Brevet Capital Taps Joan Hull to Lead EB-5 Capital Strategy

Brevet Capital Management, a Miami-based private equity firm specializing in infrastructure and lower-middle-market investments, has appointed Joan Hull, CFA, as Director of EB-5 Capital Development—a senior role created to formalize the firm's approach to a financing mechanism that's quietly become a material component of real estate and infrastructure deal structures.

The hire signals something broader: EB-5 financing, once viewed as niche and administratively burdensome, is increasingly being integrated into institutional capital strategies. Hull's mandate centers on structuring EB-5 capital for Brevet's existing portfolio companies and evaluating new investment opportunities where immigration investor funds can provide cost-efficient, patient capital.

For context, the EB-5 Immigrant Investor Program allows foreign nationals to obtain U.S. green cards by investing a minimum of $800,000 in projects that create or preserve at least ten jobs per investor. What makes it attractive from a capital formation standpoint isn't just the size of the investment pool—it's the cost. EB-5 capital typically comes at significantly lower rates than traditional debt, often in the 2-4% range, and can be structured with longer tenors and minimal amortization requirements.

Hull joins Brevet from a background that straddles finance and regulatory navigation—precisely the skill set required to operationalize EB-5 structures at scale. Her role will involve identifying projects within Brevet's portfolio that meet job creation thresholds, working with regional centers that facilitate EB-5 investments, and ensuring compliance with immigration and securities regulations. It's part capital markets function, part regulatory project management.

The EB-5 program has existed since 1990, but its utilization has swung wildly based on policy changes, processing backlogs, and geopolitical factors. The program was reauthorized and reformed in 2022 through the EB-5 Reform and Integrity Act, which introduced new investor categories, raised minimum investment amounts, and created set-asides for rural and high-unemployment areas.

Those reforms were meant to address fraud and misuse, but they also made the program more attractive to institutional players. The new structure provides clearer pathways for investors, faster processing for certain categories, and more predictable timelines—reducing some of the uncertainty that previously made sponsors wary.

From a capital deployment perspective, EB-5 financing sits in a unique part of the capital stack. It's typically structured as mezzanine debt or preferred equity—subordinate to senior lenders but senior to common equity. That positioning allows sponsors to use EB-5 capital to reduce overall cost of capital while preserving upside for equity holders. In infrastructure projects with stable, long-duration cash flows—ports, energy facilities, transportation assets—it's a natural fit.

But here's the catch: job creation requirements are strict, and the definition of what qualifies as a "new" job versus a "preserved" job can be contentious. Projects must demonstrate direct or indirect job creation through economic modeling that passes USCIS scrutiny. That means sponsors need sophisticated advisory teams and airtight documentation—exactly the kind of operational complexity that requires a dedicated executive like Hull.

Brevet Capital Management focuses on lower-middle-market infrastructure, industrial services, and real estate—sectors where capital intensity is high and traditional financing can be expensive or difficult to source. The firm has historically targeted investments in the $10 million to $100 million range, often in assets that are operationally complex or require hands-on value creation.

According to the announcement, Hull will work across Brevet's portfolio to identify opportunities where EB-5 capital can either reduce leverage costs or enable larger projects that might otherwise be capital-constrained. Think: port terminal expansions, logistics facilities in designated rural areas, affordable housing developments in qualified census tracts, or renewable energy projects with significant construction employment.

The firm hasn't disclosed specific portfolio companies that will utilize EB-5 capital, but the strategic logic is clear. If Brevet can consistently access EB-5 funding at sub-5% rates on a subordinated basis, it can afford to be more aggressive in bidding for assets or more patient in holding periods—competitive advantages in sectors where basis points matter.

The table above illustrates where EB-5 capital sits in a typical infrastructure or real estate deal. The cost advantage is significant—but only if the project can clear job creation hurdles and navigate the regulatory timeline.

Joan Hull holds the CFA designation and brings experience in both capital markets and structured finance. While Brevet's announcement doesn't detail her full employment history, the role itself implies familiarity with securities law (EB-5 investments are typically structured as securities offerings), immigration compliance, and project finance. Those aren't adjacent skill sets—they're orthogonal disciplines that rarely overlap except in EB-5 structures.

The EB-5 market has been remarkably volatile. Annual visa issuance peaked around 10,000 in the mid-2010s, driven largely by Chinese nationals. That pipeline slowed dramatically due to country-specific backlogs, pandemic-era travel restrictions, and geopolitical tensions. But the 2022 reforms and recent processing improvements have reignited interest.

Data from USCIS shows that EB-5 petition approvals are trending upward again, with a more geographically diversified applicant base—less reliance on China, more activity from India, Vietnam, South Korea, and the Middle East. That diversification matters because it reduces concentration risk for sponsors who raise EB-5 capital.

From a sponsor perspective, the appeal is straightforward: low-cost, patient capital that doesn't require the same return expectations as equity and doesn't come with the restrictive covenants or amortization schedules of traditional debt. The trade-off is operational burden—extensive documentation, ongoing job creation reporting, investor relations with individuals whose primary goal is immigration status rather than financial returns.

But that burden is becoming more manageable. A cottage industry of EB-5 advisory firms, regional centers, and specialized law firms has emerged to handle the administrative heavy lifting. What used to be bespoke and ad hoc is now more standardized—closer to a repeatable playbook than a one-off experiment.

