EB-5·Direct
Vol. I · Edition One
WARNING · BEFORE YOU READ FURTHER

If you're using an agent because you're too rich or too busy to bother — that's fine. But sign nothing.

01

There is nothing legitimate to sign with an agent.

Agents are not your lawyer. They are not your fund. They are not your immigration officer. They are an introducer, paid by the regional center. A real introduction requires zero paperwork on your end. If they hand you something to sign, ask why — and read every word.

02

Never, ever sign an exclusivity agreement.

This is the death trap. Once you sign exclusivity, that agent's commission is locked in no matter who you ultimately invest with — even if you switch agents, go direct, or walk away and come back a year later. The regional center pays them anyway, out of your money. You have just paid $80K–$150K for nothing.

03

Verbal intros, emails, and brochures are free.

Everything an agent legitimately does for you — connecting you with a regional center, forwarding project decks, scheduling a call — happens without a signature. If a signature is being requested, it is not for your benefit. It is for theirs.

THE ONLY PERSON YOU SIGN WITH: your independent immigration attorney — and the regional center itself, on the subscription agreement.
Independent
NO COMMISSIONS
NO REFERRALS
NO KICKBACKS
An Investor's Field Manual

The agent is the friend middleman.

EB-5 is a real visa program with real risks. The agent layer on top of it is mostly theatre — and that theatre can quietly cost you up to USD 200,000 over the life of your investment. Here's how the money actually moves, and how to go direct in an afternoon.

FILED · For prospective EB-5 investors READ · 7 min UPDATED · 2026

Two ways to do EB-5. One costs $200,000 more.

WITH AGENT
The default path
Qualifying investment$800,000
Upfront "admin fee"+ $80,000
Investor return over 5 yrs @ 0.25%/yr+ $10,000
Total back to you$810,000
Net cost of the visa−$70,000
The agent is paid out of your $80K upfront fee. The RC keeps its 8–10% credit spread either way. You finance the agent on top.
vs.
GOING DIRECT
What you can actually negotiate
Qualifying investment$800,000
Upfront "admin fee"$0 — negotiated
Investor return over 5 yrs @ 2%/yr+ $80,000
Total back to you$880,000
Net cost of the visa+$80,000
No agent means no commission to fund. The RC has $80K of room to redirect — into your fee waiver and into your yield.
~$200,000
The swing between the two paths over five years. Same visa. Same regional center. Same project. The only variable is whether there's a middleman in the chain.
The agent adds zero value you can't get for free by calling the regional center yourself.
The thesis of this site
§ NEGOTIATE

The regional center has plenty to share. You just have to be the one they share it with.

Here's what almost nobody explains plainly: EB-5 capital is private credit. The regional center makes 8–10% on your money, conservatively. Often 12–15%. That spread exists no matter what. The RC's economics don't change because you brought an agent or didn't. What changes is who they share the surplus with — the agent who introduced you, or you, the investor. You don't have to ask permission to be the one who's chosen. You have to ask the question. Two specific levers:

01
UPFRONT FEE

The $80K "admin fee" → $0

This fee exists almost entirely to fund the agent commission. The actual cost to the regional center of processing one investor is a tiny fraction of $80K — call it $5K–$10K for legal, escrow setup, and fund administration. Ask for it to be waived in full. A serious RC, told you have no agent, will negotiate. The ones that refuse are signaling they're set up to feed the agent channel and aren't interested in direct investors.

You save: $60,000–$80,000
02
INVESTOR RETURN

Your yield: 0.25% → 2–3%

EB-5 capital is private credit. The regional center earns 8–10% at the conservative end on your money — and many private-credit EB-5 deals run 12–15%. They take their fixed cut. After that, there is a real surplus left over. The question is who that surplus goes to: the agent who introduced you, or you. That is a choice the regional center is willing to make once you ask. With no agent commission to fund (typically 1.5–2% of capital per year, capitalized), your share of the yield can rise materially. 2% on $800K for 5 years is $80,000 — the exact size of the agent's slice you just removed.

