EB-5 Business Plan Cost: Matter of Ho-Compliant Plans

USCIS adjudicators rely on the business plan to evaluate job creation feasibility. Matter of Ho (1998) set the baseline: a business plan must be comprehensive, credible, and verifiable. For Direct EB-5, the investor commissions their own. For Regional Center, the project's plan covers it.

• •Direct EB-5 only: $7K-$15K typical for a Matter of Ho-compliant business plan from a specialised EB-5 plan writer (Wright Johnson, MasterPlans, EB5 Business Plans, etc.).
• •Regional Center investors: don't commission a separate plan. The project's existing business plan + economic study (filed with the I-956F) covers job creation evidence.
• •Matter of Ho requirements: market analysis, financial projections, organizational chart, hiring schedule with W-2 employee count, marketing strategy, competition assessment.
• •Job creation linkage: the plan must show how the $800K-$1.05M creates 10 full-time qualifying jobs (W-2 for Direct, indirect/induced for Regional Center via economic model).
• •Why specialised writers: generalist business plan writers don't know Matter of Ho criteria. USCIS rejects non-compliant plans even if the underlying business is sound.
• •Update cycle: for Direct EB-5 investors filing I-829 years later, the plan often needs a refresh to show actual vs projected job creation.

For 95%+ of EB-5 investors filing through a Regional Center, the business plan is the project's responsibility. Direct EB-5 investors should budget separately for a specialised writer.