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Project self-review framework

EB-5 Regional Center Project Self-Review Framework (v0.1)

This framework helps you organize and check the facts of one EB-5 regional center offering. It does not score, rank, recommend, or predict any project's immigration or capital outcome — every judgement stays with you. For each item you record three things only: what the fact is, which document and page it came from, and which evidence status it holds. No registration; your draft stays in this browser.

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Three common misconceptions, corrected first

First, "the regional center is USCIS-approved" does not mean "the project is good." Designation only confirms eligibility to sponsor EB-5 projects; it is not an endorsement of any specific project, investment opportunity or business activity, and one regional center can sponsor a good project and a bad one at the same time. What you evaluate is the specific offering your money enters, not the regional center's name. Second, immigration safety and capital safety are two different things and cannot be merged into one score: a project can create ample qualifying jobs (low immigration risk) while EB-5 sits at the bottom of the capital stack with unlimited developer extensions (high capital risk) — and the reverse holds too. Anything that folds both into one "overall rating" or star count is hiding one side. Third, there are only four outcomes: green card with capital returned; green card with capital impaired; capital returned but immigration failed; both failed. Job cushion, I-956F approval and TEA qualification are process indicators on the way to those four boxes, not outcomes.

How this form works

  • No registration. Your draft autosaves in this browser only and is not uploaded until you choose to submit.
  • Every field is optional while you work — record the facts you remember and refine later.
  • Each section explains why the item is asked and how to answer it. Read the note first if a field is unclear.
  • You can print or save a PDF copy for yourself at any time.
  • Submit only when you want our review: a name plus one contact method (email or phone) is all we need.

“Direct vs. Regional Center EB-5” explains how the routes differ; this framework puts one specific offering's facts on paper.

Use it alongside the comparison tool
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Basic information and the offering under review

Why this is asked：First confirm who is filling this in and which offering it covers. One regional center may have several offerings in the market at once, so facts must attach to the specific offering, never to the regional center's name.

How to answer：Contact details are used only for our reply. What you enter about the offering is used only for this review and is never published.

Basic facts about this offering

Asset class, state and city, investment amount, set-aside category (rural / high unemployment / infrastructure), total raise and investor count, and which documents you currently hold.

How to record

Three evidence statuses

For every fact this framework does one thing: label its evidence status. Confirmed — supported by an official record or independent third-party document: USCIS notices, court records, county recorder filings, audit reports, construction monitoring reports, executed loan agreements in original form. Stated but unevidenced — appears only in documents the issuer wrote: PPM, business plan, marketing materials, roadshow statements. Not provided — mentioned in the documents but never shown to you, or not mentioned at all.

Rule: issuer-stated status ("70% complete", "equity is in", "permits are in hand") is recorded as "stated but unevidenced" until you hold the third-party document. This is not suspicion; it is bookkeeping.

Five dimensions

Dimension 1 | Immigration

This dimension asks how much margin for error the job creation has, and which model supports it.

1. Job cushion

Why this is asked：Qualifying jobs forecast in the economic report ÷ (investor count × 10). Below 1.2 leaves almost no margin for error.

How to answer：Find the job summary table in the economist's report and record the forecast total, the investor count and the resulting multiple.

2. Jobs already realized at the time you invest

Why this is asked：How many jobs correspond to expenditures already incurred, as a share of the forecast total. This is the line between what has happened and what still has to.

How to answer：Third-party documents only: construction monitoring reports, expenditure ledgers, fund administrator reports. "Progress" stated in a business plan does not count.

3. I-956F status

Why this is asked：Approved / pending how long / RFE issued / not filed. An I-956F approval only reflects the project's filing status at USCIS; it does not mean later investors will be approved, still less that the money comes back.

How to answer：Find the original USCIS notice and record its date and receipt prefix. A summary or verbal statement is recorded as "stated but unevidenced".

4. Job model type

Why this is asked：Do the jobs come mainly from construction expenditure or operating revenue? Does the construction period reach 24 months? Operating jobs depend on future revenue assumptions and carry more uncertainty.

How to answer：Read the methodology section of the economist's report and record the construction/operations split and the construction duration.

5. TEA basis

Why this is asked：Statutory rural, or a high-unemployment census tract? Which year's unemployment data? How far above the threshold?

