What is the EB-5 minimum investment, and when does it change?

The EB-5 Reform and Integrity Act of 2022 set the minimum at $800,000 for a targeted employment area (rural or high unemployment) and $1,050,000 for a standard investment. Both remain in force. The Act provides for adjustment in line with inflation every five years, with the first adjustment due on 1 January 2027. The adjusted figures have not been published, so any specific 2027 number is a projection rather than a rate.

Can I finance the $800,000 EB-5 investment with a securities-backed loan?

Yes. USCIS allows Lombard loan financing provided you prove lawful source of funds for the collateral portfolio. At 50-60% LTV for equity portfolios, you need $1.35-1.6 million in liquid securities to borrow $800,000. Example: an executive with $2 million in listed equities borrows $800,000 (40% LTV), invests in an EB-5 project, and keeps the portfolio exposure. After 5 years, when EB-5 capital returns, the loan principal is repaid. Total opportunity cost: roughly $120,000 in interest (3% over 5 years) against a capital gains charge in the region of $148,000 on liquidating appreciated stock. Rates and tax positions vary; these are illustrations, not a quotation.

What portfolio value do I need to finance $800,000 EB-5 via Lombard loan?

Indicative portfolio values by asset class: developed market equities (50-60% LTV) $1.35-1.6M; diversified ETF portfolios (60-70% LTV) $1.15-1.35M; investment-grade bonds (70-85% LTV) $0.95-1.15M. Conservative practice is to borrow at 40-50% of total portfolio value so the facility survives a drawdown. Example: a $2.5M portfolio borrowing $800K sits at 32% utilisation, and a 40% market fall would take the LTV to roughly 53%, leaving margin-call headroom. LTV bands are set by the lender and vary with the collateral.

How long must I keep the Lombard loan for EB-5?

Typically 5-7 years. EB-5 requires capital to remain 'at risk' for 2+ years while creating jobs. However, most Regional Center projects hold capital for 5-6 years before returning principal. You maintain the Lombard loan until your EB-5 investment is returned, then repay the loan. Rolling credit facility means you can repay early without penalty if capital is returned sooner. Interest accrues only on outstanding balance; many investors pay interest quarterly from dividends or salary to avoid compounding.

What is the capital gains tax savings from Lombard financing versus selling stocks for EB-5?

Assuming long-term capital gains: federal 20% plus 3.8% NIIT plus state tax (California 13.3%, for example) gives 37.1%. On an $800,000 liquidation with a 50% cost basis, the $400,000 gain attracts roughly $148,400 in tax. The Lombard alternative is $800,000 borrowed at 3% for five years, roughly $120,000 in interest, so the direct saving is around $28,400. The larger effect is that a $1.6M portfolio stays invested: at 8-10% compound that is roughly $750,000 to $975,000 of growth over five years, before loan repayment. Rates, state tax and returns all vary, and interest is not deductible in every case, so take advice on your own position rather than relying on this illustration.

Can I use Lombard loan proceeds for the EB-5 job creation requirement?

Yes. USCIS does not restrict how you source the $800,000, only that you prove lawful origin of the collateral assets. Your loan proceeds go directly to the EB-5 Regional Center or direct investment entity, which then creates the required 10 jobs. Job creation is the responsibility of the project, not your financing method. Source of funds documentation requires: proof of portfolio acquisition (brokerage statements, tax returns showing income to build wealth), loan agreement, wire transfer records showing loan disbursement to EB-5 project.

What happens if my EB-5 project fails and I lose the $800,000?

You still owe the Lombard loan—the lender has no exposure to your EB-5 project success. The loan is secured by your portfolio, not the EB-5 investment. If the project fails: (1) You may still qualify for permanent residency if jobs were created during the at-risk period (I-829 approval based on job creation, not investment return). (2) You must repay the $800,000 loan from other sources. (3) Your portfolio remains as collateral; you could liquidate positions to repay. This is why institutional investors diversify across 2-3 EB-5 projects or choose only established Regional Centers with 100% I-829 approval history.

