August 15, 2011 – Broad Oak Management, LLC and PenberaParis, LLC announced today a strategic joint venture to provide a full suite of investment banking, economic, marketing, management, funding, and administrative support services to U.S. Citizenship and Immigration Service investment programs. “Conducting business with PenberaParis offers our clients superb technical expertise, access to the international capital markets, and the protections afforded by compliance with U.S. and international securities laws,” said John C. Braddock, managing partner of Broad Oak. This joint venture between an accomplished investment banking firm and experienced econometric and regional center management firm is the first of its kind in the U.S. It is aimed at assuring that issuers, project companies, and investors receive high quality, cost competitive, and effective services.  “The bridge with Broad Oak allows PenberaParis to execute its ‘2020 Plan’ integrating premier econometrics with efficient regional center administration, investment banking, and SEC-compliant investor recruitment on behalf of multiple top-tier regional centers across the U.S.,” said Dr. Joseph J. Penbera, chairman of PenberaParis.

EB5 Program Services

PenberaParis, LLC and its strategic partner Broad Oak Management, LLC http://www.broadoakgroupinternational.com/what_we_do_bom.html offer the following services to regional center clients and issuers of EB-5 securities:

• Regional Center Formation, Management, and Administration:
• Preparing USCIS:
• Regional center application
• Business plan
• Job creation study
• Annual status reports
• Opinion letters to accompany I-526 and I-829 investor petitions
• Assistance in drafting offering documents
• Regional center management, administration, and IT support
• SEC-Registered Broker-Dealer & FINRA-Registered Investment Bankers:
• Top-tier project selection
• Due diligence research
• Operating capital budgeting and funding
• Risk management policies and procedures
• Structuring and valuing EB-5 securities
• Assistance in preparing risk disclosure, subscription documents, translation
• Marketing: international investor network
• Non-EB-5 funding for the regional center ”Capital Stack”
• Post-green card project monetization: institutional investor network
• Legal and Regulatory Compliance:
• USCIS
• SEC-registered broker-dealer
• FINRA-compliant sales practices
• International securities and currency regulations
• Escrow
• OFAC clearance

Almost two decades of experience with the EB5 Program indicates that there are six critical success factors in the formation and management of an EB5 Regional Center

• Preparation of the Regional Center Application

PenberaParis prepares the comprehensive Application for Designation as a USCIS-approved Regional Center pursuant to the rules of the EB-5 Program of the Immigration and Nationality Act (8 U.S.C. 1153 (b)(5)(A)-(D); INA 203 (b)(5)(A)-(D)); Regional Center designation provides the required authority for the recruitment of foreign investors for approved investment Projects. We have prepared the Regional Center Application for Centers in California, Florida and Texas, encompassing more than 1000 investors and more than $500 million in foreign capital. The “typical” Regional Center application is well over 100 pages in length, exclusive of exhibits. Our staff provides support in every aspect of the Application, including the describing the region, defining the investment alternatives and the scope of the Center, explaining the project(s) and presenting the job creation and financial summaries, detailing the USCIS compliance and investor processing procedures (including OFAC clearance processes), providing the marketing and promotional plan, responding to Code of Federal Regulation questions, and the like. We also prepare the “Economic Output Analysis” which is based upon sound econometric modeling techniques; Dr. Penbera’s has many years of experience as a Senior Fulbright Scholar in Economics, is a noted forecast economist, and a member of the National Association of Forensic Economists (NAFE). We provide the narratives, as well as the associated charts, tables, and exhibits, and include collateral information such as estimated tax revenues. We also prepare the Application submission forms, and provide guidance about targeted employment area (TEA) designation, and how to obtain endorsements.

• Assistance on the Preparation of the Required Business Plan

PenberaParis Associates assist the project companies -- the recipients of the foreign investor capital--in the preparation of the required Comprehensive Business Plan in accordance with the USCIS precedent case, The Matter of Ho. We provide plan templates and do the required editing. We have helped to prepare business plans in many sectors, including agriculture, energy, manufacturing, retail, real estate development, transportation, and sports/entertainment. Our range of experience is from small and medium-sized enterprises, to very large corporate plans, and for both public-listed and private companies.

