NJ for Expedited Processing of its 1-924 Application for Regional Center. The
operations of the USIF-NJ would not only attract needed investment to the devastated areas in
New Jersey, it would be an excellent example of the ability of the EB-5 Regional Center Pilot
Program to react with speed and flexibility to contribute capital to the needy areas of the United
States.
We thank you in advance for your consideration of this Expedited Processing Request.

4

657

 EXHIBIT NAME

U.S. Government Evidence of the Devastation from Hurricane Sandy
•

•
•
•

•

TAB
NUMBER

24.

President Obama's Executive Order Declaring Disaster Area for New
Jersey Counties that form part of the Regional Center's Territory,
dated October 30, 2012.
President Obama's Executive Order Creating the Hurricane Sandy
Rebuilding Task Force dated December 7, 2012.
President Obama's Appropriations Request to the House of
Representatives for Hurricane Sandy Relief, dated December 7, 2012.
U.S. Department of Labor, Bureau of Labor Statistics, "Hurricane
Sandy: A Pre-Stonn Look at Affected Areas," dated November,
2012.
U.S. Department of Labor, "Employment Losses After Hurricane",
dated December 5, 2012. Analysis on the impact of Hurricanes
confirming the negative impact of the stonn on employment and
household earnings.

658

 Executivl: Order

Establishing the Hurricane Sandy Rebuilding Jask Force

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12/14/12 10:57 AM

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Off1ce of tt1e Press Secretary

'-'-1""\..J.J

For Immediate Release

December07, 2012

IrS THE RIGf IT

TAX CUTS

THIN(~

TO DO

Executive Order -- Establishing the Hurricane Sandy
Rebuilding Task Force
EXECUTIVE ORDER
ESTABLISHING THE HURRICANE SANDY REBUILDING TASK FORCE

By the authonty vested in me as President by the Constitution and the laws of the United States of America, it is
hereby orderel1 as follows:
S<Jction 1. Purpose. Hurricane Sandy made landfall on October 29, 2012, resulting in major flooding, extensive
structural damage, and significant loss of life. A dangerous nor'easter followed 9 days later causing additional
damage and undermining the recovery effort. As a result of these events, thousands of individuals were displaced
;:md millions lost power. some for an extended period of time. Over 1,600 stores were closed, and fuel distribution

BI.OG POSTS ON THIS ISSUE
Deccm1ller 14, 2012 9:52AM EST

Hanukkah at the vVhite House: A Menorah
that Survived Sandy

wa,, sr:verely disrupted. further complicating the recovery effort. New York and New Jersey·- two of the Nation's

President Obama and First

most populous States-- were especially hard hit by these storms.

Lady Michelle Obama
welcomed friends and

The Fecleral Emergency Management Agency (FEMA) in the Department of Homeland Security is leading the

leaders from the Jewish

recovery efforts to assist the affected region. A disaster of Hurricane Sandy's magnitude merits a comprehensive

and collaiJorative approach to the long-term rebuilding plans for this critical region and its infrastructure. Rebuilding

community to celebrate
the sixth night of Hanukkah.

efforts must address economic conditions and the region's aged infrastructure -- including its public housing,

transf'ortatron systems, and utilities -- and identify the requirements and resources necessary to bring these

Decemtlet 14. 2012 12:00 AM Es·T

systoms to a more resilient condition given both current and future risks.

West Wing Week: 12/14/12 or "True to
Ourselves and Our History"

This order establishes the Hurricane Sandy Rebuilding Task Force (Task Force) to provide the coordination that is
necessary to support these rebuilding objectives. In collaboration with the leadership provided through the National

December 13,2012 400 PM EST

Disaster Recovery Framework (NDRF), the Task Force will identify opportunities for achieving rebuilding success,

US Leadership to Advanee Equality for
LGBT People Abroad

cons1s1ent witrt

triH

NDRF's commitment to support economic vitality, enhance public health and safety, protect and

In honor of Human Rights Week, Samantha Power

enhance natural and manmade infrastructure, and ensure appropriate accountability. The Task Force will work to
ensure that tt1e F<Jderal Government continues to provide appropriate resources to support affected State, local,

explains how advancing the human rights of

and !nb~l communrlles to improve the region's resilience. health. and prosperity by building for the future

lesbian, gay, bisexual and transgender (LGBT)

:;@s;,._:LEstablist1rnent of the Hurricane Sandy Rebuilding Task Force. There is established the Hurricane Sandy

from, our comprehensive human rights agenda.

people around the world is central to, not separate

f~ebuilding Task

Force, which shall be chaired by the Secretary of Housing and Urban Development (Chair).
VIEW ALL RELATED BLOG POSTS.

