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BURNABY · EB-5 FIELD GUIDE

Does a big projected jobs number mean my ten are covered?

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THE DIRECT ANSWER

Not by itself. The requirement is at least ten qualifying full-time jobs attributable to your investment under the method the structure permits. A large projection built on expenditure that may not occur, or divided among more investors than expected, can still leave an individual allocation short. Ask how the number reaches you.

Test the assumptions, not the headline

Take the three or four inputs that drive most of the model — hard construction spend, project timeline, and operating revenue — and ask what evidence supports each. Find out what the figure becomes if construction costs fall, a phase is deferred, or occupancy underperforms. A sponsor unwilling to run that sensitivity has given a projection without a range.

Ask counsel whether the method used matches the structure being subscribed to. Add one structural question to that sensitivity analysis: what the cushion is actually made of. A headline figure said to cover subscribers several times over is a ratio between a projected total and a number of investors, and both halves can move.

If the offering is not fully subscribed, the denominator falls but so may the project, since a partially funded build may not spend what the model assumed. If it is oversubscribed or expanded, the numerator has to grow with it. Ask what happens to the ratio in each case, and ask separately whether the jobs are allocated among investors by a stated method or simply asserted to be sufficient.

Remember that the underlying requirement is at least ten qualifying full-time jobs attributable to the investor, counted by a method the structure permits, and that this is proved years later rather than at subscription. Hypothetical example: an investor examining a data centre project finds the cushion assumes full subscription and a construction budget set two years earlier, and asks for the ratio recalculated on the current budget and the actual subscription to date.