Money and structure

Bridge financing

Also called bridge loan, interim financing.

Bridge financing is the interim debt or equity a developer or the principal of a new commercial enterprise uses to start a project before EB-5 capital arrives, and which the EB-5 capital then replaces.

What it decides

USCIS lets the new commercial enterprise claim credit for the jobs that bridged spending created, provided the financing being replaced was genuinely interim. Replacement by EB-5 capital should generally have been contemplated before the temporary financing was taken. Where it was not, credit still follows so long as that financing was itself contemplated as short term money to be replaced by more permanent long term financing, which covers the common case of expected traditional financing falling through. It follows from that condition that money already sitting as permanent long term financing is not bridge financing, and replacing it earns no job credit. Separately, the full amount of the investment must be made available to the business or businesses most closely responsible for creating the jobs. Where the new commercial enterprise is not the job-creating entity, the capital must go into the new commercial enterprise first and then be made available to the job-creating entity or entities.

Governed by USCIS Policy Manual, Volume 6, Part G, Chapter 2, Section D.1, Bridge Financing (6 USCIS-PM G.2(D)(1)) (https://www.uscis.gov/policy-manual/volume-6-part-g-chapter-2); Matter of Izummi, 22 I&N Dec. 169, 179 (Assoc. Comm. 1998) (https://www.justice.gov/eoir/vll/intdec/vol22/3360.pdf). Izummi is USCIS's footnote 108 and supports only the last two sentences, on where the capital must be made available, not the bridge financing rule itself.

Related terms

Loan modelThe loan model is the regional center structure in which the new commercial enterprise lends the pooled investor capital to a separate job creating entity, most often a company the project developer controls, instead of taking an ownership stake in it.
Capital stackThe capital stack is the ranking of a project's funding sources by priority of claim, from senior debt, which is paid first and absorbs losses last, down through mezzanine debt and preferred equity to common equity, which is paid last and absorbs the first losses. It is a finance term rather than an EB-5 one: nothing in the EB-5 statute or regulations fixes where a project's EB-5 money must rank.
Senior debtSenior debt is the borrowing that ranks first in a project's capital stack, normally secured by a first lien on the project assets, and it is paid ahead of every junior claim, an EB-5 loan included, out of project cash flow and out of the collateral if the borrower defaults.

Checked against primary sources on 6 August 2026. Back to the glossary