Simply Shenandoah: A Compelling Rural EB-5 Project

The Simply Shenandoah EB-5 project is an ongoing luxury wellness resort. It is located in a prime location in Shenandoah County, Virginia, just 90 minutes from Washington, D.C.

The project is planned to include 120 total guest rooms, a spa & aquatics facility, a yoga studio & fitness center, a meeting & event space, food & beverage facilities, and other amenities across approximately 548 acres in Shenandoah County, Virginia.

In this article, we discuss why Simply Shenandoah’s features make it one of the most compelling rural EB-5 projects available today.

Overview of the Simply Shenandoah EB-5 Loan Project

Secured Loan Structure: The Simply Shenandoah EB-5 investment is structured as a secured loan. The loan is secured by a first-priority deed of trust on 548 acres of property within the project, as well as the Simply Shenandoah Resort & Spa project itself, and security interests in the assets of the project company, Carson Hospitality LLC, and its subsidiary.

Four-Year Loan Term: Simply Shenandoah features a shorter-than-average four-year loan term. This time frame aligns well with the USCIS sustainment period requirements.

Rural TEA Designation: The project is in a rural targeted employment area (TEA). By investing in a rural TEA project, EB-5 investors are able to invest at the lower minimum amount of $800,000 instead of the non-TEA amount of $1,050,000. Investors also receive priority I-526E petition processing and gain access to rural set-aside visas, which make up 20% of all EB-5 visas.

Prime Location: The project is located in Shenandoah County, Virginia, 90 minutes from Washington, D.C.

Significant Job Creation: Construction is underway, with more than 100 qualifying EB-5 jobs already created. Upon completion, the project is expected to create 2,047 eligible EB-5 jobs—more than twice the number of jobs required for all EB-5 investors in the project to qualify for their Green Cards.

Experienced Developer: The project is led by Ron “Omani” Carson, chairman and founder of Carson Group (a nationally recognized wealth management firm with $21B in assets), and Mike Marburg, CEO and founder of Simply Shenandoah Resort and Wellmore Partners.

Independent EB-5 Oversight: EB5AN controls the project’s regional center sponsor and the general partner of the EB-5 fund. EB5AN is 100% independent from the developer. Independent EB-5 project oversight helps prevent conflicts of interest between the developer and those involved in the EB-5 investment, which in turn reduces the risk for EB-5 investors.

Construction Completion Guaranty: The developer has provided a construction completion guaranty to ensure the punctual and substantial completion of the project.

I-526E Approval Refund Guaranty: If an EB-5 investor’s Form I-526E petition is denied by USCIS, the developer has agreed to refund the $800,000 investment amount within a defined period, subject to the terms of the guaranty.

Job Creation Guaranty: The developer has guaranteed that 100% of EB-5 funds will be used for qualified project costs and that the project will create at least 10 jobs per EB-5 investor.

Third-Party Fund Administration: Proxy Fund Services (PRXY) will serve as the project’s third-party fund administrator. Third-party fund administration is important for EB-5 compliance and adds a layer of security and transparency for EB-5 investors. PRXY’s proprietary platform tracks and records all EB-5 draws and project expenditures throughout the project life cycle.

With these features, Simply Shenandoah is a best-in-class rural EB-5 project that stands out in the market today. While Simply Shenandoah offers exceptional features, EB-5 investors must still consider the inherent risks of the EB-5 program itself. The next section explains how to evaluate and manage these general risks.

Understanding Financial Risk for EB-5 Investors

EB-5 investors’ funds must be at risk for the investment to qualify for permanent residence. Under EB-5 program rules, for an investment to be considered “at risk,” the full $800,000 must be subject to gain or loss. This at-risk requirement means that no EB-5 investment can be entirely risk free.

While the EB-5 program does require some risk, the level of risk EB-5 investors face does not need to be high. Unfortunately, many EB-5 projects available today are riskier than they have to be. Even worse, many EB-5 investors do not even know how risky these projects are.