You save: + $80,000–$120,000
SCRIPT · Use verbatim

"I'm investing directly. I have no migration agent, no referral, no third party in this transaction. I'd like to discuss waiver of the administration fee and a higher investor return rate that reflects the commission savings you'd otherwise be paying out. What can you offer a direct investor?"

If they pretend not to understand — they understood. Move on.

§ 01

What agents won't tell you

i

The "free" agent isn't free

If the agent is charging you nothing, the regional center is paying them — out of your admin fee. Industry estimates put commissions at $40K–$150K per investor, with no fiduciary duty to you.

ii

They don't pick the safest deal

They pick the deal that pays the highest commission. These are often the same deals struggling to attract investors on their own merits.

iii

Your return is negotiable — you've just never been told

EB-5 capital is private credit. The regional center earns 8–10% on your money at minimum — often 12–15%. That spread exists either way. The only question is whether the RC shares its surplus with you, or with the agent who introduced you. With no agent, 2–3% to the investor is on the table — that's $80K–$120K over five years.

iv

"Approved by USCIS" ≠ Safe

USCIS approves regional centers as entities. It does not vet individual projects, predict repayments, or rank developers. Roughly 580+ centers are approved; quality varies wildly.

v

You don't need an agent for intros

Every major regional center has a full BD/marketing team that will set up calls, send materials, and connect you to immigration attorneys — for free. That's their job.

vi

The lawyer is the actual expert

An independent immigration attorney does the work that matters: source-of-funds, I-526E, I-829. They're paid hourly or flat — usually $15K–$30K total — and they answer to you alone.

§ 02

The four-step direct playbook

STEP 01

Hire an independent EB-5 attorney first

Before you talk to any regional center. The attorney is your only paid advocate. Pick one with 100+ EB-5 cases and no exclusive RC referral fees.

STEP 02

Shortlist 3–5 regional centers

Use the USCIS list and IIUSA membership as the universe. Filter by repayment track record, I-526E approval rate, and project capital stack.

STEP 03

Email or call them direct

Ask for the offering memorandum, audited financials of prior projects, default history, and a full fee disclosure. Watch what they hand over freely.

STEP 04

Have your attorney review everything

OM, escrow agreement, NCE structure, JCE economics, refund clause. If they push back on attorney review — walk.

§ 03

How to actually evaluate the project.

Once you've shortlisted regional centers and you're on calls with them, here is what you ask about. The first two questions are the only ones that protect your primary purpose — getting the visa. The rest protect your money.

A useful surprise: regional centers are more patient with direct investors than with agent-sourced ones. Without the agent siphoning off their margin you are simply more profitable to them — and they know an unaccompanied investor is less likely to negotiate as hard as a professional agent would. Ask dumb questions. Ask them twice. Watch their webinars before the call and ask more dumb questions during. They will take it.

CRITICAL · VISA 01

I-956F Project Approval

Before the RIA 2022, regional centers could float projects with no project-level pre-approval. Now USCIS requires Form I-956F — a project-specific filing — before investors can even file their I-526E. An I-956F-approved project is one USCIS has already vetted at the project level for compliance, business plan, and TEA designation.

ASK: "Is the project's I-956F filed? Approved? When? Can I see the approval notice?"
Red flag: "We're investor-funded but pre-I-956F" — means you'd be filing I-526E into a project the government hasn't blessed. Avoid unless your attorney specifically signs off.
CRITICAL · VISA 02

Job Creation Coverage / Cushion

You need 10 jobs per investor. The economic report attached to the offering counts how many jobs the project will create — and divides by number of investors. The ratio you want is jobs per investor > 10, ideally 1.3×–2× over (so 13–20+ jobs per investor on paper).

