Question Detail: My friend owns a large firm in China that aggregates EB-5 investors. However, he can only accept an annual percentage from the regional center and not the admin fee. He offered me, a U.S. citizen, the admin fee in exchange for helping out with emails, arranging calls, etc. If I set up an LLC to accept this admin fee, do I need to be a registered broker-dealer? I am thinking I do not because I am not the regional center or the person aggregating the EB-5 investors. Also, if the EB-5 investor creates two escrow accounts, one for the EB-5 investment and one for the admin fee, can the admin fee be released from escrow directly to the LLC I set up? Or does it have to pass through the regional center first and then is passed to the LLC?