Summary – EDC Decision Meeting 20260716
1 Virgin Islands Economic Development Commission Decision Meeting of Thursday, July 16, 2026 Summary Report During the Virgin Islands Economic Development Commission (“VIEDC”) Decision Meeting on Thursday, July 16, 2026, the Governing Board heard recommendations from the VIEDC Team regarding seven (7) application matters and one (1) compliance matters, and voted as follows: Regular Session: ➢ Action Items: ❖ Applications: A. Black Diamond Advisors, LLLP – Name Change Black Diamond Advisors, LLLP (“Black Diamond Advisors”) was issued a Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits to own and operate a Category IV – Designated Services Business providing asset management services, business management and consulting services and investment management and advisory services to clients outside the USVI. Black Diamond Advisors conducts an alternative asset management business in conjunction with its USVI counterpart, Black Diamond Holdings, LLLP, Black Diamond Capital Advisors, LLC and its subsidiaries Black Diamond Capital, LLC. …
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1 Virgin Islands Economic Development Commission Decision Meeting of Thursday, July 16, 2026 Summary Report During the Virgin Islands Economic Development Commission (“VIEDC”) Decision Meeting on Thursday, July 16, 2026, the Governing Board heard recommendations from the VIEDC Team regarding seven (7) application matters and one (1) compliance matters, and voted as follows: Regular Session: ➢ Action Items: ❖ Applications: A. Black Diamond Advisors, LLLP – Name Change Black Diamond Advisors, LLLP (“Black Diamond Advisors”) was issued a Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits to own and operate a Category IV – Designated Services Business providing asset management services, business management and consulting services and investment management and advisory services to clients outside the USVI. Black Diamond Advisors conducts an alternative asset management business in conjunction with its USVI counterpart, Black Diamond Holdings, LLLP, Black Diamond Capital Advisors, LLC and its subsidiaries Black Diamond Capital, LLC. Black Diamond Advisors raises new funds on a strategic basis, dependent of course on market conditions. Black Diamond Advisors is located on the island of St. Thomas. On February 9, 2026, Black Diamond Advisors legal counsel notified VIEDC of a name change. VIEDC was informed that its corporate name has formally been changed to Black Diamond Capital Management II, LLLP, effective as of July 25, 2025, and requested that the VIEDC issue an addendum to the Certificate, reflecting the change in its legal name from Black Diamond Advisors, LLLP to Black Diamond Capital Management II, LLLP. The Governing Board voted (4 – 0) to: 1. Acknowledge the name change from Black Diamond Advisors, LLLP to Black Diamond Capital Management I, LLLP effective July 25, 2025. 2. Require a First Modified Certificate of tax incentives to Black Diamond Advisors, LLLP be issued with the name change, Black Diamond Capital Management I, LLLP. B. Black Diamond Holdings, LLLP – Name Change Black Diamond Holdings, LLLP (“Black Diamond Holdings”) was issued a Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits to own and operate a Category IV – Designated Services Business conducting an alternate asset management business. Black Diamond Holdings operates in conjunction with its USVI counterpart, Black Diamond Advisors, LLLP, Black Diamond Capital Holdings, LLC and its subsidiaries Black Diamond Capital, LLC. Black Diamond Holdings provides asset and business management and consulting services and investment management and advisory services to clients outside the USVI. Black Diamond Holdings is located on the island of St. Thomas. On February 9, 2026, Black Diamond Holdings legal counsel notified VIEDC of a name change. VIEDC was informed that its corporate name has formally been changed to Black Diamond Capital Management II, LLLP, effective as of July 25, 2025, and requested that the VIEDC issue an addendum to the Certificate, reflecting 2 the change in its legal name from Black Diamond Holdings, LLLP to Black Diamond Capital Management II, LLLP. The Governing Board voted (4 – 0) to: 1. Acknowledge the name change from Black Diamond Holdings, LLLP to Black Diamond Capital Management I, LLLP effective July 25, 2025. 