EB-5 regulations do not require an equity investment, but in order to fund an EB-5 project using a loan model, certain considerations apply. According to 8 CFR § 204.6(e), a loan to a new commercial entity (NCE) is not a qualifying investment. For project’s sponsored by regional centers, however, an NCE can make a loan to a project’s job creating entity (JCE) since indirect jobs are counted toward job creation. For projects using the direct investment model, the NCE could make a loan to a wholly owned subsidiary. Additionally, the source of the funds for investment can be a loan.