As of September 16, 2025, the Department of State (DOS) has reached the annual limit on EB-5 visas from the unreserved category for fiscal year 2025. The DOS statement indicated that the annual limit included carryover of unused EB-5 reserved visas (Rural, High Unemployment Area, and Infrastructure) from Fiscal Year 2023. As a result, embassies and consulates may not issue any further unreserved visas for the rest of the fiscal year, which ends September 30^th, 2025.

EB-5 Visa Category Overview:

Each year, the Immigration and Nationality Act (INA) caps the number of EB-5 visas. Specifically, INA 203(b)(5) allocates 7.1% of the worldwide employment-based visa limit (150,000 in FY25) to EB-5 visas. Of these 10,653 available EB-5 visas, the INA designates 68% (~7,242) for unreserved categories, and 32% (~3,408) for reserved categories including 20% for rural, 10% for High Unemployment Areas, and 2% for infrastructure.

The unreserved category is the largest pool of applicants and includes both the pre-Reform and Integrity Act (RIA) I-526 petitioners and the post-RIA petitioners who are not in a reserved category. According to Lucid’s analysis, there are an estimated 39,238  unreserved visas in the backlog as of January 2025. While the final number of visas issued in FY25 is still unknown, it’s likely that the annual limit in FY25 took a healthy swipe at unreserved backlog. For reference, the DOS issued 14,501 unreserved visas in FY24, when the annual limit was capped in August 2024.

DOS issuing a larger number of unreserved visas is good news because it takes a bite out of the pre-RIA backlog. Since USCIS was slow to adjudicate reserved visas in FY22 and FY23, these became available to the large unreserved pool. In addition, reaching the unreserved cap also prevents potential EB-5 visas being lost to other employment-based categories.

Explaining the carryover in reserved visas

The INA explains that any unused reserve category visas will carry over to the immediate succeeding fiscal year. If they remain unused in that subsequent carryover year, the reserved visas become available to the unreserved category.

Unused reserve visas from 2023 added to the number of unreserved visas issued in FY25. This also occurred last year, when the unused reserve visas from 2022 were added to the  FY24 unreserved annual limit.

Looking forward to FY26, of the ~3,653 reserved visas available in FY24, only 423 were issued. Because the recent DOS statement on the unreserved annual limit did not mention the reserved limit, we can assume that the FY25 reserved caps have not been reached either. According to the IIUSA data dashboard, DOS only issued 568 reserved visas as of May 2025 (7 months into the fiscal year). This equates to an average reserved visa issuance of ~81 per month. Therefore, DOS is on pace to issue ~974 reserved visas in FY25 (baring an unforeseen uptick in reserved visa issuance to close out the year). Assuming DOS taps the reserved carryover from FY24 (3,653) before dipping into the FY25 set-aside (3,409), there should still be ~2,680[1] carryover reserved visas from FY24 reallocated to the unreserved category in FY26.

Reserved Visa Concerns

While the delay in adjudicating I-526Es certainly benefits investors in unreserved categories, significant concerns remain for those petitioners in rural, high unemployment areas, and infrastructure projects. Since the passage of RIA in March 2022, USCIS has never reached the annual set aside cap for the reserved visas and the vast majority continue to rollover into the unreserved category.

However, CMB is optimistic that this could change as USCIS nears the completion of the remaining pre-RIA I-526s and diverts all their adjudication efforts to I-526Es with priority on the reserved categories. If this occurs, it is possible that the unused reserved visas from FY25 will remain in their intended place by rolling over and boosting FY26s reserved capacity.

IIUSA filed a lawsuit in 2024, seeking an injunction to prevent the rollover of reserved visas into the unreserved category, to help protect EB-5 investors in reserved categories Had USCIS properly implemented RIA in a timely manner, the reserved visas in FY23 and FY24 would have been used as intended. While the injunction was ultimately not successful, IIUSA heard the concerns of those investors and attempted to take action on their behalf. Our hope is that the adjudication developments in the coming year, as discussed above, will finally enable visa issuance up to the true set-aside cap for reserved visas.

