Under the official framework, the applicant makes a gift to the United States and pays a processing fee. This is not an investment: no capital is placed at risk in an enterprise, no jobs are required and no investment principal is returned.
Establish the nature of the payment before the amount
Hypothetical example: the couple are told this is like buying residence and are given no detail beyond a price. The first thing to settle is what kind of transaction it is. Under the official framework the money is given, not invested.
That distinguishes it sharply from EB-5, where capital goes into a new commercial enterprise, remains at risk, must create at least ten full-time jobs for qualifying U.S. workers, and may be lost or eventually returned depending on the venture. It also distinguishes it from the conventional visa categories, which are built on statutory criteria about work, transfers or investment and have long-established practice behind them.
Because this program is recent and has been revised, check the current official material for what the payment is, what it obtains and what conditions attach, and record the date checked.