How to answer：Find the TEA analysis and record the basis, the data year and the margin above the threshold.

6. Regional center track record

Why this is asked：How many years since designation? Any NOID, NOIT, sanction or termination record? These are publicly checkable facts.

How to answer：Check the USCIS regional center and terminated-center lists and note the date you checked.

Dimension 2 | Capital

This dimension asks who stands ahead of your money if the project runs into trouble, and who can change the repayment date.

1. Where EB-5 sits in the capital stack

Why this is asked：Senior secured / second lien / mezzanine / preferred equity / common equity — this item alone sets the order of recovery.

How to answer：Ask for the loan agreement and intercreditor agreement in original form. A paragraph of summary in the PPM is not enough.

2. EB-5 share of total capitalization

Why this is asked：EB-5 amount ÷ total project cost. Above half means the project does not exist without EB-5.

How to answer：Find the sources-and-uses table and record the EB-5 amount, total cost and ratio.

3. Is there an institutional lender with no immigration motive

Why this is asked：Has a bank or institutional fund actually funded (not "term sheet signed", not "in discussion")? This is the strongest external signal: someone is betting without wanting a green card.

How to answer：Check county recorder mortgage filings, or the executed credit agreement. Letters of intent only means "stated but unevidenced".

4. Developer cash equity

Why this is asked：How much cash is actually in (land contributed at appraised value does not count), as a share of total cost. This is how much the developer loses.

How to answer：Ask for audit reports, closing statements, bank confirmations. "Already invested" in a business plan does not count.

5. Extension rights

Why this is asked：How many extensions, how long each, on what conditions, approved by whom. "Sponsor's sole discretion, no cap" is the weakest form.

How to answer：Find the extension clause in the loan agreement and copy out the count, term, conditions and approver.

6. Affiliation and control of funds

Why this is asked：Are the NCE and JCE controlled by the same party? Is there an independent fund administrator? Is there an audit?

How to answer：Read the related-party section of the PPM plus the LPA/OA. For a corporate NCE describe share ownership; for a limited partnership describe limited partnership interests and the GP/LP division of authority.

7. Rate the JCE actually pays

Why this is asked：What rate does the NCE charge the JCE? Subtract your coupon — who keeps the spread? A JCE paying 8% while you receive 0.5% and a JCE paying 1% while you receive 0.5% are two entirely different projects.

How to answer：Find the interest clause in the loan agreement and the fee section of the PPM; record both rates and who keeps the difference.

Dimension 3 | Execution

This dimension asks how far the work has actually got, and what the people doing it have completed before.

1. Construction status at the time of the raise

Why this is asked：Not started / under 30% / 30–70% / over 70% / complete — your entry point determines how much still has to happen.

How to answer：Use construction monitoring reports, dated site photographs and expenditure ledgers, and record the report date.

2. Permits and title

Why this is asked：Are all permits in place? Is title clean? One missing key permit can stop everything.

How to answer：Ask for the permits themselves and the title report. "Permits are in hand" as a statement is recorded as "stated but unevidenced".

3. Form of construction contract

Why this is asked：GMP with payment and performance bonds / GMP without bonds / cost-plus / no contract yet — this decides who absorbs overruns.

How to answer：Read the contract itself, or the PPM's description of it, and note which source you used.

4. Developer track record in the same asset class — verified

Why this is asked：How many comparable projects completed? A record listed in the PPM is only "stated" until you verify it.

How to answer：Check each one against county recorder title records and public news, and record how many you actually confirmed and how.

5. Litigation and default record of the developer and its principals

Why this is asked：Any loan defaults, foreclosures, securities litigation, SEC or state enforcement in the last ten years?

How to answer：Search PACER, state court systems and the SEC site. Record the search date and any case numbers; also record "searched, nothing found".

Dimension 4 | Market deviation

This dimension asks one question: if there were no green card, what would a normal lender in the same position require, and how many of those things is this offering missing? The seven items below are standard in ordinary subordinate lending and are not prohibited by the EB-5 at-risk rule — at-risk prohibits guaranteed return of capital and guaranteed returns. Each missing item is something the issuer chose not to give, not something the law forbids.

