Without an escrow account, investors wire their capital contribution directly to the designated NCE EB5 account and they separately wire their administrative fee to a different account, either held by the NCE or the NCE manager or general partner. This avoids commingling the investment amount and administrative fees in the designated NCE EB-5 account.
Even without escrow, the same investor protection rules apply:
Investor funds must arrive in a designated, segregated NCE account.
PRXY must approve of each release of funds from the designated, segregated NCE account to the JCE.
Typically, proof on an investor’s I-526E filing, is required to release the investor(s) funds from the designated, segregated NCE account to the JCE account ensuring compliance and trust.