EB-5 Financing 2026: $800K Lombard Loan Without Selling Stocks

How to Finance the $800K EB-5 Investment Without Selling Your Stock Portfolio

⚡ Key Takeaways: Lombard vs Liquidation for EB-5

Factor	Sell Stocks	Lombard Loan	Advantage
Capital Gains Tax	~$163K on the assumptions below	Deferred, not avoided	Lombard
Portfolio Exposure	Reduced ($800K+ sold)	Maintained (full $2M)	Lombard
Compounding	Stops on sold shares	Continues on full portfolio	Lombard
Cost Over 5 Years	Tax paid upfront	~$120K interest at 3%	Depends on rates
Liquidity	Reduced	Preserved, but encumbered	Lombard
Required Portfolio	~$1.01M to net $800K	~$1.6M at 50% LTV	Liquidation

Bottom line: for an investor holding appreciated securities, borrowing against the portfolio defers a capital gains charge and keeps the full balance compounding. It also introduces leverage, a margin-call risk and an interest cost that persists whether or not markets cooperate. Whether it is the better route depends on your cost basis, your marginal rate, the borrowing rate available to you and your tolerance for a collateral call. The figures throughout this article are illustrations on stated assumptions, not a quotation and not advice.

Timing: the EB-5 Reform and Integrity Act of 2022 provides for the minimums to be adjusted for inflation every five years, with the first adjustment due on 1 January 2027. The adjusted amounts have not been published.

The 1 January 2027 inflation adjustment

The EB-5 Reform and Integrity Act of 2022 requires the minimums to be adjusted for inflation every five years. The first adjustment falls due on 1 January 2027, measured against the statutory base amounts.

TEA (Targeted Employment Area): currently $800,000
Standard Investment: currently $1,050,000

USCIS has not published the adjusted figures. Any specific 2027 amount circulating in the market is a projection from CPI-U, not a published rate, and should be treated as such. Regional Center processing typically runs three to six months, so anyone whose decision turns on the current amounts should factor that in, but no deadline should be presented as confirmed until USCIS publishes one.

Sources: EB-5 Reform and Integrity Act of 2022 (8 U.S.C. § 1153(b)(5)(C)(iii))

What Is the Current EB-5 Minimum Investment?

The EB-5 Reform and Integrity Act of 2022 set, and still sets, the minimums:

Targeted Employment Area (TEA): $800,000 — rural or high unemployment
Standard Investment: $1,050,000

The Act provides for adjustment every five years, with the first adjustment due 1 January 2027. The adjusted amounts have not been published.

For an investor holding $2M-$5M in appreciated securities, selling enough stock to fund $800,000 triggers a capital gains charge. Securities-backed lending offers a superior alternative: borrow against your portfolio at 3% interest, avoid immediate taxation, and maintain compounding on the full portfolio value.

What Is the Liquidation Tax Problem for EB-5?

Scenario: Tech Executive with $2M in FAANG Stock

Asset Profile:

Current value: $2,000,000 (RSUs vested 2019-2024)
Cost basis: $900,000 (45% of current value across the whole portfolio)
Unrealized gain: $1,100,000

Tax on $1.05M Liquidation:

Shares sold: $800,000
Proportional gain: $800K × ($1.1M / $2M) = $440,000 taxable gain
Federal long-term capital gains: 20% = $88,000
Net Investment Income Tax (NIIT): 3.8% = $16,720
California state tax (example): 13.3% = $58,520
Total Tax: $163,240

After-Tax Proceeds:

Gross liquidation: $800,000
Tax paid: -$163,240
Net Available: $636,760

The problem: to net the full $800,000 you must sell roughly $1,005,000 of stock, on which the charge is about $205,000. Rates here assume a California resident at the top long-term rate; a Texas or Florida resident would face 23.8% rather than 37.1%, and the case for borrowing weakens accordingly.

How Does Lombard Financing Work for EB-5?

Same Portfolio, Zero Liquidation

Loan Structure:

Collateral: $2,000,000 stock portfolio
Loan-to-Value (LTV): 50% for diversified equity portfolios
Maximum borrowing capacity: $1,000,000
EB-5 loan amount: $800,000 (40% portfolio utilization)
Interest rate: SOFR + 2.5% spread, about 3% annually (March 2026 rates)

5-Year Cost Analysis (Typical EB-5 capital lockup):

Annual interest: $800,000 × 3% = $24,000
Total interest (5 years): $120,000
Interest cost versus the tax deferred: $163,240 of tax deferred against $120,000 of interest. Note that the tax is deferred, not forgiven: it falls due whenever the shares are eventually sold.

