I have heard that a direct EB-5 project can be a 'pooled' investment, is this true?

This is indeed true. To explain the point using restaurants is an example, under a 'direct' EB-5 structure, a project can have investors invest into a New Commercial Enterprise which will in turn loan money to a group of direct projects, in this case multiple restaurant locations. Investors would be eligible to claim the job creation from all the locations together, which diversifies their risk in terms of having enough available jobs. At the same time, this approach allows for the project owners to fund multiple subprojects in a single deal.

Yes, this is correct. Nonetheless, certain requirements must be met to ensure it is an EB-5 approved project (i.e., jobs created, minimum investments from each investor, etc.).

Yes BUT something to keep in mind is that when you pool EB-5 investments to raise money for a series of businesses, the investors need to place the investment in a single entity (a holding company if you will) and if the project is not hosted under a Regional Center, the different businesses would have to be wholly owned by the holding company. Also keep in mind that in such case, all the different locations will have to be TEA so the investors can qualify for the lower minimum of $500,000, otherwise the minimum will be $1M and therefore hard to sell.

Correct. But one of the main advantages of the regional center alternative would be lost. Under the regional center paradigm, the economist that is hired runs a government approved input/output statistical model such as RIMS II, IMPLAN or REMI to determine the total economic impact of the project and consequent job creation. After the two year required conditional green card period, as long as the NCE follows its business plan and budget and the project is completed these projected number of jobs are in fact assumed to have beeen created. In the pooled direct investment route, you would lose this benefit and would need to explicitly prove that actual jobs were created. Another, disadvantage is that you as the investor would need to get the location approved as TEA if you want to stay within the $ 500,000 minimum investment requirement.