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Part 1 of this entry introduces the hypothetical foreign broker from Qatar, Petra Ventures, which finds GCC investors for private U.S. ventures. Petra of course prefers to avoid registering as a broker with the securities laws of both its domestic and foreign jurisdiction, considering that registration is both costly and time-intensive. Assuming Petra confirms that the GCC's regulatory regime offers a shelter from registration for foreign finders, it must still make certain of its legal standing as an unregistered entity brokering private deals partly in the U.S.
The SEC requires brokers that transact in private securities on behalf of others to register,[i] and it includes domestic private placement agents and finders into this scheme.[ii] Commission Staff guidance defines a finder as any person who finds investors for, makes referrals to, or splits commissions with registered brokers, investment companies, or other securities issuers and intermediaries—including for private venture capital placements.[iii]
The Commission offers two registration exemptions for the activities of parties to private trades.
Regulation S Exemption
Via the Regulation S Exemption, the Commission exempts issuers, distributors, and any of their respective affiliates who offer and sale outside the United States from the registration requirements.[iv] Offers occur outside the United States if:
(1) The offer or sale is made in an offshore transaction;
(2) The issuer, distributor, or any of their affiliates make no directed selling efforts in the United States; and
(3) The purchaser of the securities (other than a distributor) certifies that it is not a U.S. citizen, and is not acquiring the securities for the account or benefit of any U.S. person. Moreover, the purchaser must agree to wait one year before reselling such securities back into the U.S.
Unfortunately, Regulation S states that nothing in its Rules obviates the need for any issuer or any other person to comply with the broker registration requirements of the Exchange Act when applicable. Though at first glance it seems the Commission carved out shelter for foreign brokers by exempting affiliates of an issuer or distributor. However, the Commission shuts the door to this potential brokers exemption by explicitly mentioning just paragraphs later that broker registration requirements remain largely in tact. Petra's ability to rely on the Regulation S exemption is at best tenuous, and it must still search elsewhere for an appropriate regulatory shelter from registration.
Foreign Broker Exemption
The SEC generally uses a territorial approach in applying registration requirements to the international operations of foreign brokers. Under this approach, all brokers physically operating within the United States that solicit securities transactions must register with the SEC, even if their activities are directed only to foreign investors outside of the United States. Additionally, foreign brokers that operate from outside of the United States who solicit U.S. investors through using the instrumentalities of interstate commerce must register.[v]
However, the Commission does provide a narrow exemption for foreign brokers who 1) operate outside the U.S., and 2) solicit exclusively to foreign entities. The Commission defines a foreign broker as any non U.S.-resident person whose securities activities, if conducted in the United States, would be described by the definition of "broker" in the Exchange Act.[vi] The Commission includes brokers temporarily present in the U.S. as well as brokers that are U.S. citizens residing abroad, into its definition of a foreign broker.[vii] Petra falls within the Commission's definition of a foreign broker, as long as Petra maintains a substantial business presence abroad and only solicits only to foreign investors.
This Foreign Broker exemption states that a foreign broker can help U.S. investors purchase any security from foreign issuer, as long as the foreign broker transacts alongside a registered broker intermediary.[viii] Though a step in the right direction, the Foreign Broker exemption hardly fits Petra like a glove. Petra connects foreign investors to U.S issuers, rather than bring U.S. investors to foreign issuers. The language in the exemption suggests that the Commission intended to focus this exemption on transactions that bring U.S. money to foreign entities, and not the other way around. The Commission's requirement that foreign brokers work in tandem with a U.S. registered broker as an intermediary supports this interpretation. Though both Regulation S and the Foreign Broker exemption address brokering activities within the penumbra of Petra's business model, neither affords Petra unambiguous shelter from registration.
Persuasive secondary sources shed some light on the ambiguity of Petra's registration requirements, stating that the SEC has not indicated that it requires registration for brokers purchasing securities in the United States and selling them to foreign investors abroad. [ix] Although the SEC could require such registration in the future, the SEC's primary concern is the protection of American investors, not foreign.
Though the SEC has not provided an explicitly apt registration exemption for Petra Ventures, Petra may continue operating its current business model without registering as long as it complies with the following guidelines:
(1) Petra must conduct all brokering through Petra ME. Petra requires further research to determine how to appropriately separate the business activities of its two branches.
(2) Petra must only solicit non-U.S. investors, including non-U.S. Citizens temporarily in the U.S., green card holders, and foreign students.
(3) Petra ME may not even hold itself out as a broker to U.S. investors, nor may it even advertise in the United States.
(4) Petra may only solicit in the GCC region to institutional investors, government authorities, investment managers, and Petra may transact with individual investors who seek out Petra without prompting.
(5) Petra must contact a lawyer familiar with Dubai Securities Law, and conduct a more thorough understanding of this foreign regulatory system.
[i] 15 U.S.C. § 78c.
[ii] Guide to Broker-Dealer Registration, Division of Trading and Markets, SEC, April 2008, available at http://www.sec.gov/divisions/marketreg/bdguide.htm#II.
[iii] Id.
[iv] Rule 903; 17 CFR §230.903.
[v] Id. at footnote 3.
[vi] Rule 15a-6(b)(3) of the Exchange Act.
[vii] Id.
[viii] 17 CFR §240.15a-6(a)(3).
[ix] "The Regulation of Investment Management and Fiduciary Services," 1 Reg. of Invest. Mgmt. & Fiduciary Serv. § 19:7.
Disclaimer: These materials have been prepared by Amin Consulting LLC for informational purposes only and are not legal advice. The material posted on this web site is not intended to create, and receipt of it does not constitute, a lawyer-client relationship, and readers should not act upon it without seeking professional counsel.
About Amin Consulting LLC: Amin Consulting is a uniquely positioned advisory and consulting Firm that, through our diverse team of Legal and Business experts, provides unique and niche services for Middle Eastern and United States based companies and investors. Whether you are a U.S. Company expanding in the Middle East, or a High Net Worth Family from the Middle East looking to diversify or protect its assets, you have come to the right place.
Our team is compromised of professionals with decades of collective consulting, legal, and business experience–specifically between those two regions of the world. Most of our consultants are Accredited and Licensed United States Attorneys as well as International Business Consultants. That allows us to provide, not only expert advice, but also added value through vertical integration of these often interconnected services.
For more information or a free consultation, send us a message here!
Posted in UncategorizedTagged Alien Investor, Business Lawyer, Consulting, Corporate Law Attorney, Foreign Investors, GCC equity marketLeave a comment
By: Eduardo Gonzalez
The GCC equity market experienced what many are calling a rollercoaster ride caused by recent market corrections in oil prices at the end of 2014. The recent developments, however, also resulted in more attractive valuations of well managed oil companies that have helped retain market confidence and reports indicate the 2015 market looks promising for investors. While oil will continue to account for a large portion of GCC revenues, the volatility in emerging-market currencies will create a shift in the market psychology of the region, and consequently the region will be poised to open its borders to economic competition in other non-oil sectors.
Domestic Sovereign Wealth Investment in Other Sectors: Long-term instability in the oil market will likely cause problems for the GCC's economic outlook, but the region's sovereign wealth funds indicate it is well prepared to compensate for the decline in oil revenues. Collectively, the region accounts for 37 percent of the world's sovereign wealth funds, creating an opportunity for GCC investors to generate growth in sectors the GCC has not traditionally targeted. Many argue that sovereign funds will be the drivers of economic development in the region—in particular, the region's focus on education and real estate indicates a push to leverage human capacity. Sovereign funds will play an increasingly important role in determining the regions economic trajectory, and taking into the account the surrounding area's financial trends will ensure investors make the best possible decisions.
Increasing Foreign Investment: Continued free trade agreement (FTA) negotiations with the Association of Southeast Asian Nations (ASEAN), China, Australia, and Europe will allow the region to benefit from more open trade borders and establish strategic partnerships with regions that excel in areas the GCC is targeting. An FTA with Singapore, for example, went into effect at the start of this year that illustrates a commitment to enhancing bilateral trade between the two regions. Ongoing talks with nearby economies will streamline the trade of goods and services, and expand the GCC's capacity for growth. In effect, the declining profitability of oil may actually accelerate economic reform that could remove restrictions on foreign investment and generate opportunities for the GCC to address its regional challenges.
Domestic Development via Bolstering Human Capital: The GCC will experience two catalysts in 2015 that will increase growth in non-oil sectors: the first is the UAE's and Qatar's upgrade to emerging market status in 2014. These states will receive a great deal of attention from foreign investors—that view 'emerging market status' as the "Wild Wild West of investing"—and may become critical elements to the GCC's success across different sectors in the coming years. As the region's markets become more flexible there will be increasing opportunities for the GCC to guide investments into areas it has traditionally left out. In fact, many argue that the booming markets will be most profitable through diversified approaches. This reality highlights the second factor to watch this year: the region's focus on increasing human capital. Dubai, for example, struggles to attract expatriates because of rising living costs, and the residential markets in both Dubai and Abu Dhabi have experienced a growing 'supply and demand' imbalance. This indicates a low rate of middle class nationals seeking to establish professional networks in a region experiencing infrastructure growth in all sectors. Dubai responded to this mismatch by focusing on improving the quality of education and working with foreign investors to provide first-class education systems that compete with nearby regions. Similar approaches will help the GCC retain skilled nationals and attract highly capable professional that will improve demographic imbalances across the MENA region.
The GCC is prepared to see a great deal of success in 2015, but the region will need to maneuver its efforts to work against a reliance on oil and towards development in other sectors. The GCC expects increased investment across all economic sectors as it relinquishes restrictions on foreign trade; and the region has the opportunity to strategically plan infrastructure developments to retain regional talent. The GCC has the means and resources to maintain its position as one of the most attractive regions for the tech-boom and it will do so by becoming a leader in modern standards.
Posted in UncategorizedTagged economic development, economic sectors, Foreign Investors, GCC equity market, oil prices, sovereign wealth funds1 Comment
Doing Business in Saudi Arabia: Options and Overview for Foreign Investors and Companies
Posted on March 25, 2014 by Wassem Amin
(Note: This Article was originally published the American Bar Association, Section of International Law Quarterly Newsletter in March 2014. For a downloadable copy of the newsletter, click here.)
By: Wassem M. Amin, Esq. MBA*
The Kingdom of Saudi Arabia is one of the fastest growing economies in the Middle East. In 2013, the government increased its budget by more than 20% than the previous year, to approximately 820 Billion Saudi Riyals ($219 Billion). Additionally, Saudi's King Abdullah pledged more than $500 billion on social welfare and infrastructure projects over the next few years. Saudi Arabia's increased spending is part of its policy to create economic diversification and reform, in turn decreasing their dependence on oil revenue and creating new jobs for the local population.
A large proportion of the Government's spending, approximately 300 billion Riyals, has been allocated to capital expenditures on investment projects and social infrastructure. Ambitious plans include building 539 new schools and universities, as well as the development of several new cities in the sprawling desert kingdom.
The biggest beneficiary of this expansionary policy is the construction industry. Demand in the construction and associated sectors, such as residential and commercial real estate development, will increase exponentially, representing an excellent market opportunity for foreign investors and international corporations seeking to enter the Saudi market.
Applicability of Islamic Finance
Construction projects in Saudi Arabia are typically either public or private. The governing law which applies to all contracts, including construction, is Shari'a, or Islamic, law. General principles of Islamic Finance are applicable, such as the duty to act reasonably, in good faith, and to mitigate losses.
In the private sector, within the construction sector specifically, the Islamic Finance principle that applies is the "istisna'a" contract, which is a contract for the sale of an asset that is yet to be constructed or manufactured. Using this structure, the party providing capital, the financier, enters into a contract with the purchaser of the building to be constructed. Usually the financier, whether a bank or investor, will then enter into a back-to-back construction contract with a general contractor for the project. The financier realizes a profit from the spread between the cost of the construction contract and the price of the purchase contract.
However, in the public sector, specific regulations and a complex legal framework govern bidding for public works, as well the interpretation and enforcement of underlying contracts. While still generally subject to Islamic Law principles, public works contracts are considered administrative contracts and are subject to the Government Bids and Procurement Law, implemented with associated regulations.
Establishing a Foreign Presence in Saudi Arabia
Recent amendments in the law and a shift in policy by the government to attract foreign direct investment have made it easier than ever for a foreign company or investor to establish business operations in Saudi Arabia. Although there are a variety of business organizations in Saudi Arabia, the most commonly used by foreign companies in undertaking construction projects are Limited Liability Companies (LLCs). That is due to the relative ease of incorporating an LLC (as opposed to, for example, a Joint Stock Company), minimal capitalization requirements, and the requirement of less corporate governance formalities.
The actual procedure of establishing an LLC in Saudi Arabia is typically a two-step process: (1) First, the foreign partner applies to the Saudi Arabian General Investment Authority (SAGIA) for a foreign investment license; (2) Second, once SAGIA issues the license, the partners in the proposed LLC apply to the Ministry of Commerce and Industry in order to incorporate the company. Once approved, the Ministry will certify the formation documents of the LLC and issue a commercial registration certificate–which permits the LLC to begin operating in the Kingdom legally.
Saudi Arabia's Foreign Investment Regulations give foreign investors a variety of options in determining how to conduct business operations in the Kingdom. However, regardless of the option chosen, if a physical commercial presence is established, foreign investors must first obtain a foreign capital investment license from the Saudi Arabian General Investment Authority (SAGIA). The following section gives an overview of the other options that may be feasible
Overview of Saudi Arabian Business Entities and Markets
Investments in Saudi Arabia may be through the formation of a new business entity or through the acquisition of assets or equity in an existing company. Commercial enterprises by foreign companies may be structured as any of the following: (1) joint ventures, (2) wholly owned subsidiaries, (3) local branches of a foreign company; or (4) representative or agent offices.
The principal body of law governing commercial enterprises in Saudi Arabia is the Companies Regulation, which is enforced and regulated by the Ministry of Commerce and Industry. In some circumstances, an enterprise may be subject to the rules and regulations of additional regulatory bodies such as the Saudi Arabian Stock Exchange (Tadawul), the Saudi Arabian Monetary Agency (SAMA), or the Capital Market Authority (CMA).
In terms of the legal type of entity established, foreign investors have several options to consider–depending largely on the scope and type of the proposed enterprise as well as the investor's exit strategy. The types of entities are: (1) Joint Stock Company; (2) Limited Liability Company; (3) Joint Venture; (4) Branches of foreign companies; and (5) Technical and Scientific offices of foreign companies.
Joint Stock Company (JSC): JSCs are the most analogous entity to a C-Corporation in the United States. They may be wholly foreign owned and are typically established with the intent towards a future public offering and listing on the Saudi Stock Exchange (Tadawul). A minimum of 5 shareholders and 3 directors on the board of directors is required. The minimum initial capitalization required is 2 Million Saudi Riyals (SR), which rises up to SR10 Million if the JSC will issue publicly traded shares.
