SMARTER, SAFER & STREAMLINED EB-5 DEPOSITS

ADM and Accelerated Impact have partnered to address the banking, liquidity, and capital-protection challenges unique to the EB-5 market through a purpose-built deposit and escrow solution.

Accelerated Impact contributes deep EB-5 expertise shaped by decades of experience navigating evolving bank policies and immigration timelines, while ADM brings over fifteen years of experience and a trusted network of U.S. financial institutions to manage complex deposit and escrow structures. Together, they deliver a more flexible, aligned solution across the EB-5 investment lifecycle.

ADM serves as the independent escrow agent for EB-5 investor funds, establishing and administering escrow accounts, safeguarding capital, and managing disbursements in accordance with offering documents. Funds are held at FDIC/NCUA-insured U.S. financial institutions within ADM’s network.

Since ADM is independent and not tied to any single balance sheet, investor funds can be allocated across multiple institutions to enhance safety, resilience, and optionality throughout the EB-5 investment lifecycle.

Led by founder Reid Thomas, Accelerated Impact brings decades of experience designing EB-5–specific banking, escrow, and compliance solutions. This specialized expertise is critical given the unique characteristics of EB-5 capital, heightened compliance requirements, and banking risk.

Accelerated Impact ensures program continuity, reduces future onboarding friction, and supports the evolution of a best-in-class EB-5 deposit solution, delivering optimized yields and enhanced security without disrupting existing escrow or banking structures.

ADM is not a bank. ADM is a regulated escrow and deposit administration firm and is a registered Municipal Advisor with the Municipal Securities Rulemaking Board (MSRB), which operates under the oversight of the U.S. Securities and Exchange Commission (SEC).

Investor funds are placed at FDIC/NCUA-insured U.S. financial institutions, where they remain subject to applicable regulations and insurance limits, while ADM administers the escrow structure in accordance with governing agreement.

Yes. The structure is designed to align with the EB-5 Reform and Integrity Act of 2022 (RIA), as codified in INA §203(b)(5), and with established EB-5 best practices.

Specifically, the solution supports RIA requirements that EB-5 investor funds be held in segregated accounts, maintained at U.S. financial institutions (subject to U.S. banking laws and regulations), and subject to independent third-party oversight prior to lawful release. Escrow mechanics and role separation are structured to align with offering documents and USCIS expectations, and to remain fully compatible with any qualified fund administration solution the NCE elects to implement, consistent with the RIA’s enhanced standards for transparency, recordkeeping, and investor protection.

This structure enhances capital protection by combining independent escrow administration with access to a network of FDIC/NCUA-insured U.S. financial institutions, rather than relying on a single bank-owned escrow.

Investor funds can be segregated across multiple institutions to maximize FDIC/NCUA insurance coverage, reduce single-bank exposure, and allow deposits to migrate within the network if needed, adding protection against liquidity disruptions or operational delays.

Key protections include:

• Access to full FDIC/NCUA insurance through multi-bank allocation
• Reduced single-bank credit and liquidity risk
• Independent escrow administration
• Clear separation of custody, administration, and advisory or technology services

This design preserves capital, supports continuity, and strengthens resilience throughout the EB-5 investment lifecycle.

Yes. Clients may direct deposits to specific institutions within ADM’s network of participating U.S. financial institutions, subject to availability, bank acceptance, and applicable escrow and deposit agreements.

Yes. Existing deposit balances can be transitioned into this solution, subject to the structure of the current accounts, applicable agreements, and any regulatory or operational considerations. Clients are encouraged to contact us to arrange a call to discuss the most appropriate transition approach.