What we review
We look at every project from two angles: whether it can support you in getting and keeping your green card, and whether your capital can come back in a reasonable time.
Regional center
Designation status, Integrity Fund payments, management background, I-829 outcomes and repayment history on past projects, and any USCIS or securities regulator sanctions.
Targeted employment area
We check census tract population or unemployment data against the rural or high-unemployment definition, and confirm it matches the I-956F.
Capital stack
How the total project cost is funded: senior bank debt, EB-5 capital, developer equity and other sources, their amounts and repayment priority; whether EB-5 is debt or equity, whether it is secured, and whether other capital is actually committed.
Completion and guarantees
The construction contract type, progress against schedule and budget, who provides the completion guarantee, and whether the guarantor can actually honor it.
Job creation
The economic model and whether its assumptions are conservative, the buffer above the minimum, and limits on counting construction jobs when construction lasts under two years.
Fund controls
Whether there is a segregated EB-5 account, a third-party fund administrator or an annual audit, and how funds are released before and after I-526E approval.
Exit and repayment
Maturity, extension terms, source of repayment (sale, refinancing or operating cash flow), redeployment, and investor rights if the issuer defaults.
Fees and conflicts
Administration fees, the investor return, related-party dealings between developer and regional center, and commissions paid to promoters or intermediaries.
Documents we read
- Private placement memorandum, subscription agreement and limited partnership agreement
- I-956F project filing and approval, and the regional center's I-956G annual reports where it provides them
- Business plan (to the Matter of Ho standard) and economic impact report
- Census data supporting the TEA designation
- Loan agreements, security documents and the senior lender's intercreditor agreement
- Completion guarantee, guarantor financial statements and construction contract
- Escrow or fund administration agreement and release conditions
- The developer's completion and repayment record on past projects
If an issuer can't produce one of these key documents, that is itself a finding that goes in the memo.
What the memo contains
Every private due diligence memo uses the same format, so you can compare projects side by side.
- SummaryOne page on whether the project meets our criteria and its three main risks.
- Findings by areaEach area above marked Verified, Watch, Pending or High risk, with the evidence behind it.
- Immigration and capital timelinesExpected green card and repayment timelines side by side, with any mismatch flagged.
- Questions for the issuerOpen questions you or your attorney can put to the issuer directly.
- SuitabilityWhether the project fits your country of birth, children's ages and source of funds.
Our independence
Due diligence is only as credible as the reviewer's relationship with the project. Our approach:
- Every project is reviewed against the same written criteria, wherever it comes from
- If a project fails our criteria, we tell you, even if it means you don't invest
Limits of due diligence
Due diligence reduces the information gap; it doesn't remove investment risk. We rely on documents provided by the issuer and on public information, and cannot guarantee a project's future performance, USCIS decisions or repayment timing.
Our memos are not legal opinions or securities advice. Before investing, consult your own attorney, tax adviser and financial adviser.