Most people in EB-5 met Eren Cicekdagi at Golden Gate Global. Fewer know what came before it. He practiced as a corporate and real estate transactional attorney at Herguner Law in Europe and Middle East, spent half a decade in real estate finance at PwC, and arrived in the immigration capital markets already fluent in the vocabulary that EB-5 conversations eventually reach anyway: capital stack, lien position, draw conditions, completion guaranty, remedies on default.
“I came into EB-5 from the credit side, not the immigration side,” he says. “The immigration outcome is why investors are in the room. But that outcome depends on whether the project gets built and the loan performs. It is a real estate underwriting question before it is anything else.”
He spent about 12 years at his prior group, a well-known San Francisco-based EB-5 Regional Center, where, as the Managing Director, he led structuring and marketing across approximately $1B in EB-5 placements in 20 offerings. By industry standards, it was a solid seat, which raises the obvious question of why he made the move.
Why Third Lake?
The answer he gives is unglamorous, and he appears to prefer it that way.
“After enough years you stop being impressed by projects only, and start looking at who is standing behind them,” he says. “In the traditional model, the regional center is a designation and a marketing budget. The sponsor is a single-purpose entity. The issuer is a single-purpose entity. The people bringing investors in have no supervisory relationship nor stake in the deal beyond underwriting the initial EB-5 loan. That is not a criticism of any one firm, it is simply how the industry was assembled. Third Lake’s structure was assembled differently, and it was not assembled for EB-5.”
Third Lake is a vertically integrated real estate and investment platform, with acquisition, development, construction, asset management, and capital markets functions, held under common ownership. In the core of the affiliated platform sits Third Lake Partners, LLC, an SEC-registered investment adviser with about $10 billion invested to date, serving family office and institutional clients. Third Lake Associates, LLC, the affiliate Cicekdagi joined as Principal, is the affiliated broker-dealer registered with FINRA and a member of SIPC. Third Lake Southeast Regional Center, LLC, holds the USCIS regional center designation.
The point of the above list is Third Lake’s tailored layering. Most EB-5 programs perform the sponsor, issuer, regional center, and distribution roles through affiliates that exist largely on paper. At Third Lake, those functions sit within a platform that was underwriting institutional real estate long before it filed anything with USCIS, and the capital markets function runs through a registered broker-dealer, with a licensed principal and representatives, written supervisory procedures, communications archiving, and examination exposure attached.
“FINRA registration is not a quality guarantee, and I would never sell it as one. What it is, is added accountability and transparency…”
“Registration is not a quality guarantee, and I would never sell it as one,” Cicekdagi says. “What it is, is added accountability and transparency needed in investment migration programs like EB-5. When a broker-dealer distributes an offering, a licensed principal has reviewed it, compliance has cleared the marketing before it goes out, and a regulator can ask questions afterward. Given what an investor is committing, and how many years of an investing family’s planning ride on it, that should be the norm rather than the differentiator. Today it is still a differentiator.”
A different underwriting posture
That institutional orientation shows up most concretely in what the platform will and will not finance. Cicekdagi is direct about where he thinks the market drifted after the rural set-aside was introduced.
“The set-aside changed where much of the EB-5 capital went. It did not change what makes a project work,” he says. “A meaningful share of that capital went into rural hospitality and resort-residential in markets with one
buyer, one lender, and one exit. Those are difficult assets to refinance on a schedule, and repayment is a schedule problem. We look for urban infill in liquid markets, with institutional debt, real sponsor equity, and a lender who underwrote the deal independently of us.”
The current focus is on Southeast and Florida Coast urban markets, where the platform has developed and delivered over 6,000 units and invested about $7 billion in product. EB-5 capital is deployed as senior or mezz debt into projects the platform itself sponsors, administered by an independent third-party fund administrator, with independent construction consulting and third-party loan servicing layered on top.
“When the sponsor, issuer, and regional center all sit under one roof, the honest answer is that investors need more independent eyes on the structure,” he says. “We strived to strike the right balance: meaningful exposure from the platform itself (i.e., significant equity investment), paired with independent checks around administration, construction oversight, and loan servicing. In an affiliated loan, a fully independent loan administrator helps provide that oversight, so investors are not relying only on alignment of interest. They are investing through a structure where the EB-5 issuer has real exposure alongside them, and where third parties are responsible for key control functions.”
What comes next?
Cicekdagi is building the distribution side deliberately rather than quickly, which includes FINRA-registered representatives, domestic broker-dealer channels, and agent markets in offshore markets.
“The agents I want are the ones asking hard questions in the first meeting, beyond the usual headlines of rural vs. HUA and referral payments,” he says. “Where does the money sit before it moves? What is the lien on, and what is it worth? What happens if the schedule slips? If a partner is not asking those questions of me, I can tell that they are not asking them for their clients either.”
Asked what he would like the market to take from the move, he keeps it straightforward.
“Third Lake is a new name in EB-5, not in real estate,” he says. “I did not join a startup regional center. I joined a real estate company with billions of dollars in completed projects, a registered broker-dealer, an SEC-registered adviser affiliate, and its own balance sheet, and we added EB-5 to that foundation. Not the other way around. That order matters more than anything else I could tell you.”
“A new name in EB-5, not in real estate.”
INFORMATION CARD
Name: Eren Cicekdagi
Title: Principal, Third Lake Associates, LLC
Licenses: Series 7, Series 24, Series 63
Background: Corporate and real estate transactional attorney, Herguner Law; real estate finance, PwC; EB-5, Golden Gate Global
Education: IBU School of Law, UNC Chapel Hill, Kenan-Flagler Business School
Platform: The Third Lake Platform includes Third Lake Associates, LLC, FINRA member and SIPC member broker-dealer; Third Lake Partners, LLC, SEC-registered investment adviser, with over $10B invested and +$6B total assets; Third Lake Southeast Regional Center LLC; Third Lake Development, LLC; and Third Lake Construction, LLC.
Contact: eren@thirdlakeEB5.com (727) 380-0000
DISCLAIMER
Paid editorial prepared by or on behalf of Third Lake Associates, LLC. For informational purposes only. This is not an offer to sell or a solicitation of an offer to buy any securities; any such offer may be made only through the applicable confidential offering documents, which control. Statements attributed to individuals reflect their views as of publication. Certain statements are forward-looking and involve risks and uncertainties; actual results may differ materially. Historical transaction and development figures describe the activities of Third Lake and its affiliates, do not represent investment performance, and are not indicative of future results. Private placement investments involve substantial risks, including possible loss of principal and lack of liquidity, and are suitable only for qualified investors able to bear such risks. Participation in an EB-5 investment does not guarantee approval of any immigration petition; immigration benefits are determined solely by USCIS. Third Lake Associates, LLC is a registered broker-dealer, member of FINRA and SIPC. Not reviewed or approved by the SEC, FINRA, USCIS, or any other regulatory authority. Not legal, tax, accounting, or investment advice.
DISCLAIMER: The views expressed in this article are solely the views of the author and do not necessarily represent the views of the publisher, its employees. or its affiliates. The information found on this website is intended to be general information; it is not legal or financial advice. Specific legal or financial advice can only be given by a licensed professional with full knowledge of all the facts and circumstances of your particular situation. You should seek consultation with legal, immigration, and financial experts prior to participating in the EB-5 program Posting a question on this website does not create an attorney-client relationship. All questions you post will be available to the public; do not include confidential information in your question.