2. Require a First Modified Certificate of tax incentives to Black Diamond Holdings, LLLP be issued with the name change, Black Diamond Capital Management I, LLLP. C. CM Sun Operations, Inc. & CM St. Croix Propco, LLP – Reconsideration On June 8, 2026, CM Sun Operations, Inc. & CM St. Croix Propco, LLP (“CM Sun & Propco”) was granted Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits as a Category III hotel/guesthouse for the purchase and financing, ownership, construction and redevelopment of the iconic Carambola Beach Resort located on St. Croix (the “Project”) and pursuant to the terms of V.I. Code Ann. tit. 29, § 708(a)(1) which allows the Commission to grant benefits to other such industries or businesses as may be considered appropriate by the Commission and which will advance the economic well-being of the Virgin Islands and its people. CM Sun & Propco are located on the island of St. Croix. On June 23, 2026, CM Sun & Propco sent written correspondence requesting the footnote on the grant of incentives, relative to the income tax exemption, to be changed in the Board Approval Letter. MOTION 1: The Governing Board voted (4 – 0) to: 1. Find sufficient grounds have been established for reconsideration pursuant to V.I.R.R. 717-403, on the basis that there has been a change in material facts and applicable law which change occurred after the public hearing; and 2. Require VIEDC to proceed on its own initiative to reconsider its December 18, 2025 decision pursuant to V.I.R.R. 717-401 and take appropriate action as authorized by law, rules and regulations to decide this matter within the applicable timeframe set forth in V.I.R.R. 717-404. MOTION 2: The Governing Board voted (4 – 0) to: 1. Approve an Amended Grant of Tax Incentives for CM Sun Operations, Inc. and CM St. Croix Propco LLP to include new footnotes language which shall now state, in relevant part, as follows: INCOME TAX EXEMPTIONS: For tax purposes, CM ST. CROIX PROPCO LLP, as a limited liability partnership, elected to be taxed as. a domestic eligible entity electing to be classified as an association taxable as a corporation and shall be eligible for the income tax exemptions. CM SUN OPERATIONS, INC. d/b/a CLUB MED ST. CROIX shall also be eligible for the income tax exemption. This exemption is subject to 29 V.I.C. §§ 713b, 713a(a)(2), 713a(a)(3), and 713. See Act 9108 enacted on June 9, 2026. pg. 10 3 INTEREST AND DIVIDEND WITHHOLDING: CM ST. CROIX PROPCO LLP, and CM SUN OPERATIONS, INC. d/b/a CLUB MED ST. CROIX partners /shareholders who are non-USVI residents are not eligible for Interest & Dividends tax exemptions. 2. Require the grant of incentives approved on July 8, 2026, to CM Sun Operations, Inc. and CM St. Croix Propco LLP to also be amended to include the applicable standard provisions pursuant to Act Nos. 9064, 9098 and 9108 as follows: A. Applicant/Beneficiary shall provide full-time employees who are the primary caregiver of a seriously ill spouse, child, parent, or any individual who is the legal dependent of that employee two (2) hours’ leave per month, each calendar year, to perform caregiving duties. To be eligible for caregiver's leave, not more than 48 hours after the absence, the caregiver shall submit proof to Beneficiary that the time off was taken in accordance with the criteria set forth in 3 V.I.C. §590b(b) (2025). Failure to submit the proof is sufficient cause for Beneficiary to not pay the caregiver for the time not worked. See Act No. 9064, Nov. 25, 2025, § 1, V.I. Sess. Laws (2025). B. Applicant Beneficiary shall provide full-time employees who are parents or legal guardians of a child with a diagnosed developmental disability, four (4) hours per month of paid leave to attend the child's medical, therapeutic, or diagnostic appointments. Leave granted under this section shall not diminish, replace, or otherwise impact any other leave to which an employee is entitled to under federal or local law. This requirement takes effect 90 days after enactment, that is, September 7, 2026. See Act No. 9098, Jun. 9, 2026, §§ 2 and 3, V.I. Sess. Laws (2026). C. Notwithstanding the provisions of 29 V.I.C. § 713b, and except as provided in 29 V.I.C. §713c(h), no income tax refund attributable to income subject to benefits authorized by V.I. CODE ANN. tit. 29, chapter 12 shall be allowed or paid to Applicant/Beneficiary, unless the cumulative income tax benefits received by such Applicant/Beneficiary under said chapter have been fully offset as provided pursuant to 29 V.I.C. § 713c (2026). See Act No. 9108, Jun. 9,2026, §§ 2 and 3, V.I. Sess. Laws (2026). 2. Require all other terms of the amended grant of grant if incentives approved on June 8, 2026, to remain unchanged and in full force and effect. 3. Require a second amended grant of incentives to be executed and a second revised board approval letter to be issued to the Applicant. 