Anything close to 10:1 is dangerous. Real-world job creation always comes in below the economic model. If projected jobs equal exactly 10× investor count and the project under-delivers by 20%, every investor's I-829 is at risk.

ASK: "How many jobs per investor in the economic report? What's the cushion? Has any prior project of yours fallen below 10:1 at I-829?"
Red flag: Cushion below 25%. Strong projects offer 50%+ cushion. Some now offer a contractual job-creation guarantee — better, ask for it.
IMPORTANT · MONEY 03

Senior Loan & Asset Coverage

EB-5 capital is almost always subordinate — behind the senior bank loan. If the project defaults, the senior lender gets paid first. Whatever's left after that is what EB-5 investors split.

What you want to see: loan-to-cost (LTC) including EB-5 around 65–75%, with the asset value (LTV at completion) leaving a margin even after the senior is paid. Translation: even if the project sells for 30% less than projected, there's still enough to pay back EB-5.

ASK: "What is the senior debt position? Loan-to-cost? Stabilized loan-to-value? In a downside case at 70% of pro forma, do EB-5 investors get fully repaid?"
IMPORTANT · MONEY 04

Developer Equity (Skin in the Game)

How much of the developer's own cash is in the deal, in a position junior to yours? If the developer has put in 10–25% of total capital as true equity below EB-5, they lose their money before you lose yours. That alignment of incentives is one of the strongest signals of a serious sponsor.

Watch for "developer equity" that turns out to be land already owned, fees rolled in, or sponsor promote — that isn't fresh skin. You want cash, freshly contributed.

ASK: "What is the developer's cash equity contribution, and where does it sit in the capital stack? Is any of it deferred or in-kind?"
IMPORTANT · TRACK RECORD 05

Developer & RC Track Record

Two records to check, separately:

The Regional Center: How many EB-5 offerings have they sponsored? How many investors? What's their I-526E and I-829 approval rate? How many investors have been fully repaid on time, vs late, vs not at all?

The Developer: What other projects have they completed (not just EB-5)? Have they ever defaulted, missed a draw, or lost a project to lender foreclosure? Are they a real estate firm with EB-5 as one capital source, or an EB-5 firm playing real estate?

ASK: "How many of your prior EB-5 investors have been repaid in full? Late? Defaulted? Send me the I-829 approval rate across all projects."
IMPORTANT · TIMING 06

Construction Status & Deployment

A project that's already shovels-in-the-ground (or further) is dramatically safer than one that's pre-construction. Job creation begins when money is spent, not when it's raised. Pre-construction projects can stall in entitlement, financing, or market shifts for years — burning your sustainment period.

Ideal: project has senior debt closed, construction underway, and EB-5 capital is being deployed as bridge or take-out. Worst: "We'll start once we hit our raise target."

ASK: "What's the construction status today? Is senior debt closed? When does EB-5 deploy? What happens to my money if the raise doesn't fill?"
NICE TO HAVE · CATEGORY 07

TEA Category: Rural vs Urban vs Infrastructure

Each EB-5 visa category has its own set-aside under RIA 2022: rural (20%), urban high-unemployment (10%), infrastructure (2%). If you're from a backlogged country (India, China), the rural category currently moves faster and gets priority processing on I-526E. For investors from elsewhere, the categories matter less to visa speed but still affect TEA qualification at $800K.

ASK: "What's the TEA designation? Rural or urban? Is the priority-processing designation reflected on the I-956F approval?"
NICE TO HAVE · STRUCTURE 08

Repayment Structure & Refund Clauses

Read the exit waterfall. When does EB-5 get repaid — at construction completion, stabilization, refinance, or sale? Most loan-style deals target 5–6 years. Equity deals are open-ended and riskier for capital recovery.

Look for a refund guarantee if your I-526E is denied through no fault of yours. Top RCs now offer this; it's table stakes for new deals.

