No you do not. However, it is strongly recommended that project owners invest in their own projects. Investors typically like to know that you have enough confidence in your project to put your own money at risk alongside theirs. A minimum of 20% owner equity is strongly recommended.
If you are the EB-5 applicant, yes, the funds must come from you. If you are the project manager, then, no, all the funds can come from outside EB-5 investors or the like.
Assuming the question is being asked by a U.S. project owner, and looking at a Regional Center structure, you don't have to rely on your own capital to complete the funding, however most EB-5 investors will start looking at a different project if more then half of the funding will come from EB-5.
In the Direct EB-5 world however, it is more common for EB-5 investors to put much higher proportions of the capital (even 100%) but they also are more likely to require equity versus a small return on capital and a managerial position to control their investment.
If you are asking from the developer's perspective and you plan to use the regional center pooled investment approach, of course not. The whole beauty of the regional center approach is that the large scale nature of the projects provide lenders incentive to lend into the project. The EB-5 investors typically refinance the mezz loans. EB-5 investors would like to see typically at least 20% participation by the developer. Our favorite capital structure is roughly 60% senior bank debt, roughly 20% mezz debt to be refinanced by EB-5 and roughly 20% of equity provided by the developer or at least raised by the developer.
Direct investments tend to be typically smaller in scale and therefore do not provide the scale justification for lenders to be interested to provide leverage. These transactions are typically mostly financed by developer's own equity.
If you are asking as the EB-5 investor who is considering to invest in an EB-5 project, then no; you can get the funds gifted to you in which case the person making the gift will need to provide information on source of funds. You can also borrow the funds against collateral you own in which case you need to show source of funds on the original collateral purchase.
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