Portfolio Compounding Preserved:

$2M portfolio stays fully invested
Historical 8% annual return (S&P 500 long-term average)
5-year growth: $2M × (1.08^5) = $2,938,000
Portfolio gain: $938,000 (even after paying $135K interest)

Net Position After 5 Years:

EB-5 capital returned: $800,000
Repay Lombard loan principal: -$800,000
Interest paid (out of dividends/salary): -$120,000
Portfolio value: $2,938,000
Net Wealth: $2,818,000

Liquidation Scenario After 5 Years:

Stock sold to net $800,000 after tax: $1,005,000
Tax paid from proceeds: -$205,000
Initial portfolio after liquidation: $995,000
5-year growth on remaining $995K: $995K × (1.08^5) = $1,462,000
EB-5 capital returned: +$800,000
Net Wealth: $2,262,000

Lombard advantage on these assumptions: roughly $556,000 ($2,818K vs $2,262K). That gap is driven almost entirely by the 37.1% California rate and the 45% cost basis. Change either and the answer changes materially: at a 23.8% federal-only rate the advantage falls by more than half, and on a portfolio with little embedded gain it largely disappears. The deferred tax also remains payable on eventual sale, so this is a timing and compounding advantage, not a tax saving.

How Much Portfolio Do You Need for a Lombard Loan?

Asset Class	Maximum LTV	Portfolio Required for $800K Loan	Conservative Utilization (40%)
Developed Market Equities (US large-cap, diversified)	50-60%	$1.35M - $1.6M	$2.0M
Diversified ETF Portfolios (60/40, All-Weather)	60-70%	$1.15M - $1.35M	$1.8M
Investment-Grade Bonds (AAA-BBB corporate)	70-85%	$0.95M - $1.15M	$1.6M
Cash / T-Bills (USD, EUR, CHF)	90-95%	$840K - $890K	$1.3M

Why Conservative Utilization Matters:

Borrowing at maximum LTV (e.g. 60% on a $1.35M equity portfolio = $800K) leaves no margin for error. A -25% market crash brings LTV to 80%—triggering margin calls.

Best Practice: Size loan at 40-50% of total portfolio value, not maximum LTV.

Example:

$2.5M portfolio (diversified equities)
Max LTV 60% = $1.5M borrowing capacity
Actual loan: $800K (32% utilization)
Margin call threshold: typically 75-80% LTV
Crash buffer: Portfolio can drop -50% ($2.5M → $1.25M) before LTV reaches 72%—still safe

What Are the EB-5 Source of Funds Requirements for Lombard Loans?

USCIS requires proving lawful source of both the EB-5 investment and the collateral assets. Lombard loans are explicitly permitted—the burden is documenting how you acquired the portfolio.

Required Documentation:

1. Portfolio Acquisition Trail:

Brokerage statements (past 5-7 years showing account growth)
Tax returns demonstrating income sources (W-2, 1099, K-1, capital gains)
For RSUs/stock options: employment verification, vesting schedules, Form 3921/3922
For inherited wealth: estate documents, probate records, tax returns of decedent
For business sale proceeds: stock purchase agreements, tax returns, wire records

2. Loan Documentation:

Lombard loan agreement (showing terms, collateral, LTV)
Wire transfer records (loan proceeds → EB-5 escrow account)
Collateral pledge agreement (securities hypothecation)

3. EB-5 Investment Documentation:

Subscription agreement with Regional Center or direct project
Wire confirmation (loan proceeds to EB-5 entity)
I-526E petition including loan as source of funds

Common USCIS Concern: "How do we know the portfolio wasn't funded by illicit proceeds?"

Solution: Show continuous account growth through documented income over 5+ years. Example: Tech executive earning $400K annually (W-2) + $200K RSU vesting = $600K/year capacity. Over 5 years: $3M gross income. After taxes/living expenses, $2M portfolio accumulation is entirely plausible.

What Is the $2M Portfolio 5-Year Lombard Strategy?