ASK: "What's the repayment trigger? Refund clause on I-526E denial? Approval-rate guarantee?"
PRIORITIES, RANKED

For the visa: I-956F approval (Q1) and job-creation cushion (Q2) are non-negotiable. Without these, your visa is at risk regardless of how well the project performs financially.

For your money: Senior debt position (Q3), developer skin (Q4), and track record (Q5) determine whether you get your $800K back. Without these, you might still get the visa — but lose your capital.

The cheat code: Ask the same question to three different regional centers. Compare answers. The serious operators give you specific numbers. The marketing-led ones give you adjectives.

§ 04

The direct directory

A starting universe — not a recommendation. All links go directly to the source. We earn nothing from any of these. Verify USCIS status on every center before wiring a cent.

USCIS — Approved Regional Centers

.gov · Authoritative

The only official list. ~580 approved centers as of late 2025. Check this before you commit to any RC. Also lists terminated centers.

Use for: verificationCost: free
uscis.gov →

IIUSA — Industry Trade Body

Association

Invest in the USA. The national trade association for the EB-5 regional center program. Member directory, code of conduct, quarterly webinars, the Industry Forum (Houston, every fall).

Use for: reputable RC shortlistHQ: Washington DC
iiusa.org →

USCIS — EB-5 Program Overview

.gov

The program rules straight from the source: minimum investment, TEA definition, I-526E vs I-829, RIA 2022 reforms, integrity fund.

Read before: any call
uscis.gov/eb-5 →

U.S. State Dept · Visa Bulletin

.gov

Monthly priority date movement. Critical if you're from China or India — the rural set-aside has its own queue. Check before you commit to a project category.

Updated: monthly
travel.state.gov →

CMB Regional Centers

Since 1997

Among the most experienced operators. 7,000+ investors across 90+ partnerships, $1.5B+ repaid to investors, 3,200+ I-829 approvals. 100% USCIS project approval rate as of 2026.

HQ: Dallas / Rock Islandinfo@cmbeb5visa.com
cmbeb5visa.com →

Golden Gate Global (3G Fund)

Since 2011

1,800+ investors. RCs across CA, FL, ID, WA. Reports 1,300+ conditional GC approvals, 600+ investors fully repaid on time.

HQ: San FranciscoOffices: NYC, Chicago, Irvine
3gfund.com →

EB5 United

10 RCs

Operates 6 owned and 4 licensed USCIS-designated regional centers. Focus on rural TEA projects (Big Sky MT, Yellowstone Club). Markets to investors seeking priority processing.

Geography: Multi-state + PR
eb5united.com →

EB5AN

10+ RCs

Network of 10+ USCIS-approved regional centers. Heavy on rural TEA. Notable for publishing the largest free EB-5 education library in the industry (1,000+ videos).

Best for: first-time research
eb5visainvestments.com →

Behring Co.

Class A multifamily

Focuses on Class A residential projects in SF Bay Area / Silicon Valley. Reports 100% USCIS approval across adjudicated petitions. Offers debt, preferred equity, and common equity options.

HQ: San Francisco
behringeb5.com →

U.S. Immigration Fund (USIF)

Large urban deals

One of the largest urban EB-5 sponsors. Major NYC, Miami, FL projects. Free EB-5 seminars and direct consultation with attorneys.

HQ: Jupiter, FL
visaeb-5.com →

Six is not a top six. It's a starting set. The full universe is the USCIS list (~580 centers) and IIUSA's member directory. Filter by track record, not marketing slickness.

Klasko Immigration Law Partners

EB-5 Specialist

Ron Klasko is widely regarded as one of the most experienced EB-5 attorneys in the U.S. Represents thousands of investors and 50+ regional centers. Strong federal-court track record on denials.

Offices: Philadelphia · NYC · DC
klaskolaw.com →

Greenberg Traurig — Immigration & Compliance

Global Firm

Kate Kalmykov & Jennifer Hermansky co-chair the EB-5 practice. Tier-1 ranked nationally; multiple Top-25 attorneys. Heavy on developer/RC side but also investor work.