4. Find CM Sun Operations, Inc. satisfied the VIEDC conditional approval of June 8, 2026, having provided favorable background reports for its remaining 4 international entities, Fosun Tourism and Culture Group (HK) Company Limited and Fosun International Limited. D. Commodore Concierge Management, LLP – Reconsideration On December 18, 2025, Commodore Concierge Nurse Management LLP (“CCNM”) was granted Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits as a Category IV – Designated Services Business for its provision of business management and consulting services, including operational and strategic consulting services, accounting and finance services, administrative, compliance, and back-office services, and family office services for a period of 20 years. CCNM also reinvests for its own account. All of CCNM’s clients are required to be located outside the USVI. CCNM’s services may be provided through one or more wholly owned, disregarded. CCNM is located on the island of St. Thomas. On February 27, 2026, CCNM submitted a name change petition. The name change was approved on March 19, 2026. The signed Board approval letter was submitted on April 17, 2026. The Certificate was transmitted to the Applicant for signature on July 6, 2026. VIEDC staff became aware of several employer laws that have been passed within the last year and are in effect that was not included in the amended grant of incentives. Staff is requesting the amended grant of incentives for CCNM be amended to include the standard provision language of said laws. MOTION 1: The Governing Board voted (4 – 0) to: 1. Find sufficient grounds have been established for reconsideration pursuant to V.I.R.R. 717-403, on the basis that there has been a change in applicable law which change occurred after the public hearing; and 2. Require VIEDC to proceed on its own initiative to reconsider its December 18, 2026 decision pursuant to V.I.R.R. 717-401and take appropriate action as authorized by law, rules and regulations to decide this matter within the applicable timeframe set forth in V.I.R.R. 717-404. MOTION 2: The Governing Board voted (4 – 0) to: 1. Amend the grant of incentives approved on December 18, 2026, and amended on March 19, 2026, to Commodore Concierge Management LLP be amended to include the applicable standard provisions pursuant to Act Nos. 9064, 9098 and 9108 as follows: A. Applicant/Beneficiary shall provide full-time employees who are the primary caregiver of a seriously ill spouse, child, parent, or any individual who is the legal dependent of that employee two (2) hours’ leave per month, each calendar year, to perform caregiving duties. To be eligible for caregiver's leave, not more than 48 hours after the absence, the caregiver shall submit proof to Beneficiary that the time off was taken in accordance with the criteria set forth in 3 V.I.C. § 590b(b) (2025). Failure to submit the proof is sufficient cause for Beneficiary to not pay the caregiver for the time not worked. See Act No. 9064, Nov. 25, 2025, § 1, V.I. Sess. Laws (2025). 5 B. Applicant Beneficiary shall provide full-time employees who are parents or legal guardians of a child with a diagnosed developmental disability, four (4) hours per month of paid leave to attend the child's medical, therapeutic, or diagnostic appointments. Leave granted under this section shall not diminish, replace, or otherwise impact any other leave to which an employee is entitled to under federal or local law. This requirement takes effect 90 days after enactment, that is, September 7, 2026. See Act No. 9098, Jun. 9, 2026, §§ 2 and 3, V.I. Sess. Laws (2026). C. Notwithstanding the provisions of 29 V.I.C. § 713b, and except as provided in 29 V.I.C. §713c(h), no income tax refund attributable to income subject to benefits authorized by V.I. CODE ANN. tit. 29, chapter 12 shall be allowed or paid to Applicant/Beneficiary, unless the cumulative income tax benefits received by such Applicant/Beneficiary under said chapter have been fully offset as provided pursuant to 29 V.I.C. § 713c (2026). See Act No. 9108, Jun. 9,2026, §§ 2 and 3, V.I. Sess. Laws (2026). 2. Require all other terms of the amended grant of incentives approved on March 19, 2026, to remain unchanged and in full force and effect. 