While the regulations state that the investor must have invested or be in the process of investing, generally investors are placing the entire $500,000 into an escrow account to be released upon a certain set of conditions (like I-526 approval). USCIS may not consider your method to meet the “invested capital” or “at risk” requirements.
The required EB-5 personal investment funds has to be placed in escrow and committed to the project at the time of filing the investors I-526 petition. The attached Business Plan will state how the funds will be committed and how the required 10 full time jobs will be created over the two year period of conditional permanent residency.