Profile:

Investor: Senior software engineer, Microsoft (2017-present)
Portfolio: $2,000,000 in MSFT stock + diversified ETFs
Cost basis: $850,000 (RSUs vested 2017-2024, some purchased)
EB-5 goal: TEA investment for Green Card

Lombard Execution:

Year 0 (2026):

Secure Lombard line of credit: $1.2M capacity (60% LTV on $2M)
Draw $1.05M for EB-5 Regional Center (senior living project in rural Ohio)
Actual LTV: 45% (conservative buffer)
Interest rate: 3% fixed for 3 years, then SOFR+2.5%

Years 1-2:

Pay interest quarterly from salary: $6,750/quarter ($27K/year)
Portfolio grows to $2.33M (8% annual return)
EB-5 petition (I-526E) approved in 18 months
Conditional Green Card issued

Years 3-5:

Interest continues: $24K/year (paid from RSU vesting)
Portfolio grows to $2.72M (cumulative 36% over 5 years)
I-829 petition filed (remove conditions on Green Card)
EB-5 capital returned: $800,000

Year 5 Outcome:

Repay Lombard loan principal: $800K
Total interest paid: $120K (5 years × $24K)
Permanent Green Card obtained
Portfolio value: $2,720,000
Total cost: $120K of interest, against roughly $205K of capital gains tax brought forward if liquidating

Wealth preservation: keeping the full $2M invested, the portfolio compounded an additional $720K over 5 years, against $358K of growth on the $995K that would remain after selling enough to net $800K. Net advantage after interest: $556K greater wealth.

How Do You Manage Risk?: What If Markets Crash?

Scenario: -40% Bear Market (2008-Level)

Starting Position:

Portfolio: $2,500,000
Loan: $800,000 (32% utilization)
LTV: 32%

After -40% Crash:

Portfolio value: $1,500,000
Loan balance: $800,000 (unchanged)
New LTV: 53%
Margin call threshold: 75%
Status: Safe—15% buffer remains

Worst-Case Scenario: -50% Crash

Portfolio: $1,250,000
LTV: 72%
Still below 75% margin call threshold
Maintain $60K-$80K cash reserve for 24-36 months interest payments
Morgan Stanley data: Average 60/40 portfolio recovers to breakeven in 3 years post-crash
EB-5 timeline: Your capital is locked for 5+ years anyway—you have time to ride out recovery

Key Insight: EB-5's 5-7 year capital lockup is actually an advantage for Lombard financing. Unlike a home purchase where you might need liquidity in 1-2 years, EB-5 investors have multi-year horizons—perfectly aligned with bear market recovery cycles.

Frequently Asked Questions

Q: Can I repay the Lombard loan early if my EB-5 capital returns sooner?
A: Yes. Lombard facilities are revolving credit lines, not term loans. You can repay any amount without penalty. If your Regional Center returns capital in Year 3 instead of Year 5, repay immediately and stop accruing interest.

Q: What if my EB-5 project fails and I lose the $1.05M?
A: The Lombard loan is still owed—the lender has no exposure to your EB-5 investment success. You must repay from other sources (salary, portfolio liquidation, other assets). This is why due diligence on Regional Centers is critical. Choose projects with 100% I-829 approval history and conservative underwriting.

Q: Do I need to inform USCIS that I'm using a loan to fund EB-5?
A: Yes—this is part of source of funds documentation. Lombard loans are fully compliant. You demonstrate: (1) lawful acquisition of collateral portfolio, (2) loan agreement, (3) wire transfer of loan proceeds to EB-5 entity. USCIS approves this structure routinely.

Q: Can I use the same portfolio collateral to finance multiple investments (e.g., EB-5 + Portugal Golden Visa)?
A: Yes, if portfolio size supports it. $1.05M EB-5 + €250K Portugal ($275K) = $1.175M total borrowing. At 40% utilization, you need ~$2.9M portfolio. Institutional investors often stack multiple residency investments on one large portfolio.

Q: Is there a minimum portfolio size where Lombard makes sense versus just paying cash?
A: If your total liquid net worth is <$1.5M, paying cash may be simpler (avoiding leverage complexity). If portfolio is $2M+, Lombard financing almost always wins due to tax savings + compounding preservation. The breakeven is roughly when your unrealized gains × tax rate < 5 years of Lombard interest.