Do not assume they are. The subscription should distinguish qualifying capital from administration charges, and counsel should review the treatment of each payment under the applicable EB-5 rules.
Identify recipient, purpose and refund terms
Obtain a written fee schedule that includes project charges, government filings, independent counsel, family processing and later removal-of-conditions work. Keep lawful-source records for relevant fee payments as well as capital. Ask whether third-party compensation is included or additional.
A bundled price or projected distribution does not eliminate the need to understand what each payment purchases and whether it is refundable. Identify for every amount who receives it, what it is for, and on what terms it is refundable. Administration or subscription fees charged by a centre or promoter are generally paid to that party for their services and are a different thing from the capital contributed to the enterprise, and the two should never be presented as a single figure.
Ask whether any fee is payable again at a later stage, what happens to it if the petition is unsuccessful or the investor withdraws, and whether it is held in escrow. Then add the costs outside the offering entirely: professional fees for your own counsel, the work of documenting the lawful source of funds, translations, and the later stage of the process. Verify the applicable investment amount from current official materials rather than from marketing material.