In a loan model it could be possible. Your investment would be made into the new commercial enterprise that makes loans to a portfolio of businesses. Based on the loan, you have a proper nexus that allows the jobs created at those three stores count for your job creation requirement. However, such a structure is best reviewed by an EB-5 attorney for compliance.
In a direct EB-5 structure, you can invest the required $500,000.00 into one Holding Company which owns 100% of its subsidiaries.The required investment amount and the job creation can be divided amongst the subsidiaries and should be invested at the same time.