Sukhpal S. Mann is the most visible development-side principal.
California corporate records identify him as manager and registered agent of The Pines of Grass Valley LLC and as manager of The Pines of Grass Valley EB5 Investors LLC.
The underlying development company, The Pines of Grass Valley LLC, was formed in California in July 2021 and remains active in current state-derived records.
Mann is also publicly associated with B&M Realty LLC and B&M Commercial Builders LLC at the same Auburn-area address.
His public professional profile identifies him as a California Professional Engineer and holder of a Class B General Building Contractor credential.
That is directly relevant to a ground-up apartment development.
The project is not being promoted only by financial intermediaries; one of the key development principals has an engineering/construction background and was the individual identified in the city planning process.
Recent project communications also show construction hiring through B&M Commercial Builders and public groundbreaking activity involving project engineers, local community representatives and city officials.
The developer-side address trail is centered around 9580 Upper Valley Road, Auburn, California.
State-derived records show The Pines of Grass Valley LLC, The Pines of Grass Valley EB5 Investors LLC, B&M Realty and B&M Commercial Builders sharing ownership, manager or address relationships involving Mann.
That provides a coherent development-side entity chain.
SHISHU BEDI: SECOND CALIFORNIA MANAGER AND PROJECT ENTITY CONNECTION
California state-derived records identify Shishu Bedi as another manager of The Pines of Grass Valley LLC and The Pines of Grass Valley EB5 Investors LLC.
Bedi is associated with a San Jose address in state corporate records.
The SEC Form D, however, focuses more heavily on the Seattle-based EB-5 management structure and does not prominently list Bedi as one of the amended Form D related persons.
This distinction is useful.
There appear to be two overlapping structures:
Development-side California ownership/management involving Sukhpal Mann and Shishu Bedi.
EB-5 NCE/manager structure involving The Pines of Grass Valley Manager LLC, PGV Coastal Manager LLC and Stephen Smith.
These should not be collapsed into one company.
The developer and the EB-5 regional-center/manager structure perform different functions.
THE EB-5 NCE: PINES OF GRASS VALLEY EB5 INVESTORS LLC
Pines of Grass Valley EB5 Investors LLC is the New Commercial Enterprise, or NCE, through which immigrant investors subscribe.
The entity was formed in California in August 2024.
Its initial state principal address was tied to the Auburn developer group.
By the September 2026 Form D, its principal business address is listed as:
9500 Roosevelt Way NE Suite 300 Seattle, WA 98115
That address shift is important but understandable.
The Seattle address is associated with the EB-5 management/regional-center side of the transaction rather than the Grass Valley construction company.
The amended SEC filing identifies:
The Pines of Grass Valley Manager LLC — Manager of Issuer.
PGV Coastal Manager LLC — Sole Member of Manager of Issuer.
Stephen Smith — President of the sole member of the issuer's manager.
This creates a multi-layer control structure:
EB-5 investors → Pines of Grass Valley EB5 Investors LLC → The Pines of Grass Valley Manager LLC → PGV Coastal Manager LLC → Stephen Smith / EB5 Coast to Coast ecosystem
The development entity receiving EB-5 capital is separate.
That separation is normal in EB-5 project finance.
Investors subscribe to the NCE; the NCE then deploys capital to the Job Creating Entity, or JCE, through debt, equity or another approved structure.
The exact NCE-to-JCE instrument is therefore central to investor risk.
STEPHEN SMITH AND EB5 COAST TO COAST
Stephen Smith is not a first-time participant in the EB-5 industry.
Industry conference materials identify him as Founder and President of EB5 Coast to Coast.
Historical industry materials show Coast to Coast operating regional centers since approximately 2011-2012 and participating in multiple EB-5 projects.
Industry speaker biographies have credited Smith with decades of real estate development experience and more than $1 billion of development activity.
Older EB-5 marketing materials stated that Coast to Coast had raised more than $50 million from more than 100 investors and sponsored multiple projects.
More recent industry conference biographies say the regional-center network has sponsored more than 400 EB-5 investors since 2012.
