IN THIS GUIDE · A hotel owner funding a regional-center investment from a property sale
Start with the EB-5 eligibility and application overview
The capital amount depends on where and what the project is
Under the 2022 Reform and Integrity Act the standard investment is $1,050,000, reduced to $800,000 for a project in a targeted employment area or an infrastructure project. Whether a particular regional-center project qualifies for the reduced amount is determined on the project's own evidence, and the amount should be confirmed against current USCIS guidance before the Okonjos commit. The figure is the capital placed at risk in the new commercial enterprise; administrative fees charged by the regional center or the project are additional and are not part of the qualifying investment. For a sale-funded investment, collect the purchase agreement, closing statement, banking trail and tax records before sending money. Later reconstruction is difficult when accounts have closed or records are unavailable.
A hotel sale is a lawful source, and the path is the harder half
The Okonjos must show both where the money came from and how it travelled. The source is the hotel: purchase records from when they acquired it, financing history, and the sale agreement and closing statement now. The path is the chain of transfers from the closing account to the escrow or enterprise account, including currency exchange. If the hotel was bought years ago with a mortgage, the evidence reaches back to how the deposit and repayments were funded. Assembling this before choosing a project shortens everything that follows. A regional-center filing should identify the relevant offering documents, economic report and how the project allocates jobs. Those records address a different issue from whether the investor’s own capital is lawfully sourced.
Regional-center jobs are counted by economic model, but the model is not the investor's
A regional-center project may count indirect and induced jobs shown by an accepted economic methodology, which is why passive investors favour it. The Okonjos should read the project's job-creation report and ask how many jobs are allocated to each investor and what happens if the project runs short. They remain responsible, at the I-829 stage, for showing that the required ten full-time jobs were created or will be created within a reasonable time, and their own capital must have been sustained in the enterprise for the period current guidance requires. Conditional residence does not end the evidentiary work. The investor should retain periodic statements, project reports and proof that the capital remains deployed as required through the sustainment period.
Engagement can be limited-partner level, but not zero
An EB-5 investor must be engaged in the new commercial enterprise through management or policy formulation. In a limited partnership or LLC structured for regional-center investment, the rights and duties of a limited partner or member under the governing documents ordinarily satisfy this, and the Okonjos need not manage anything day to day. Those governance rights, rather than proof that the investors read every report or cast every available vote, are the relevant evidence. A completely passive investor with no management or policy-formulation rights does not meet the requirement. The ten-job requirement and the capital-at-risk requirement are separate. A project can present a jobs model yet still leave a source-of-funds or deployment problem unanswered.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.