3. Require a second amended grant of incentives to be executed and a second revised board approval letter to be issued to Commodore Concierge Nurse Management LLP. E. Heavy Materials, LLC – Change In Ownership Heavy Materials, LLC (“Heavy Materials”) was granted tax exemptions to own and operate a Category II – Manufacturing Business. Heavy Materials manufactures aggregates and sand through open surface procedures at quarries located on St. Croix and St. Thomas and for its production and sale of cement blocks, soil cement, and ready-mix concrete to customers located throughout the U.S. Virgin Islands (“USVI”). Heavy Materials is located on the island of St. Croix. On June 2, 2025, IGY-AYH submitted a petition requesting a change in its ownership structure. Heavy Materials stated that the parent company of Yardarm, LLC previously was Vulcan Materials Company, a publicly traded company headquartered in Birmingham, Alabama. B&J Holdings I LLC acquired 100% membership interests of Heavy Materials on May 15, 2026. The Governing Board voted (4 – 0) to: 1. Approve and acknowledge the change in ownership structure and member interest of Heavy Materials, LLC with the admission of B&J Holdings I LLC pursuant to 29 V.I.C. § 714(b) with 100% membership interest. 2. Require the admission of B&J Holdings I LLC shall be effective May 15, 2026. 3. Require the Second Modified Certificate of tax incentives to be amended to reflect the changes. 4. Require all other terms and provisions of the Certificate remain unchanged and in full force and effect. 6 F. IGY-AYH St. Thomas Holdings, LLC dba American Yacht Harbor – Extension/Modification IGY-AYH St. Thomas Holdings, LLC (“IGY-AYH”) was granted tax exemptions to own and operate a Category II & III – Commercial Real Estate and Marina Facility known as American Yacht Harbor which leases boat slips and tenant occupied marine and related facilities. IGY-AYH is located on the island of St. Thomas. On September 11, 2025, IGY-AYH submitted a request for a “(1) a five-year extension of its EDC Certificate pursuant to VI CODE ANN. tit. 29, § 713a(b)(3) for its additional investment in its business in infrastructure, new construction, or refurbishment of $2,000,500 and (2) an additional five-year extension of its EDC Certificate pursuant to VI Code Ann. tit. 29, § 713a(b)(4) for its additional investment in its business in infrastructure, new construction, or refurbishment of $1,000,000, for a total extension of ten (10) years. All other terms and conditions of its “EDC Certificate will remain the same.” The Governing Board voted (4 – 0) to: 1. Find IGY-AYH St. Thomas Holdings, LLC is of particular importance to the economy of the U.S. Virgin Islands and shall continue to promote the economic development of the U.S. Virgin Islands. 2. Find on April 16, 2026, IGY-AYH St. Thomas Holdings, LLC was in compliance with its Certificate requirements for the periods January 1, 2016 to December 31, 2017 and January 1, 2018 to September 30, 2023. 3. Find, pursuant to 29 V.I.C. §§ 713a(b)(4) and (5), IGY-AYH St. Thomas Holdings, LLC is eligible for a total of 15 additional years of tax incentives upon the expiration of its certificate if it remains in compliance with the requirements of its certificate, as follows: a. A 10-year extension at one hundred percent (100%) of existing incentives pursuant to 29 V.I.C. §§ 713a(b)(5), and 715; and b. Five (5) years for additional investment in an aggregate amount of not less than One Million Dollars pursuant to 29 V.I.C. § 713a(b)(4). 4. Find to comply with applicable law, at a minimum, IGY-AYH St. Thomas Holdings, LLC’s compliance clearance must cover up to March 25, 2025. 5. Require tax incentives be granted to IGY-AYH St. Thomas Holdings, LLC conditioned upon receipt of compliance clearance for, at a minimum, the period October 1, 2023 through March 25, 2025, upon which time a Third Extended Third Modified Certificate shall commence consecutively from expiration of its prior tax incentive period. G. St. Thomas Family Partners – Reconsideration On April 16, 2026, St. Thomas Family Partners, LLP (“STFP”) was granted Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits as a Category IV – Designated Services Business for its provision of family office services, investment management and consulting services, and business and real estate management and advisory services for a period of 20 years. STFP is located on the island of St. Thomas. 7 STFP committed to employing a minimum of five (5) full-time employees. STFP is also committed to making a minimum capital investment of $100,000. STFP further agreed to meet all statutory and special conditions, and other applicable requirements for the grant of tax incentive benefits. On April 29, 2026, Family Partners accepted the terms of the grant of incentives and requested a correction to the commencement date of the Capital Investment provisions. The requested change was approved on May 26, 2026. Subsequently, by letter dated June 15, 2026, STFP accepted the terms of the amended grant of benefits and requested the issuance of its VIEDC Certificate with all tax incentive benefits commencing as of January 1, 2026. VIEDC staff became aware of several employer laws that have been