Those numbers come from industry and company promotional material, not audited financial statements, so they should be treated as background claims rather than independent performance verification.
Smith is nevertheless highly visible in the EB-5 industry.
He has spoken at immigration-investment conferences and has been quoted by EB5Investors.com discussing project selection after the EB-5 Reform and Integrity Act of 2022.
Mainstream media coverage has also quoted him regarding the use of rural EB-5 capital for U.S. development projects.
This background gives the project considerably more EB-5-specific infrastructure than a developer attempting to raise immigrant capital for the first time.
I-956F APPROVAL: IMPORTANT IMMIGRATION MILESTONE, NOT AN INVESTMENT GUARANTEE
The Pines website and EB5 Coast to Coast both state that USCIS has approved the project's Form I-956F.
That is one of the most important immigration-side milestones for a modern regional-center EB-5 project.
I-956F is the application for approval of an investment in a commercial enterprise associated with a regional center.
The filing covers the project structure, business plan, economic methodology and related EB-5 documentation.
Approval is meaningful because USCIS has reviewed the project filing before individual investors' I-526E petitions are adjudicated.
But the meaning must be kept precise.
I-956F approval does not mean:
USCIS guarantees the project will be completed. USCIS guarantees repayment of investor capital. USCIS guarantees the apartment project will be profitable. USCIS guarantees every I-526E petition will be approved. USCIS guarantees every investor will receive a green card.
Individual investors still need to establish lawful source and path of funds and satisfy other immigration requirements.
The project still must create sufficient qualifying jobs.
At-risk investment requirements still apply.
I-956F approval reduces one category of project-level immigration uncertainty; it does not eliminate investment risk.
RURAL EB-5: WHY THE $800,000 MINIMUM AND GRASS VALLEY LOCATION MATTER
The project is being marketed under the rural EB-5 category.
That matters because rural investments have strategic immigration advantages under the Reform and Integrity Act.
The minimum qualifying investment is $800,000 rather than the higher standard threshold applicable to non-TEA investments.
The program also reserves a portion of annual EB-5 visas for qualifying rural investments, and rural petitions may receive priority-processing treatment under current law and USCIS practice.
For this project, the economics are straightforward:
24 investors × $800,000 = $19,200,000.
That exactly matches the SEC Form D maximum offering.
The rural immigration category can make the project more marketable to foreign investors because visa availability and adjudication speed can matter as much as financial return.
But investors should separate immigration attractiveness from financial attractiveness.
An investment can qualify as rural and still lose money.
Likewise, a strong real estate project can still encounter individual immigration problems arising from an investor's source-of-funds documentation.
FORM D CHANGED FROM RULE 506(b) TO RULE 506(c) WITHIN FOUR DAYS
One of the most interesting regulatory details is the rapid amendment of the securities exemption.
The September 14, 2026 initial Form D was recorded as:
$19.2 million offering. Rule 506(b). Residential. CIK 0002155180.
The September 18 amendment instead checks Rule 506(c).
It also adds:
First sale: September 14, 2026. Minimum investment: $800,000. Amount sold: $100,000. Investors: 1.
This change matters.
Rule 506(b) generally prohibits general solicitation.
Rule 506(c) allows general solicitation, provided all purchasers are accredited investors and the issuer takes reasonable steps to verify accredited status.
Public EB-5 marketing is already visible through the project website, industry channels and online communications.
Rule 506(c) therefore appears more consistent with broad international promotion.
Prospective investors should treat the September 18 amendment as the more current securities-offering disclosure.
The initial 506(b) filing should remain in the historical timeline because it demonstrates that the exemption was changed shortly after launch.
THE $100,000 SOLD FIGURE VERSUS THE $800,000 MINIMUM
The September 18 amended Form D reports:
Minimum investment: $800,000. Total amount sold: $100,000. Investors: 1.
That looks unusual.
One investor contributing only $100,000 appears inconsistent with an $800,000 minimum.
There are several possible explanations.
The $100,000 could represent an initial subscription deposit or staged funding before the investor completes the full $800,000 investment.
The investor could have legally committed $800,000 while only an initial amount had been funded and reported as sold.
