No. The participation condition can involve policy formulation as well as day-to-day management. Qualifying limited-partner rights may satisfy it, but the actual documents require assessment.
Read the rights that are really granted
Do not infer the result from a marketing label. Identify relevant voting or policy provisions and any restrictions without treating generic commercial language as a legal conclusion.
Give immigration counsel the escrow agreement, subscription documents and offering memorandum together, because the release condition only makes sense alongside how the enterprise will use the money. A thorough personal funding history does not establish the project's job-creation evidence, and a strong project presentation does not establish the investor's lawful capital, so identify unresolved points on both sides before committing, and confirm current filing requirements directly. Genuine job sharing is distinct, and direct versus regional-center evidence differs; the report’s label alone does not settle the investor’s showing. For a direct EB-5 restaurant the investor must therefore design an operation with at least ten year-round full-time roles: kitchen, service, management and administration, each documented by payroll and Form I-9 records.