Case Study · Nevada · Full-Service Hotel · EB-5
Hotel Feasibility Study, Nevada — An EB-5 Worked Case
This is how our independent feasibility study company and feasibility consultant team analyzed a new-build, roughly 300-key full-service hotel in a Las Vegas submarket, financed with an EB-5 tranche inside the capital stack — from STR-based demand and competitive-set penetration through the stabilized coverage a senior lender documents and the economic impact and job-creation analysis an EB-5 filing requires. It is a representative, anonymized worked example of the methodology — not a specific client deal — set in Clark County, Nevada.
A ground-up full-service hotel, with EB-5 in the stack.
A developer came to our feasibility study company with a ground-up, roughly 300-key full-service hotel in a Las Vegas submarket and two audiences to satisfy at once. A senior construction lender needed the projected cash flow independently tested before it would commit, and an EB-5 regional center needed a defensible economic impact and job-creation report to support the offering it would file. The build program is a flagged full-service hotel with food and beverage, meeting and event space, and structured parking, positioned off-Strip near a defined demand generator rather than on the resort corridor itself.
A hotel is a going-concern operating business rather than a passive real-estate play, so a senior lender's question is not “what is the dirt worth” but “can this specific property penetrate its competitive set, ramp to a stabilized RevPAR, and cover its debt.”1 The EB-5 question is different again and runs in parallel: not whether the deal pencils, but how many qualifying jobs the project creates, counted the way USCIS accepts, and whether the economic model that produces that count is transparent and defensible.12 Our scope was the independent demand, penetration, competition, coverage, and job-creation analysis that supports both filings.
Representative and anonymized. Every figure below is illustrative of a typical engagement of this type; the property, submarket, and parties are composited, not a real named developer, address, or completed transaction.
STR demand, segmentation, and the penetration ramp.
Hotel demand is read through STR-style segmentation and a competitive-set penetration index, not a flat occupancy assumption. The submarket draws on Las Vegas leisure visitation, a submarket corporate and group base, and convention overflow when the Strip compresses.
The national frame sets the discipline: full-year 2025 U.S. hotel performance ran occupancy 62.3 percent, ADR $160.54, and RevPAR $100.02, the first occupancy and RevPAR declines since 2020.1 Las Vegas draws on a far larger visitor base — an estimated 38.5 million visitors in 2025 and convention volume near 6 million attendees — but that base is cyclical and was down on the year, so a defensible study models the cycle rather than annualizing a peak.25 The subject is held to fair-share penetration of its competitive set at stabilization rather than an above-fair-share assumption, and the occupancy build follows the observed ramp: STR data show new-construction hotels begin near a 58 percent occupancy index in month one and reach a 100 percent RevPAR index only around month 17, with an average occupancy build-up near three years.9 Stabilized ADR of $190 on 74 percent occupancy — a $140.60 RevPAR — sits below the Las Vegas market-aggregate RevPAR of about $149, a deliberately conservative off-Strip placement.4
| Demand driver | Basis | Supported figure |
|---|---|---|
| Leisure transient | Las Vegas ~38.5M visitors; off-Strip value positioning2 | ~45% of room-nights |
| Corporate & group | Submarket corporate demand; on-site meeting & event space | ~35% of room-nights |
| Convention overflow | ~6M convention attendees; Strip compression nights5 | ~20% of room-nights |
| Stabilized occupancy | Blended, held to ~fair-share penetration9 | 74% |
| Stabilized ADR | Off-Strip full-service, below market aggregate4 | $190 |
| Stabilized RevPAR | ADR × occupancy | $140.60 |
Demand segmentation and penetration logic grounded in STR/CoStar performance data and the Las Vegas visitation base; see sources 1, 2, 4, 5, and 9. Figures are illustrative of the engagement type.
The competitive set and a defensible penetration index.