The amendment could reflect transitional timing in the offering documentation.
But public Form D alone does not explain the discrepancy.
FilingDossier should therefore not invent an answer.
The correct diligence question is:
Has the first investor contractually subscribed for the full $800,000 and funded an initial $100,000 installment, or is another structure being used
The subscription agreement and escrow terms should resolve this immediately.
This is an excellent example of why raw Form D figures require interpretation rather than automatic reporting.
PREFERRED EQUITY OR SENIOR DEBT A MATERIAL PUBLIC DISCLOSURE CONFLICT
The most important structural inconsistency appears outside the SEC filing.
The current EB5 Coast to Coast project page describes the EB-5 investment as:
"EB-5 structured as senior debt."
By contrast, Sukhpal Mann's own recent public project announcement states:
"EB-5 funds will be provided in the form of a preferred equity investment from the NCE to the JCE."
These structures are not interchangeable.
Senior debt usually means the NCE lends money to the project/JCE.
Relevant terms would include:
Principal. Interest rate. Maturity. Collateral. Priority. Loan-to-cost. Loan-to-value. Default remedies. Guaranties.
Preferred equity generally means the NCE acquires an equity interest with priority over common equity but below true secured debt.
Relevant terms would include:
Preferred return. Redemption. Distribution priority. Control rights. Subordination. Exit terms.
A senior lender may have foreclosure or security rights that a preferred equity investor does not possess.
A preferred-equity investor may share different economic rights and risks.
The project could potentially use terminology differently in marketing, or the structure may have changed over time.
But prospective investors should not rely on either web statement.
The final executed PPM, NCE operating agreement, JCE agreement and capital-stack documents must establish the actual instrument.
This should be one of the first questions sent to the project.
$39 MILLION DEVELOPMENT COST AND THE CAPITAL STACK
EB5 Coast to Coast describes The Pines as an approximately $39 million multifamily development.
If $19.2 million of EB-5 capital is ultimately raised, EB-5 would represent roughly half of total stated project cost.
That makes the rest of the capital stack critically important.
Potential other sources could include:
Developer equity. Construction debt. Land equity. Preferred equity. Bridge financing. Other private investors.
Current public materials do not provide a complete verified capital-stack breakdown.
Property records show relatively small prior mortgages associated with project parcels, including Mid Valley Financial loans recorded against Bennett Street properties in 2025.
Those historic parcel loans are not evidence of the final construction facility.
A $39 million ground-up multifamily project would generally require a much larger construction financing solution.
Investors should request:
Total development budget. Sources and uses. Current developer equity invested. Land basis. Construction loan. EB-5 position. Contingency. Interest reserve. Cost-overrun support. Completion guaranty. Repayment guaranty.
The project's marketing page says the developer provides both a personal construction completion guaranty and a loan repayment guaranty.
Those statements are potentially meaningful, but guaranties are only as strong as the guarantor's legal obligation and financial capacity.
Investors should review the executed guaranty rather than rely on a bullet point.
CONSTRUCTION COMPLETION GUARANTY: USEFUL, BUT CREDIT QUALITY MATTERS
EB5 Coast to Coast says the project includes a personal construction completion guaranty.
Completion guaranties can reduce a major risk in development projects.
If construction costs exceed the budget, the guarantor may be required to contribute additional capital to finish the property.
But the value depends on:
Who guarantees. Net worth. Liquidity. Other guarantees outstanding. Carve-outs. Maximum liability. Enforcement jurisdiction.
A guarantee from a highly liquid sponsor is very different from a guarantee from a developer whose assets are already pledged across multiple projects.
The same principle applies to the claimed repayment guaranty.
A repayment guaranty does not create money.
If the guarantor lacks sufficient resources at maturity, investors can still experience delays or losses.
Financial statements and guarantor liquidity are therefore central diligence documents.
I-526E DENIAL REFUND GUARANTY
The marketing page also states that the project provides an I-526E denial refund guaranty within 120 days of denial.
This can be attractive to EB-5 investors because immigration denial creates an unusual liquidity problem.
However, the scope should be read carefully.
