Yes, as a direct investment, but the ten jobs must be full-time employees on the new enterprise's own payroll rather than jobs estimated by an economic model. The capital, source-of-funds, engagement and conditional-residence rules are the same.
Direct investment trades a job model for a payroll
The EB-5 program allows an investor to establish a new commercial enterprise directly and to count the jobs it creates itself. The trade-off is in the job count. A regional-center investor relies on an approved economic methodology that credits indirect and induced jobs; a direct investor must show ten actual full-time positions, at least thirty-five hours a week, held by U.S.
citizens, permanent residents or other authorized workers, excluding the investor and their family. Seasonal landscaping labour, independent-contractor plough operators and part-time staff are the natural workforce of the trade and none of them count as written. The Paradise couple's plan therefore needs a services mix, such as commercial grounds maintenance contracts paired with winter snow and interior plant-care work, that supports ten year-round positions, and it needs to show that within the conditional period.
The engagement requirement is easily met by owners who will manage the operation. The capital threshold depends on whether the location qualifies as a targeted employment area under the definitions in force at filing.