How to answer：Look for each one in the LPA and the loan agreement. Record the page where the clause sits; if you cannot find it, record "not provided".

1. Hard maturity date

Why this is asked：Is there a maturity date that cannot be pushed back unilaterally?

2. Completion guaranty

Why this is asked：Who guarantees the project gets built, and can that guarantor actually pay?

3. Interest reserve

Why this is asked：Where does interest come from, and is it funded in advance?

4. Intercreditor agreement

Why this is asked：Are the boundaries with the senior lender written down?

5. Default remedies

Why this is asked：What can your side do after a default, and who exercises it?

6. GP / manager removal rights

Why this is asked：On what conditions and with what vote can the manager be replaced?

7. Periodic reporting obligation

Why this is asked：Is reporting a contractual duty or a voluntary practice?

Pricing gap

Why this is asked：Market rate for the same year, asset class and location (construction mezzanine is typically 10–15%) minus your coupon. The wider the gap, the more clearly the issuer knows you do not care about yield.

How to answer：Record the market range you found, its source, and your coupon.

Fee load

Why this is asked：Administrative fees + intermediary commissions ÷ investment amount. Above 10%, ask where the money went.

How to answer：Use the PPM fee section and the referral or service agreement you signed; record both amounts and the ratio.

Dimension 5 | Transparency

Ask from the position of an ordinary investor who has already wired the money and will not retain separate counsel: what can I see? Transparency is the one dimension where absence is itself the answer — if you cannot see it, write that down.

1. Underlying documents in original form

Why this is asked：Loan agreement, intercreditor agreement, economist's report, I-956F approval — did you receive originals or summaries?

How to answer：List each document and which version you hold (original / summary / not provided).

2. Ongoing reporting rights

Why this is asked：Does the LPA state audited annual accounts (within how many days), quarterly construction and loan status, job progress, K-1 delivery deadlines? What is in the contract is a right; what is said at a roadshow is a promise.

How to answer：Copy out the clause page numbers and the stated day counts.

3. Material event notice obligations

Why this is asked：Extensions, refinancing, senior loan default, a NOIT received by the regional center, litigation — must the NCE notify you within a stated number of days?

How to answer：Find the notice clause in the LPA/OA and record the trigger list and day counts.

4. Whether third-party reports are actually delivered

Why this is asked：Fund administrator, construction monitor, auditor — are the reports sent to investors, or do they merely exist?

How to answer：Record whether the contract specifies recipients and frequency.

After you fill it in

What you end up with

With all five dimensions filled in you do not hold a score; you hold a table: every fact, its source, its evidence status. Put it beside the same table for two or three other offerings and the differences show themselves. It usually lands in one of four shapes: documents complete and mostly confirmed (rare — the remaining question is whether the terms themselves are good); documents complete but mostly "stated, unevidenced" (most common — the next step is sending the unverified list to the issuer and asking for third-party documents, treating whatever cannot be produced as "not provided"); key documents not provided (loan agreement only in summary, no proof of equity, no third-party construction report — here you are evaluating the issuer's account, not the project); documents contradicting each other (construction spend in the economic report not matching the budget, PPM maturity not matching the business plan's repayment date — the contradiction is itself the finding).

Which of the four shapes does your table land in

Pick one and write down what leads you there.

Unverified list: which third-party documents to request from the issuer

List everything recorded as "stated, unevidenced" or "not provided". That list is your next document request.

Contradictions between documents

Where two documents say different things about the same fact, record both sources and page numbers.

Anything else you want us to look at with you

Anything outside the five dimensions, including the part you feel least sure about.

What this framework cannot do

It cannot tell you whether the project will succeed. It cannot verify whether documents are genuine — it only tells you which ones remain unverified. It carries no data-backed weighting: which indicators actually predicted outcomes and which only looked important requires back-testing against projects that have run their full course, and that is the next version's work. Until then it does one thing: it lets you know, before you sign, what you know and what you do not.

This framework does not score, rank or recommend any project, and does not predict immigration or capital outcomes. It is not legal, investment or immigration advice. Project sourcing, service providers, payees and related interests are disclosed as they are at the consultation and engagement stage. v0.1 · September 2026 · corrections and omissions welcome.

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