EB-5 Redeployments

[Also available on Reddit.]

Although most EB-5 projects seems to be handled fairly and ethically, there is a scenario that pops up more than occasionally that is troubling:

Eb-5 immigrant investor invests in an offering. The governing documents, drafted years ago, are silent on the possibility of a redeployment.  Without consent and scant disclosures, the fund manager makes a new investment and redeploys the investor capital  they have been entrusted with into another project controlled by the same group that handled the initial offering. The fund manager sits on both sides of the transaction. No independent third party reviews the transaction, no investor input is solicited. The attorneys that represent the immigrant investor may also be representing the regional center or others on the management side.

Why would anyone be expected to trust the integrity of this transaction? In the event of an investor loss, I think these would be difficult cases to defend given the blatant conflicts, potential self dealing and complete lack of independent process.