# RIA Integrity Measures and the I-956 Form Family

> How the EB-5 Reform and Integrity Act rebuilt regional center oversight through Forms I-956, I-956F, I-956G, I-956H, and I-956K, the fund administrator and audit requirement, the penalties for non-compliance, and what investors should ask for before subscribing.

- URL: https://eb5policy.com/policy/integrity-measures-i956/
- Language: en
- Category: policy
- Published: 2026-08-14
- Tags: RIA, integrity, regional centers, I-956

The EB-5 Reform and Integrity Act of 2022 (RIA), signed into law on March 15, 2022, carries the word "integrity" in its name for a reason: it rebuilt the regional center program around a new set of filing, disclosure, and oversight mechanisms. Before the RIA, establishing a regional center and registering a project were comparatively loose processes. After the RIA, every key step a regional center takes, from obtaining designation to registering a project, reporting annually, declaring its personnel, and registering its promoters, corresponds to a form beginning with "I-956." Understanding this family of forms is the foundation for judging whether a regional center is operating in compliance. This article summarizes the RIA's principal integrity measures and explains what investors can ask to verify before subscribing. For background on the RIA as a whole, see [What the RIA Changed](/policy/ria-overview/).

## The I-956 family: what each form does

| Form | Filed by | Purpose | Relevance to investors |
|---|---|---|---|
| I-956 | Regional center | Application for regional center designation (existing centers also had to reapply after the RIA) | Confirm the designation is in good standing |
| I-956F | Regional center | Project application disclosing the new commercial enterprise (NCE), job-creating entity (JCE), business plan, economic analysis, and offering documents | Prerequisite for the I-526E; I-526E adjudication depends on I-956F approval |
| I-956G | Regional center | Annual statement disclosing use of funds, job creation, project progress, and material changes | A window into the project's actual progress |
| I-956H | Persons involved with the regional center | Bona fides declaration covering individuals who manage or control the regional center, NCE, or JCE | Screens out persons with fraud, securities, or similar violations |
| I-956K | Direct and third-party promoters (migration agents, sales intermediaries) | Registers promoters under USCIS oversight | Investors can check whether the agent selling them a project is registered |

Several points deserve emphasis:

- **The I-956F is the central project-level filing.** The RIA requires the regional center to file an I-956F for each project before investors can file I-526E petitions. Investors may file while the I-956F is pending, but USCIS adjudicates the I-526E only once the I-956F is approved. "I-956F filed" and "I-956F approved" are therefore two different states, and investors should ask to see the receipt or approval notice.
- **The I-956 and I-956F currently carry the same fee**, $17,795 each (the 2024 increases were stayed by court order in November 2025); the I-956G is $3,035. From November 30, 2026 the I-956 rises to $44,115, the I-956F to $42,675, and the I-956G falls to $2,165. Current amounts should be confirmed against the USCIS fee schedule; see [EB-5 Fees at a Glance](/policy/uscis-fees-2024/).
- **The I-956H covers** anyone with substantive control over, or a management role in, the regional center, NCE, or JCE, so that USCIS can review their backgrounds and bar participation where warranted.
- **The I-956K matters** because it brings overseas migration agents, who previously operated outside U.S. oversight, into a registration system. Promoters must disclose their commission arrangements with the regional center and comply with USCIS rules.

## Fund oversight: third-party administrator or annual audit

The RIA sets a clear requirement for how NCEs handle investor money: **the NCE must engage a third-party fund administrator to oversee the movement of investor funds**, or, as an alternative, **provide annual audited financial statements**.

Under the fund administrator model, each transfer from the NCE to the JCE is in principle reviewed against the offering documents and business plan before release, with records retained. Under the audit model, there is no administrator, but an independent accounting firm audits the NCE annually and issues a report. Each model has its own cost, and the regional center will state in the offering documents which one it uses.

For investors, the value of this requirement is an independent checkpoint between the moment funds enter the NCE and the moment they are deployed. Before subscribing, confirm:

1. whether the NCE uses a fund administrator or the audit alternative;
2. the name, qualifications, and independence of the administrator or audit firm; and
3. whether investors receive periodic use-of-funds reports.

## Annual reporting and recordkeeping

Each year the regional center must file an I-956G annual statement covering capital raised and deployed per project, progress on job creation, any material changes, and any pending litigation. The RIA also requires regional centers to retain project-related records for USCIS inspection.

Failure to file, or a filing with material omissions, can lead to fines and, in serious cases, suspension or termination of the designation. Investors cannot necessarily obtain the I-956G directly from USCIS, but they can ask the regional center for a copy or summary of what was filed.

## Consequences of non-compliance: fines, suspension, termination

The RIA gives USCIS a range of enforcement tools: audits and site visits of regional centers, NCEs, JCEs, and associated persons; fines for violations; suspension or termination of regional center designation; and bars preventing specific individuals from further participation in the program.

The most important consequence for investors is **what happens after a regional center is terminated**. The RIA provides relief for good-faith investors: after termination, an investor may, within a set period (currently 180 days, subject to the USCIS notice), associate with another compliant regional center or project and retain the original priority date. For the details, see [Priority Date Retention](/policy/priority-date-retention/).

## A pre-subscription verification checklist

Integrity measures only work if investors actually verify them. The following items are worth requesting or confirming before signing subscription documents:

- [ ] Evidence that the regional center designation (I-956) is in good standing, and that the center appears on the USCIS list of approved regional centers
- [ ] The receipt or approval notice for this project's I-956F; if filed but not yet approved, the filing date
- [ ] A copy or summary of the most recent I-956G annual statement
- [ ] The name of the fund administrator or audit firm, the key terms of its engagement, and how investors receive use-of-funds reports
- [ ] Whether the agent marketing the project has registered on Form I-956K, and whether commissions are disclosed in the offering documents
- [ ] Whether the principal persons of the regional center, NCE, and JCE have filed I-956H declarations, and whether any litigation or regulatory action is pending
- [ ] The escrow, release-condition, and refund provisions in the offering documents

These checks do not replace commercial due diligence on the project itself (see [Seven Things to Check Before Choosing a Project](/projects/how-to-evaluate-a-project/)), but they screen out the most basic compliance risks.

## Key takeaways

- The RIA built end-to-end regional center oversight on five forms: I-956 (designation), I-956F (project application), I-956G (annual statement), I-956H (bona fides declaration), and I-956K (promoter registration).
- I-956F approval is a prerequisite for I-526E adjudication; distinguish "filed" from "approved."
- The NCE must use a third-party fund administrator or provide annual audited financial statements.
- Regional centers that fail their reporting obligations face fines, suspension, or termination; good-faith investors can re-associate within the prescribed period and keep their priority date.
- Before subscribing, ask for proof of the I-956 filings, the annual statement, fund administrator details, and promoter registration.