\d) In addition to the Chair. the Task Force shall consist of the head of each of the following executive departments,

agencies. and offices, or their designated representatives
)"I'

(ii the Department of the Treasury;
(ii) tl1e Department of the Interior;
(11i) the Department of Agriculture;
(iv) the Department of Commerce;
linkndln

(v) the Department ot Labor;

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 Executive Order······ Establishing the Hurricane Sandy Rebuilding Ja~k Force

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(vi) tr1e Department of Health and Human Services;
(vit) the Department of Transportation;
(vtti) tile Department of Energy;
(ix) th•'J Department of Education;

(x) Ihe Deparlment of Veterans Affairs;
(xt) Ihe Department of Homeland Security;
(xi1) the Enwonmental Protection Agency;

(x;it) the Small Business Administration;
lxtv) the Army Corps of Engineers;
(xv) the Offtce of Management and Budget;

(xvi) lhe National Security Staff;
(xvit) the Domestic Policy Council;
(xv11i) the Nattonal Economic Council;
(xtx) the Council on Environmental Quality:
(xx) the Office of Science and Technology Policy;
(xxt) tho Council of Economic Advisers;
1xxtt) t11e White House Office of Public Engagement and Intergovernmental Affairs;
(xxiti) the White House Office of Cabinet Affairs; and
(xxtv) such otr1er agencies and offices as the President may designate.
(b) Tho Ch<W shall regularly convene and preside at meetings of the Task Force and determine its agenda as the
Ti!Sk Force exercises the functions set forth in section 3 of this order. The Chair's duties shall also include:
(1) communicating and engaging with States, tribes, local governments, Members of Congress, other
stakeholders and interested parties, and the public on matters pertaining to rebuilding in the affected region;
(it) mordin.,ttng the efforts of executive departments, agencies, and offices related to the functions of the Task
Force: and
(in) specifying t11o form and subject matter of regular reports to be submitted concurrently to the Domestic Policy
Council. the Nattonal Security Staff, and the Chair.

Sec. 3. Functions of the Task Force. Consistent with the principles of the NDRF, including individual and family
empowerment, leadership and local primacy, partnership and inclusiveness, public information, unity of effort,
timeliness and flexibility, resilience and sustainability, and psychological and emotional recovery, the Task Force
shall:

(;;) worl< closely with FEMA in the coordination of rebuilding efforts with the various intergovernmental activities
taken in conJunction with the NDRF;

(tl) de sen be Ihe potentially relevant authorities and resources of each member of the Task Force:

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(c) identity and work to remove obstacles to resilient rebuilding in a manner that addresses existing and future risks

and vulnerabilities and promotes the long-term sustainability of communities and ecosystems;
(d) coordinalt' w1th entities in the affected region in efforts to:

(i) ensure the prompt and orderly transition of affected individuals and families into safe and sanitary longterm l1ous1ng;
(1i) pl~n lor the rebuilding of critical infrastructure damaged by Hurricane Sandy in a manner that accounts for
current vulnerabilities to extreme weather events and increases community and regional resilience in responding to
futurr,, impacts:
(iii) support the strengthening of the economy; and
(rv) understand current vulnerabilities and future risks from extreme weather events, and identify resources and

''ut!lrlnties that can contribute to strengthening community and regional resilience as critical infrastructure is rebuilt
and c;cosystem functions are restored;
(e) pnor to the terminat1on of the Task Force, present to the President a Hurricane Sandy Rebuilding Strategy

iStrategy) 8S provided in section 5 of this order;
(f) engage local stakeholders, communities, the public, Members of Congress, and other officials throughout the

areas '1ffected by Hurricane Sandy to ensure that all parties have an opportunity to share their needs and
v1ewpo1nts to 1nform the work of the Task Force, including the development of the Strategy; and

(g)

communicate with affected tribes in a manner consistent with Executive Order 13175 of November 6, 2000,

regar,Jing 1!18 consultation and coordination with Indian tribal governments.

Serc_i..l.S!§ltorce Advisory Group. The Chair shall, at his discretion, establish an Advisory Group to advise the
1ac;k ForcG ;Jnd 1nvite individuals to participate in it Participants shall be elected State, local, and tribal officials and

rnay 1nciu 1:le Governors, Mayors, County Executives, tribal elected officials, and other elected officials from the
affectc"d 1·egion as the Chair deems appropriate. Members of the Advisory Group, acting in their official capacity,
may designate employees with authority to act on their behalf. The Advisory Group shall generally advise the Task

Force ''s requested by the Chair, and shall provide input on each element of the Strategy described in section 5 of
th1s order

Ser;c_i Hurricane Sandy Rebuilding Strategy. (a) Within 180 days of the first convening of its members, the Task
Force shall prepare a Strategy that includes:

(1)

(liJ;;

a summary of Task Force activities;

long-term rebuilding plan that includes input from State, local, and tribal officials and is supported by Federal

agencies. which is informed by an assessment of current vulnerabilities to extreme weather events and seeks to
m1tr9ate future risks,

(i1i) specific outcomes, goals, and actions by Federal, State, local, and tribal governments and the private sector,
such as the establishment of permanent entities, as well as any proposed legislative, regulatory, or other actions
that coulcl support the affected region's rebuilding: and
(1v)

a plan for monitoring progress.

