By David A. Sudeck —
This post is the second in a series presenting my current thoughts on the viability and timeliness of EB-5 financing for new hospitality construction. Each installment is published as a standalone post, allowing readers to engage with individual topics as they are released.
EB‑5 loans are especially synergistic with projects that are located in rural areas, as defined under the 2022 Reform and Integrity Act (“RIA”), and that synergy is intentional.
Importantly, “rural” does not necessarily mean isolated or hard to access. A rural Targeted Employment Area (“TEA”) is defined as a location outside a metropolitan statistical area (“MSA”) and with a population of 20,000 or less. This includes many well-known destinations, including ski towns, national park areas, and multiple Hawaiian Islands. Developers can easily confirm eligibility by entering a project address into the U.S. Citizenship and Immigration Services (“USCIS”) TEA designation map, which should be an early step in evaluating any capital stack.
Under the RIA, 20 percent of all EB‑5 visas are set aside (i.e., reserved) for rural projects, with priority processing attached to this designation. This built-in preference is not an incidental byproduct of the 2022 reforms; it reflects a deliberate policy choice to channel capital toward rural hospitality and other rural development, and it has translated into a meaningful practical advantage for developers who intend to develop qualified sites.
Due to the expedited processing by UCSCIS for rural projects, approvals for rural filings are currently being issued in as little as four to eight months. By comparison, I‑956F applications for non-rural projects, which do not receive the same statutory priority, have generally been taking roughly 18 to 36 months to process, though current figures should be confirmed against USCIS’s published processing times (as this can vary based on service center backlogs). Immigrant investor applications (I‑526E) processing times and visa availability timelines also currently vary significantly between rural and non-rural applications, with rural projects currently enjoying expedited processing times and availability. Developers recognized this advantage quickly, and by mid-2025, rural filings made up more than half of all new EB‑5 petitions. The speed differential is significant enough that it has reshaped how sponsors think about site selection and capital stack sequencing from the earliest stages of a deal.
As EB-5 usage expands and rural filings continue to climb, processing queues will inevitably lengthen. The current time frame reflects early adoption dynamics rather than a permanent structural benefit. Developers evaluating hospitality projects in qualifying locations should therefore treat the present processing environment as a window of opportunity rather than a fixed feature of the program, and act accordingly while the fast lane remains open.
Feel free to reach out with any questions or thoughts on this topic, and please meet with us at the upcoming 2027 EB‑5 & Global Immigration Expo in Newport Beach, California, January 20–22, 2027. Click here to register.
David is a partner and co-chair of Blank Rome’s Hospitality practice, where he focuses on the hospitality industry, with particular emphasis on the financing structures that support hotel development and acquisition. His practice draws on extensive experience guiding developers, lenders, and investors through complex capital stacks in the hospitality sector. Learn more about his practice here.
