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COALDALE · EB-5 FIELD GUIDE

Do the ten EB-5 jobs have to be in the business a Coaldale investor puts money into?

Sources checked:

THE DIRECT ANSWER

In a direct investment, yes: the new commercial enterprise must create at least ten full-time positions for qualifying U.S. workers. A regional-centre investment may count indirect and induced jobs under an approved methodology, which changes the evidence but not the requirement.

The counting method is chosen before the money moves

Hypothetical example: the couple are told the project will support hundreds of jobs and assume their ten are comfortably covered. Ask how their allocation is calculated. In a regional-centre structure, the total modelled jobs are divided among investors, so the relevant number is the jobs attributed to their subscription, not the headline.

Ask what assumptions drive the model — construction spending, expenditure timing, revenue — and what happens if the project spends less than projected. In a direct investment the arithmetic is simpler and the burden is heavier: ten full-time positions for qualifying workers, proven with payroll records at the time conditions are removed. Full-time has a defined meaning and seasonal or part-time arrangements need to be examined against it.

The other requirements apply either way: qualifying capital at risk, lawful source and path, and the investor engaged in management or policy formulation rather than passive in every sense.