고급 SOF & 심사 트렌드: 2026년 변경 사항과 청원에 미치는 영향

RFE and NOID patterns have shifted in 2026 - and the two areas where EB-5 filings face the most friction remain the least examined by investors: source-of-funds documentation strategy and capital protection structures.

Adjudicators are applying different scrutiny to SDIRA-funded filings, HELOC documentation, margin loans, and gift-based funding strategies than they were six months ago. On the capital side, the distinction between a senior loan label and a first lien position - and what the NCE Manager’s fiduciary obligation actually covers - is more consequential than most investors realize.

With fewer than six months until the September 30, 2026 grandfathering deadline, and source-of-funds preparation requiring three to six months, the window to build a defensible filing strategy is narrowing.

In this session, Phuong Le and Hallie Schechter from KLD LLP will break down the adjudication trends shaping filings right now, and Jenny Zhan, CEO of Beyond International Group, will walk through the capital protection structures and NCE Manager framework that determine how your investment is actually protected.

What We Will Cover

1. Path of Funds vs. Source of Funds
2. The distinction triggering the majority of RFEs - why confusing the two remains the most common filing mistake, and what documentation strategies are holding up under current adjudication.
3. 2026 RFE and NOID Patterns by Funding Method
4. What’s changed across SDIRA (the NOID wave and which documentation is working), HELOC, margin loans, gifts, and unsecured lending. Real patterns from active cases - not general guidance.
5. Filing Prep Checklist
6. The 3–6 month preparation timeline for investors approaching their filing window - what to assemble, what to validate, and what most people start too late.
7. Capital Protection Structures and NCE Manager Framework
8. Bridge financing mechanics, senior loan vs. first lien positioning, and what each means for capital recovery priority. How Beyond International Group structures EB-5 capital and what the NCE Manager’s fiduciary obligation covers.
9. Live Q&A
10. Bring your questions and hear practical answers from attorneys and EB-5 project leadership.