Clear, concise answers to key questions about jobs, fund flow, litigation, timelines and USCIS filings for the Villa Roma EB-5 offering.
Simplified explanations based on current offering documents. Always consult your immigration and legal counsel.
The EB-5 Immigrant Investor Program is a U.S. program that allows eligible foreign investors to make a qualifying investment in a U.S. business and seek U.S. lawful permanent residence (a green card) if all program requirements are satisfied and USCIS approves the required filings. In general, EB-5 requires an at-risk investment of lawfully sourced capital and the creation of at least 10 qualifying full-time U.S. jobs per investor (as defined by USCIS).
In an EB-5 regional center project like Villa Roma EB-5 Project, the New Commercial Enterprise (NCE) is the entity into which EB-5 investors subscribe and invest. For this offering, the NCE is Fay Villa Roma Phase 1 Development, LP (a Delaware limited partnership). The NCE affiliated Regional Center is EB5 United Northeast Regional Center, LLC*, a USCIS-designated EB-5 Regional Center.
The NCE then deploys EB-5 capital to the Job-Creating Entity (JCE), which is the project company that uses the funds for the business plan and supports EB-5 job creation. For Villa Roma, the JCE is Fay Hospitality Catskills, LLC, the owner of the Villa Roma Resort & Conference Center in Callicoon, Sullivan County, New York (Catskills / Upstate New York). The NCE is expected to invest in the JCE as preferred equity, as described in the offering documents.
A Targeted Employment Area (TEA) is a location that may qualify for a reduced EB-5 minimum investment amount under U.S. law. A TEA can generally be either an area that qualifies based on unemployment data or a rural area meeting the statutory definition (often referred to as a Rural TEA).
Villa Roma is located in a qualifying Rural TEA, as described in the project materials and offering documents. Rural TEA status is being used to structure the Villa Roma offering at the $800,000 EB-5 minimum investment amount under current EB-5 regulations (subject to change).
A Rural TEA EB-5 investment is an EB-5 investment made in a project located in a Rural Targeted Employment Area (TEA) as defined under U.S. law. Villa Roma is a Rural TEA EB-5 project in Upstate New York (Catskills) and is offered as a regional center EB-5 investment.
Certain Rural TEA petitions may be eligible for priority processing where available, as determined by USCIS, and subject to applicable requirements, procedures, and case-specific factors. No processing timeframe is guaranteed.
Under current EB-5 regulations, the minimum investment amount is generally $800,000 for projects located in a qualifying TEA (including a Rural TEA) and $1,050,000 for non-TEA projects.
Villa Roma qualifies as a Rural TEA, and the offering is structured at the $800,000 EB-5 minimum investment amount per investor (plus applicable fees as described in the offering documents). Minimum investment amounts are set by law and may change; investors should confirm current requirements with qualified EB-5 immigration counsel.
Each EB-5 investor must be credited with the creation of at least 10 qualifying full-time U.S. jobs under EB-5 rules. In a regional center EB-5 project, job creation may include certain direct, indirect, and induced jobs calculated using accepted economic methodologies, as documented in an economic impact analysis.
For Villa Roma, the independent economist’s analysis estimates total job creation of approximately 777 jobs (approximately 12.14 jobs per investor based on 64 investors), which reflects an estimated job cushion of 21.4% above the minimum required, as further described in the project materials.
Timing is fact-specific and depends on the investor’s filing path and USCIS requirements. In many cases, job creation is demonstrated at the stage of removing conditions (Form I-829), based on evidence that the required jobs were created (or will be created within a timeframe permitted by USCIS), consistent with the business plan and supporting documentation. Investors should rely on their immigration counsel for timing guidance based on current rules and their circumstances.
In many cases, yes—gifted funds or loan proceeds may be used if the investor can document the lawful source of funds and any other requirements that apply under EB-5 rules. The donor or lender may need to provide supporting documentation showing how the funds were lawfully obtained. Investors should consult qualified EB-5 immigration counsel regarding the proper documentation for their situation.
The documentation depends on the investor’s circumstances and may include items such as personal and/or business tax returns, employment and income records, bank records, evidence of the sale of property or a business, dividend or distribution records, inheritance documentation, and records supporting securities or real estate transactions—sufficient to document the lawful source and path of funds under applicable EB-5 visa requirements.
Typically, the investor petition for a regional center EB-5 investment is filed with USCIS (commonly Form I-526E). If the investor is outside the United States, visa processing is generally handled through consular processing after USCIS petition approval and subject to visa availability. The petition to remove conditions (Form I-829) is filed with USCIS. Investors should follow guidance from qualified EB-5 immigration counsel.