Questions include:
Does it cover any denial Does it exclude source-of-funds problems Does it exclude fraud or misrepresentation by the investor Does it cover administrative fees Does it cover only principal Who funds the refund Is the refund obligation guaranteed by the developer Is there a reserve
An "I-526E denial refund" is not the same as guaranteed repayment at the end of the investment term.
Investors need to distinguish immigration-denial protection from ordinary investment redemption.
CITY ENVIRONMENTAL REVIEW AND SITE HISTORY
The 2022 Planning Commission record notes that commissioners discussed the history of cleanup requirements from local and state Environmental Health.
The project ultimately proceeded under a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program.
This is important because it means environmental issues were considered in the municipal approval process rather than being absent from the project history.
A Mitigated Negative Declaration under CEQA generally indicates that potentially significant environmental effects can be reduced to less-than-significant levels through identified mitigation measures.
It does not mean the site has "no environmental issues."
It means the project was approved subject to mitigation.
For a construction investor, relevant diligence should include:
Phase I environmental report. Any Phase II work. Soil remediation history. Contaminated-material handling. Groundwater issues. Closure letters. Mitigation requirements. Cost allocation.
Unexpected environmental remediation can delay construction and increase cost.
The city's public discussion makes this a real diligence topic, not a hypothetical one.
INFRASTRUCTURE, SIDEWALKS, BUS STOPS AND SEWER
City records also show attention to public infrastructure.
The Planning Commission discussed sidewalks and bus-stop needs along Bennett Street.
Earlier City Council materials addressed a public utility easement for new sewer facilities associated with The Pines.
These details may appear minor compared with a $39 million development, but they illustrate the complexity of ground-up multifamily.
Apartment construction requires more than erecting buildings.
Developers must coordinate:
Sewer. Water. Stormwater. Road access. Fire access. Sidewalks. Utilities. Transit interfaces. Landscaping. Parking.
Delays in utility work can prevent occupancy even when buildings are substantially complete.
Investors should therefore ask which off-site improvements remain unfinished and whether their costs are already included in the guaranteed maximum development budget.
108 UNITS AND RENTAL MARKET CONCENTRATION
The project will contain 108 one- and two-bedroom apartments.
At this scale, leasing performance can be materially affected by local supply.
Grass Valley is a much smaller rental market than Sacramento, Phoenix or the Bay Area.
A new 108-unit project can therefore represent a meaningful addition to local apartment inventory.
That cuts both ways.
Limited new supply can support strong rents and occupancy.
But if projected rents are too aggressive, the building cannot rely on a vast metropolitan tenant pool.
The project website cites strong regional housing demand and Bay Area migration.
Those are sponsor claims that need to be tested against:
Current vacancy. Competing projects. Median renter income. Achievable rents. Concessions. Population trends. Employment. Absorption.
The development's proximity to historic downtown can improve marketability.
The website also emphasizes resort-style amenities, pet facilities, pool and fitness center.
These can support rents but increase operating and maintenance cost.
PROJECT SCALE VERSUS EB-5 JOB CREATION
EB-5 investors need qualifying employment creation, not simply real estate appreciation.
For regional-center projects, job creation can be calculated using accepted economic methodologies and can include indirect and induced jobs in addition to direct project employment.
The approved I-956F should contain the job-creation methodology.
Prospective investors should obtain:
Total estimated qualifying jobs. Required jobs for 24 investors. Job cushion. Construction expenditure assumptions. Timing. Economic model. Contingency if project cost is lower than budget.
Twenty-four EB-5 investors generally require at least 240 qualifying jobs because each investor must be credited with at least ten jobs.
A prudent project normally targets a material job cushion above the minimum.
The fact that I-956F has reportedly been approved indicates USCIS accepted the project filing, but investors should still review the job cushion because actual expenditure and project changes can matter later.
CONSTRUCTION IS UNDERWAY — A DIFFERENT RISK STAGE THAN A PRE-DEVELOPMENT EB-5 DEAL
The project website currently says construction is underway.
Recent public posts show a groundbreaking event and construction hiring.
This is significant.
