With rumors (unconfirmed as of yet, but as any small community, the EB-5 community is always rife with rumors) that some I-526s have been receiving tenant-occupancy RFEs, I wanted to point you to a great article discussing issues of EB-5 tenant-occupancy in the context of hotels and hotel management companies. I would think that nursing home operators are faced with the same issue, namely, that hotel builders/nursing home builders operate in the way that they “lease” the facilities to a hotel management company/nursing home operator. But this is not a “lease” in the way, say, the Olive Garden leases space in a mall, but an operating model that grew out of managing liabilities. The plot thickens…