(rJ) The executrve departments, agencies, and offices listed in section 2(a) of this order shall, as appropriate and to

the extent permrtted by law, align their relevant programs and authorities with the Strategy.
Sec. 6. Adrntnistration. (a) The Task Force shall have a staff. headed by an Executive Director, which shall provide
support for the functions of the Task Force.
(b l The Exc,cutive Director shall be selected by the Chair and shall supervise, direct, and be accountable for the
administration and support of the Task Force.
(c) At the rPquest of the Chair, other executive departments and agencies shall serve in an advisory role to the Task

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Force on rssues within their expertise.
(d) The: Task Force may establish technical working groups of Task Force members, their representatives, and

rnvited Advisory Group members and elected officials, or their designated employees, as necessary to provide
advrce in support of !herr function.
(e) The Task Force shall terminate 60 days after the completion of the Strategy described in section 5 of this order,

afier whrch FEMA and the lead agencies for the Recovery Support Functions, as described in the NDRF, shall
contrnue the Federal rebuilding coordinating roles described in section 3 of this order to the extent consistent with
the NDRF

Sec. 7. General Provisions. (a) For purposes of this order, "affected tribe" means any Indian tribe, band, nation,
pueL1Io. vrllage, or community that the Secretary of the Interior acknowledges to exist as an Indian tribe pursuant to
the Federally Recognized Indian Tribe List Act of 1994 (25 U.S.C. 479a), located or with interests in the affected

(Ll) To the extent permitted by law, and subject to the availability of appropriations, the Department of Housing and

Urban Development shall prov1de the Task Force with such administrative services, facilities, staff, equipment,
mobile communications, and other support services as may be necessary for the Task Force to carry out its
functrons. using funds provided from the Disaster Relief Fund by agreement with FEMA and any other available and
appror,riate funding.
(c) Members of the Task Force, Advisory Group, and any technical working groups shall serve without any

c1lici!lronal cornpensation for their work on the Task Force, Advisory Group, or technical working group.
(d) Nothinq in this order shall be construed to impair or otherwise affect:

(i) the authority granted by law to an executive department, agency, or the head thereof, or the status of that

clepartment or agency within the Federal Government; or
(11) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or

legislative proposals.
(e) This order shall be implemented consistent with applicable law, and subject to the availability of appropriations.

rf) 1 his order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at
law or in equrty by any party against the United States, its departments, agencies, or entities, its officers.
employees. or agents, or any other person.

BARACK OBAMA
THE WHITE HOUSE,
DHcern!Jm 7, 2012.

http' 1jwww. whitehouse.gov /the-press-office/ 2012 I 12/07 I executive-order-establishing-hurricane-sandy-rebuilding-task -force

Page 4 of 4

662

 EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503

December 7, 2012
The Honorable John Boehner
Speaker of the House of Representatives
Washington, D.C. 20515
Dear Mr. Speaker:
In late October, Hurricane Sandy made landfall and struck the East Coast from North
Carolina to Maine, particularly impacting coastal areas. High winds and storm surge caused
widespread flooding, loss of life, displacement of persons, and significant damage to private
property, public infrastructure, and Federal Government facilities. A dangerous nor' easter
followed nine days later causing additional damage and undermining the recovery effort. As a
result of these events, thousands of individuals were displaced, and millions lost power.
Thousands of stores and businesses were damaged or closed, and fuel distribution was severely
disrupted, further complicating the recovery effort. New York and New Jersey-two of the
Nation's most populous States-were especially hard hit by these storms. Recovery efforts
continue today throughout the region. All told, although estimates of the total damage of
Hurricane Sandy remain in flux, current projections are that Sandy is on track to be the second or
third most costly natural disaster in U.S. history, behind Hurricane Katrina (2005) and close to
Hurricane Andrew (1992). While much of this damage is covered by insurance, current
estimates suggest that a significant amount of damage is not covered.
At the direction of the President, and under the auspices of the National Response and
Disaster Recovery Frameworks, numerous Federal agencies contributed resources and personnel
to respond to the devastating impacts of the storm. As the impacted region addresses the damage
caused by the hurricane, the Administration believes additional Federal resources are necessary
to fund response, recovery, and mitigation efforts. This letter and the enclosed materials request
the funds necessary to finance a needed recovery effort and to help the region prepare for future
challenges, including future severe storms and coastal flooding, as well as impacts associated
with a changing climate.
ln total, the Administration requests $60.4 billion in Federal resources for response,
recovery and mitigation related to Hurricane Sandy damage in all affected States. This includes
et1brts to repair damage to homes and public infrastructure and to help affected communities
prepare for future storms. Attached is a detailed appendix outlining the specific needs, funding
accounts, provisions, and principles that comprise the Administration's request for assistance.
Our Nation has an obligation to assist those who suffered losses and who lack adequate resources
to rebuild their lives. At the same time, we are committed to ensuring Federal resources are used
responsibly and that the recovery effort is a shared undertaking: private insurers must fulfill
their commitment to the region; public assistance must be targeted for public benefit; resources
must be directed to those in greatest need; and impacted States and localities must contribute, as
appropriate, to the costs of rebuilding. Accordingly, consistent with the increased emphasis it
has placed on the integrity of all Federal spending activities, the Administration proposes that