Limited Liability Company (LLC): As with JSCs, Saudi law permits an LLC to be wholly foreign owned and managed. LLCs must have at least 2, but not more than 50, member-investors. Each member owns a pro-rata equity share equal to the uniform nominal value. Liability of individual members, under most circumstances, is limited to the member's paid-in capital. Minimum initial capitalization for an LLC with any foreign members is typically SR500,000. However, for certain industries, such as agricultural or industrial projects, the minimum capital may be much higher. Unlike JSCs, LLCs do not issue shares and cannot be publicly traded on the Saudi Arabian Stock Exchange.
Joint Ventures – LLCs and JSCs may both be wholly owned or established with a Saudi business partner. The decision to establish a Saudi partner may be mandatory in some fields, such as establishing a branch of international law firm. However, in other cases, a foreign investor may benefit from a Saudi partner's expertise and familiarity of the local market, customs, and traditions. The risks and benefits of doing so must be carefully analyzed after thorough due diligence is conducted.
Branches of Foreign Companies – Branch offices are set up to represent foreign companies in Saudi Arabia. Similarly to JSCs or LLCs, branch offices are allowed to engage in direct business activities. However, their scope of business is limited to that of the parent company.
Technical and Scientific Offices (TSOs) – TSOs are easily set up in Saudi Arabia and are usually established when a foreign company enters into long-term distribution or agency arrangements with local companies. However, their scope of allowed commercial activity is limited to providing technical support and assistance to local distributors, agents, and consumers. TSOs are prohibited from engaging in any direct business activities.
Other Commercial Arrangements – Distribution arrangements may be done through a joint venture with a Saudi partner or by appointing a local distributor or agent on your behalf. Other options, such as franchising or a direct international sale, may also be available, depending on the type of service or product the foreign company offers.
Saudi Arabia is a lucrative market for foreign companies and investors. At a time when the market in the United Arab Emirates is beginning to get stagnant and saturated, Saudi Arabia remains ripe with opportunities. However, the cultural, political, and legal landscape is complex and varies dramatically from that of countries such as the USA or in Europe. Unaccustomed foreign companies or investors should seek out advisory or legal firms who are proficient and have expertise in Saudi Arabia.
Disclaimer: These materials have been prepared by Wassem M. Amin, Esq. for informational purposes only and are not legal advice. The material posted on this web site is not intended to create, and receipt of it does not constitute, a lawyer-client relationship, and readers should not act upon it without seeking professional counsel.
Wassem M. Amin, Esq., MBA is an Associate Attorney at Dhar Law LLP in Boston, MA and is the Vice Chairman of the Middle East Committee as well as the Islamic Finance Committee of the American Bar Association's International Law Section. Wassem has extensive experience in the Middle East region, having worked as a consultant in the area for over 9 years. Wassem currently focuses his practice on Business Immigration (EB-5 Regional Center and Investor Representation) and International Business Transactions. For more information, please visit the About Us page or http://www.dharlawllp.com.
Posted in Dhar Law LLPTagged Foreign Investors, Wassem Amin, Wassem M. AminLeave a comment
Client Advisory: Canada's Shutdown of Immigrant Investor Program Will Impact U.S. EB-5 Quota
By Wassem M. Amin, Esq., MBA
The Canadian Government announced on February 12, 2014 that it is shutting down the Immigrant Investor Program, effective immediately, with all pending cases being rejected. As reported in Forbes.com, an estimated 45,000 Chinese Immigrant Investors with applications pending will be affected by this decision. With the increased popularity of the U.S. EB-5 Immigrant Investor Program in China, it is inevitable that some of those affected applicants will choose to divert their investments here.
Assuming that even a fraction of those 45,000 investors applied through the EB-5 Program, the impact on the EB-5 Quota will be substantial. U.S. Immigrations Laws allot 10,000 annual visas to EB-5 Immigrant Investors. The visas are awarded on a first-come, first-serve basis. As discussed in prior posts, forecasts indicate that this quota will be met as early as June of 2014–effectively backlogging all Chinese Immigrant Investor applicants.
However, it is critical to note that prior forecasts did not account for the potential influx of rejected Chinese Immigrant Investors from Canada. This poses immediate consequences for EB-5 applicants from China. An unexpected increase in Chinese applicants will result in the EB-5 quota being met earlier than the deadline previously forecasted, perhaps as early as April of 2014. That will cause applications processed by USCIS after the deadline to be backlogged, perhaps by a year or more, in addition to current processing times for an I-526 (Immigrant Investor Application).
Potential EB-5 Applicants, particularly those from China, are advised to contact a legal professional to discuss the potential impacts this may have on their applications.
Wassem M. Amin, Esq., MBA is an Associate Attorney at Dhar Law LLP in Boston, MA and is the Vice Chairman of the Middle East Division of the American Bar Association. Wassem has extensive experience in the Middle East, having worked as a consultant in the region for over a decade. Wassem currently concentrates his practice on Corporate Law, Business Immigration and International Business Transactions. He has advised countless Eb-5 Investors and assisted developers in structuring USCIS-compliant EB-5 Regional Centers as well as sourcing investors throughout the Middle East. For more information, please visit the About Us page or request more information on our Contact Us page.
Posted in EB-5, ImmigrationTagged EB-5, Foreign Investors, IIUSA, Immigrant Investor, Immigrant Visa, Immigration Law, Immigration Reform, Wassem Amin2 Comments
EB-5 Chinese Quota Retrogression: Analysis of Potential Impact and Recommended Solutions
Posted on February 4, 2014 by Wassem Amin
(Visit our Publications Page for a FREE PDF Download of this Article)
Over the past few years, the skyrocketing popularity of the EB-5 Immigrant Investor Visa program has fueled record demand from foreign investors. The EB-5 Immigrant Visa allows foreign investors and their immediate family members to obtain permanent residency, providing an eventual path for citizenship, in exchange for a $500,000 to $1,000,000 investment in a job-creating enterprise. The overwhelming majority of EB-5 foreign investors, over 80%, have come from China. Allotted a maximum quota of 10,000 visas per year, the EB-5 Immigrant Visa is further subject to a numerical per country limit in the event that quota is met. Known as "retrogression," this limitation essentially works by creating a backlog in visa availability for immigrant investors from oversubscribed countries.
The U.S. Department of State cautioned in a December 2012 bulletin that projected demand of EB-5 Visas in that fiscal year may subject Chinese immigrant investors to retrogression. Although that never came to fruition (not due to demand, but primarily caused by slow processing times), the Department of State renewed its caution alert again in December 2013. Although the 10,000 visa-quota has never been met since the inception of the EB-5 Program, based on new statistics recently released by the United States Citizenship and Immigration Service ("USCIS"), it is now evident that the demand will surpass the available quota inevitably, perhaps as soon as this Fiscal Year 2015. This no longer makes the likelihood of Chinese quota retrogression a question of "if," but rather "when."
The implications of Chinese quota retrogression are far-reaching and affect not only potential Chinese investors but the entire EB-5 industry, including Regional Centers, project developers, agents, and professional service providers such as attorneys. This article will begin with a brief overview of the EB-5 program and how visa retrogression works. It will then assess the potential ramifications of Chinese EB-5 visa retrogression for investors and the EB-5 industry. Finally, it will propose solutions to alleviate the potential impact of Chinese quota retrogression on project developers and Regional Centers.
In 1990, the U.S. Congress created the employment-based fifth preference ("EB-5") immigrant visa category for immigrants who invest in and manage U.S. commercial enterprises that benefit the U.S. economy and create jobs. Allotted 10,000 immigrant visas annually, the EB-5 immigrant visa was designed to attract foreign direct investment into projects that would directly impact the economy, i.e., not merely passive investments.
Immigrant investors can apply for an EB-5 visa through two primary routes. The first route is through a direct investment into a qualifying "new commercial enterprise." The second is through the Regional Center Pilot Program. The Regional Center Pilot Program allows USCIS to designate private or public entities as so-called Regional Centers to function as conduits or administrators of large or medium-scale projects funded, at least in part, by EB-5 investors. Regardless of which route is selected, the EB-5 Investor Visa allows foreign investors to obtain permanent residency in the United States conditioned upon an investment of a minimum of $1,000,000 (or $500,000 in a high unemployment or rural area) in a project which creates and sustains at least 10 full-time jobs for U.S. workers.
How Does Visa Retrogression Work?
Congress sets limits on the number of immigrant visas that can be issued each year. In order to adjust status to that of legal permanent resident, an immigrant visa must be available to the applicant both at the time of filing and at the time of adjudication. Visa retrogression occurs when more people apply for a visa in a particular category or country than there are visas available for that month. Retrogression typically occurs toward the end of the fiscal year as visa issuance approaches the annual category, or per-country limitations. When an applicant files an immigrant petition, he or she is given a "priority date." The priority date is the date when the immigrant petition is properly filed with USCIS. If, at the time of adjudication, an applicant's priority date no longer meets the cut-off date published by the Department of State, due to retrogression, his or her case must be held in abeyance until a visa once again becomes available.
The EB-5 Program is allotted 10,000 annual immigrant visas. However, that number is misleading because the quota counts an investor as well as his beneficiaries, i.e.,if an average investor is married and has two children, the total number of visas counted towards the quota will be four. In reality, the average number of actual EB-5 principal investors is around 3,000, substantially lower than the available quota.
Once that annual quota is met, the per country limitations on EB-5 visas will be imposed, creating a waitlist for applicants from oversubscribed countries. Since Chinese applicants account for the substantial majority of EB-5 visas, they will be the ones directly impacted. This backlog would essentially delay an investor's ability to obtain an immigrant visa by a year or more, in addition to normal USCIS processing times for an I-526 (the Immigrant Investor Petition). Therefore, if, for example, an I-526 petition normally takes 6-9 months, a backlog due to visa retrogression would extend processing times to an average of two years, if not more.
What is the Likelihood of a Chinese Visa Retrogression?
In FY2013, 8,567 EB-5 visas were issued. In the first two months of FY2014, over 6,700 EB-5 petitions are already pending with USCIS. Absent Congressional action, the prospect of EB-5 petitions exceeding the annual 10,000 allotment is inevitable. Once that quota is met, the per country limits will result in visa retrogression for Chinese investors, delaying their ability to obtain an immigrant visa by at least a year or more, in addition to the time it takes to process the I-526.
Potential Implications
In the long-term, the delay and complications of EB-5 processing will result in Chinese investors looking to other countries that actively compete for foreign investors, including Australia, Canada, and the United Kingdom. Retrogression adds further strains on the EB-5 program which has already been plagued by extraordinarily slow processing times and delays by USCIS. Faced with the prospect of waiting two or more years before being able to immigrate to the United States, a Chinese investor may decide to immigrate elsewhere. Other countries will surely capitalize on visa retrogression to draw away potential investors.
In addition, the Chinese retrogression creates a significant conflict of interest between project developers, Chinese investors and immigration agents. It also raises new ethical issues for an attorney representing the project developer or the Chinese investor.
From an investor's perspective, an investor with children who are reaching the age of 21 may have incentives to delay the approval of the I-526 as long as possible. Under the Child Status Protection Act ("CSPA"), commonly known as the "age-out provisions," a child can immigrate as a beneficiary of a parent's immigration application until he or she turns 21. The CSPA freezes the age of children who are derivative beneficiaries of an I-526 petition while the petition is pending, but not once the petition is approved and awaiting the quota to become available for an immigrant visa. This benefits a Chinese investor whose children are close to aging out. Thus, it will be their benefit to delay the I-526 approval as long as possible.
From a Regional Center or project developer's perspective, job creation projections and capital redemption timelines will be directly impacted by retrogression. Capital redemption, or the investor's exit strategy, is, essentially, the time period before which the investor can have his capital returned. A protracted visa immigrant visa availability will tie up the investment money for a longer period of time. Although that may seem like a benefit to the project developer, most current EB-5 investments provide for an exit strategy in which the developer sells or refinances the business, using the proceeds to repay investors. A delay in visa availability will delay the developer's ability to do so–since an investor cannot redeem capital before the approval of an I-829, which is the petition to remove conditions on investor's permanent resident card.
Another potential implication is whether such a delay would impact the developer's ability to access investor funds. In a typical investment through a Regional Center, the investor's capital is held in an escrow account until the approval of the I-526, at which point the funds are released to the developer. Previously, an I-526 approval typically meant that the investor would be able to immigrate to the United States (or adjust their status) shortly thereafter because an immigrant visa was always available. However, visa retrogression will delay that process by a significant period of time. An investor, therefore, may dictate that the funds be held in escrow until a visa becomes available, not simply until the I-526 is approved. Without alternate financing, this delay could essentially result in an inability to proceed with a project's development and, ultimate failure.
From an attorney's perspective, counsel for a Regional Center must recognize the additional securities disclosures that may result from visa retrogression. Specifically, new risk factors for offering documents or Private Placement Memoranda would need to be disclosed. Similarly, counsel for an investor would need to highlight the possible implications to their client.
Solutions and Proposals
Bridge Financing
However, the growth in EB-5 financing market has the creation of spurred specialized loan companies that address this very issue. There are now several companies that provide specialized EB-5 bridge loans which allow a developer access to all or some of its anticipated capital.
Bridge or interim financing provides the opportunity for EB-5 project developers to take out short term financing to help construct and develop the project, then the EB-5 capital, as it is received, may replace that short term financing yet still receive credit for job creation by USCIS.
Moreover, in its latest Policy Memorandum, USCIS has specifically indicated that such financial arrangements are allowed in the EB-5 context. In a May 20, 2013 Adjudications Policy Memorandum, USCIS stated, in pertinent part:
It is acceptable for the developer or the principal of the new commercial enterprise, either directly or through a separate job-creating entity, to utilize interim, temporary or bridge financing – in the form of either debt or equity – prior to receipt of EB-5 capital. If the project commences based on the bridge financing prior to the receipt of the EB-5 capital and subsequently replaces it with EB-5 capital, the new commercial enterprise still gets credit for the job creation [arguably the main requirement of the EB-5 program] under the regulations….Developers should not be precluded from using EB-5 capital as an alternative source to replace temporary financing simply because it was not contemplated prior to obtaining the bridge or temporary financing.
Tapping Alternative Markets
Prudent project developers and Regional Centers should hedge the risk of any impact a shortage in Chinese investors may cause. Since over 80% of EB-5 investors are from China, even a small decrease in the number of investors may have an significant impact. Creating an alternative pipeline of EB-5 investors from different regions is the key to ensuring continued and sustained growth in the EB-5 Program.
[1] Wassem M. Amin, Esq., MBA is an Associate Attorney at Dhar Law LLP in Boston, MA and is the Vice Chairman of the Middle East Division of the American Bar Association. Wassem has extensive experience in the Middle East region, having worked as a consultant in the area for over 9 years. Wassem currently concentrates his practice on Corporate Law, Business Immigration and International Business Transactions. He has advised countless Eb-5 Investors and assisted developers in structuring USCIS-compliant EB-5 Regional Centers as well as sourcing investors throughout the Middle East. For more information, please visit the About Us page or request more information on our Contact Us page.
Posted in Dhar Law LLP, EB-5Tagged Alien Investor, Dhar Law LLP, EB-5, Foreign Investors, Green Card, Immigrant Investor, Wassem Amin, Wassem M. Amin1 Comment