A project already under construction has passed several hurdles that a concept-stage EB-5 project has not:
Land assembled. Planning approvals obtained. Design advanced. Construction mobilized. Contractors engaged.
But construction-stage investments still face major risks.
Cost overruns. Schedule delays. Subcontractor defaults. Weather. Material prices. Labor shortages. Change orders. Inspection delays. Financing gaps.
Investors should request a current construction report rather than rely on ceremonial groundbreaking photos.
The most useful data would include:
Percent complete. Budget spent. Remaining contingency. Construction lender draws. Expected completion. Certificate of occupancy schedule. Preleasing.
B&M COMMERCIAL BUILDERS AND VERTICAL INTEGRATION
Recent project communications connect B&M Commercial Builders LLC to construction hiring for The Pines.
California corporate data also links B&M Commercial Builders to the same Auburn address network used by Sukhpal Mann and the development companies.
This suggests a vertically connected development/construction structure.
That can improve control and speed.
It also creates related-party risk.
If the general contractor is affiliated with the developer, investors should understand:
How the contract was priced. Whether it is fixed-price or cost-plus. Contractor profit. Change-order approval. Independent construction monitoring. Lien releases. Performance bonding. Completion support.
An affiliated contractor is not inherently negative.
Developer-builders often execute projects efficiently.
But related-party contracting requires transparent cost controls.
EB5 COAST TO COAST: REGIONAL CENTER EXPERIENCE VERSUS PROJECT-SPECIFIC RISK
EB5 Coast to Coast has a much longer history than The Pines offering.
Stephen Smith has been visible in EB-5 conferences and industry media for years.
Historical promotional material claimed multiple regional centers, multiple funded projects and significant numbers of approved petitions.
More recent event biographies describe the platform as sponsoring hundreds of investors.
This operating history can reduce process risk around immigration documentation.
But investors should not transfer another project's track record automatically to The Pines.
Every EB-5 deal has unique:
Developer. Collateral. Construction financing. Job creation. Exit. Repayment. Market risk.
A regional center can process many successful immigration cases while one individual real estate project underperforms financially.
Immigration administration and investment underwriting should therefore be evaluated separately.
NO SEC INVESTMENT-ADVISER APPROVAL SHOULD BE IMPLIED
Pines of Grass Valley EB5 Investors LLC filed Form D.
That does not mean the SEC approved the investment, reviewed the apartment underwriting or certified the EB-5 program.
The amended filing itself includes the standard warning that the SEC has not necessarily reviewed the information and has not determined whether it is accurate or complete.
Likewise, USCIS I-956F approval addresses the EB-5 project filing.
It is not an SEC investment-quality determination.
For investors, there are two separate regulatory dimensions:
SEC securities exemption. USCIS immigration program compliance.
Neither guarantees investment repayment.
SERVICE PROVIDERS AND PROFESSIONAL PARTIES
The public Form D identifies Thomas Garrott as attorney for the issuer and signatory to the September 18 amendment.
EB5 Coast to Coast is the visible regional-center/marketing platform.
Carel van der Merwe is listed publicly as the project's EB-5 investor contact.
The public material reviewed does not yet clearly identify:
Escrow bank. Fund administrator. Independent auditor. Construction lender. Economic-impact economist. I-956F immigration counsel. Securities counsel beyond filing signatory. Third-party construction monitor.
These parties should be obtained from the PPM.
For EB-5, escrow arrangements are particularly important because investors need to understand when capital is released to the project.
Possible triggers include:
Subscription. I-526E filing. I-526E approval. Project milestones.
The fund's treatment of the first $100,000 should also be understood in this context.
LIQUIDITY AND EXIT RISK
EB-5 capital must remain at risk for the period required by immigration law, and private real estate interests are inherently illiquid.
The investor cannot treat the $800,000 like a bank deposit.
Repayment ultimately depends on the project's exit or other available capital.
Possible exits can include:
Permanent refinancing after stabilization. Sale of the apartment complex. Developer repayment from other sources. Capital recapitalization.
Each has risk.
A refinance depends on stabilized NOI, interest rates and valuation.
