Yes. Removal-of-conditions preparation and government charges belong in the full EB-5 budget, even though the filing occurs later. Project subscriptions and initial legal engagements may not include that work.
Clarify later-stage obligations in writing
Ask whether the project charges for evidence packages and what independent counsel will do to evaluate them. Include translations or additional professional work if records change or are incomplete. Verify government fees at filing rather than using an old estimate.
Keep funds available separately from the investment because a hoped-for capital repayment is not a guaranteed way to finance this required immigration stage. Set aside the later-stage money at the beginning, in a place the family will not spend it. The removal-of-conditions preparation and its government charges fall years after the initial outlay, and a household that has planned only to the residence grant meets them without provision.
Ask whether the project charges for evidence packages and what independent counsel will do to evaluate them, and include translations or additional professional work where records change or prove incomplete. Verify government fees at filing rather than relying on an old estimate. Keep those funds separate from the investment, since a hoped-for capital repayment is not a reliable way to finance a required stage.