While requirements vary, EB-5 filings typically include documentation showing: the investment and transfer/commitment of funds; lawful source of funds; the qualifying nature of the investment (including Rural TEA / TEA documentation where applicable); and evidence supporting the job creation plan and compliance with EB-5 requirements.
For a Villa Roma EB-5 investor, the project-related portion of the filing is generally supported by offering documents and project materials (including the project business plan and economic impact analysis) provided in connection with the offering, subject to counsel’s review and USCIS requirements.
For general information, investors may review the USCIS website’s EB-5 Immigrant Investor Program resources and should consult qualified EB-5 immigration counsel for advice specific to their case.
In general, conditional permanent residents may travel, subject to the rules applicable to lawful permanent residents. Extended travel outside the United States may impact residency requirements, and certain travel may require additional documentation. Investors should consult immigration counsel regarding travel planning.
No. Conditional permanent residence is typically granted for a limited period (generally two years). To obtain permanent residence without conditions, eligible investors file Form I-829 during the applicable filing window and must demonstrate satisfaction of program requirements, including investment and job creation requirements, subject to USCIS adjudication.
In general, an EB-5 investor’s spouse and unmarried children under 21 may be eligible as derivative beneficiaries, subject to USCIS requirements and individual circumstances.
Form I-956 relates to USCIS approval of a regional center to participate in the EB-5 Regional Center Program. Form I-956F is the project filing for a specific offering under the regional center program.
For the Villa Roma EB-5 Project, the project’s Form I-956F was filed on February 3, 2026. These forms are part of the compliance framework for EB-5 regional center projects; investors should review the offering documents and consult counsel regarding current filing status and how it relates to their filing strategy.
Form I-956 and I-956F Status:
What this means generally: I-956 relates to the regional center’s approval; I-956F relates to the specific project/offering submitted under that regional center.
Investor next-step timing: Based on current USCIS procedures described, investors may be able to file Form I-526E as early as 02.14.2026, subject to eligibility, subscription acceptance, and immigration counsel’s advice.
Important caveat: Any timing/processing references are estimates and may change based on USCIS policy, workload, and whether priority processing is available.
Eligibility to file Form I-526E depends on USCIS rules and procedures, including project filing posture and required documentation. For Villa Roma, based on current procedures described in the project materials, investors may file Form I-526E as early as February 14, 2026, subject to investor eligibility, acceptance of the subscription, and immigration counsel’s advice. Any references to timing or processing are estimates and are subject to change based on USCIS policy and processing practices.
In many EB-5 offerings, the investor’s capital contribution is deposited into an account designated for the offering and is released and deployed into the project when specified release conditions are satisfied, as described in the offering documents. EB-5 rules generally require that capital be invested and at risk to qualify.
For the Villa Roma EB-5 Project, investor capital contributions are held in a dedicated account subject to oversight by JTC USA Holdings Inc. (JTC), an independent and unaffiliated fund administrator, which is expected to monitor, track, and verify the movement of funds in accordance with applicable EB-5 requirements, as described in the offering documents.
For the Villa Roma EB-5 offering, the administrative fee is $80,000 per unit (one-time). The administrative fee is non-refundable, subject to and as further described in the definitive offering documents.
Investors evaluating investment in the Villa Roma EB-5 Project focus on a combination of immigration-related and project-related factors, subject to the terms of the offering documents and the risks described therein. Key considerations include:
(i) Rural TEA EB-5 status, which supports the $800,000 EB-5 minimum investment amount under current law (subject to change) and may be eligible for priority processing where available as determined by USCIS;
(ii) a regional center EB-5 project structure: EB5 United Northeast Regional Center, LLC* serves as the regional center affiliated with this offering;
(iii) a hospitality redevelopment of an existing operating resort—the 434-acre Villa Roma Resort & Conference Center in the Catskills / Upstate New York—with a targeted $52.1 million Property Improvement Plan (PIP) designed to reposition the property as a modern, all-season destination;
(iv) job creation planning supported by the project’s economic impact analysis, which estimates approximately 777 total jobs (approximately 12.14 jobs per investor based on 64 investors), reflecting an estimated job cushion above the minimum EB-5 requirement;
(v) third-party fund administration oversight by JTC USA Holdings Inc. (JTC) to monitor, track, and verify the movement of funds in accordance with applicable EB-5 requirements, as described in the offering documents; and
(vi) a targeted investor hold period of approximately five (5) years, with the potential for up to one (1) additional year, and potential exit sources that may include operating cash flow, refinancing, and/or sale, as further described in the offering documents.
No investment return, return of capital, job-creation outcome, immigration outcome, or processing timeframe is guaranteed, and prospective investors should review the PPM and consult their own EB-5 immigration counsel and other advisors.