Skip to content
BROCK · EB-5 FIELD GUIDE

How should loan expenses enter the EB-5 budget?

Sources checked:

THE DIRECT ANSWER

Interest, lender charges, collateral valuation and loan advice are borrowing costs. They sit alongside government, project and immigration-professional expenses and should not be assumed to count as qualifying investment capital.

Measure the net amount and ongoing obligation

Check the actual disbursement after deductions against the contribution required by the investment. Keep separate reserves for repayment and family costs. Obtain current fee information for every immigration stage, including removal of conditions.

Do not use projected project income or an expected repayment date as a guaranteed source for meeting the lender’s contractual demands. Measure two things separately: the net amount that actually reaches the enterprise, and the obligation that continues afterwards. Arrangement fees, broker commissions, legal costs, valuation fees and any insurance required by the lender all reduce the first, so a facility of a stated size may deliver materially less.

The second is the servicing cost over the term, and it should be modelled against income that exists independently of the investment. Add the preparation costs of evidencing the arrangement, including the lender's own documentation where the lender is an individual. Where interest is variable, model an increase rather than the current rate.

A structure that works only on the most favourable assumptions is a structure whose risk has not been priced.