Offices: National (45+)
gtlaw.com →

Miller Mayer LLP

17+ yrs EB-5

Stephen Yale-Loehr and Brian Hinrichsen — repeat Top-25 attorneys. Represents both individual investors and regional centers. Cornell-affiliated; strong academic and policy footprint.

HQ: Ithaca, NY
millermayer.com →

WR Immigration

Investor-side

Bernard Wolfsdorf and Joseph Barnett (Vice Chair, AILA EB-5 Committee). Repeat Top-25. Known for investor-focused EB-5 work and due diligence on regional centers.

Offices: LA · NYC · Oakland · Online
wolfsdorf.com →

Jackson Walker — Business Immigration

Texas

Christian Triantaphyllis — 8+ consecutive years on EB5 Investors' Top 25. AILA EB-5 Committee, IIUSA Board. Catharine Yen recognized in Rising Stars.

HQ: Houston
jw.com →

Lawler & Lawler

500+ EB-5 cases

Martin J. Lawler — Best Lawyers in America. Files mandamus actions in federal court for stuck I-526/I-829 cases. Smaller boutique, hands-on with investors.

HQ: San Francisco
aboutvisas.com →

Saul Ewing LLP — EB-5

$8B+ structured

Cross-disciplinary team (immigration + securities + tax + real estate). Has structured 450+ EB-5 offerings totaling $8B+. Multilingual practice (Mandarin, Hindi, Gujarati, more).

Offices: 16 nationwide
saul.com →

Darren Silver & Associates

LA Boutique

Board-Certified Immigration. Selected Top EB-5 Attorney by EB5 Investors Magazine. Mandarin, Spanish, Korean spoken in-office.

HQ: Los Angeles
darrensilver.com →

For a vetted full list: EB5 Investors Magazine — Top 25 Immigration Attorneys 2025.

EB5AN — YouTube

1,000+ videos

By far the largest free EB-5 education library. Multilingual. Covers I-526E walkthroughs, source-of-funds, project selection, post-greencard tax. Operator-affiliated but useful for fundamentals.

Bias: sponsors own RCs
youtube.com/@EB5AN →

IIUSA — Webinars & Industry Forum

Trade body

Quarterly compliance webinars (some member-only, many public). Annual Industry Forum in Houston each fall — the single largest gathering of RCs, attorneys, and developers. Public sessions are recorded.

Best for: policy & regulation
iiusa.org/events →

Behring Co. — Webinars & YouTube

RC-hosted

Regular live webinars and project tours. Their educational library is openly published — useful even if you don't invest with them. Strong on debt vs equity structure trade-offs.

Bias: they're an RC
behringeb5.com/webinars →

JTC Group — EB-5 Webinars

Fund admin

JTC is an independent fund administrator (not an RC). Their on-demand panels are some of the most candid sessions on capital stack risk, RIA compliance, and what investors should actually demand.

Best for: due diligence frame
jtcgroup.com/events →

EB5 Investors Magazine

Trade press

The industry's main trade publication. Publishes the annual Top-25 attorneys list, Q&A column where leading attorneys answer reader questions, and a YouTube channel of conference panels.

Use for: attorney shortlists
eb5investors.com →

Greenberg Traurig — EB-5 Insights

Attorney blog

Free blog + Immigration Insights podcast hosted by Kate Kalmykov. Excellent ongoing commentary on USCIS audits, RIA implementation, and visa bulletin movements. No sales pitch.

Best for: staying current
eb5insights.com →

Rule of thumb: webinars hosted by attorneys, fund administrators, and trade bodies are more useful than ones hosted by the centers selling you the investment.

§ 05

Questions to ask your agent — before you sign

If they hesitate on any of these — particularly #1 and #2 — walk. A clean agent has nothing to hide. The unclean ones rely on you not asking.