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EB-5 Targeted Employment Areas & Senior Housing | Haven Senior Investments
Disclaimer For informational purposes only — not immigration, legal, or investment advice. EB-5 investments are securities offerings. All immigration matters require a qualified immigration attorney. Consult licensed legal and financial professionals before pursuing any EB-5 investment. Haven Senior Investments is not an immigration attorney, broker-dealer, or registered investment advisor.
Capital Solutions · EB-5 Program

EB-5 Targeted
Employment Areas
& Senior Housing

The EB-5 Immigrant Investor Program provides a pathway to U.S. permanent residency for foreign nationals who invest in qualifying commercial enterprises and create American jobs. Senior housing development in rural or high-unemployment areas can qualify as a Targeted Employment Area (TEA) project — enabling the reduced $800,000 investment threshold and access to reserved visa set-asides under the EB-5 Reform and Integrity Act of 2022.

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$800K
TEA investment
minimum
$1.05M
Non-TEA investment
minimum
10 jobs
Required per
investor
~10K
Annual EB-5
visas available
EB-5 Investment Thresholds — 2026
$800,000
TEA Investment — Rural, High-Unemployment, or Infrastructure
The reduced minimum applies when the project is located in a Targeted Employment Area — a rural area, a high-unemployment census tract, or an eligible public infrastructure project. Includes visa set-aside benefits and, for rural TEAs, priority processing.
$1,050,000
Standard Non-TEA Investment
The standard minimum applies to all other projects — those located outside of qualifying TEAs or infrastructure projects. No visa set-aside benefits. No priority processing preference.
Investment thresholds set by the EB-5 Reform and Integrity Act of 2022 (RIA). Next scheduled inflation adjustment: 2027. Amounts confirmed as of April 2026.
Program Overview

What Is the
EB-5 Program?

The EB-5 Immigrant Investor Program was created by Congress in 1990 under the Immigration Act as the fifth employment-based (EB) immigration category. It grants U.S. lawful permanent resident status — a green card — to foreign nationals and their immediate families who invest qualifying capital in a U.S. commercial enterprise that creates at least 10 full-time jobs for American workers.

The program is administered by U.S. Citizenship and Immigration Services (USCIS) under the oversight of the Office of Residential Care Facilities (for the regional center program). Approximately 10,000 EB-5 visas are available annually — covering the investor, their spouse, and unmarried children under 21.

Investors may invest directly (standalone) or through an approved Regional Center — a USCIS-designated entity that pools EB-5 investments into qualifying commercial projects and uses economic modeling to count indirect and induced jobs, not just direct employment.

EB-5 Reform & Integrity Act of 2022 (RIA)
The RIA — signed March 15, 2022 — significantly reformed the EB-5 program. It reauthorized the Regional Center Program through September 30, 2027, codified TEA designations in federal statute, established visa set-asides for rural and high-unemployment projects, transferred TEA designation authority from states to DHS, and introduced new integrity and oversight requirements for regional centers. Investors who file I-526/I-526E petitions before the program's reauthorization expiration are protected by grandfathering provisions.
The EB-5 Process — Key Steps
1
I-956F (Regional Center projects first)
Project Approval — Regional Center Path
For regional center investments, the project must first obtain USCIS approval via Form I-956F before investors can file I-526E petitions. Projects with I-956F approval have already received USCIS validation of job creation methodology.
2
I-526 (standalone) / I-526E (regional center)
Immigrant Investor Petition
The investor files with USCIS demonstrating qualifying investment amount, lawful source of funds, TEA designation evidence (if applicable), and the project's job creation plan. The TEA designation — if claimed — is adjudicated as part of this petition.
3
DS-260 or I-485
Visa Application or Adjustment of Status
Upon I-526/526E approval, the investor applies for an immigrant visa (from abroad) or adjustment of status (if already in the U.S.). Concurrent filing of I-485, I-765, and I-131 is permitted under the RIA for eligible investors already in the U.S.
4
Conditional Permanent Residence (2 years)
The investor and family receive conditional green cards valid for 2 years. During this period, the investment must remain deployed and jobs must be created (or under creation for regional center projects).
5
I-829
Removal of Conditions — Permanent Residency
The investor files I-829 to remove conditions on their permanent residence — demonstrating that 10 qualifying jobs were created and the capital remained invested for the required sustainment period (minimum 2 years per current USCIS guidance).
Targeted Employment Area Types

Three Ways to Qualify
for the $800,000 Threshold

Under the EB-5 Reform and Integrity Act of 2022, three categories of projects qualify for the reduced $800,000 investment minimum — each with distinct criteria and different immigration benefits.

