Administrative or subscription fees charged by the project, government filing charges under the published fee schedule, immigration legal fees, and the cost of assembling source-of-funds evidence. None of these count toward the required investment amount.
Keep four budget lines apart
The qualifying capital is one line and must reach the threshold in force on its own. Project administrative fees are a second line and are typically not returnable in the way the investment might be, so read what the offering says about them. Government charges are a third line: the initial petition, later stages for the family, and the eventual petition to remove conditions each carry their own charge under the published schedule, and they should be confirmed at the time rather than quoted from an older document. Professional and evidence-gathering costs are the fourth, and in a case built on property and a loan they are larger than people expect because registry searches, valuations, translations and accountant statements accumulate. Adding any of these to the capital total to reach the threshold misstates the investment.
Hypothetical example: A dental-supply company owner is considering an EB-5 project after paying for an independent valuation of collateral used in a loan. The first review should distinguish the investment amount from filing fees, project administration charges, document collection, translations, tax work, and travel. The loan agreement and valuation settle whether borrowed funds have appropriate backing; a project fee schedule settles what is paid to the offering, not whether it counts as capital. Confirm all current government charges from official sources before payment. A low advertised project charge does not change the separate requirement for lawful funds at risk and qualifying job creation, so compare the full cost and documentary burden.