The real question is whether institutional investors will view EB-5 capital as a core component of infrastructure and real estate finance or whether it remains a tactical tool used opportunistically. Brevet's hire suggests the former. Dedicating a senior role to EB-5 capital development isn't something you do for a one-off deal. It's a signal that the firm sees this as a competitive advantage worth building internal expertise around.

EB-5 isn't without risk—and much of it is non-financial. The program exists at the intersection of immigration policy and economic development, which means it's subject to political winds. Reauthorization battles in Congress have historically been contentious, and future reforms could alter minimum investment thresholds, job creation formulas, or regional center structures.

There's also execution risk. If a project fails to create the required jobs within the specified timeframe, investors may not receive their green cards—and sponsors may face legal liability. That's why rigorous economic modeling and conservative job creation projections are essential. Overpromising on job creation to attract investors is a path to regulatory scrutiny and investor lawsuits.

If EB-5 capital becomes more widely adopted by institutional sponsors—and Brevet's hire suggests it will—it changes the competitive dynamics of infrastructure and real estate dealmaking. Firms with the operational sophistication to access EB-5 capital can underbid competitors who rely solely on traditional debt and equity. That advantage is particularly pronounced in sectors where margins are thin and financing costs directly impact returns.

Consider a logistics facility in a rural area, which qualifies for priority EB-5 processing. A sponsor using EB-5 mezzanine debt at 3% instead of institutional mezzanine at 12% can afford to pay more for the asset or accept a lower stabilized yield while still hitting target returns. That's not a trivial edge—it's structural.

The same logic applies to affordable housing projects in Qualified Opportunity Zones or energy infrastructure in high-unemployment areas. EB-5 capital doesn't just lower the cost of capital—it can make otherwise marginal projects investable.

Brevet isn't alone. Several private equity and real estate firms have established dedicated EB-5 platforms or partnered with regional centers to access immigration investor capital. What's less common is the explicit creation of a senior capital development role—most firms handle EB-5 through external advisors or ad hoc internal teams.

That Brevet chose to bring this function in-house and attach a CFA-credentialed executive to it suggests the firm sees EB-5 not as a niche financing tool but as a repeatable component of its investment strategy. That's a bet that regulatory stability will hold, that investor demand will remain robust, and that the operational complexity can be systematized.

EB-5 compliance hinges on job creation metrics, and the math can get contentious. Direct jobs—employees hired directly by the project entity—are the easiest to count. Indirect jobs—those created in the supply chain—require economic modeling, typically using IMPLAN or RIMS II multipliers. Induced jobs—those created by workers spending their wages in the local economy—are even harder to defend.

USCIS has historically scrutinized job creation claims, particularly for projects that rely heavily on indirect and induced job calculations. Sponsors have learned to be conservative, often targeting 15-20 jobs per investor even though the requirement is only ten. That buffer is essential because job creation is verified retroactively, and shortfalls can jeopardize investor immigration status.

For infrastructure projects—construction-heavy, operationally complex—direct job creation during the build phase is usually easy to demonstrate. The harder part is sustaining those jobs through operations, which is why many EB-5 structures rely on construction employment and indirect jobs during the development period.

Brevet hasn't announced specific projects that will utilize EB-5 capital under Hull's leadership, but the strategic direction is clear. The firm is positioning itself to access a low-cost, patient capital source that most competitors either don't understand or don't want to operationalize.

For the broader EB-5 market, this hire is a data point in a larger trend: immigration investor capital is moving from the fringes to the mainstream. As more institutional sponsors build internal expertise, as regional centers professionalize, and as regulatory pathways clarify, EB-5 becomes less exotic and more embedded in standard infrastructure and real estate finance.

The risks remain—political volatility, regulatory complexity, execution challenges around job creation. But for sponsors who can navigate those risks, EB-5 offers a cost-of-capital advantage that's hard to replicate elsewhere.

Whether Brevet can turn that advantage into superior returns depends on execution—Hull's ability to structure compliant deals, identify the right projects, and manage the operational burden of ongoing investor relations and job creation reporting. The appointment itself doesn't answer those questions. But it does signal that Brevet believes the answers are worth pursuing.

How scalable is this model? Can Brevet deploy EB-5 capital across multiple portfolio companies simultaneously, or will each deal require bespoke structures and dedicated resources? If the latter, the cost savings from low-interest capital may be offset by higher administrative overhead.

What happens if regulatory winds shift? The EB-5 program has been reauthorized multiple times, often with eleventh-hour extensions. If Congress lets the program lapse or significantly alters its structure, sponsors relying on EB-5 capital will need contingency plans—backup financing that can be deployed quickly if immigration investor funds become unavailable.

And perhaps most importantly: does the market have enough EB-5 investor demand to support institutional adoption at scale? If every mid-market infrastructure sponsor decides to tap EB-5 capital, will there be enough foreign investors willing to put $800,000 into projects that may or may not deliver the immigration outcomes they expect?

Those questions don't have answers yet. But Brevet's decision to hire Joan Hull suggests the firm thinks the upside is worth the uncertainty. Whether that bet pays off will depend on execution, regulation, and geopolitics—three variables that rarely cooperate.