Rural Area TEA
Rural Targeted Employment Area
$800,000
A rural TEA is any area not located within a Metropolitan Statistical Area (MSA) as designated by the Office of Management and Budget, and not within the outer boundary of any city or town with a population of 20,000 or more. Rural TEAs receive the strongest immigration benefits — reserved visa allocation AND priority processing, making them the most attractive TEA category for investors from backlogged countries.
Not within any MSA as designated by the OMB
Not within the outer boundary of a city or town with 20,000+ population (per most recent U.S. Census)
20% visa set-aside — the largest reserved category
Priority processing — I-526E approvals as fast as 29 days for eligible rural projects
Strong fit for assisted living and memory care development in rural communities
High-Unemployment TEA
High-Unemployment Targeted Employment Area
$800,000
A high-unemployment TEA is a census tract or combination of contiguous census tracts in which the weighted average unemployment rate is at least 150% of the national average. Under the RIA, DHS — not states — now designates high-unemployment TEAs, eliminating the gerrymandering of distant high-unemployment tracts to cover prime urban real estate that characterized pre-RIA practice.
Weighted average unemployment ≥ 150% of U.S. national average
Defined by census tract(s) including the tract where the enterprise principally operates
May include contiguous adjacent census tracts for the weighted average calculation
10% visa set-aside for high-unemployment area investments
DHS makes designation — state designation letters no longer controlling
Infrastructure TEA
Infrastructure Project
$800,000
A qualifying infrastructure project — such as a road, bridge, airport, or public facility — financed in part with EB-5 capital and administered by a governmental entity. Infrastructure TEAs receive the smallest set-aside (2%) but qualify for the reduced investment threshold. Not applicable to senior housing projects, which are private commercial enterprises rather than public infrastructure.
Must be administered by a governmental entity at state, local, or federal level
Public infrastructure — roads, bridges, water systems, public facilities
DHS determines eligible infrastructure project status
2% visa set-aside — smallest reserved category
Not applicable to private senior housing development projects
Visa Set-Aside Allocation

32% of Annual EB-5
Visas Are Reserved for TEAs

One of the most significant benefits introduced by the EB-5 Reform and Integrity Act is the creation of reserved visa set-asides for TEA investments. Under the RIA, 32% of the approximately 10,000 annual EB-5 visas are reserved for investors in qualifying TEA projects — separate from the general unreserved pool.

For investors from countries with significant EB-5 visa backlogs — primarily China and India — TEA set-aside visas represent a critical pathway around years-long waiting periods. Investors from backlogged countries who invest in rural TEA projects can access a dedicated visa pool that is not subject to the same per-country queue as unreserved EB-5 visas.

Rural TEA Priority Processing — Current Data
Under the RIA, rural TEA I-526E petitions receive priority processing. Recent data shows average I-526E approval times of 4.8 months when filing after I-956F approval and 11.3 months when filing before project approval — dramatically faster than the multi-year backlog that plagued the pre-RIA program.
Rural Area TEA20%
~2,000 visas annually reserved for investors in qualifying rural TEA projects. Largest set-aside category. Includes priority processing preference. Strong fit for rural senior housing development.
High-Unemployment Area TEA10%
~1,000 visas annually reserved for investors in high-unemployment TEA projects. Second largest set-aside. DHS now exclusively designates qualifying areas under the RIA.
Infrastructure Projects2%
~200 visas annually reserved for investors in qualifying public infrastructure projects. Not applicable to senior housing — infrastructure TEAs are public projects administered by governmental entities.
Unreserved Pool68%
~6,800 visas annually in the general unreserved pool — available to all EB-5 investors including non-TEA at $1.05M. Subject to per-country limits, creating backlogs for investors from China and India.
How TEA Designation Is Obtained

TEA Designation Is Adjudicated
by DHS — Not States

Under the original EB-5 program, states played a significant role in designating high-unemployment TEAs — and states routinely approved gerrymandered designations that connected distant high-unemployment tracts to allow prime urban developments to qualify for the reduced $800,000 threshold. The EB-5 Reform and Integrity Act eliminated this by transferring TEA designation authority exclusively to DHS.