passed within the last year and are in effect that was not included in the amended grant of incentives. Staff is requesting the amended grant of incentives for St. Thomas Family Partners LLP be amended to include the standard provision language of said laws. MOTION 1: The Governing Board voted (4 – 0) to: 1. Find sufficient grounds have been established for reconsideration pursuant to V.I.R.R. 717-403, on the basis that there has been a change in applicable law which change occurred after the public hearing; and 2. Require VIEDC to proceed on its own initiative to reconsider its April 16, 2026 decision amended on May 26, 2026, and take appropriate action as authorized by law, rules and regulations to decide this matter within the applicable timeframe set forth in V.I.R.R. 717-404. MOTION 2: The Governing Board voted (4 – 0) to: 1. Amend the grant of incentives approved on April 16, 2026, and amended on May 26, 2026, to St. Thomas Family Partners LLP to include the applicable standard provisions pursuant to Act Nos. 9064, 9098 and 9108 as follows: A. Applicant/Beneficiary shall provide full-time employees who are the primary caregiver of a seriously ill spouse, child, parent, or any individual who is the legal dependent of that employee two (2) hours’ leave per month, each calendar year, to perform caregiving duties. To be eligible for caregiver's leave, not more than 48 hours after the absence, the caregiver shall submit proof to Beneficiary that the time off was taken in accordance with the criteria set forth in 3 V.I.C. § 590b(b) (2025). Failure to submit the proof is sufficient cause for Beneficiary to not pay the caregiver for the time not worked. See Act No. 9064, Nov. 25, 2025, § 1, V.I. Sess. Laws (2025). B. Applicant Beneficiary shall provide full-time employees who are parents or legal guardians of a child with a diagnosed developmental disability, four (4) hours per month of paid leave to attend the child's medical, therapeutic, or diagnostic appointments. Leave granted under this section shall not diminish, replace, or otherwise impact any other leave 8 to which an employee is entitled to under federal or local law. This requirement takes effect 90 days after enactment, that is, September 7, 2026. See Act No. 9098, Jun. 9, 2026, §§ 2 and 3, V.I. Sess. Laws (2026). C. Notwithstanding the provisions of 29 V.I.C. § 713b, and except as provided in 29 V.I.C. §713c(h), no income tax refund attributable to income subject to benefits authorized by V.I. CODE ANN. tit. 29, chapter 12 shall be allowed or paid to Applicant/Beneficiary, unless the cumulative income tax benefits received by such Applicant/Beneficiary under said chapter have been fully offset as provided pursuant to 29 V.I.C. § 713c (2026). See Act No. 9108, Jun. 9,2026, §§ 2 and 3, V.I. Sess. Laws (2026). 2. Require all other terms of the amended grant of grant of incentives approved on May 26, 2026, to remain unchanged and in full force and effect. 3. Require a second amended grant of incentives to be executed and a second revised board approval letter to be issued to St. Thomas Family Partners LLP. ❖ Compliance: ▪ Ocwen USVI Services, LLC – Revisit; Resolution of Non-Compliance On August 1, 2012, Ocwen USVI Services, LLC (“OCWEN”) f/k/a Ocwen Mortgage Servicing, Inc. was granted Virgin Islands Economic Development Commission (“VIEDC”) tax incentive benefits to own and operate a Category IV - Designated Services Business. providing business and management consulting services primarily to clients in the residential and commercial loans industries and a call center. Ocwen services, acquires, holds, and manages sub-performing and non-performing residential loans and other secured and unsecured debts nationwide and internationally. All of Ocwen’s clients would be located outside the U.S. Virgin Islands. Bloom Analytics is located on the island of St. Croix. The compliance report covering the period October 1, 2012 to December 31, 2022 determined that Ocwen failed to provide sufficient information or substantiating documentation to determine compliance in several areas of its standard provisions and special conditions. Ocwen responded through their Counsel via letter dated 03.09.2026. On May 26, 2026 the Governing Board tabled discussion on OCWEN’s Resolution of Non-Compliance in Executive Session. The Governing Board voted (4 – 0) to: 1. Acknowledge Ocwen USVI Services, LLC received compliance clearance from the Virgin Islands Department of Labor (“VIDOL”) and complied with the requirements of Standard Condition No. 1. 2. Find Ocwen USVI Services, LLC did not comply with the requirements of Standard Condition No. 1 as it relates to the Virgin Islands Bureau of Internal Revenue (“VIBIR”) due to a VIBIR Notice of Deficiency. 