Most EB-5 projects lack basic financial protections, increasing the risk of loss for EB-5 investors. To make informed investment choices, investors must understand the risks associated with an EB-5 investment and with the project they choose. When EB-5 investors invest in projects with more financial risk, they are more likely to lose their funds and have their immigrant petitions denied by USCIS.

To avoid riskier projects, EB-5 investors must do their own research, including by evaluating the track record of both the developer and the regional center sponsor. Even though the EB-5 program requires projects to transparently disclose risks, most EB-5 regional centers and projects do not see transparency as a fundamental EB-5 investor right. As a result, many in the industry share the least information possible—and only when required to do so.

Each EB-5 project has its own risk profile, and EB-5 investors should conduct careful research before they invest and weigh the risks before making decisions. By understanding the risks and asking good questions, EB-5 investors can make informed decisions in line with their financial and immigration goals.

Understanding the EB-5 Rural TEA Designation

What Is a Rural TEA?

A TEA is an area that either is rural or has a high unemployment rate. A rural TEA is an area that is outside of a metropolitan statistical area and outside of a city with a population of 20,000 or more.

Benefits of Choosing a Project in a Rural TEA

EB-5 projects in rural TEAs offer EB-5 investors several key benefits.

Reduced Investment Amount: The standard amount for an EB-5 investment is $1,050,000. Investments in TEA projects, however, qualify at a lower investment threshold of $800,000.

Access to Set-Aside EB-5 Visas: Investing in a rural TEA project qualifies EB-5 investors for set-aside EB-5 visas. Under the EB-5 Reform and Integrity Act of 2022 (RIA), 32% of all annual EB-5 visas are reserved. Of these, 20% are reserved for rural TEA investors. Set-aside visas are not currently affected by backlogs (known as visa retrogression), which is a key issue for investors from countries with high demand for EB-5 visas like China and India. Without visa backlogs and with priority processing (discussed next), rural EB-5 investors often experience shorter wait times and can immigrate to the United States more quickly compared to those seeking unreserved visas.

Priority Processing for Form I-526E: EB-5 investors in rural TEA projects in particular qualify for priority processing of Form I-526E. This means USCIS processes the I-526E petitions of rural EB-5 investors ahead of others. As a result, many rural EB-5 investors have their petitions processed in months rather than years.

Evaluating Rural EB-5 Projects

Potential EB-5 investors should thoroughly research projects before they invest. Even basic due diligence can help investors avoid risky projects. Research is one of the most important ways for EB-5 investors to improve the likelihood that they will be repaid and obtain their Green Cards.

One key item to look for is how much money the developer has invested in the project. A developer that has invested nothing has nothing to lose and is not as motivated to succeed. The less developer equity in a project, the more risk EB-5 investors face.

Some projects have developer equity but plan to use EB-5 funds to replace this equity. When this is the case, the developer is passing its risk on to the EB-5 investors. Projects that allow developer equity to be replaced with EB-5 funds should generally be avoided.

As part of their research, EB-5 investors should also look at the regional center sponsors. Projects tied to trusted regional centers are much less risky. Such regional centers are led by professionals who have extensive experience, strong track records, and a deep knowledge of the EB-5 program’s rules. And importantly, regional centers should be independent from developers to avoid conflicts of interest.

Notably, the RIA added new rules for reporting and compliance. Because USCIS has not yet provided guidance on all of these changes, EB-5 investors should look for projects sponsored by regional centers that have experience navigating changes to the EB-5 program. EB-5 investors face higher risk when they invest in projects sponsored by inexperienced or poorly managed regional centers, as these sponsors may not be able to respond quickly to any changes in the program.

Evaluating the Simply Shenandoah EB-5 Project Is Easy

EB5AN makes it easy for EB-5 investors to research the Simply Shenandoah EB-5 project. We give potential investors full access to the project’s financial documents. And we encourage investors to visit the site to observe construction progress and operation.

Our regional center team is also happy to answer any questions a prospective EB-5 investor may have.