TEA designation for the investor's specific project is now adjudicated as part of the I-526 or I-526E petition process. The investor must provide sufficient evidence that the project location qualifies under the applicable TEA criteria — rural area or high-unemployment census tract — through supporting documentation submitted with the petition.

RIA Change — State Designation Letters No Longer Controlling
Prior to the RIA, state government designation letters were typically accepted by USCIS as sufficient TEA evidence. Under the RIA, only DHS may designate high-unemployment TEAs. USCIS will no longer defer to state designations for high-unemployment areas. Rural TEA determinations are based on OMB MSA designations and census population data — objective criteria that do not require state involvement.
Evidence for TEA Designation — What to Submit
OMB Metropolitan Statistical Area map For rural TEA claims: documentation showing the project location is not within any MSA as currently designated by the OMB Office of Management and Budget
U.S. Census population data For rural TEA claims: census data confirming no city or town within or adjacent to the project boundary exceeds 20,000 population (most recent decennial census)
BLS Local Area Unemployment Statistics (LAUS) For high-unemployment TEA claims: published unemployment data from the Bureau of Labor Statistics at the census tract level — demonstrating weighted average unemployment ≥ 150% of national rate
Census tract identification and mapping The specific census tract(s) in which the enterprise principally does business — and any contiguous adjacent tracts included in the weighted unemployment calculation
Project location documentation Evidence connecting the project's principal place of business to the qualifying TEA — address, site plans, and geographic documentation placing the enterprise within the designated area
TEA designation is adjudicated by USCIS as part of the I-526/I-526E petition. Work with a qualified immigration attorney to assemble the correct evidence package — insufficient documentation is a common basis for petition denial or RFE (Request for Evidence).
Senior Housing as an EB-5 Project

Why Senior Housing Is a
Natural EB-5 Project Type

Senior housing development — particularly assisted living and memory care communities in rural areas or high-unemployment communities — is among the most natural fits for EB-5 capital. The job creation profile of a senior housing community, the location characteristics of rural and underserved markets, and the long-term capital need of development all align with what the EB-5 program was designed to incentivize.

A 100-bed assisted living community employs 80–130 full-time workers — far exceeding the 10-job-per-investor threshold even for a moderate number of EB-5 investors. For rural communities where alternative care for aging populations is limited, senior housing development provides both the social infrastructure and the job creation that TEA designation is designed to reward.

Rural markets are underserved for senior care — rural AL and MC development often faces limited competition and strong local demand, where the nearest alternative may be hours away
Job creation aligns with TEA community benefit — the nursing aides, dietary staff, housekeeping, and administration that senior housing creates are exactly the jobs that rural and high-unemployment TEAs need
Long-term capital hold matches EB-5 sustainment — senior housing is a long-duration asset; the 2-year minimum sustainment period aligns with typical senior housing development and lease-up timelines
Rural TEA designation is often clear-cut — rural senior housing development sites are frequently in areas that meet the rural TEA criteria without ambiguity, unlike urban projects that require complex census tract analysis
Demographic demand is highest where EB-5 incentives apply — rural and underserved communities have aging populations with limited care options, creating real demand for the facility EB-5 capital builds
Job Creation — 100-Bed Assisted Living Community
10
Jobs Required Per EB-5 Investor
A 100-bed assisted living community typically creates 80–130 full-time positions — supporting 8–13 EB-5 investors at the minimum job threshold. Regional center investments use economic modeling to count direct, indirect, and induced jobs — potentially supporting even more investors.
Direct care staff — CNAs, medication aides, charge nurses, memory care specialists
Dietary and culinary — cooks, dietary aides, dining services staff
Housekeeping and laundry — environmental services staff throughout the building
Activities and programming — life enrichment coordinators and programming staff
Administration and management — executive director, DON, admissions, billing, marketing
Maintenance and facilities — maintenance staff and groundskeeping
Indirect and induced jobs (regional center) — construction supply chain, local spending, economic multiplier effects
Key Investor Considerations

