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If we're not using escrow, does that change how funds move?

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.