The Regional Center entity can be a different entity than the new commercial enterprise. The EB-5 rules are specific in stating that the new commercial enterprise has to be for profit. While regional centers can be owned by government agencies which are non- profit.
The relationships between the entities (regional center, new commercial enterprise, job creating entity, etc.) can take many forms. For example, an acceptable relationship between a NCE and JCE is the mere loaning of the investment funds from one to the other (of course, there are also agreements in place between the entities). For a regional center, it does not have to have an ownership interest in the NCE, but whatever form the arrangement, an agreement should be in place for the benefit of all parties.