What Every EB-5 Investor
Needs to Understand

01
Lawful Source of Funds Is Essential
Every EB-5 investor must document that the investment capital was obtained through lawful means — salary, property sales, business income, gifts, loans, or inheritance. USCIS scrutinizes source of funds carefully, and insufficient documentation is a leading cause of I-526/I-526E denials or Requests for Evidence. Work with an immigration attorney experienced in EB-5 source of funds documentation from your country of origin.
02
Regional Center vs. Standalone Investment
Standalone (direct) EB-5 investors must create 10 direct jobs — employees on the enterprise's payroll. Regional center investors may count direct, indirect, and induced jobs through economic modeling, making job creation much easier to satisfy. Most EB-5 senior housing projects are structured as regional center investments precisely because indirect and induced job creation through construction and operations easily meets the threshold.
03
Investment Is At Risk — Not a Loan Guarantee
EB-5 regulations require that the investment be "at risk" — the capital must be committed with no guaranteed return. Arrangements that promise principal preservation or guaranteed returns may disqualify the investment from EB-5 eligibility. Thoroughly evaluate each project's structure, financial projections, and developer track record before committing capital.
04
Visa Backlogs Vary Dramatically by Country
The annual numerical limit and per-country cap create backlogs for investors from heavily oversubscribed countries — primarily China and India. TEA set-aside visas provide meaningful relief for investors from these countries. Investors from countries with little or no backlog (most of the world) can obtain green cards relatively quickly after I-526E approval regardless of TEA status.
05
Immigration and Investment Outcomes Are Separate
An investor's immigration path depends on USCIS processing their petition correctly — not on the investment performing well financially. Conversely, a financially successful investment does not guarantee green card approval if the immigration process has procedural issues. Work with both qualified immigration counsel and independent financial advisors — never rely on project sponsors alone for both immigration and investment guidance.
06
Program Stability Through 2027
The EB-5 Regional Center Program is reauthorized through September 30, 2027 under the RIA. Investors who file I-526/I-526E petitions before expiration are protected by grandfathering provisions even if the program changes at reauthorization. In early 2025, the Trump administration proposed a potential "Gold Card" alternative program — but the EB-5 program remains active and unaffected as of April 2026, and no definitive legislative change has been enacted.
Program Update — 2025 In February 2025, the Trump administration announced a proposal to replace the EB-5 visa with a "Gold Card" investor visa program at a $1 million investment threshold, with a higher-tier "Platinum Card" also discussed. As of April 2026, no legislation has been enacted to replace or eliminate the EB-5 program. The EB-5 Reform and Integrity Act of 2022 remains in force, the Regional Center Program continues to operate, and USCIS continues to process I-526 and I-526E petitions under existing rules. Investors considering EB-5 should monitor legislative developments and work with immigration counsel to understand the current status of any proposed changes at the time of their filing. Investors who file before any potential program change retain grandfathering protections under the RIA.
How Haven Supports EB-5

Senior Housing Expertise
for EB-5 Project Developers

Haven Senior Investments works with real estate developers, regional centers, and capital partners who are incorporating senior housing into EB-5 project structures. Our senior housing expertise supports the development and underwriting side of EB-5 senior housing projects — not the immigration process itself.

Haven is not an immigration attorney and does not provide immigration advice. For immigration matters — petition preparation, source of funds documentation, TEA evidence assembly, and I-526/I-526E filing — work with a qualified immigration attorney experienced in EB-5 proceedings. Haven connects developers and regional centers to the senior housing expertise needed on the real estate and operational side of EB-5 projects.

Senior housing project development advisory
Haven advises on senior housing development projects in rural and high-unemployment markets — including market feasibility, site analysis, operator selection, and development planning for communities that may qualify as EB-5 TEA projects
Market feasibility studies for TEA projects
Haven's market feasibility studies assess senior housing demand in rural and underserved markets — providing the market data that developers need to confirm viability before pursuing EB-5 capital for a senior housing project
Capital stack advisory for senior housing development
Haven evaluates where EB-5 capital fits in a senior housing development capital stack alongside construction loans, HUD 232, bridge debt, and equity — ensuring the EB-5 component is properly positioned and sized
Immigration attorney referrals
Haven maintains relationships with immigration attorneys experienced in EB-5 proceedings for senior housing projects — and can make referrals to qualified counsel for the immigration-specific elements of an EB-5 project
Haven Senior Investments provides real estate and development advisory services only. Haven is not an immigration attorney, does not provide immigration advice, and cannot prepare or file EB-5 petitions on behalf of investors. EB-5 investments are securities offerings regulated under federal securities law — Haven is not a registered broker-dealer or investment advisor. All immigration and securities matters require appropriately licensed and qualified professionals. Haven assumes no liability for immigration, securities, or investment outcomes related to EB-5 programs.
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