A sale depends on buyer demand and cap rates.
A guaranty depends on guarantor capacity.
Investors should ask for the expected EB-5 investment term and permitted extension rights.
A five-year business plan can become seven years if real estate markets weaken.
MULTIFAMILY VALUATION AND INTEREST-RATE RISK
A newly completed 108-unit property will ultimately be valued largely from stabilized NOI and market cap rate.
Suppose stabilized NOI is $2.5 million.
At a 5% cap rate, the property value is $50 million.
At 6%, it is approximately $41.7 million.
At 7%, approximately $35.7 million.
The project's stated development cost is about $39 million.
This illustrates why exit cap rate matters enormously.
If construction cost is $39 million and stabilized value is only $36 million, refinancing or investor repayment becomes much more difficult.
If stabilized value is $50 million, the capital stack has much more cushion.
The PPM should therefore disclose projected stabilized NOI and exit cap rate.
Investors should stress-test both.
RURAL EB-5 DEMAND VERSUS FINANCIAL RETURN
The rural category itself may attract strong investor demand because immigration benefits can be compelling.
This can sometimes cause investors to focus more heavily on visa prospects than economics.
That is dangerous.
An EB-5 investor has two objectives:
Immigration success. Return of capital.
A project can achieve one without fully achieving the other.
Investors should therefore independently underwrite both.
The strongest EB-5 project is not simply one with fast immigration processing.
It is one with sufficient job creation and a credible repayment source.
NEGATIVE-EVIDENCE REVIEW
The reviewed public sources do not identify a defining SEC securities-fraud enforcement action involving Pines of Grass Valley EB5 Investors LLC, Sukhpal Mann or the current project.
The more relevant public concerns are project-specific and documentary.
The principal diligence flags are:
The September 14 Form D originally identified Rule 506(b), while the September 18 amendment changed to Rule 506(c).
The latest filing shows $100,000 sold to one investor despite an $800,000 minimum.
Current project marketing describes the EB-5 structure as senior debt, while the developer's public announcement describes NCE-to-JCE funding as preferred equity.
The city planning record references prior environmental cleanup considerations and required mitigation.
The project remains under construction rather than completed and stabilized.
The full construction capital stack and construction lender are not identified in the reviewed public materials.
The final service-provider stack is not fully public.
None of those points proves misconduct.
They are simply the issues a sophisticated investor should resolve before subscription.
FINAL ASSESSMENT
Pines of Grass Valley EB5 Investors LLC is a verifiable 2026 EB-5 securities offering tied to a real, municipally approved Northern California multifamily project.
The latest September 18 Form D amendment reports:
$19.2 million total offering. Rule 506(c). $800,000 minimum investment. First sale September 14, 2026. $100,000 sold. $19.1 million remaining. One investor. No disclosed sales commissions. No disclosed finder's fees.
The offering amount corresponds exactly to 24 investors at the $800,000 rural EB-5 threshold.
The underlying project is not merely a proposed address on an offering memorandum.
Grass Valley planning records show a multi-year entitlement history for 108 apartments on Bennett Street, including four three-story apartment buildings totaling approximately 109,644 square feet, a clubhouse, parking, landscaping and related infrastructure.
The project received environmental approval through a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program.
Its development history includes sewer easements, infrastructure planning and permit extensions.
Current project materials say USCIS has approved Form I-956F and that construction is underway.
The development side is tied to Sukhpal Mann, a professional engineer and building contractor associated with B&M Realty, B&M Commercial Builders and the underlying Pines development entities. Shishu Bedi also appears as a manager in California corporate records.
The EB-5 investment side is separately managed through The Pines of Grass Valley Manager LLC, PGV Coastal Manager LLC and Stephen Smith's EB5 Coast to Coast ecosystem.
That separation between developer/JCE and EB-5 NCE/manager is appropriate to understand and should be preserved in FilingDossier's entity graph.
Stephen Smith brings substantial EB-5 industry history and has been publicly active in regional-center development and immigration-investment conferences for many years.
The strongest unresolved issue is the exact legal position of EB-5 capital.
