EB-5 projects can be financed by a loan model in a EB-5 Regional Center context. The EB-5 project can be EB-5 compliant, marketable to investors and can have clear exit strategies for the investor. Our law firm has been involved representing EB-5 Developers and operators in the preparation of EB-5 projects incorporating the loan model to finance projects.
An approvable EB5 project must comply with the USCIS rules, regulations, and procedures. A marketable EB5 project must be acceptable to whichever foreign market you are attempting to cater to (China, South America, etc.). For example, USD $1 million investments are going to be a tough sell when there are many USD $500,000 options available for projects located in TEAs.
Preparing a potential project for the EB5 market and for approval by USCIS is a unique, multi-layered process that is best served by the guidance of a qualified EB5 attorney, like those at our law firm, who can coordinate with other professionals. We can help arrange the legal and financial infrastructures to make your project both approvable and marketable.
You need to have a sit-down, face-to-face (or teleconference) with an EB-5 profession just to figure out IF it would be worth the effort and expense to go forward. I am not going to lie to you, it is really a fact-dependent and project-specific question. You might be best served by seeking Regional Center status yourself, IF you are up to the task. There is much advance planning, ongoing monitoring for compliance, and follow-up involved in being a Regional Center operator.