Six properties anchor the subject's competitive set. The STR competitive-set RevPAR index — the subject's RevPAR divided by the set's — is the core penetration test, and the study justifies the set rather than cherry-picking weak comparables to inflate it.
| Property | Positioning | Rooms | Est. RevPAR (2025) | Read |
|---|---|---|---|---|
| Comp A | Upper-upscale full-service | 340 | $143 | Primary comp; strong meeting space |
| Comp B | Upscale select-service | 180 | $119 | Newer, limited F&B |
| Comp C | Upper-midscale | 220 | $105 | Older, value-oriented |
| Comp D | Upscale full-service | 300 | $150 | Flagged, loyalty base |
| Comp E | Upper-upscale, casino-adjacent | 260 | $160 | Gaming-driven draw |
| Comp F | Upscale full-service | 240 | $130 | Aging product, trailing-edge |
Competitive set defined for the engagement; anonymized. Rooms-weighted set RevPAR is approximately $137; the announced supply pipeline was scanned alongside the standing set, consistent with defensible penetration practice.
The rooms-weighted competitive-set RevPAR is about $137, against the subject's stabilized RevPAR of $140.60 — a penetration index near 103 percent. That modest premium is not assumed; it is justified by the subject being the newest full-service product in the set, with superior meeting and event space and a defined demand generator, exactly the demand-generator and product-quality rationale a defensible study must show before crediting above-fair-share penetration.9 Critically, the premium arrives only at stabilization. The penetration index ramps from roughly 74 percent in Year 1 (a $101.50 RevPAR) to about 91 percent in Year 2 ($124.44) before reaching 103 percent in Year 3, so the model never assumes a new entrant immediately exceeds fair share — the single most common way hotel penetration forecasts fail review.1 The index is also stress-tested for a competing flag opening during lease-up, the risk a two-to-four-year ramp is most exposed to.
Nevada: a cyclical tourism base, mid-correction.
The Las Vegas backdrop is the decisive market condition, and in 2025 it was softening. Any hospitality pro forma built on 2023–2024 RevPAR is stale; the study models the visitation cycle explicitly rather than capitalizing a peak year.
Las Vegas visitation fell 7.5 percent to an estimated 38.5 million in 2025, with twelve straight months of year-over-year declines and average hotel occupancy off to 80.3 percent.2 Strip ADR slipped 4.6 percent to $196.54 and Strip RevPAR fell 8.2 percent to $163.52, and CoStar recorded Las Vegas as the largest RevPAR decline of any top-25 U.S. hotel market.34 The picture is not uniformly negative: statewide gaming set a record $15.8 billion, a fifth straight record year, and convention volume held near 6 million attendees against a 2019 peak of about 6.6 million.35 An early-2026 turn is real but unproven — May 2026 visitation rose about 2 percent and convention attendance 14.7 percent, and UNLV projects a rebound toward 40.1 million visitors — so the study treats the recovery as a projection, not a result, and grades the ramp against it.6
Two Nevada-specific factors round out the market read. On the tailwind side, Nevada levies no state personal or corporate income tax and carries a low effective property tax, which supports both the operating margin and the going-concern exit. On the risk side, a long-horizon Southern Nevada study must acknowledge the Colorado River constraint: Lake Mead sat near 35 percent of capacity in mid-2026, with the 2007/2019 operating rules expiring at year-end and no successor agreement, a governance risk we flag rather than ignore.14 The pipeline also matters — the Athletics' roughly $2 billion, 33,000-seat stadium is on schedule for spring 2028, a future demand catalyst for the submarket that the study notes but does not yet underwrite.15
Why the submarket supports the project — and the TEA.
Clark County concentration, in-migration, and the site's proximity to a demand generator support the demand case, while the census geography supports the EB-5 targeted-employment-area designation that sets the reduced $800,000 minimum.
Nevada's 2025 population reached roughly 3.32 million, up about 1.6 percent, with growth led by net in-migration — nearly 42,000 gross annual arrivals from California — rather than natural increase; Clark County holds about 73 percent of the state's residents.7 That concentration puts the subject in the middle of the state's deepest labor and lodging-demand pool, near a defined submarket demand generator that supports the corporate and group segment through the week and the leisure segment on weekends.
The site also carries the EB-5 detail that sets the entire capital structure: it sits within a targeted employment area. Under the EB-5 Reform and Integrity Act of 2022, a project in a TEA — a rural area or an area of high unemployment — qualifies for the reduced $800,000 minimum investment rather than the $1,050,000 standard, and the study documents the qualifying census-tract geography that supports that designation before a single investor subscribes.11 That $800,000 threshold, multiplied across 31 investors, is what sizes the EB-5 tranche in the stack that follows.
