Comment Submitted by Richard W. Pierce, Richard W. Pierce Law Office LLC

The proposed regulations omit a sub-category of the long term investor visa. The CNMI historically has provided long term investor visas to the top managers of hotels and other facilities n which the parent, that is the investor, is an alien corporation. The Hyatt and Hafa Dai, for instance, are owned by Japanese corporations. Current managers of the hotels may not be eligible for L visas (because of the requirement that he/she worked in a foreign country prior to application) but they will have their CNMI long term permits. You should alter the regulations to permit this type of long term permit holder to have the benefit of the E-2 CNMI visa.