Conclusion

DOS reaching the annual limit on unreserved EB-5 visas for fiscal year 2025 is beneficial to pre-RIA investors due to the reduction in their backlog. Concerns still exist for investors in reserved categories as their set-aside visas continue to rollover into the unreserved queue. USCIS’s goal for FY26 should be to prioritize reserved categories in the coming fiscal year. They have never been in a better position to do so, as the pre-RIA backlog of un-adjudicated cases dwindles. A renewed prioritization by USCIS would hopefully bring sufficient quantities of reserved petitioners to DOS for processing to finally reach the reserved EB-5 visa cap next fiscal year.

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[1] (3,653 FY24 reserved rollover minus estimated 974 FY25 reserved issuance)

I-526E petition for conditional green card adjudicated 7 months after EB-5 project approved by USCIS

CMB Regional Centers (CMB), one of the most experienced regional center operators in the EB-5 industry, today announced the first approval of a petition for conditional permanent residency in the United States (I-526E petition) by United States Citizenship and Immigration Services (USCIS) for an investor in its Group 84 – Hillwood Daytona BTS project.

The I-526E petition is filed by an individual seeking a green card through the EB-5 Immigrant Investor Program, with approval signifying the eligibility of the investor and their immediate family members for conditional permanent residency in the United States.

“This first approval of an I-526E petition is a significant milestone for our business and, most importantly, for the investors and families who have entrusted us with a critical step in their immigration journey,” said Noreen Hogan, President at CMB. “We are thrilled for this investor and look forward to additional USCIS approvals in the near future.”

The CMB Group 84 EB-5 partnership lent $79.2 million to a Hillwood Development Company-affiliated entity for the construction of a Daytona Beach (Florida) build-to-suit logistics facility for a Fortune 500 tenant. CMB and Hillwood Development Company (Hillwood) have cultivated one of the most successful EB-5 lender-borrower relationships in the EB-5 space, with over 40 EB-5 projects and more than $500 million in EB-5 loan repayment to investors.

CMB and Hillwood have generated significant traction over the past year with regard to record-setting speed for approvals of their EB-5 collaborations, far outpacing the USCIS-reported 13 months (for 80% of cases) for I-956F petitions:

• CMB Group 89 – Hillwood City Creek (I-956F approved in 39 days)
• CMB Group 86 – Gable House Apartments (I-956F approved in under five months)
• CMB Group 90 – Hillwood Treeline (I-956F approved in just over six months)
• CMB Group 93 – Coachella Valley (I-956F approved in three months)
• CMB Group 98 – Hillwood Commerce 71 (I-956F approved in under three months)

About CMB Regional Centers

CMB has been a leader in the EB-5 industry for over 28 years, with its first regional center designation approved in 1997. Since then, CMB has assisted over 6,600 investor families, from over 100 countries, in their pursuit of immigrating to the United States. CMB currently maintains a 100% project approval rate on all partnerships that have undergone USCIS adjudication. To date, CMB has repaid over $1.4 billion USD to investors.

To learn more, contact CMB directly at [email protected].

Hogan, President of CMB Regional Centers, has officially been elected for a third term 

CMB Regional Centers (CMB) today announced that Noreen Hogan (President, CMB) has been reelected as Vice President of Invest in the USA (IIUSA), the leading industry trade group for the EB-5 Immigrant-Investor Program.  

“I am honored and humbled to serve as Vice President of IIUSA,” said Hogan “I look forward to continuing our work to advance, enable and improve the EB-5 Regional Center program.” 

IIUSA, the investment-based immigration industry’s leading advocacy group, brings together more than 200 EB-5 Regional Center members around a shared purpose: stimulating the United States economy by cultivating foreign investments that create American jobs. IIUSA’s work has been integral in generating $32 billion in investment, creating hundreds of thousands of new jobs, and revitalizing communities across the country. 

“EB-5 is at an inflection point, and IIUSA’s mission has never been more vital,” said Hogan “As leaders from across the Regional Center industry, it is our responsibility to ensure the EB-5 program remains a sustainable source of capital for job-creating projects and a viable pathway to permanent residency for investors.” 

A pioneer in the Regional Center industry, CMB’s track record demonstrates both the promise and the potential of EB-5 to harness the power of foreign investment to reinvigorate American communities. An acronym for “California Military Base”, CMB was founded in 1997 with a focus on leveraging EB-5 to revitalize former military bases in California. CMB’s first EB-5 projects laid the groundwork for McClellan Air Force Base and Norton Air Force Base to transform into McClellan Park (the largest master-planned community in California) and the San Bernardino International Airport, respectively. 