One current public source describes the project as senior debt.
A recent developer statement describes the NCE-to-JCE investment as preferred equity.
Those are materially different structures.
The final PPM and transaction documents must resolve the discrepancy.
The second major issue is capital stack.
A $39 million apartment project funded with up to $19.2 million of EB-5 capital requires substantial additional capital, and the construction loan, developer equity, contingency and repayment waterfall should be independently verified.
The third is construction execution.
The project is active, but not yet complete and stabilized.
The fourth is exit value.
The investors' eventual return of capital depends on a functioning repayment or refinancing source, not merely successful immigration processing.
For a prospective EB-5 investor, the priority documents are the approved I-956F package, PPM, subscription agreement, NCE operating agreement, NCE-to-JCE loan/preferred-equity agreement, project sources-and-uses statement, construction loan, current construction report, guaranties, job-creation analysis, appraisal, environmental reports and escrow agreement.
SEC SNAPSHOT
Issuer: Pines of Grass Valley EB5 Investors LLC CIK: 0002155180 Entity Type: Limited Liability Company Jurisdiction: California Year Organized: 2024 Latest Principal Business Address: 9500 Roosevelt Way NE, Suite 300, Seattle, WA 98115 Phone: 206-774-8320 Initial Form D: September 14, 2026 Latest Form D Amendment: September 18, 2026 Initial Exemption: Rule 506(b) Latest Exemption: Rule 506(c) Industry: Residential Real Estate First Sale: September 14, 2026 Total Offering Amount: $19,200,000 Latest Total Amount Sold: $100,000 Latest Remaining: $19,100,000 Latest Investor Count: 1 Minimum Investment: $800,000 Sales Commissions: $0 Finder's Fees: $0 Offering Duration: Not More Than One Year Issuer Manager: The Pines of Grass Valley Manager LLC Manager Sole Member: PGV Coastal Manager LLC EB-5 Manager Executive: Stephen Smith Stephen Smith Role: President of sole member of issuer manager Latest Form D Signatory: Thomas Garrott Signatory Role: Attorney for Issuer Underlying Project: The Pines of Grass Valley Project Type: Multifamily Apartments Project Address: 450 Bennett Street, Grass Valley, CA 95945 Historic Planning Addresses: 452, 474 and 500 East Bennett Street Planning Application: 20PLN-02 Approved Residential Units: 108 Residential Mix: One- and Two-Bedroom Apartments Apartment Buildings: Four Building Height: Three Stories Approximate Apartment Building Area in City Record: 109,644 square feet Additional Improvements: Parking; Landscaping; Clubhouse; Amenities; Utility Infrastructure City Approval History: Project approved / entitlement extended by Grass Valley Planning Commission Environmental Review: Mitigated Negative Declaration Environmental Compliance: Mitigation Monitoring & Reporting Program City Infrastructure History: Sewer/public utility easement and related improvements Current Construction Status: Project website states construction underway Project Website: thepinesofgrassvalley.com USCIS Project Status Claimed by Sponsor: I-956F Approved EB-5 Category: Rural Target EB-5 Investors: Approximately 24 EB-5 Investment Per Investor: $800,000 24 x $800,000: $19,200,000 Estimated Total Development Cost in EB5 Coast to Coast Materials: Approximately $39 million Developer-Side Principal: Sukhpal S. Mann Developer-Side Additional Manager: Shishu Bedi Underlying Development Entity: The Pines of Grass Valley LLC Underlying Development Entity Formed: July 19, 2021 Underlying Development Entity Status: Active in reviewed California state-derived record Developer-Related Entity: B&M Realty LLC Construction-Related Entity: B&M Commercial Builders LLC Sukhpal Mann Professional Background: Professional Engineer; General Building Contractor EB-5 Platform: EB5 Coast to Coast EB-5 Platform Founder / President: Stephen Smith Public EB-5 Investor Contact: Carel van der Merwe Public Investor Contact Email: [[email protected]](mailto:[email protected]) EB-5 Capital Structure on Current EB5 Coast to Coast Page: Described as Senior Debt EB-5 Capital Structure in Recent Developer Public Statement: Described as Preferred Equity from NCE to JCE Critical Diligence Finding: Senior debt versus preferred-equity public descriptions must be reconciled against final legal documents