EB-5 capital helped build Hudson Yards by filling the slice of the capital stack that senior banks would not lend against. Related Companies raised money from foreign investors in several tranches during the early 2010s, working through a regional center it set up and controlled itself rather than an unaffiliated sponsor, then deployed it as cheap subordinate financing for the platform and towers going up over the West Side rail yard. Each investor committed the minimum then in force, $500,000, and received a conditional green card once the project's economic model produced ten jobs attributable to their share. Phase one opened to the public in 2019.
Published totals for that raise vary widely from one account to the next, so treat any single dollar amount you read as a claim rather than a fact.
Where the money sat in the capital stack
Megaprojects do not raise EB-5 because it is the easiest money in the room. They raise it because of where it sits. A senior construction lender takes first position and prices accordingly. Equity takes the residual and demands the upside. Between those two layers sits a gap that often runs 10 to 20 percent of total project cost.
Filling that gap with conventional mezzanine debt can cost a sponsor low double digit interest. EB-5 money fills the identical slot at a fraction of the coupon, because investors in these deals routinely accept well under 1 percent a year. What they came for is the visa. That spread is the entire commercial logic of the program, and once you see it you understand who each offering was designed to serve.
Position also tells you where your risk lives. Subordinate capital is repaid last, so if a project underperforms the senior lender is made whole before a single EB-5 dollar returns, which is precisely the sequence described in our account of what happens when an EB-5 project fails.
The TEA designation that helped rewrite the law
Hudson Yards occupies some of the most valuable land in North America. It still qualified for the reduced investment amount, because the rules then in force allowed a state to combine the project's census tract with a chain of neighboring tracts until the blended unemployment figure cleared 150 percent of the national average. Critics called that gerrymandering. They had a point.
Congress closed the door. The EB-5 Reform and Integrity Act of 2022 moved Targeted Employment Area designation to the Department of Homeland Security and confined a high unemployment area to the tract where the enterprise is principally doing business plus tracts directly adjacent to it. Unemployment inputs come from published federal series such as the Bureau of Labor Statistics local area unemployment statistics. A luxury development on the Hudson River can no longer borrow the unemployment rate of a neighborhood several miles uptown.
Practical consequence for anyone reading an urban offering in 2026: ask for the tract map, not the summary paragraph.
How the jobs were counted, and how they are counted now
Large real estate projects generate their EB-5 job numbers from economic models rather than payroll records. An economist takes hard construction spending plus projected revenue from the finished building and runs both through a regional multiplier model such as RIMS II or IMPLAN. The output is a job count split into direct employment plus the indirect and induced jobs the model attributes to the same spending.
Two features of that method deserve your attention before you rely on it. Model output scales with expenditure, so a project delivered under budget produces fewer countable jobs than the offering projected. The 2022 statute also capped jobs from construction activity lasting less than two years at 75 percent of the total claimed, which pushes sponsors toward longer build cycles and toward operating jobs that show up on an actual payroll.
USCIS tests all of it years later, at the Form I-829 stage, when the model has met reality. Our explainer on the ten job requirement walks through what the agency actually accepts as proof.
Did the investors do well?
On immigration, largely yes. A completed and occupied complex throwing off income is close to ideal I-829 evidence, because the construction spend was verifiable and the operating jobs exist in the tax records of real businesses. Compare that with an investor spending the conditional period watching a fence around a vacant lot.
On money, the picture is duller. EB-5 investors in a deal of this type earn a nominal coupon for five or more years while their capital is locked, and repayment depends on the sponsor refinancing or selling the asset. Nobody should evaluate $800,000 of EB-5 capital the way they would evaluate an index fund. Treat it as the price of the visa, with a reasonable expectation of recovering most or all of the principal eventually.
Read a megaproject offering the way an underwriter would
Scale is reassuring. Reassurance is not underwriting. Four questions do most of the work on a large offering:
- Is the senior debt committed? A signed construction loan is a very different object from a term sheet.
- How much of the raise is subscribed? A project needing 300 investors that has closed 40 is exposed to whatever happens to visa demand next year.
- What is the job cushion? Divide total modeled jobs by the number of investor slots. A ratio near 10 leaves no margin for a budget overrun, and sponsors with real headroom quote the number happily.
- Has the I-956F been receipted? The project application filed on Form I-956F has to be on file before any investor in that deal can file a petition.
Our list of 25 questions to ask a regional center before investing goes further. The USCIS Policy Manual chapter on immigrant investors tells you what the adjudicator will look for in those same documents.
Could this deal be done the same way in 2026?
Not in the same shape. The chained TEA is gone and the $500,000 tier went with it. Regional centers now file annual statements on Form I-956G. They also submit to audits and register the overseas agents who market their offerings. Most raises now require an independent fund administrator as well.
Competition changed too. Manhattan megaprojects no longer have the field to themselves, because 20 percent of the annual visa supply is reserved for rural projects and those petitions receive priority adjudication. Serious capital has moved toward smaller markets as a result, a shift visible in the story of a community rebuilt with immigrant investment.
Hudson Yards rewards study on two levels. Underneath the marketing it shows EB-5 doing what the statute intended, financing construction that employed American workers on a deck built over a working rail yard. It also shows how far the incentives could be bent before 2022, which is why the compliance regime you deal with today looks nothing like the one those first investors signed into.