IN THIS GUIDE · How a regional center's revised expenditure model affects a Mirabel investor's own EB-5 evidence, family timing and deadlines
Start with the EB-5 eligibility and application overview
What the revised model actually has to show
Job creation under a regional center petition is credited when a permitted methodology is applied to defined inputs — construction expenditures, revenues, or similar measures. It is not spending alone that counts. If a hypothetical Nevada project reclassifies costs from hard construction to soft costs or equipment, the counted jobs can move even when the total budget does not. Ask which inputs the economist now uses. Hypothetical example: a regional center converts a former paper-mill site into a biochar processing project and moves part of the equipment budget into site remediation. The investor asks the economist which changed inputs remain in the model, which do not, and whether the resulting allocation still supports the jobs attributed to that investor.
Direct and regional center methods are not interchangeable
A standalone I-526 investor in a direct enterprise and an I-526E investor in a regional center project do not prove jobs the same way; the permitted methods differ, and at least ten qualifying full-time positions must be attributable to each investor. Your own household — you, your spouse and your children — cannot be counted toward that requirement, and other workers must satisfy the applicable qualifying-employee criteria; lawful work permission alone does not make a nonimmigrant a qualifying employee. The decision is not simply whether ten jobs appear in a project summary, but whether the applicable direct or regional-center method attributes the necessary qualifying jobs to the investor. Keep the current allocation, the methodology, and the supporting project data together so a later revision can be compared rather than reconstructed from memory.
Your capital position is judged separately
Model revisions do not change what you must independently establish: qualifying capital of US$1,050,000, or US$800,000 where a targeted employment area or infrastructure basis applies, placed at risk, with both a lawful source and a lawful path of funds documented. Statutory adjustments begin January 1, 2027, so confirm the applicable amount close to your actual filing date rather than assuming today's figure. Trace the investor's funds through each transaction rather than stopping at the subscription payment. Sale agreements, tax filings, bank records, gift records where relevant, and wire confirmations can establish different links in the chain. A project-side change does not repair a gap in the investor's own record.
Designation is not endorsement
A regional center's designation says it may sponsor pooled projects; it is not a government endorsement of the business, a guarantee of approval, or assurance that the amended model will be accepted. Notices and project circulars can also contain errors. If a designation letter, a marketing deck and the amended economic report describe the categories differently, treat the conflict as something to investigate with counsel, not to repeat. Ask for the dated report, budget, and disclosure that governed when the investment decision was made, then compare them to every later version. The choice to proceed, wait, or seek advice should follow a documented explanation of any material difference, not a marketing assurance that the designation remains in place.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.