About CMB Regional Centers 

CMB Regional Centers (CMB) has been a leader in the EB-5 industry for over 28 years, with its first regional center designation approved in 1997. Since then, CMB has assisted over 6,600 investor families, from over 100 countries, in their pursuit of immigrating to the United States. CMB currently maintains a 100% project approval rate on partnerships that have undergone United States Citizenship and Immigration Services (USCIS) adjudication. To date, CMB has repaid over $1.4 billion USD to investors. 

To learn more, contact CMB directly at [email protected].  

CMB Regional Centers Logistics Project Awarded I-956F Approval by USCIS

Investors will be eligible for immediate adjudication of conditional green card petitions 

DALLAS, May 1, 2025 – CMB Regional Centers (CMB), one of the most experienced regional center operators in the EB-5 industry, today announced that its Group 98 – Hillwood Commerce 71 project has received Form I-956F approval less than three months after filing with United States Citizenship and Immigration Services (USCIS). 

I-956F approval indicates that USCIS has confirmed the project meets all necessary EB-5 Immigrant-Investor Program requirements, making Group 98 investors eligible for immediate adjudication of their conditional green card (I-526E) petitions by USCIS.  

“Securing I-956F approval is a critical milestone in the EB-5 process, and the continued speedy approvals of our projects in high-unemployment areas highlight the underwriting rigor we apply to our investment opportunities,” said Noreen Hogan, President at CMB “With this approval, our Group 98 investors are that much closer to achieving their goal of permanent residency in the United States.” 

Located in the growing business hub of Columbus (capital city of Ohio), Hillwood Commerce 71 will include the development and construction of two Class-A industrial logistics facilities, a wastewater treatment facility, and associated infrastructure improvements required to complete the redevelopment of the site. EB-5 funds will be utilized in all aspects of the development and construction activities of the project. 

The approval continues the trend of record-setting USCIS approval timeframes for CMB EB-5 projects, far outpacing the USCIS-reported 14 months processing time (for 80% of cases) for I-956F petitions: 

• CMB Group 89 – Hillwood City Creek (I-956F approved in 39 days) 
• CMB Group 86 – Gable House Apartments (I-956F approved in under five months)
• CMB Group 90 – Hillwood Treeline (I-956F approved in just over six months) 
• CMB Group 93 – Coachella Valley (I-956F approved in three months) 

CMB and Hillwood Development Company (Hillwood) have cultivated one of the most successful EB-5 lender-borrower relationships in the EB-5 space, with over 40 EB-5 projects and more than $500 million in EB-5 loan repayment to investors. Hillwood is among the largest and most successful developers in the United States and has developed projects for over 90 companies listed in either the Fortune 500 or Global 500. 

Group 98 is the thirteenth CMB EB-5 partnership to achieve an I-956F approval under the EB-5 Reform and Integrity Act of 2022 (RIA).  

Previously approved partnerships include: 

• CMB Group 78 – Hillwood California BTS 
• CMB Group 81 – Inland Empire Industrial 
• CMB Group 82 – Hazleton Logistics Park
• CMB Group 83 – Hillwood SOMI Hayward
• CMB Group 84 – Hillwood Daytona 
• CMB Group 86 – Gable House Apartments
• CMB Group 87 – Kona Bay Hampton Hotel
• CMB Group 88 – Hillwood Detroit Fairgrounds 
• CMB Group 89 – Hillwood City Creek  
• CMB Group 90 – Hillwood Treeline 
• CMB Group 91 – Hillwood DTW Air Cargo
• CMB Group 93 – Coachella Valley 

About CMB Regional Centers 

CMB Regional Centers (CMB) has been a leader in the EB-5 industry for over 28 years, with its first regional center designation approved in 1997. Since then, CMB has assisted over 6,600 investor families, from over 100 countries, in their pursuit of immigrating to the United States. CMB currently maintains a 100% project approval rate on partnerships that have undergone United States Citizenship and Immigration Services (USCIS) adjudication. To date, CMB has repaid over $1.4 billion USD to investors. 

To learn more about CMB, the EB-5 program, and Group 98 please visit the CMB website or contact us directly at [email protected].