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16. Help guests find the very best seats with Pokemon tags that double as wine glass charms.
17. And use your favorite board games as table numbers for a fun ice breaker.
18. Or if Legos are more your jam, set some up as centerpieces people can build themselves.
19. Skip the traditional first dance and make some magic with wands instead.
20. Create a tabletop Quidditch game for some mid-wedding wizardry.
21. When that's all done, cut into this Catan-believable wedding cake.
22. Or tempt the fate of a Red Wedding with this Game of Thrones-themed cake.
23. Use this sonic screwdriver cake cutter and server to cut the first slice.
24. Show guests why you're so serious about each other with this Joker-inspired signature cocktail.
25. Instead of a guest book, have guests sign this Groot and Rocket poster.
26. Take some out-of-this-world portraits.
27. And when the big day's finally over, drive off into the sunset with this sweet new windshield decal.


The registration for PUBG PC Tournament supported and organized by IGZ, Goutfits & Harshit Singh went live this morning. The tournament is featuring cash prize of INR 30,000 & goods for the winners.
India is one of the world's second largest community rapidly growing in terms of casual gaming and technology. The gaming community in India has witnessed a magnificent extension of gaming. PUBG, which is the hottest title in India right now, has millions of active gamers every month.
The PUBG India community has been putting a lot of efforts in elevating the scenario.
Announced last week, the PUBG PC tournament for professional will be one of its kind. The registrations are active on the IGZ website and more details will be made available on IGZ facebook page for information. The event is organized and handled by one of the community's senior member, Harshit Singh.