663

 controls be put in place to ensure that funds are used appropriately to protect against waste,
fraud, and abuse.
As you know, the Balanced Budget and Emergency Deficit Control Act of 1985
(BBEDCA), as amended by the Budget Control Act of 2011, allows the Congress to designate
certain spending for disaster relief, which is not subject to the discretionary caps specified in the
statute. Annually, the Office of Management and Budget (OMB) calculates the allowable limit
on funding that can be designated for disaster relief and, for fiscal year (FY) 2013, OMB
calculated a disaster relief adjustment limit of $11.8 billion.
Under the Continuing Appropriations Resolution, 2013 (Public Law 112-175), $6.4
billion in funding enacted in FY 2012 for the Federal Emergency Management Administration
Disaster Relief Fund (DRF) counts toward the FY 2013 disaster relief adjustment1s allowable
limit. No other agencies received funding through the Continuing Resolution that would count
toward that limit. The Administration therefore recommends that the Congress provide and
designate $5.4 billion in additional DRF funding for disaster relief, appropriating the remaining
funds permitted for the disaster relief adjustment in FY 2013 pursuant to the BBECDA. If the
enacted FY 2013 appropriation for the DRF provides a different level of funding designated for
disaster relief than that available pursuant to the Continuing Resolution, the amount remaining
under the disaster relief adjustment's allowable limit would be different and the Administration's
recommendation would need to be adjusted accordingly.
BBEDCA provides that funding may be designated as an emergency requirement if it is
sudden, urgent, unforeseen, and temporary and is for the prevention or mitigation of, or response
to, loss of life or property, as defined in sections 250(c)(20) and 250(c)(2I). The extraordinary
destruction wrought by Hurricane Sandy has created funding needs that meet this definition. In
addition to the amounts recommended to be designated for disaster relief, the Administration
estimates a remaining $55.0 billion in budget authority (including additional borrowing
authority) in FY 2013 is necessary to respond to, and recover from, the impacts of Hurricane
Sandy, and mitigate against future such disasters. The Administration requests that this amount
be provided and designated as an emergency requirement pursuant to BBEDCA. An emergency
designation pursuant to BBEDCA is not subject to the discretionary caps specified in the statute.
Accordingly, this emergency funding can and should be provided without offset.
Thank you for your consideration of these recommendations, additional details for which
are included in the enclosure to this letter. The Administration looks forward to working with
the Congress to help communities recover and rebuild.

0

J · rey . Zients

cputy Director for Management
Enclosure
Identical letter sent to The Honorable Harry Reid
2

664

 Appendix: Detailed Estimates of Necessary Federal Resources
This appendix provides details of the Administration's estimate of Federal funds needed to
address damage from Hurricane Sandy, divided among the respective budget accounts. While
precise losses are still being determined, there is a great need for timely assistance. The
Administration's request ensures urgent and essential needs are being met, while recognizing the
need to prevent losses of this magnitude from future disasters as well as ensuring that funds are
used most effectively and on appropriate activities with proper spending controls. In particular,
the Administration recommends the principles outlined below to guide Hurricane Sandy funding
assistance:
Helping those in greatest need- As a Nation, we have always worked together to assist those
who have suffered losses from disasters, and lack adequate resources to rebuild their lives and
communities. Assistance should be targeted primarily to low- and moderate- income individuals
and families, and limited to repairing and rebuilding primary residences only.
Sharing the responsibility for rebuilding States and localities should contribute to the costs
of rebuilding. The level of damage caused by Hurricane Sandy is expected to meet the
regulatory threshold necessary to increase the Federal share of most disaster programs to 90
percent. In accordance with the whole community approach outlined in the Federal Emergency
Management Agency's National Disaster Recovery Framework, impacted States and localities
will share, as appropriate, the remaining 10 percent of costs.
Ensuring private insurers fulfill their commitments- Federal funds should not supplant
private insurance payments for damage covered by insurance policies in place at the time of the
disaster. While Federal support should be available to those who have suffered losses through no
fault of their own, private insurers must fulfill their commitments to policyholders.
Targeting public assistance for public benefit- Through the Small Business Administration,
the Federal Government has loan programs appropriate to assist many businesses in covering
unmet physical and economic losses from disasters. With limited exceptions related to small
businesses that face long-term business disruption, public resources should not be used to restore
lost revenue or pay for repairs to privately-owned business assets.
Building for the future- To build a more resilient Nation prepared to face both current and
future challenges, including a changing climate, Federal agencies in partnership with State, local,
and tribal officials, and the science community, should inform all plans for recovery and
rebuilding to address the increased risk and vulnerabilities of extreme weather, sea level rise, and
coastal flooding. These investments in planning and rebuilding for the future will help guarantee
the most effective use of public resources invested in the recovery effort and help revitalize the
health, social, economic, and environmental fabric of communities impacted by Hurricane
Sandy.