The EB-5 capital stack.
Total project cost lands at $85 million, about $283,000 per key. The stack layers a senior construction loan, a $24.8 million EB-5 tranche as patient preferred capital, and developer equity — a structure in which the EB-5 layer lowers the blended cost of capital and lifts the developer's return.
| Cost component | Amount |
|---|---|
| Land (controlled / contributed) | $8.0M |
| Site work & infrastructure | $5.0M |
| Building shell & core (~300 keys) | $38.0M |
| FF&E (guestrooms & public areas) | $9.0M |
| Food & beverage / meeting build-out | $4.5M |
| Soft costs (A&E, permits, fees) | $7.5M |
| Financing & construction-period carry | $6.0M |
| Pre-opening & working capital | $3.0M |
| Contingency | $4.0M |
| Total project cost | $85.0M |
All-in cost of ~$283K/key sits between the HVS select-service (~$223K) and full-service (~$409K) medians, reflecting an off-Strip submarket with contributed land; hard construction spend (site work + shell + FF&E + F&B build-out) totals $56.5M. See source 8.
| Layer | Amount | Share |
|---|---|---|
| Senior construction loan | $47.0M | 55.3% |
| EB-5 tranche (mezzanine / preferred) | $24.8M | 29.2% |
| Developer equity | $13.2M | 15.5% |
| Total capitalization | $85.0M | 100.0% |
EB-5 tranche = 31 investors × $800,000 TEA minimum = $24.8M, structured as a mezzanine / preferred layer subordinate to the senior loan. See sources 11 and 12.
The senior construction loan of $47.0 million, about 55 percent of cost, carries the development and converts to permanent financing at stabilization; at an illustrative 7.1 percent — consistent with late-2025 hospitality debt near 7.11 percent — on a 25-year amortization, permanent debt service runs about $4.02 million a year, the number the projected coverage must clear.10 The $24.8 million EB-5 tranche is 31 investors at the $800,000 TEA minimum, structured as a mezzanine or preferred layer subordinate to the senior loan.11 Because EB-5 investors prioritize a qualifying, at-risk investment and job creation over yield, this is patient, low-cost capital, and its presence between the senior loan and the developer's $13.2 million of equity lowers the blended cost of the stack and is a principal reason the developer's levered return reaches the high teens. For the regional center, though, the stack is only bankable once the job-creation analysis is in place: the regional center files Form I-956F to approve the offering, supported by the project's economic impact analysis and business plan, before its investors file the individual I-526E petitions.12
Bankable on stabilized coverage, and returns for the developer.
The stabilized model builds revenue from rooms, food and beverage, and other operated departments, nets the going-concern cost structure to an NOI, and carries senior coverage from a sub-1.0x ramp year to 1.45x at stabilization.
| Line | Basis | Amount |
|---|---|---|
| Rooms revenue | 300 keys × 74% occ × $190 ADR ($140.60 RevPAR)4 | ≈ $15.4M |
| Food & beverage revenue | Full-service outlets, banquet & catering | ≈ $7.1M |
| Other operated & rentals | Parking, resort/other fees, meeting rentals | ≈ $2.5M |
| Total revenue | Rooms + F&B + other | ≈ $25.0M |
| Gross operating profit (GOP) | ~33.6% GOP margin, full-service benchmark10 | ≈ $8.4M |
| Management fee | ~3% of total revenue | ≈ ($0.75M) |
| FF&E reserve | ~4% of total revenue8 | ≈ ($1.0M) |
| Fixed charges (property tax, insurance) | Low Nevada property-tax basis | ≈ ($0.8M) |
| Net operating income (NOI) | ~23.4% NOI margin | ≈ $5.85M |
GOP margin anchored to the CBRE full-service benchmark (~33.5%); NOI is net of a management fee, an FF&E reserve of 3–5% of revenue, and fixed charges. See sources 8 and 10.
| Year | Stage | Occ / ADR | NOI | DSCR |
|---|---|---|---|---|
| Year 1 | Ramp (reserve-supported) | 58% / $175 | ~$3.6M | 0.90 |
| Year 2 | Building | 68% / $183 | ~$4.8M | 1.20 |
| Year 3 | Stabilized | 74% / $190 | ~$5.85M | 1.45 |
DSCR is NOI divided by ~$4.02M permanent annual debt service ($47.0M, ~7.1%, 25-yr amortization). The Year-1 sub-1.0x figure is covered by a funded interest reserve, consistent with the observed ramp. See sources 9 and 10.