This past week Blake and I got the chance to sneak away from work, chaos and whatever else for a little Mommy & me time. We two items on our to-do list; one, get Daddy a really good Father's Day present and two, have a picnic! Two very important tasks if you ask me.
We headed to Target (because well, it's Target) and found Marcus the perfect Father's Day card. I literally let Blake pick it out and it was the cutest to watch her look at every single card then finally reach out to grab one. The first one she grabbed, was the one we got–and it just so happened to be perfect 😉 (and not a wedding or thank you card. Ha!). Blake held the card, folded it in half and ate it while we shopped around for the perfect present. I figured a folded, crinkled up card was exactly what a Father's Day card should look like, so I let her just do her thing!
Our picnic included a whole lot of attempts to eat tall grass, crawling after bugs and eating in between. It was the perfect opportunity to use our Gathre mat from The Baby Cubby and have some girl time. I know she's totally young and doesn't get it yet, but that hour away from real life, work and chaos was amazing. I got to soak in every second with her, listen to her babble, watch her play with her little stuffed animals and snuggle her way too much (who am I kidding there are never too many baby snuggles!). It was perfect.
She kissed every single thing I pulled out of the bag (she's really into that right now)–her hat, her cow stuffed animals, the food pouches, the ground, my bag and well really everything EXCEPT me. Ha! I don't know what it is but she will never give Mama a kiss–but I'm determined to break that habit! She talked to all the things, clapped at the birds and said "here you go" and "thank you" every time I would give her something. Seriously it was the perfect little date.
A big thank you to The Baby Cubby for the goodies for our picnic.
The Baby Cubby is for every parent out there who has ever felt overwhelmed or discouraged about becoming a parent. Their team is made up of parents who have been there, they know what it's like and are passionate about encouraging, inspiring, and reminding parents how amazing they are and how important their role is. The way they do that is by finding the best and safest baby gear and providing it to parents in a fun shopping experience where they do things like test strollers on their stroller track, price match everyday – even amazon, offer free shipping nationwide at BabyCubby.com and actively engage with parents via social media and their cubby community blog to discuss some of those hard topics of parenting. You can read a little bit more about what they're passionate about and why we do what we do on their about us page, here.


text:
Paratheocris viridis is a species of beetle in the family Cerambycidae. It was described by Per Olof Christopher Aurivillius in 1907, originally under the genus Theocris. It is known from Cameroon.