665

 Coordinating mitigation projects- Projects to mitigate against future such disasters should be
guided by regional response plans crafted through Federal agencies in partnership with State,
local, and tribal entities. These plans will present options ranked by estimated cost-effectiveness,
and will be developed in coordination with the work of the interagency Hurricane Sandy Task
Force led by Housing and Urban Development Secretary Shaun Donovan. Relevant Federal
programs receiving mitigation funds should have flexible transfer authority, to enable funding to
be channeled through the most appropriate Federal programs to accomplish priority activities.
For example, funding provided for transportation mitigation could be utilized for projects
involving multiple modes other than just public transportation.
Planning at the local level- Federal agencies must work in partnership with State, local, and
tribal officials to develop mutually agreed upon assessments of future risks and vulnerabilities
facing the region, including extreme weather, sea level rise, and coastal flooding and incorporate
these into their recovery planning and implementation. This will enable regionally-consistent
policies and planning to guide decisions on wisely investing recovery funds for long-term
resilience. Involving public officials from all levels of government in the planning process will
ensure the strongest recovery for the Nation's communities and citizens.
Ensuring the integrity of Federal spending Consistent with the increased emphasis on the
integrity of all Federal spending activities, agencies should be required to implement a
comprehensive program of internal controls for all programs supporting Sandy recovery efforts.
Using existing Office of Management and Budget (OMB) guidelines, agencies should submit
internal control plans to ensure that funding decisions are aligned with award purposes and have
been properly reviewed, and to make certain that awards receive proper oversight. These plans
should include enhanced grant management protocols that include quarterly program and
financial monitoring, timely submission of single audit reports and grants closeout, and improper
payments testing and reporting for all Federal programs supporting Sandy recovery activities. In
addition, any spending plans submitted to agencies by recipients of Sandy-related funds should
be reviewed by OMB for consistency with these principles and applicable law. Furthermore, the
Administration recommends that a trigger be established to withdraw awards for certain grants
that are not expended within 24 months of award

666

 llurricanc Sandy: BLS Spotlight on Statistics

Page 1 of7

Spotlight on Statistics
10 i2 ARCHIVE
ti:JF"I'~Ai~E

Feedback

SI\NDY: i1 PRE
LOOK AT AfTECIHJ

Please send us
H!SP!I!'.JlC
f

:r i<l.!/l.CE MO!~JTH

Hurricane Sandy: A Pre-storm Look at
Affected Areas

your feedback

and comments
about this
article.

OF 200?

Hurricnm;' Sandy swept up tlw East Coast of the United Stat('/< in late Ortolwr :lOI:I. The ;;torm began
in tlw southern Caribbean St'<l and quickly developed first into a l:mpical storm, then into a
10111\RCHl\IE

hunicane. Hurricane Sandy made landJidl in the [nited States the evening of October 29 near
Atlantic City, New ,Jersey,

OUT

High winds and flooding caused

AT WORK

doz('ns of de;;th;; and mas,ivP damage
to homes, businesS<!S, power systems.

1.010 ARCHIVE

transportation s.vstems, and other
FOR THOUGHT

property in many states, especially

COI.l.EGE

New .Jersey and thl' Nl'w York

TPtWEL

metropolitan area. Sandy's n!ach

Ei'1PL0Yt<IENT SITUATION

placed it among the largt•st Atlantic
tropical cyclone,; on record.

,VfiiCI\I.J AfiERlCAN
"10NTH

It willlw months before the economic
impact of Sandy can hr fully asses:;ed

2009 ARCHIVE

using data from the t:.S. Burl'an of
Labor Stati;;tics and other
orgnniLations. This Spotlight on Statistics provides a brief look at the pre-Sandy labor markd in
ANNIVERSARY
;j';(JkKtK

~)/,FETY

some oftlw arms of the United States hit hardest by the ;;torm.

AND

hi::J\l..l'H

AHER!CI\N
r,IOI'if~

Hurricane Sundy struck at the most densrly populated region of the United State:;. Four of th€' five
200R ARCHIVE

counties with the highest number of labor lon.:t> participants per square mile in 2011 were among
those hardest hit by Sandy. All 26 <>f the counties designated as major disaster areas are among the
top 10 per\'ent of r.s. counti('s in terms of labor force cknsity. The avnng(' dem;ity for th(•.'r 26

counties, 1,:301labor force pnrtieipanb per sq\w.re mile, was app1·oximately :)0 times 1·hE' average
dcn.~ily of I: he

WORLD

United Stales in 2011. The number of labor force participtmt8 in these 26 counties

ranged from just under 27,000 in Bril;tol County. Rhode [8land, to over 1.1 million in both Kings
County (Brookl~11) and Quc(•ns County in ~cw York Their nm•mploymcnt rate" ranged from 6.5

1007 ARCHIVE

percent in Rockland County, New York tn

12.9

percent in Ailantic Cmmtv, New Jc~rsey.

