Adoption of Regulation A+ and its impact is yet to be seen; it is too early to predict how it will affect the EB-5 industry. However, at first glance, your assessment is correct that it may prove to be too onerous for it to be utilized by the EB-5 industry.
Since the SEC announced the adoption of Regulation A+ on Wednesday, some people have asked if EB-5 offerings can also be offered under Reg A+. Is this correct? If so, is it safe to say that, compared to 506(c), Reg A+ offerings are far too financially onerous and time consuming to become commonplace in EB-5?
I do not believe that Reg A+ will have much effect on EB-5 given the size of EB-5 individual investments. Any reasonable project will be using Regulation D.