References

Endemic fauna of Cameroon
Theocridini
Beetles described in 1907

redpajama_set_name: RedPajamaWikipedia


The red carpet at the 88th Academy Awards was flooded with incredible gowns featuring intricate beading, tiered embellishments, plunging necklines and princess-worthy jewels. Here, Rachel Zoe's best-dressed list from the star-studded evening.
"Charlize is red-carpet royalty and this dress absolute perfection on her."
"Rooney's look is both ethereal and incredibly elegant. Her hair and makeup is flawless—I adore the dramatic lip."
"I love the fact she's wearing a white jumpsuit...It's really chic."
"Naomi takes an otherwise simple column gown to a really glamorous place with this ombre moment."
"Cate is a total goddess tonight, as she has been all awards season."


text:
Get Quotes from Top Plumbers in Bakersfield, CA
Enter the location of your project:
Questions to Ask Before Hiring a Plumber in the City of Bakersfield
One in every Ten homes in the City of Bakersfield lose around 90 gallons of water daily to undetected leaks. Such leaks include dripping faucets, faulty toilet, loose sprinkler head, and broken underground pipes and can add several hundred dollars to your annual utility bill if you delay in fixing them.
When looking to hire a plumber to resolve these types of matters, it is important to make sure that this plumber is licensed, insured, experienced, and properly equipped for the task at hand. You can find good plumbers near you seeking out the plumber who can provide get satisfactory answers to the following questions:
Are You Licensed to Practice as a Plumber in the City of Bakersfield?
How Much Do You Charge Compared to Plumbers in the City of Bakersfield?
Do You Comply with the City of Bakersfield Building Code for Plumbing?
Will You Get the Plumbing Permits as Required by the City of Bakersfield Code?
What Kind of Plumbing Services Do You Offer?
Do You Offer Emergency Plumbing Services in the City of Bakersfield?
Do You Carry the Necessary Insurance Policy for Plumbers in the City of Bakersfield?
How to File a Complaint Against a Bad Plumber in the City of Bakersfield
State: * SelectAlabamaAlaskaArizonaArkansasCaliforniaColoradoConnecticutDelawareDistrict of ColumbiaFloridaGeorgiaHawaiiIdahoIllinoisIndianaIowaKansasKentuckyLouisianaMaineMarylandMassachusettsMichiganMinnesotaMississippiMissouriMontanaNebraskaNevadaNew HampshireNew JerseyNew MexicoNew YorkNorth CarolinaNorth DakotaOhioOklahomaOregonPennsylvaniaRhode IslandSouth CarolinaSouth DakotaTennesseeTexasUtahVermontVirginiaWashingtonWest VirginiaWisconsinWyoming
License Number: *
Plumbers in Bakersfield are regulated at the state level by the California Contractors State License Board (CSLB). Any plumber that wishes to perform plumbing work in the city worth a total value of $500 or more, including the cost of labor and materials for the job, must obtain an appropriate license from this agency. Individuals that wish to obtain a license from the CSLB must be no younger than 18 years old, and they must complete the following steps:
Submit acceptable and verifiable documentation signifying that they have attained a minimum of four years of experience in plumbing work. Note that this work experience must be attained at the journeyman level.
Complete and submit an Application for Original Contractor License Form, along with an application fee and any other required documents.
Pass a CSLB-administered licensing examination. It should be noted that the CSLB runs a reciprocity program that allows eligible applicants from the States of Nevada and Arizona to waive the trade section of its licensing examination.
Plumbers that fail to obtain a license from the CSLB and perform work worth $500 or more in Bakersfield are subject to misdemeanor charges, which are punishable by statutory penalties of up to six months in jail, fines of up to $5,000, or both. These individuals can also receive administrative charges of anywhere between $200 and $15,000, with repeat offenders receiving even stiffer penalties. Likewise, plumbers that intentionally mislead residents of the city into believing that they possess a valid CSLB-issued license or illegally use a license issued to another individual can face felony charges, which are punishable by incarceration in state prison.
You can contact the CSLB at (800) 321-2752 to get more information on the penalties for unlicensed plumbing in Bakersfield, confirm the validity of your intended plumber's license, or direct any other plumbing license-related queries. You can also confirm the validity of your intended plumber's license online via the CSLB's Check a Contractor License platform.
Plumbers typically charge for their services after considering several factors. These include the nature and scope of the task that they are expected to perform, the cost of parts, materials, and permits that may be required for the job, and the amount of physical labor required to complete the job. The plumber's level of experience and expertise may also influence their rates. Nonetheless, you should always consider getting quotes from several plumbers near you and comparing these quotes to ensure that you are charged a fair and reasonable rate for your plumbing project.
Plumber in the City of Bakersfield earns an annual average wage of $56,960. Below is a breakdown of the average hourly wages for plumbers in Bakersfield compared with plumbers in other parts of California and other major cities in the country:
Bakersfield Plumbers Hourly Average Wage
California Plumbers Hourly Average Wage
Los Angeles Plumbers Hourly Average Wage
Atlanta Plumbers Hourly Average Wage
New York City Plumbers Hourly Average Wage
Detroit Plumbers Hourly Average Wage
Houston Plumbers Hourly Average Wage
Plumbing work in the City of Bakersfield is regulated by a set of standards and requirements collectively referred to as the city's plumbing code. This plumbing code, which is an adopted and modified version of the 2019 Edition of the California Plumbing Code, applies to the installation of new plumbing systems as well as the alteration of existing plumbing systems in Bakersfield. The provisions of the code are implemented and strictly enforced by relevant authorities to promote the public safety and welfare of the residents of Bakersfield in relation to their use and interaction with plumbing systems.
Violations of any provision of the city's plumbing code are punishable as administrative citations, infractions, or misdemeanors, and violators are subject to fines of up to $1,000, jail time of up to six months, or a combination of both. As such, it is always in your best interest to hire a plumber that is not only conversant with the city's plumbing code but also complies with its provisions. While licensed plumbers in Bakersfield typically fit these criteria, you should always get confirmation on this from your intended plumber. It is also a good idea to contact the Building Division of the Bakersfield Development Services Department at (661) 326-3720 to get information on the specific provisions of the city's plumbing code that apply to your plumbing project.
The Building Division of the Bakersfield Development Services Department is authorized to administer and enforce the provisions of the city's plumbing code. These provisions include the issuance of permits for the installation of new residential and commercial plumbing systems in Bakersfield as well as the alteration, replacement, and removal of existing residential and commercial plumbing systems. However, per the requirements of the 2019 Edition of the California Plumbing Code, which the City of Bakersfield adopts and implements, permit exemptions are made for some types of plumbing-related work. These include:
Plumbing work related to the stopping of leaks in drains, vent, soil, or waste pipes, provided that no concealed traps, drain, vent, soil, or waste pipes in this work will require removal and replacement with new material.
Plumbing work related to the stopping or repairing of leaks in valves, fixtures, and pipes, and the removal and reinstallation of water closets, provided that these repairs do require or involve replacing or rearranging any valves, fixtures, or pipes.
Plumbing work related to minor changes, alterations, or repairs as determined by the city's Building Division, provided that this work does not affect structural features, sanitation, safety, egress, or accessibility to the property.
Interested parties that wish to obtain a plumbing permit from the Building Division of the Bakersfield Development Services Department are typically required to complete an Application for Building Permit and pay a stipulated permit fee. Depending on the nature of the plumbing project, the submission of drawings, plans, and calculations, and any other specified documents may also be required. The application form, permit fee, and other required documents can be submitted at:
City of Bakersfield Development Services
Hours: 8:00 a.m. - 5:00 p.m., Mondays to Fridays
Permit applications may also be made online via the city's Click2Gov portal. Note that a user account may have to be created before this portal can be properly utilized. Also, once the requested permits have been issued, the Building Division typically conducts inspections of the project at various stages as well as when it is completed to ensure that it complies with the applicable provisions of the city's plumbing code. Queries related to the Bakersfield plumbing permit and inspection processes can be directed to the city's Building Division via the contact information provided above. These queries can also be made via email.
Licensed plumbers in Bakersfield generally provide a full range of plumbing services to interested residential and commercial customers and other interested parties in the city. These services include sewer and drain maintenance services, general plumbing repairs, water heater maintenance, kitchen and bath remodeling, leak detection, video inspections, and new plumbing system installations. However, before hiring a plumber near you, it is necessary to make sure that this plumber specializes in providing the specific type of service that you need.
Provided below are cost estimates for common plumbing services available in the City of Bakersfield:
$70 - $80 per hour (excluding cost of parts and materials)
$95 - $105 per hour (excluding cost of parts and materials
Plumbing for remodel or home addition
$4,200 - $5,500 (for re-piping of 1,500 sf home with pex)
Clearing drain clogs or blockages
Drain line video inspection
Toilet installation or replacement
$150 - $160 (for labor only)
$7,100 - $8,500 (for new conventional system in three-bedroom house)
Septic tank cleaning or pumping
$260 - $310 (for 1,000 gallon tank)
Sewer line cleaning
Sewer line installation and repair
$60 - $75 per linear foot
$825 - $1,190 (for submersible pump)
$2,260 - $2,430 (for roof-mounted 7,500 cfm unit)
Water main installation or repair
Well pump installation
$730 - $880 (for mid-grade shallow well jet pump up to 25 feet deep)
Single-family residents in Bakersfield pay over $19 every month as water use quantity rates and service charges every month. As such, any plumbing issues that lead to water leaks can become quite expensive if left unattended. On the other hand, fixing simple household water leaks is estimated to save American homeowners approximately 10% on their water bills. However, while all household plumbing issues should always be speedily resolved, some of these issues usually require more urgent attention than others. Examples of these types of plumbing matters include burst pipes, clogged toilets, and no running water. Unfortunately, some of these problems occur at odd hours during which it may be difficult to consult a regular plumber. When faced with these types of emergency plumbing situations, it is common to look for the services of 24-hour plumbers near you.
However, before hiring these types of plumbers, it is in your best interest to ensure that they are licensed, skilled, reliable, and close enough to start work on the emergency plumbing situation right away. You can find plumbers in Bakersfield that fit these criteria through online resources made available by third-party review websites like the Better Business Bureau, Google Review, and Yelp. You can also utilize the CSLB's online Find My Licensed Contractor portal to find qualified 24-hour plumbers near you. Note that you should always verify the licensing status of these plumbers before finalizing any hiring agreements with them.
Plumbers in Bakersfield are not mandatorily required to carry commercial general liability insurance. Nevertheless, you should always only hire plumbers that can provide verifiable proof of this insurance, as this financially insulates you from any liabilities related to on-the-job injuries. Plumbing is a highly hazardous occupation, and plumbers typically face several chemical, physical, and biological hazards whilst on the job. These include slips, trips, and falls, exposure to parasites and potentially toxic chemicals, and cuts and lacerations from work tools. In 2019 alone, the Bureau of Labor Statistics recorded 21,490 nonfatal work-related injuries amongst plumbers and other general maintenance and repair workers. Considering this, it is important to ensure that any plumber you hire is not only duly insured, but that the plumber's insurance plan provides coverage for any injuries that may occur during your plumbing project.
Note that plumbers must maintain a contractor's bond of $15,000 during the validity period of their licenses. Also, plumbers in the city that have at least one employee are statutorily required to carry workers' compensation insurance. It is advisable to request proof of this bonding and insurance from your intended plumber and authenticate it with the relevant issuing organization.
In December 2019, a collaborative operation between the Kern County District Attorney's Office and the California Contractors State License Board in Bakersfield resulted in the arrest of 16 alleged unlicensed contractors. It was also discovered that one of these individuals was a registered sex offender. Con artists in Bakersfield typically utilize different methods and techniques to defraud unsuspecting homeowners that are looking to retain the services of plumbers in the city. A popular technique used by these con artists is showing up unsolicited, offering discounted plumbing inspections and repairs, receiving upfront payment for the work, and then absconding without doing any work. According to the CSLB, more than $49 million was recovered for consumers in Bakersfield, and the State of California as a whole, between 2018 and 2019. However, there is no guarantee that you will receive restitution if you fall victim to a plumbing scam in Bakersfield. As such, it is in your best interest to proactively prevent these scams from occurring in the first place. You can do this via the following steps:
Verify the licensing status of any plumber that you intend to hire
Get multiple bids for your project
Request and check customer references from your preferred plumber. You can also utilize resources like Better Business Bureau to get online reviews on this plumber
Obtain a written contract for the project
Avoid cash payments
Do not pay an upfront payment that exceeds $1,000 or 10% of your project's total value, whichever is less
File a complaint with the CSLB concerning any deceptive or fraudulent activities by your plumber
In addition to contacting the CSLB about fraudulent plumbing-related activities, you can also file a complaint with the Kern County District Attorney's Office by mailing a completed, signed, and dated Consumer Complaint Form to:
Kern County District Attorney
Consumer Fraud Unit
Justice Building
1215 Truxtun Avenue
Finally, you can take personal action against fraudulent plumbers and seek restitution to the tune of $10,000 by filing a lawsuit at the Kern County Superior Court's Small Claims Division located at:
Note that it is advisable to consult with a qualified private attorney before taking legal actions of any kind.

