Osvaldo F . Torres graduated from the University of Pennsylvania Carey Law School in 1987 . During his 35- year career , Torres has helped clients navigate complex corporate and securities transactions . For the past 12 years , Torres has been immersed in the EB-5 space . He regularly represents regional centers , developers and issuers with offering , loan and redeployment matters for hotel , multifamily , senior living , franchising and other projects . Torres is frequently invited to speak at EB-5 conferences on securities issues . He is a member of the EB-5 SEC Roundtable , serves on IIUSA ’ s Leadership , Public Policy and Editorial Committees , and is rated AV Preeminent by Martindale-Hubbell .
WHAT DO YOU THINK ABOUT THE EB-5 REFORM AND INTEGRITY ACT OF 2022 ?
Not an easy question to answer . I have mixed feelings . When the Integrity Act finally passed , like most , I felt a great sense of relief and joy . Finally , all those years of EB-5 industry uncertainty and in-fighting seemed to have come to an end . Then , upon once again closely reading the final text of the Integrity Act , I slumped into dejection . It was mired with inconsistencies and ambiguities . It was quicksand . Irrespective , I remain hopeful . I know good is served by helping others come to this great nation .
HOW ARE YOU HANDLING THE ISSUE OF REDEPLOYMENT ?
Redeployment may no longer be a material concern for projects approved after passage of the Integrity Act because the definition of the “ sustainment period ” appears to have been altered by the new law . However , for pre-Act projects , redeployment lives on and the same issues that mire redeployment will continue with respect to such projects . But who really knows ? Some believe that the new definition of the sustainment period was changed in error . Still , I do not see projects returning funds before the underlying deals run their normal “ exit ” course — usually about 5 years if all goes well .