SEARCH SPOTLIGHT

FEEDBACK
US YOUR
frrDBACK AND

C0~1~1ENTS

IH!S ISSUE OF
SP:ALIGHT ON STATISTICS.

http://www. bls.gov/spotlight/20 12/sandy/

12113/2012

667

 Hurricane Sandy: BLS Spotlight on Statistics

Page 2 of7

Labor force participants per square mile, counties declared major
disaster areas after Hurricane Sandy, 2011 annual average
New York County, NY
Kings County, NY
Bronx County, NY
Queens CoLmty, NV
Hudson County, NJ

Richmond County NY
Essex County, NJ
Union County, NJ
Na.>~au

Count·r ~IY
Bergen CoL1nty, NJ

Middles.ex County, NJ
Bristol Count';, Rl
Westchester County, NY
Rockland County, NY
Suffolk County, NY
Fairfield County. CT

Ne'N Haven County, C'T
Monmouth Count1·. NJ
Somer;etCounty, NJ
Newport Count'/, Rl

43ll

Ocean County, NJ

425

Middles.e~ County, CT

257

Atlantic County, NJ

244

Cape May Count)•, NJ

232

New London CoLmty, Ci

228

Washington County, Rl

10,000

()

laoorforc~

20,000

30,000

50,000

40,000

density {labor fore~ partidpanh per :;quare mile!

Source U.S. Bureau of laoor Statistics

Source: Local Area Unemployment Statistics ! Chart Data

zones
The mupo bdow ~<how selected arcus of New Yurk and New ,Jersey that were hit particnlarly hard by
t1ood damage from llnniranc S;mdy.

Lnw-h~ng

areas in New York City are itkntificd as being in

evacuation zones A, B. or C. Zone A is I:!JP lowest and most vulnerable level, with Band C being
pmgressivdy higher. A major portion oi Staten Island employrnent..···29 percent in October 2011, a
year before Hurricane Sandy ...... was located in the most exposed zone A. ln Manhattan, 7 percent of
c~mployment

was located in thr: zone A areas. ln Queens, 2 percent of employment was in mne A

nreas. (County employnwnl: dnta for Odnlwr 2012 will not be published until .June 27.
2011

201;).

October

employment data are shown here as the best ;Jpproxirnation of the seasonal employment lewls

whenllurricam• Sandy struck)
N(•w ,Jersey countiPs are classifiNl into four hurricane zone,;, refkcting their \1tlncrability to
hurrieane force storms of eatt>gory

hj.

llurrkanes an• eal(•gori7.ed as 1-5 based on increasing rates of

sustained wind opeed. Maps are presmtcd for Hudson County {which iw:ludf;'s Hoboken, J.:rsey City,

and other municipalitit•s) and Atlantic County fwbicb indud,,s Atlantic City). The New .Jersey
Department of Labor and Industry ha8 permitted BLS to publish these maps with dots showing the
location of t;•mployers.
N'<)

infC•rmation is cnrrently available Oll how many of these emplo)\~rs suffered damage as u rt.•:;ull of

Hurricane Sandy.
In Hwhon County, 40 percent of employment as of October 2011 was within the category 1 zone; in
Atlantic County,

20

peret•nt of employment was in

th<~

category 1 zone.

Evanmtion zone~ were provided by the New Yurk City Oft1cc of Erncrgeney Management. New .Jersey
hurricam' zom•s W('l'C provided by the United States Army C011)S of Engineers.

http://www. bls.gov/spotlight/20 12/sandy/

12113/2012

668

 Page 3 of7

llurricanc Sandy: BLS Spotlight on Statistics

Flood evacuation and hurricane zones, selected areas in New York and New Jersey,
October 2011
Select a map:jAtlantic, NJ

.;::j

Source: Ouarkrlv Census of Employment and Wages I Chart Data

areas
In 2011, among the four metropolitan divisions that compose the New \:'ork-N01ihem New ,JerseyLong Island metropolitan statistical area (Y!SA), New York-Whi!P Plains-Wayne had the highest
average total nonfilrrn cmploylm'nt (5,218.ooo). Within New .krsey. 98o.Mo wen· employed within
11H• Edison-New Brunswiek division.
Within the New England region. those areas affected by llurricane Sandy were primarily in
Connecticut. The largest area, Hartford, employcd 538,900 in 2011. Partl)· located in Connecticut as
well as Rhode Island, the Norwich-N'ew London area <'mploycd 128.600.

http://www .bls.gov/spotlight/20 12/sandy/

12113/2012

669

 llurricane Sandy: BLS Spotlight on Statistics

Page 4 of?

Total nonfarm employment, metropolitan areas and divisions declared major
disaster areas after Hurricane Sandy, not seasonally adjusted,
2011 annual average
Atlanti::Cit•tHammonton, NJ

5,218,600

267,100

Wa

62,200
0

2,000,000

Source: U.S. Bureau of Labor Statisti::s

4,000,000

6,000,000

Employment

Source: State and Metropolitan Area Current Emplovm(•nt Statistics I Chart Data

areas
In those metropolit;m statistical areas and divisions affected hv Hurricane Sandv. the mnjority of
employment in :!011 was in the Education and Health Services and Trade, Transportation, and
Ctilitic,; industries. The Information industry had the fewest jobs.