redpajama_set_name: RedPajamaCommonCrawl


text:
Meliá Hotels sees revenues fall over summer
Meliá Hotels International has revealed its results for the first nine months of the year.
The company generated revenues of €1,414 million up to September, lower than in the same period in 2017 due to the significant number of hotels under renovation and in the process of opening throughout the year.
Net profit increased by 10.1 per cent compared to the previous year and EBITDA grew by 9.1 per cent.
Meliá saw a sharp improvement in the EBITDA margin (up 83 basis points), attributable above all to improved efficiency both in sales and in management in general as the group continues to move forward with its digital transformation.
Earnings per share also grew by 10.1 per cent, to €0.52, compared to €0.47 in the same period in 2017.
Gabriel Escarrer, chief executive, Meliá Hotels International, said: "The first nine months of 2018 confirm the competitive advantage created by a strategy focused on digital and sales strength and the extensive renovation and repositioning of our assets and brands.
"Our commitment to a model that prioritises adding hotels under management agreements is also beginning to bear fruit, providing us with increasing revenues from management fees and maximising our scale and structure in different markets.
"I am proud to highlight the positive performance of the group in the first nine months of 2018, despite the competition from recovering destinations in north Africa and Turkey and the fall in bookings by northern Europeans caused by the exceptionally good weather they have had this summer."
Breaking Travel News spoke with Gabriel Escarrer, chief executive of Meliá Hotels International, at World Travel Market in London earlier this week to discover more about the group's plans for 2019. Find out more below:
Ryanair strikes deals with four European cabin crew unions
Ramada showcases wine offering with new initiative
melia hotels and resorts
Meliá Koh Samui opens in Thailand
Gran Meliá Arusha takes brand into Africa for first time
Meliá Ho Tram Beach Resort to open next month
Gran Meliá Sancti Petri to open in Andalusia, Spain, this month
Meliá rides out challenging market to report increase in profits
Innside Charles de Gaulle opens in Paris
Innside Prague Old Town takes brand into Czech Republic for first time
Innside by Meliá expands to include resort destinations


Before discussing how to write a strong medical school personal statement, we first need to understand the qualities of a strong essay. York times, january. A short essay which contains the typical arguments for affirmative action Arguments AGAINST Affirmative Action: Affirmative action is reverse seventy nine short essays on design discrimination Bekijk alle prijzen van Admissions Essay en bespaar tot 40%.. Several people, including my friends didn't know about the death of my dad that feels like it happened just last month. Christians, Wealth and Poverty The Bible does not say that money is bad. But here are a few things that happened at both. Finance is likely not the most exciting field in the world for many. Believing that happiness is 5 paragraph essay topics ideas characterized by a pleasant emotion, ranging from a simple smiling to intense joy would be seventy nine short essays on design missing the true meaning of happiness. May perform research related to speech and language problems Speech-language disorders may be a primary disability or may occur with other disabilities. You are presenting an opinion and trying to persuade readers, you want to win readers over to your point of view 10. Does your research or term paper require MLA style? why apply for scholarships essay You'll hear it from us time and time again – apply early, and apply often Scholarship Essay Theme: College. Dream is motivation. ALSO. Every part of the essay paper is important.
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to Groennfell Meadery on Sunday for the Game + SF/F Novel Swap. The event will be a good place to meet with fellow gamers and readers to swap games and novels!
Come hungry, thirsty, and ready for swapping – with delectable delights available from Groennfell!
There will be plenty of tables, however tables are first come, first serve.
Missing pieces/pages are the liability of the parties involved. Check before giving, check upon receiving.
We rock, you rock. Everyone is welcome regardless of gaming activity, gender, race, or sexual orientation. This is our community to build.


Conversation Piece can supply a native speaking German teacher to help you learn German in the comfort of your own home in Croydon. We offer a wide range of lessons to suit all levels. We were established in 1990 and supply the BBC with German teachers.
Clients contact us when they have a need to improve their German language skills. They need to be able to communicate fluently in German as quickly as possible often in a corporate environment. Conversation Piece have a number of teachers in travelling distance of Croydon that are experienced in teaching, not only advanced German, but also tailoring the syllabus to incorporate the business world.


text:
Through their eyes: exploring the complex drivers of child marriage in humanitarian contexts
Written by Nicola Jones
Hero image description: Adolescent married girl with her two children in Dhaka, Bangladesh Image credit:Nathalie Bertrams/GAGE
Child marriage, while declining in most parts of the world, remains common in many communities – especially in countries beset by conflict and other humanitarian disasters. Indeed, all 10 of the countries with the highest rates of child marriage are considered fragile, and research has found that child marriage is one of the issues most sensitive to conflict. A growing body of evidence underscores that this is because although the drivers of child marriage tend to be similar across development and humanitarian contexts – and revolve around physical and economic insecurities and deep-seated gender norms – fragility, conflict and disaster augment concerns and can increase the risk of child marriage.
Buoyed by evidence that the practice has intergenerational costs to families, communities and national economies, child marriage has risen steadily up the development agenda in the 25 years since the Beijing Declaration highlighted its cost to girls. However, even as the contours of humanitarian crises have continued to evolve, with more people displaced and for longer periods of time than since the second world war, the humanitarian sector has been slower to embrace ending child marriage as necessary for progress. Two years on from the Global Compact on Refugees, and as the Covid-19 pandemic threatens to undo decades' worth of progress towards eliminating child marriage, it is more important than ever that the global community refocus its efforts to support the capabilities of refugee and stateless adolescents – and foster refugee self-reliance – by stepping up efforts to ensure that they are not married as children.
This report begins with a brief overview of the evidence base. It then describes the sample and methodological approach used by Gender and Adolescence: Global Evidence (GAGE) to explore the drivers of child marriage in humanitarian settings and how tailored policy and programming might be brought to bear to reduce it. We first lay out the high-level drivers of child marriage – disentangling economic drivers, gender norms, and drivers related to crisis. We then explore the diverse views of the actors involved in the marriage decision-making process, looking at preferences through their own eyes and seeking solutions in their own narratives. The report concludes with priority recommendations for programming, policy, and research and evaluation.
Image credit:Nathalie Bertrams/GAGE
Elizabeth Presler-Marshall, Nicola Jones, Sarah Alheiwidi, Sally Youssef, Bassam Abu Hamad, Kifah Bani Odeh, Sarah Baird, Erin Oakley, Silvia Guglielmi and Agnieszka Małachowska
Nicola Jones
Principal Research Fellow


text:
Q: Fatal Error Index Out Of Range ( Swift 2.3 ) When i run my project i get Fatal error: Index Out Of Range and i can't find a solution for it.
I would appreciate some help,Thank you in advance!
Here is my code :
import UIKit

