No. A lender’s decision addresses financing, while EB-5 separately requires lawful source and path, capital actually placed at risk, investor engagement in management or policy formulation, and job creation. On September 7, 2026, the thresholds were US$1,050,000 generally or US$800,000 for a qualifying targeted employment area or infrastructure project, with the statutory adjustment beginning January 1, 2027; at least ten full-time jobs for qualifying U.S. workers are required.
Explain the full financing arrangement
Identify borrower, lender, collateral, repayment terms and the applicant’s rights to use the proceeds. Record whether the loan is approved, executed or funded. Do not present a conditional approval as available capital. The receiving investment must also meet the applicable at-risk and job-creation requirements; a loan does not settle those questions.
Hypothetical example: A commercial-orchard owner proposes to use proceeds from a land-backed loan for EB-5, but the lender will release money only after a co-owner signs a revised security agreement. The first review should identify the borrower, collateral owners, lender, repayment obligation, executed documents, and actual access to proceeds. It should also assess the receiving investment's at-risk capital and qualifying job-creation requirements separately. Produce a funding diagram that marks every condition still outstanding. Do not describe a conditional facility as invested capital or assume that collateral ownership proves the applicant may use all proceeds. Sequence financing confirmation before the project subscription. The decision is whether the applicant can document lawful source and path, control of the funds, and a qualifying investment without overstating what the loan documents provide.
The review should end with a list of conditions that must be satisfied before funds are treated as available. That list prevents a lender's preliminary approval from being confused with invested capital.