The processing fee is described on the official page as nonrefundable. The gift is paid only after successful vetting and on instruction, and once made it is a gift to the United States and is not returned.
Nothing paid under the framework comes back
The Torbay couple should treat every amount under the framework as spent when paid. As read September 7, 2026, the US$15,000 processing fee per person is paid first and is nonrefundable, so a couple whose vetting fails, or who withdraw, do not recover it. The US$1,000,000 gift per person is requested only after successful vetting and is made to the United States; it is not an investment, produces no return and is not refundable in any circumstance the page describes.
That is the essential difference from EB-5, where the capital is at risk but remains the investor's investment, and from E-2, where the money buys a business the investor owns. The official page warns that small additional Department of State fees may apply depending on the applicant; do not add a separate USCIS petition fee unless current official instructions require one. The couple's financial adviser should record the framework as an outflow with no asset, and should say so plainly if that changes the decision.
Re-verify the terms before each payment.