Within Nt~w .Jersey, compared with all other affected areas, tht• Atlantic City-Hannnontun area
employed the highest share of total nonfarm employml'flt in the Leisure and llospiiality industry

(3,J.:.! pereent) and the lowest sharP in the Information industrv (o.6 jJ(~lWnll.
Within Connecticut and Rhode !:<land, l:he Norwich-New London ;m~a had the highest ohare of
Government emplovmenl (:27.5 percent) among all affected areas.

http://www.bls.gov/spotlight/2012/sandy/

12113/2012

670

 Hurricane Sandy: BLS Spotlight on Statistics

Page 5 of7

Percent distribution of total nonfarm employment, by major industry,
metropolitan areas and divisions declared major disaster areas after Hurricane
Sandy, not seasonally adjusted, 2011 annual average
<:(

Vl

Atlantic City-Hammonton, NJ

:;e
3:

Edison-New Brunswick, NJ

z"'

c c

"'> £<;

<1;

z

~

1)\

0 0
it

if1

0

>

Bridgeport-Stamford-Norwalk, CT
~

Hartford-West Hartford·

., ~

East Hartford, CT

!1 ~
~~

z!!:""'~

.?:"

Norwich-New London, CT-Ri

u

0%

20%

40%

5ll%

80%

100%

Per rent of total nonfarm employment
1111 Mining, logging, and constructJOn
!Ill Trade, trilnsportation, ar1d uti!ities
1111 financial activities
iii' Education and health services
&lather services

I Manufacturing
!llllnformatmn
Ill Professional and busitH!SS services
1 Lersure and hospitality
Wl G<>vernment

Source. U 5 Bureau of Labor Statistics

Sonree: State and Metropolitan Area Current Employnwnt Statistic;, I Chart Data

The dmis bdow show employment levels in the w largest occupations in each of six mrtropolitan
arras or divisions that were heavily affcded by J!urricanc Sandy. In five of the ><ix areas or divisions,
the largest occupation in May 20ll wm< retail salespersons: in tlw Atlantic City-llammonlon area,
retail salesperson:, was the sE-cond-largest occupation, Gaming dealers was the largest occupation in
Atlantic City-Hammonton; for the• nation as a whole, gaming dealers was the :.!70th largest

'lC('upation. Security guards abo was among the' largest occupations in Atlantic City-[larnmonton,
the only one of the six aruas nr divisions in which SC('ttrity guards was among the top to. Cashiers,

j<Jnitors and dean~rs, and general officr,• clerk:; W('re among the 10 largest occupations in all six ar0<1S
or divisions,

I

Select a chart: New York-White Plains-Wayne NY-NJ Metropolitan Division

http://www .bls.gov/spotlight/20 12/sandy/

::J

12/13/2012

671

 Hurricane Sandy: BLS Spotlight on Statistics

Page 6 of7

Larsest Occupations in N11w York·Whitl! Plains• Wayne NY·NJ
Metropolitan Division, May 2011
16U10

cleane>r~. e>>:cept maid$
and housei<eepinede;mer;

Jar.1tors and

Secreta,ieund adfl'mistra·!•ve
t>ctp~lti~l.

mtd•(al,

~nd

~ssiltonu,

t<tcuwe

Hnm<e heolth oide<

40,000

80:.000

120,00()

l£0,000

200,00()

Emplo'/ffitl'll

Source: Occupational Employment Statistics I Chmt Data

Private industry employers in th,, large metropolitan areas hit hankst by llurrinme Sandy--N<•w
York, Boston, and Philaddphia-all hnvt: higher average hourly comp\:ns<Jtion costs than the overall
average for the United States. Total compensation costs are composed of wages, salaries, and
benefits. During the first quartl'r of 2012. the New York metropolitan area had the highest hourlv
employer c:ost at $36.:39. followed by Boston at $35.86, and Philadelphia-Camden at $:n.st. flourly
employer costs for the United

St~l:es

during the same period averaged $28.;8.

Average hourly employer compensation costs for private industry
workers in selected metropolitan areas, March 2012
Benefits

United States

N,;w Vork·Newark·Bridgeport, NY·N.I·CT·PA

Boston·Worcester-Manrhester, MA-NH

Phil3delphia·Camden·Vineland, PA-NJ·DE·MD

SO

$5

$10

$1S

$20

$2S

$30

$35

$40

Source. U.S. Bureau of Labor Statistic>

Source: National Compensation Survey ! Chart Data

More

http://www.bls.gov/spotlight/20 12/sandy/

12/13/2012

672

 llurricanc Sandy: BLS Spotlight on Statistics

Page 7 of7

State and Metropolitan Area Eeonomi<)S at a Glal1t'<) data:
Connecticut I Delaware I District of Columbia I Maryland I New Jersey I New York I Rhode Island
Virginia

1

Note: Data in text. chart>. and table' are the latest available ut the time ({pllblication. Intrrnet
link:; may lead to more l'ecent data.
Generallnformation: (:zo:.:) 691-5200
Media Contact: (202) 691·5902
W\NW.bl$.gov/spotlight