    // MARK : Data

    var names = ["Shalvata",
                 "Markid",
                 "Litzman Bar",
                 "The Cat & The Dog",
                 "Light house",
                 "Ku"]

    var streets = ["האנגר 28,נמל תל אביב",
                   "אבן גבירול 30,תל אביב",
                   "רחוב נמל תל אביב",
                   "קרליבך 28,תל אביב",
                   "האנגר 23,נמל תל אביב",
                   "דרך שלמה 117,תל אביב"]

    var images = [UIImage(named: "Shalvata"),
                  UIImage(named: "Markid"),
                  UIImage(named: "Litzman Bar"),
                  UIImage(named: "CatNDog"),
                  UIImage(named: "LightHouse"),
                  UIImage(named: "Ku")]

    /////////MARK : END Of Data ! ///////////

    override func viewDidLoad() {
        super.viewDidLoad()

        allUsers = createUsers(names: names, streets: streets, images: images)

        filteredUsers = allUsers

            }

    var allUsers: [User]!
    var filteredUsers: [User]!

    func createUsers(names names: [String], streets: [String], images: [UIImage?]) -> [User] {
        var users = [User]()
        guard names.count == streets.count && names.count == images.count else { return users }
        for (index, name) in names.enumerate() {
            let user = User(name: name, streetName: streets[index], image: images[index])
            users.append(user)
        }
        return users
    }

    override func tableView(tableView: UITableView, numberOfRowsInSection section: Int) -> Int {
        //Search:

        if tableView == self.tableView {

            return self.names.count
        } else {
            return self.filteredUsers.count
        }
    }

    override func tableView(tableView: UITableView, cellForRowAtIndexPath indexPath: NSIndexPath) -> UITableViewCell{
        let cell = self.tableView.dequeueReusableCellWithIdentifier("CustomCell", forIndexPath: indexPath) as! CustomCell
        let user = filteredUsers[indexPath.row]
        cell.photo.image = user.image
        cell.name.text = user.name
        cell.streetName.text = user.streetName

        return cell

    }
}

I get the error in the line:
let user = filteredUsers[indexPath.row]
Error line:
Thread 1: EXC_BREAKPOINT(code=1, subcode=0x10033ddc0)
if anything else is needed just say so,I am using Xcode 8 and Swift 2.3,
I recently started coding so i am a beginner, Sorry for that ;P

A: Because both arrays can have different number of elements at the same time. So you need add a condition inside below method to access user based upon tableview.
override func tableView(tableView: UITableView, cellForRowAtIndexPath indexPath: NSIndexPath) -> UITableViewCell{
    let cell = self.tableView.dequeueReusableCellWithIdentifier("CustomCell", forIndexPath: indexPath) as! CustomCell

    let user:User!

    if tableView == self.tableView {
        user = allUsers[indexPath.row]
    } else {
        user = filteredUsers[indexPath.row]
    }
    cell.photo.image = user.image
    cell.name.text = user.name
    cell.streetName.text = user.streetName

    return cell
}

redpajama_set_name: RedPajamaStackExchange


European Union's Vice President : CryptoCurrencies Are Welcomed But Need Regulatory Mapping.
The European Union (E.U.) would now be focusing in the event of crypto assets classification and restrictive mapping. The Vice President of the European Commission 'Valdis Dombrovskis' proclaimed at a recent meeting of Economic and Financial Affairs Council (Ecofin) in Vienna.
Mentioning further he claimed that, so as to deal with major problems involved with the digital currencies, the E.U. would be now paying attention on the challenge which is to "categorize and classify" crypto assets by the end of this year. Adding further he declared that the organization will think about whether or not existing E.U. financial regulation can be imposed, or if there's rather a requirement to develop some new rules.
As Dombrovskis stressed, the Commission has already teamed up with other European Authorities so as to develop a supposed "regulatory mapping" of crypto assets to supply a "solid ground" to determine the standing of digital currencies, along with to setup the further necessary required steps in this area.
In his speech Dombrovskis paid special attention to ICO's, mentioning them as a "viable type of alternate finance," and stating that ICOs generated around $6 Bln last year. Dombrovskis more emphasised that "this figures are considerably bigger" in 2018.
Concerning alternative issues within this field, Dombrovskis mentioned the foremost risks of crypto, together with "lack of transparency," protecting investors, market integrity, fraud, and hacking.
In this regard, the Latvian politician advised the necessity to stay observance in the dynamics of the crypto business, stressing the importance of cooperation with international partners at the Financial Stability Board (FSB) and G20.
This summer, the FSB claimed that crypto assets don't cause any material risk to International Financial Stability, whereas the sphere still wants in-depth observance because of speedy market development.
New Analysis Report : Investors Interest In ICO's Is Slowly Fading Away.
Winklevoss Brothers Successfully Launched World's First Regulated Stablecoin.


Liaison for Districts 1 and 2: Jordan Meadows, Westpointe, Rose Park, Fairpark, Poplar Grove, and Glendale.
Elaine was born in Santa Ana, California, and later moved to Kearns, Utah. She graduated from the University of Utah with a Bachelors degree in Social Work with an emphasis in macro-level practice. Elaine served as a legislative leadership intern during the 2017 General Session, and became the Executive Assistant and Campaign Manager for State House Representative Sandra Hollins. She has been active in numerous grassroots activist groups, such as the Utah Women of Color Council. She also has experience working in the healthcare field, working with various healthcare organizations to assist the uninsured and underinsured to find funding and navigate processes to receive healthcare. When not working, Elaine enjoys hiking, a good cup of coffee, and admiring artwork.


GOODGER David. Peacefully in St Elizabeth Hospice on December 20, 2018 aged 80 years. Beloved husband of Maureen and a much loved father and grandfather. A Service of Thanksgiving for his Life will be held at Rushmere St Andrew Parish Church, on Friday, January 18, at 11.00 a.m. Family flowers only please. Donations if wished for St Elizabeth Hospice and Rushmere St Andrew Church (cheques payable to St Andrew's Rushmere PCC) may be sent to Farthing Funeral Service, Deben House, 650, Woodbridge Road, Ipswich, IP4 4PW.


text:
The 1609 Expulsion of the Moriscos in Early Modern British Thought
Nabil Matar
English, Language and Literature
Explorations in Renaissance culture
10.1163/23526963-90000375
Matar, N. (2009). The 1609 Expulsion of the Moriscos in Early Modern British Thought. Explorations in Renaissance culture, 35(2), 132-149. https://doi.org/10.1163/23526963-90000375
The 1609 Expulsion of the Moriscos in Early Modern British Thought. / Matar, Nabil.
In: Explorations in Renaissance culture, Vol. 35, No. 2, 2009, p. 132-149.
Matar, N 2009, 'The 1609 Expulsion of the Moriscos in Early Modern British Thought', Explorations in Renaissance culture, vol. 35, no. 2, pp. 132-149. https://doi.org/10.1163/23526963-90000375
Matar N. The 1609 Expulsion of the Moriscos in Early Modern British Thought. Explorations in Renaissance culture. 2009;35(2):132-149. doi: 10.1163/23526963-90000375
Matar, Nabil. / The 1609 Expulsion of the Moriscos in Early Modern British Thought. In: Explorations in Renaissance culture. 2009 ; Vol. 35, No. 2. pp. 132-149.
@article{05bd26b64702462ca5d6dbee3559186b,
title = "The 1609 Expulsion of the Moriscos in Early Modern British Thought",
author = "Nabil Matar",
doi = "10.1163/23526963-90000375",
journal = "Explorations in Renaissance culture",
publisher = "Brill Academic Publishers",
T1 - The 1609 Expulsion of the Moriscos in Early Modern British Thought
AU - Matar, Nabil
U2 - 10.1163/23526963-90000375
DO - 10.1163/23526963-90000375
JO - Explorations in Renaissance culture
JF - Explorations in Renaissance culture


text:
Q: Getting Geometry error: One or more input features have invalid geometry from QGIS I am trying to use the "Split With Lines" tool to split a polygon layer that consists 1000+ separate objects.