Developer Guarantee Claimed in Marketing: Personal Construction Completion Guaranty Repayment Guarantee Claimed in Marketing: Developer Loan Repayment Guaranty I-526E Denial Protection Claimed: Refund guaranty within 120 days of denial Exact Guarantee Terms: Must be verified from executed documents Current Construction Lender: Not publicly confirmed in reviewed current project materials Historical Parcel Financing Evidence: Mid Valley Financial mortgages associated with Bennett Street project parcels Current Total Developer Equity: Not publicly confirmed Current Construction Loan Amount: Not publicly confirmed Current Loan-to-Cost: Not publicly confirmed Current Appraised Stabilized Value: Not publicly confirmed Current Projected Stabilized NOI: Not publicly confirmed Current Projected Rents: Not independently verified Current Job-Creation Estimate: Requires I-956F/economic report Minimum Jobs Required for 24 EB-5 Investors: At least 240 qualifying jobs Current Job Cushion: Not publicly confirmed in reviewed sources Current NCE Auditor: Not publicly confirmed Current Fund Administrator: Not publicly confirmed Current Escrow Bank: Not publicly confirmed Current Construction Monitor: Not publicly confirmed Current Immigration Counsel: Requires project documents Current Securities Counsel: Thomas Garrott appears as Form D attorney/signatory; complete counsel structure should be confirmed Current Investor Return / Interest Rate / Preferred Return: Not publicly confirmed in reviewed sources Current Investment Term: Requires PPM Current Extension Rights: Requires PPM Current Redemption / Repayment Mechanics: Requires transaction documents SEC Registered Investment Adviser Status: Do not infer from Form D USCIS Approval Warning: I-956F approval is not a guarantee of I-526E approval, visa issuance, project completion or return of capital SEC Filing Warning: Form D is a notice filing and not SEC approval or endorsement Primary Risks: Ground-up construction, capital-stack completion, cost overruns, environmental mitigation, leasing and absorption, small-market concentration, construction financing, interest rates, exit cap rates, repayment/refinancing, guarantor credit quality, immigration compliance, job-creation execution, securities-structure ambiguity and long-duration illiquidity Entity Confusion Warning: Distinguish Pines of Grass Valley EB5 Investors LLC, the EB-5 NCE, from The Pines of Grass Valley LLC, the underlying California development entity, and from The Pines of Grass Valley Manager LLC / PGV Coastal Manager LLC, the EB-5 management structure. Duplicate Brand Rule: Pines of Grass Valley EB5 Investors LLC, The Pines of Grass Valley LLC, The Pines of Grass Valley Manager LLC and related project entities should be treated as one project brand for FilingDossier deduplication. EB5 Coast to Coast itself is a broader regional-center platform and should only be merged with other projects when the user explicitly wants sponsor-level analysis. Independent Conclusion: Pines of Grass Valley EB5 Investors LLC is a genuine rural EB-5 offering backed by an identifiable 108-unit California multifamily development with a multi-year municipal approval trail, active development entities, visible construction activity and an experienced EB-5 regional-center platform. The latest Form D shows a $19.2 million Rule 506(c) offering with an $800,000 minimum, one investor and $100,000 sold as of September 18, 2026. The project website reports I-956F approval and active construction. The most important unresolved diligence issues are the actual NCE-to-JCE capital instrument, because current public sources conflict between senior debt and preferred equity; the complete $39 million development capital stack; construction lender and cost-overrun protection; job cushion; guarantor financial strength; and the source of eventual investor repayment. These questions concern investment structure and execution rather than whether the project itself exists.
Independent research summary based on SEC Form D, City of Grass Valley planning records, California entity records, The Pines of Grass Valley project disclosures, EB5 Coast to Coast materials and independent EB-5 industry records. SEC Form D, USCIS I-956F approval, municipal entitlement and developer guarantees do not constitute investment approval, guarantee immigration success or guarantee return of capital.