• Preparation of the Required Job Creation Study

PenberaParis provides job creation studies using both RIMS II (U.S. Bureau of Economic Analysis) and IMPLAN (U. of Minnesota, MIG) approaches. This Job Creation Study is an essential part of the required evidentiary proof that a minimum of ten (10) jobs per investor will be created. We are skilled at utilizing the handbook, software, and purchased data resources relating to the RIMS II and IMPLAN approaches and applying these to the defined region, the industry and industrial classifications, job categories, and capital invested. We are guided by the professional principles and ethical practices. We have determined direct and indirect jobs and “job multipliers” and performed economic analyses for a wide range of projects, including farming, wine-making, transportation, hotels, affordable housing, luxury housing, major retail shopping center, film production, sports stadium, solar power, biofuels, oil extraction, and equipment manufacturing, among others.

• Assistance in Drafting Offering Documents

PenberaParis provides initial drafts of key documents which are, then, reviewed by the project company’s legal advisors, thus saving considerable time and expense. The offering documents may, typically, include the Private Placement Memorandum, The Subscription Agreement, Promissory Note, Escrow Agreement, and Limited Partnership Agreement. We also assist on the crafting of the investment Units, and on decision-making regarding the terms, including the “reasonable assurance” of return of principal (the EB5 Program prohibits guarantees to the investor), and distributions, potential conversion of debt to equity, extensions, and exit strategies.

• Marketing to Investors and Investor Recruitment

PenberaParis recognizes from the outset that recruiting investors is a competitive process which requires special knowledge of what appeals to immigrant investors. The project, investment terms, and job creation relating to the ultimate filing of the I-829 are important considerations. Also important are the established and emerging marketing and recruitment channels, relationships with immigration attorneys and recruitment networks, working within securities and USCIS regulations, creating Finder Agreements, constructing the I-526 exemplar, setting up escrow guidelines, website creation, and the like.

• Management of The Center

PenberaParis is engaged in the management of Centers directly and/or indirectly through its staffing relationships with USRCS in Cupertino, CA. PenberaParis’ objective is to take Center management responsibilities off of the project company so that it can concentrate on its core business and properly utilize the investor capital. In exchange, we receive equity in the Center and serve as the managing member of the general partner of the limited partnerships formed to receive investor monies. Typically, the Center has a full-time Executive Director and support staff, a pre-operating budget of about six months overhead, and resources to pay certain upfront marketing and advisory fees. The Center’s key administrative functions include investor contacts and tracking, marketing and promotions, USCIS compliance and reporting, administering certain aspects of recruiting, funds clearance, IT systems, and the like.

Engaging in the EB5 Center formation process…

1. Call Dr. Penbera at 559-360-3535, or email him at jpenbera@comcast.net .

2. If there seems to be a match between your needs and our services, a face-to-face meeting will occur so that you can ask questions and thoroughly understand the process, and we can get a feel for the project and its marketability. If you are located out of California, you will be responsible for certain visitation expenses.

3. This meeting may take more than one day with part of it including discussion of the crafting of a Memorandum of Understanding (MOU). The MOU clarifies who is doing what in terms of the six items indicated above, over what timeline, and at what cost.

4. When the MOU is executed, the engagement is started and work begins on the various work products, the first of which is the project business plan.

5. Your Regional Center application will, generally, be ready in draft form within 60-90 days of completion of your project business plan.

6. Your final application will be submitted when all reviews are done, including any legal review. The application must be accompanied by a fee paid directly to Homeland Security.

7. No one can or should make any guarantee as to when USCIS will review and approve an application. However, new fast-track rules are now being promulgated for so-called “shovel-ready” projects; these are projects which are ready-to-go excepting the required capital.