Geometry error: One or more input features have invalid geometry.

The tool keeps finding invalid geometry.  I have used all of the general solutions like the "Buffer", "Fix Geometries", "V.Clean", and "Reproject Layer" tools.  None of them have worked.  Is there any other way to fix the invalid geometry?
I have manually gone through and fixed all of the invalid geometry.

Then ran the "Split With Lines" and it will not complete.  It crashes out QGIS for some reason.
Why does the tool keep crashing and not completing the operation?
This is what I am trying to do for the entire data set:


Rees Pollock was my first choice of employment because it has all the advantages of a small firm without compromising on the quality of work produced, employees recruited or clients acquired.
Rees Pollock offers up many opportunities for professional development. In a short space of time I have been given a lot of responsibility and quickly become familiar with all the sections of an audit. Rees Pollock also has a varied client base, which offers an insight into many industries – from finance to hospitality to retail. This exposure has lent itself neatly to the understanding of concepts that I am studying now for my qualification.
However Rees Pollock's greatest asset is the people. Each employee is valued as an individual, which is the foundation of the Rees Pollock culture. This positive working environment is emphasised by the approachability and supportive attitude shown by everyone who works here; a comradeship reflected in our regular pub trips and student events!


text:
Guan Eng calls for probe over purported letter to CIA
Neily Syafiqah Eusoff & Sangeetha Amarthalingam
July 26, 2018 14:55 pm +08
KUALA LUMPUR (July 26): Finance Minister Lim Guan Eng has called for a thorough investigation over a purported government letter to the US Central Intelligence Agency (CIA) seeking the US's support for then prime minister Datuk Seri Najib Razak's administration in relation to the 14th general election (GE14).
"I think this issue needs to be investigated more thoroughly because it is a drastic action taken by the senior government officer (during Najib's administration). Who allows an officer to write such letter without (upper level) instructions?
"It (the letter) involved the sovereignty of the country as it seems to invite foreign authority in our domestic affairs," he told reporters at the Parliament lobby today.
Lim said such letter raises many questions.
"Now that we know there is such a letter (to the CIA), so was this kind of letter sent to other countries as well? Are there any more letters that we should address and investigate?" he added.
"We don't want to see (a situation) like 1MDB (1Malaysia Development Bhd), where at first no one admitted that they had received the money from the fund until we investigated it and found out that they received the money from the fund," he said.
According to news reports published on July 24, the National Patriots Association (Patriot) has lodged a police report against Hasanah Abdul Hamid, the former director-general of the Malaysian External Intelligence Organisation — supposedly an intelligence agency within the former Prime Minister's Office.
Hasanah had allegedly signed the letter appealing to the US to support Najib's administration, even if Barisan Nasional won with a simple majority or a single seat.


What Can You Really Learn in 1 Hour on Social Media?
Recently I was invited on #MediaChat as a guest by Aaron Kilby to discuss the topic of "Changing Careers to Do What You Love". There were 161 people who participated in the hour-long Twitter chat, which takes place on Thursdays at 7pm PST/10pm EST. Although I got to discuss things that were unique to me, I came out of the experience with more information than I could have ever imagined.
The Twitter chatters were very enthusiastic about the topic, which was exciting to see. Engaging in conversations about their past and how they got where they are now, who they are inspired by, and their passions. My main takeaway is that everyone has a different story. You will never find two people alike, and that's what makes everyone individually interesting. Whether it's family, friends, jobs, or life, people live life to the best of their capability.
Learning from experiences of others will only make us stronger as a whole. Never take a single second for granted. Look at the positives in any situation, and when things are looking dim, outreach to others for help or support.
In that hour, I heard stories of triumph, struggles, success, and inspiration. The amazing part is that this was all done via social media. You could feel the emotion in words. People were human.
This is why it is stressed in social media to be a human and not a robot. That feeling led to relating to others on a more personal, yet professional level. Brands involved in the chat offered realistic advice and made it seem as if you matter.
That's what people want. They want to feel as if they matter. Don't be afraid to tell a story, be sympathetic, and to show emotion. The real you will come through and people will respect that and try to build a connection with you. Let your words do the talking and create relationships that may spur from online to offline one day.
#YouMatter: What is one way you show others that they matter?
How Can You Benefit From Twitter Chats?
The key to networking on social media is engagement, and the key to engagement is being human. Twitter is a great platform to do all of the above. Your community and potential leads could literally be at your fingertips. That leads us into the use of Twitter Chats. Why not take full advantage of a platform when the opportunities are right in front of you?
Twitter Chats direct you to a great opportunity to get in front of your desired audience, as well as to network with like-minded people. Generally, Twitter Chats are moderated on a weekly basis with a specific hashtag, in which related communities follow and contribute. From podcasts, to questions, to open conversations, Twitter Chats allow you to build and grow relationships.
Multiple sites have compiled lists of active Twitter Chats, as well as their weekly schedules. As social media changes frequently, it is best to do your research to make sure the schedule is still up-to-date. Sites, such as Nurph and TweetDeck, allow users to see a feed from the hashtag in a more organized structure for easy following. However, you are still able to participate by just using Twitter.
Twitter Chats are beneficial in multiple ways and can be addicting! Contribute your knowledge, learn from others, find your influencers, build relationships, and target your audience. Be active and engage!
What are your favorite Twitter Chats?


Crochet was never a trend I thought I would be interested in. After helping my friend Ellie on her fashion project (which you can find here) which was inspired by the SS16 collection by Tommy Hilfiger, the Crochet trend has caught my attention. Perfect for festivals, beach holidays and nailing the boho look. I thought I'd do another trend focus because it's been a while, hasn't it? There are some pretty gorgeous picks on the high street right now and if they don't tickle your fancy, you could even pick up a crochet kit from Deramores and make your own garms.
So, there we have my top picks. I'm hoping to style up some pieces myself over the next couple of weeks. I think the trend is perfect for festivals and holidays. If you're unsure about the trend, I love the striped tee from ASOS which has a little crochet detailing around the neckline. What's your thoughts on this trend? Do you like it?
Beautiful style picks! I'm so in love with the off the shoulder crochet Topshop dress, it's gorgeous!
Love the Asos white top, gorgeous with a tan!


text:
Q: How to Customize ANTLR exception in C# I am using ANTLR 3
I am trying to custom the exception message raised from Praser.
Expression which I am using :-
2+*3

Error message recived from ANTLR is :
no viable alternative at input '*' line 1:3

I want to custom this exception message to
 Invalid Expression Term line 1:3

I tried to override GetErrorMessage(RecognitionException e, string[] tokenNames) method of parser but not able to figure out how to customize this description.
Similar to these I've to customize other exception message also.
Can anyone provide me some initial guidance how to proceed with this issue.
I am using c# 4.0

A: You can model your implementation of GetErrorMessage after the one in BaseRecognizer. All of the message templates are included in this method.
https://github.com/antlr/antlr3/blob/master/runtime/CSharp3/Sources/Antlr3.Runtime/BaseRecognizer.cs#L275

A: Catch the NoViableAltException and any other RecognitionException derived exceptions and throw out your own exception. The line number and column number can be picked up from RecognitionException.Line and RecognitionException.CharPositionInLine.

A: I've implemented in this way probably it may benifit others also :-
In my parser class :-
public override string GetErrorMessage(RecognitionException e, string[] tokenNames)
    {
            String msg = string.Empty;
            if (e is NoViableAltException)
            {
                msg = "Invalid Expression Term";
            }
            else if (e is UnwantedTokenException)
            {
                msg = "Bracket Mismatch";
            }
            else if (e is MissingTokenException)
            {
                msg = "Invalid Parameter";
            }
            else
            {
                base.GetErrorMessage(e, tokenNames);
            }
            return msg;
    }


Someone sent me this cool website that tracks aircraft around the world. Click on any aircraft, and a sidebar will display the planes' origin and destination, the aircraft type, its tail number, latitude and longitude, and more. The little yellow balls are aircraft waiting to take off, or private aircraft in flight.
I live in Wichita, and just noted that the Dreamlifter is coming in from England with some parts after a long flight. The other night after the KU / K-State basketball game in Manhattan - about midnight there were several small planes departing Junction City headed back to Wichita - probably wealthy fans.
During the big snowstorms - there was a distinct lack of flights over the southern states.
FlightAware is also lots of fun.
These sites utilize a flight plan filed for the flight and a transponder. If no flight plan is filed, the origin and destination of the aircraft can't be displayed. I use flightaware all the time.