Simply Shenandoah Is a Best-in-Class Rural EB-5 Project

Simply Shenandoah is a compelling rural EB-5 project. It has a host of best-in-class features that help reduce the risks faced by EB-5 investors. Construction has already begun, and more than 100 qualifying EB-5 jobs have been created, meaning investors have less to worry about when it comes to creating the required number of jobs.

With a short target investment period and rural TEA benefits, Simply Shenandoah distinguishes itself as one of the most attractive low-risk EB-5 opportunities available today.

Secured Loan Structure and Collateral

The Simply Shenandoah EB-5 investment is structured as a secured loan. The loan is secured by a first-priority deed of trust and security interests in the assets of the project company, Carson Hospitality LLC, and its subsidiary.

Four-Year Loan Term

The EB-5 loan has an initial term of four years, with a single one-year extension option available at the borrower’s election. This structure is shorter than many rural EB-5 loan terms, which often range from five to seven years and include multiple extensions.

The streamlined maturity profile is designed to align construction, stabilization, and exit within a defined time frame while maintaining limited flexibility for execution.

Rural TEA Designation

Simply Shenandoah is located in a rural TEA. This designation allows EB-5 investors to qualify at the lower $800,000 investment level instead of the standard $1,050,000.

As discussed above, rural TEA projects also benefit from priority I-526E petition processing and access to the 20% rural set-aside visa category.

Significant EB-5 Job Creation

A key EB-5 program requirement is that each EB-5 investment must create at least 10 qualifying jobs for U.S. workers. Because Simply Shenandoah is a regional center project, it can count both direct and indirect jobs created through spending on construction.

To support up to 100 EB-5 investors, the project must create at least 1,000 jobs. As previously mentioned, the project has already created more than 100 qualifying EB-5 jobs from development activity. Upon completion, the project is expected to create 2,047 EB-5–eligible jobs, more than twice the number of jobs required for all EB-5 investors in the project to qualify for their Green Cards.

Experienced Developer

The project is led by Ron “Omani” Carson, chairman and founder of Carson Group (a nationally recognized wealth management firm with $21B in assets), and Mike Marburg, CEO and founder of Simply Shenandoah Resort and Wellmore Partners.

An Independent Regional Center With a Proven Record

EB5AN is the regional center sponsor for Simply Shenandoah. Because EB5AN is 100% independent from the developer, it can prioritize the interests of its EB-5 investors without conflicts of interest. EB5AN has facilitated over $1.0 billion in EB-5 investment, supporting projects with total development costs exceeding $7 billion.

Over the past decade, EB5AN has helped more than 2,700 immigrant families from over 70 countries and regions relocate to the United States through its low-risk, high-quality investment opportunities. All adjudicated regional center–sponsored projects offered by EB5AN have received USCIS approval.

Construction Completion Guaranty

The developer has provided a construction completion guaranty to ensure the punctual and substantial completion of the project. This guaranty helps mitigate the risk of construction delays or non-completion and supports EB-5 job creation.

I-526E Approval Refund Guaranty

If an EB-5 investor’s I-526E petition is denied by USCIS, the developer has agreed to refund the investor’s $800,000 investment amount within a defined period, subject to the terms of the guaranty.

Job Creation Guaranty

The developer has guaranteed that 100% of EB-5 funds will be used for qualified project costs and that the project will create at least 10 jobs per EB-5 investor. This assurance strengthens job creation reliability and reduces the risk of petition denial due to any job shortfalls.

Simply Shenandoah: A Unique, Low-Risk Rural EB-5 Project

While no EB-5 investment can be completely risk free, Simply Shenandoah gets as close as possible. This project has been structured with investor protections and independent oversight at its core.

Simply Shenandoah offers a compelling set of safeguards: loan security; job creation, I-526E approval refund, and completion guarantees; rural TEA benefits; and experienced project management. These features are designed to reduce risk and increase the likelihood of both immigration and financial success.

For more information on the Simply Shenandoah rural EB-5 project or to explore additional EB-5 investment opportunities, please schedule a one-on-one call with EB5AN.