“…on average, the size of the U.S. multiplier
is slightly more than double that of the local MSA multiplier.”
the regional center.” Thus the regulations call for impacts to
be shown regionally or nationally as well as both within and
without the regional center (boundary area). In addition, the
December 2010 letter from USCIS Director Mayorkas to
Congressman Patrick Leahy (the well-known “Leahy Letter”)
advises that although regional centers are required to focus their
investment activities on a single contiguous area, there is nothing in the regulations that mandates all indirect job creation to
take place within that area, implying that indirect jobs outside
the regional center boundary can be considered. By contrast, in
the September 15, 2011 stakeholder meeting USCIS released
a PowerPoint presentation advising practitioners under the
heading “Common Issues Resulting in RFEs or Denials in Form
I-924 Applications,” of the inappropriateness of “The application
of national or state data in the economic model when more
accurate regional data is readily available to demonstrate
the economic impacts/job creation of the regional center’s
investment projects.” Although these are but a few citations of
seeming inconsistency in guidance versus regulations, there are
likely others, and the issue is that there are large differences in
total multiplier effects between the various areas.
MSA multiplier would result in 2,268 jobs versus 5,056 for
the entire United States, an increase of 123 percent (note that
inflation adjustments were not considered in this calculation for
expositional purposes). The size of the U.S. multipliers relative
to that of the MSA multipliers in the table range from a low of
79 percent larger for Nursing and community care facilities to
a high 148 percent larger for “Construction of new commercial
structures” (the sector used for hotel construction).
For example, the following table illustrates total final demand
(expenditure) employment multipliers for common EB-5
project industries using the IMPLAN model 2013 data-year
for three areas: the entire United States, the State of Florida,
and then the Miami-Fort Lauderdale-West Palm Beach Florida
MSA. As can be seen, the difference in local MSA multipliers
versus the national multipliers is dramatic: on average, the size
of the U.S. multiplier is slightly more than double that of the
local MSA multiplier. The implication is that use of a U.S.
multiplier would result in approximately 100 percent more jobs
than the MSA multiplier. For example, for a $100 million, 28
month construction project modeled under IMPLAN sector
60 (multifamily residential construction), using the Mi ami
Guidance on real estate commissions (not asset sales price)
on real estate would also be helpful. In general, our firm
considers that realtor commissions do create jobs. But it is
an especially thorny issue when dealing with large real estate
projects involving timeshare condominiums. Our firm has been
hired for several projects where the construction budget for the
condominium may be $300-$500 million, but the sales of each
unit for 52 weeks per year generates hundreds of millions of
dollars of total sales income that can total two to three times the
size of the construction budget. From these sales, commissions
are paid to the sales staff and this is a line item in the developer’s
construction budget – not part of operations which takes place
Insurance is another line item that economists see in almost
every project, and no guidance has been given on this issue to
which our firm is aware. While we know insurance companies
employ many people across the United States, the premiums are
most assuredly split between local agents, underwriters, and the
corporate headquarters, which are likely to be located in large
financial centers such as New York City or Chicago. Our firm
has conducted economic studies on large projects with insurance
expenditures of as much as $60 million, and we used this in the
economic model, which was approved by USCIS. In the absence
of clear guidance from USCIS on the treatment of insurance
payments, some clients are hesitant to use expenditures on
insurance, and ask us to remove them.
IMPLAN IMPLAN Industry Sector
United States
Florida Total
Miami MSA
Sector Total Effects Effects Total Effects
Code Multiplier Multiplier Multiplier
57
Construction of new commercial structures, including farm structures
47.3707
21.4364
19.1250
60
Construction of new multifamily residential structures
50.5546
25.3977
22.6794
449
Architectural, engineering, and related services 54.5641 30.3060 27.9636
483
Nursing and community care facilities 61.5462 37.0907 34.3400
499
Hotels and motels, including casino hotels
53.9243
29.3364
26.1161
501
Full-service restaurants 64.0053 37.4122 33.9460
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