3. Find Ocwen USVI Services, LLC failed to substantiate compliance with Standard Condition No. 5 (local payroll account) for 2012-2020 and 2022. 9 4. Find Ocwen USVI Services, LLC failed to substantiate compliance with Standard Condition No. 9 (new shareholders) by failing to submit parent company tax returns as requested and require Ocwen USVI Services, LLC to provide parent company tax returns within 10 days of receipt of this VIEDC Board decision. 5. Find Ocwen USVI Services, LLC initially failed to comply with Special Condition No. 1 (charitable contributions – public school programs and initiatives requirement). 6. Find with the inclusion of contributions towards the University of the Virgin Islands University Bound Program (formerly Upward Bound), Ocwen USVI Services, LLC complied with Special Condition No. 1 in total but had shortfalls in 2014, 2019, 2020, 2021 and 2022 due to contributions made to World Ocean School which did not qualify as part of its public school programs and initiatives requirement. However, forgive Ocwen USVI Services, LLC for failure to comply with Special Condition No. 1, on an annual basis, for the years 2014, 2019, 2020, 2021 and 2022 and acknowledge that, in aggregate contributions, compliance was met in full. 7. Find Ocwen USVI Services, LLC failed to provide documentation to substantiate compliance with the requirements of Special Condition No. 2 (Prepaid Charitable Contribution) but provided such documentation after completion of the compliance review and substantiated compliance with this requirement. 8. Find Ocwen USVI Services, LLC failed to provide sufficient documentation to support finding that all eligible employees were covered by the health insurance policy each year during the period October 1, 2012 through December 31, 2022 and that Ocwen USVI Services, LLC contributed to each employee’s coverage as required by Special Condition No. 4 (health insurance). 9. Find Ocwen USVI Services, LLC provided life insurance coverage to its employees as required by Special Condition No. 5 but failed to provide sufficient documentation to determine all employees received coverage each year at the amount specified in its Certificate and that the employer paid one hundred percent (100%) of coverage. 10. Find Ocwen USVI Services, LLC failed to provide documentation to support compliance with Special Condition No. 6 (401(k) retirement plan) for 2012-2015. 11. Find Ocwen USVI Services, LLC failed to provide sufficient information for the years 2016-2022 to determine the appropriate employer match and profit sharing. 12. Find while pension and profit-sharing expenses were reported on the tax returns, sufficient information was not submitted to determine that funds were submitted to third-party administrator(s)/custodian(s) on behalf of employees. 13. Accept documentation provided by Ocwen USVI Services, LLC to substantiate compliance with Special Condition No. 7 (paid time off) and find Ocwen USVI Services, LLC in compliance with said Special Condition. 10 14. Accept documentation provided by Ocwen USVI Services, LLC to substantiate compliance with Special Condition No. 11 (additional leave) and find Ocwen USVI Services, LLC in compliance with said Special Condition. 15. Accept documentation provided by Ocwen USVI Services, LLC to substantiate compliance with Special Condition No. 12 (donated leave) and find Ocwen USVI Services, LLC in compliance with said Special Condition. 16. Find Ocwen USVI Services, LLC failed to provide sufficient documentation to substantiate compliance with Special Condition No. 13 (contractor’s insurance) for 2013, 2017 and 2018. 17. Find Ocwen USVI Services, LLC provided sufficient documentation to substantiate compliance with Special Condition No. 15 (procurement from local entities) and in compliance with said Special Condition. 18. Find Ocwen USVI Services, LLC failed to provide sufficient documentation to confirm that its clients were all located outside of the U.S. Virgin Islands for the period October 1, 2012 through December 31, 2022. 19. Find Ocwen USVI Services, LLC complied with the requirement to provide proof of publication notices in 2016. 20. Fine Ocwen USVI Services, LLC Five Thousand Three Hundred Eighty-six Dollars and Forty-eight Cents ($5,386.48) for failure to timely file its 2018 and 2019 Reports of Stockholders to be paid within 10 calendar days of receipt of notice from VIEDC. 21. Issue an Order to Show Cause why tax incentive benefits to Ocwen USVI Services, LLC should not be revoked, suspended, or modified for non-compliance with the terms and conditions of its VIEDC Certificate pursuant to 29 V.I.C. § 722.