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12113/2012

673

 Strong Headwinds: Employment Losses after Hurricanes

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UNITED STATES
DEPARTMENT OF LABOR

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Strong Headwinds: Employment Losses after Hurricanes
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on December 5, 2012 · 4 comments

s,·crdary Solis visits Staten Island, N.Y., to view
twm ~ry and rebuilding efforts in the wake of
Hurricane Sandy.
L:tst week. Secretary Solis toured areas of Staten Island, N.Y., and saw firsthand the devastation caused by Hurricane Sandy. It was her second trip to
\1,.,, York as part oft he administration's ongoing efforts to provide support tor the hardest-hit areas. More than a month after the storm, piles of debris
.,till remain where homes and businesses once stood. Hut there are other impacts that are harder to see.
ll<~,ed

on past experiences with other major hurricanes, we know that they can have a significant impact on employment thwugh reduced hiring- as
and because it is difficult for job seekers to travel to interviews. And job losses can have a
ck\ astating effect on households who also have lost their homes, belongings, and in some cases, loved ones.
ht"tncs"'' downsize and close during and after the storms

f'rcl11ninary evidence suggests that Sandy will be the second costliest storm in U.S. hist01y. We already know that the economy experienced weaker
saks and lower industrial production in October as a result of the stonn. And in the first week following Sandy, Unemployment Insurance claims
tllc'rca,cd by 25 percent.
r~tail

I he ol'llcial unemployment rate t(Jr November will be based on individuals' activities in the first week after Sandy (Nov. 4-10), so that measure also
could b~ a!Teded. In other states, we have seen employment drop atler hurricanes and sometimes take many months to recover. For example, a study
c'\:ttnining the employment impacts of hurricanes in Florida found that hurricanes in that state generated employment drops of between 1.5 and 5
percent, depending on the strength of the hurTicane .
.lobs in a variety llf industries have been impacted by hurricanes and the largest losses can occur in service-related industries, which mostly depend on
lo;.:al demand. Given the importance of service sector jobs in the regions affected by Sandy, we may be seeing large drops in employment in the next
k11 m,mths in New Jersey and New York. (See the Bureau of Labor Statistics release on the pre-Sandy characteristics of the areas affected by the
hurricane.)

http://social.dol.gov/blog/strong-headwinds-employment-losses-after-hurricanes/

12/13/2012

674

 Strong llcadwinds: Employment Losses after Hurricanes

Page 2 of5

SwTiary Solis visits a neighborhood on Staten
bland.
It ''reasonable to expect drops in employment and increases in unemployment after Sandy. However. as with other recent economic statistics (such as
Industrial production and retail sales), we'll have to be careful with the interpretation of the survey data. A fUJiher complication is that the reference
11 c·c:k was one week earlier than the usual reference week (the one containing the I2th of the month) because of where Thanksgiving fell on the
calendar. For this n;:ason. the household data refer to the week following the storm and the data collection started two weeks following the storm, a time
wh~n 111any people in mid-Atlantic states still faced disruptions in electricity and transportation.
Om· ol the lessons learned from past hurricanes is that it is important to reach out to the residt'nts and victims sooner rather than later. This is precisely
wll\ the administrution is ensuring that suppmi reaches those affected by Hurricane Sandy quickly. The Labor Department has already authorized the
:il a liability of$46.7 million in National Emergency Grants for New Jersey, New York, Rhode Island and Connecticut. The department has also made
mPr~ than $2 million in Disaster Unemployment Assistance available to individuals whose jobs were interrupted or lost as a direct result of Sandy.
Although the residents ofthe aftected areas, local economies and the national economy will likely feel the effects of Sandy for some time. the
assistance and support of the federal govemment and private sector will be crucial in generating infrastructure investments, which in turn will bring
hack hoth jobs and economic growth.

Adriana Kugler is Chie(Economist at the U.S. Department olLabor.
Jagsed as: Adriana Kugler, Bureau of Labor Statistics, Disaster Unemployment Assistance, economy. employment,

Hurri~ane

Sandv, Job Growth.

:\,Jit(lnal Emergencv Grant. New York, recovery, Staten Island, l.Jnemplovmcnt Insurance

: 4 c'(>mmcnts ... read them below or add one :

lMuhamcd Hany Mouaaz December 6. 2012 at 3:12am
That's really very good system
_£Brian Cain

D~cembcr

6. 2012 at 4:09am

It\ cra?y how much damage nature can do. With the unemployment rate skyrocketing, you're right; it's important to reach out now as opposed
to later.
}the~

Phenomenal Lauren G December 7, 2012 at 5:06am
It s~ems that it is important business for businesses to make it their business to provide for the victims of Sandy. I believe we as a people can get
together and get it done.(~

:lilldovision December 9, 2012 at 5:53am
I am sorry to hear this. I hope all things going to be all right soon.
Lc~I\L'

a Comment

Bl'l,lrl' you post, please prove you arc sentient

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