No. The administrative fee is paid in addition to the required investment and is not capital at risk in the enterprise. Government filing fees, including the EB-5 Integrity Fund fee, are also additional and set by the USCIS fee schedule.
Budget the fee, the capital and the government charges as three lines
Hypothetical example: a Mission physiotherapist reads a regional center's offering and assumes the total quoted includes everything. It usually includes the investment plus an administrative fee, and the fee portion does not count toward the US$1,050,000 or US$800,000 minimum, because it is not invested in the job-creating enterprise and is not at risk in the same way. On top of that sit the government charges: the investor petition filing fee, the EB-5 Integrity Fund fee established by the 2022 reform act, and later the fees for immigrant visa processing or adjustment of status and for Form I-829, each per the current USCIS fee schedule, Form G-1055.
Professional fees for the source-of-funds work are separate again. A budget that treats the offering's headline number as the whole cost will be short by a substantial margin. Hypothetical example: A small winery owner receives a project invoice that combines the capital contribution, a syndication fee and legal costs in one total.
The first review should unbundle each amount and identify what enters the new commercial enterprise as qualifying capital. The subscription agreement, escrow instructions and project budget settle the use of funds; invoices settle the separate charges. Do not describe every payment as investment simply because it is necessary to participate.
Compare the required amount with the project's location and structure, and keep enough liquidity for taxes, filing costs and contingencies without mischaracterizing those reserves as capital already at risk.