For example, some complain that savvy developers are gaming the system by connecting higher-end developments with lower-end housing projects in order to qualify projects in major cities as targeted employment areas
Many of these credits are based on targeted employment areas
. The boundaries of these areas tend to change over time as census data is accumulated and qualification requirements get modified.
"The changes will raise the investment amount, change the way targeted employment areas
are calculated and essentially make the program harder to participate in than it already is," said Sam Newbold, an EB-5 specialist at the law firm Chiesa, Shahinian & Giantomasi.
The qualifying minimum investment generally is $1 million; however, an investment of $500,000 may qualify for investments within certain high-unemployment or rural areas, also known as targeted employment areas
She added that she expects there will be changes in the way targeted employment areas
are looked at.