The stabilized 1.45x coverage is the figure the senior lender documents, and it clears the coverage a cash-flow-volatile hotel credit demands with real headroom. By Year 2 the project already covers permanent debt service at 1.20x, and the Year-1 figure of 0.90x is intentionally below 1.0x — it is the ramp year, and a funded interest reserve carries the shortfall rather than a pro forma that pretends the hotel stabilizes on opening day.9 Modeling stabilized performance from month one, or an above-fair-share penetration on day one, is the most common way hotel pro formas fail review; the ramp here is deliberately graded to the STR curve.1
On the equity side, the developer's $13.2 million injection earns growing distributions once the senior loan and the EB-5 preferred return are served, and the low cost of the EB-5 layer is precisely what lifts the levered result. The exit is valued on a going-concern basis: capitalizing a Year-10 stabilized NOI at a hotel overall rate near 8 percent — consistent with hotel cap rates around 7.3 to 8.1 percent in 2025 — implies a value comfortably above the senior balance and the redeemed EB-5 capital, leaving meaningful net equity.10 Blended with interim cash flow, the illustrative developer levered equity IRR is about 18 percent over a 10-year hold.
Verdict: financially feasible and bankable, and job-compliant. On independently derived demand, a stabilized 1.45x senior DSCR, a ~18% developer levered IRR, and a job count that clears the EB-5 requirement with roughly a 2.3× cushion, the projections support both the senior credit and the I-956F filing.
The economic impact report: 310 jobs required, ~720 supported.
The EB-5 deliverable is an economic impact and job-creation analysis, not a lender's feasibility study. It answers one question: how many qualifying jobs the project creates, counted the way USCIS accepts, with a defensible cushion over the requirement.
| Input | Basis | Figure |
|---|---|---|
| EB-5 investors | $24.8M tranche ÷ $800,000 TEA minimum11 | 31 |
| Jobs required per investor | Full-time (≥35 hrs/week) positions12 | 10 |
| Total jobs required | 31 investors × 10 jobs | 310 |
| Employment channel | Modeled basis | Direct | Indirect + induced | Total |
|---|---|---|---|---|
| Construction | $56.5M hard spend, ~24-month build (≥2 yrs)13 | 180 | 240 | 420 |
| Stabilized operations | ~300-key full-service operations, revenue + payroll | 170 | 130 | 300 |
| Total qualifying jobs | Direct + indirect + induced | 350 | 370 | 720 |
Indirect and induced jobs modeled with Clark County RIMS II multipliers applied to documented inputs; construction jobs qualify as permanent because the build exceeds 24 months. See sources 12 and 13. Figures are illustrative of the engagement type.
The requirement is 310 jobs — 31 investors at ten each — and the project supports roughly 720 qualifying jobs, a cushion of about 2.3 times. That margin is deliberate: an analysis that produces exactly the required jobs with no buffer leaves the petitions exposed if any assumption is discounted on review, so a defensible cushion is expected.12 The jobs come from two channels. Because the construction period exceeds 24 months, the construction jobs modeled from the $56.5 million of hard spend count as permanent rather than transient, and stabilized hotel operations add a durable, ongoing block on top.13 Both are estimated with Clark County RIMS II multipliers — a recognized Bureau of Economic Analysis input-output model — applied to documented inputs, with the model, its geography, and its multipliers all disclosed so a reviewer can trace every job from assumption to conclusion.13
The counting also stays comfortably inside the regional-center rules. A regional-center investment may satisfy up to 90 percent of the requirement with indirect and induced jobs modeled through input-output analysis; here the modeled direct jobs alone — roughly 350 — already exceed the 310-job requirement, so reliance on the 370 indirect and induced jobs is well within the cap and is not a binding constraint.12 The analysis supports the regional center's Form I-956F and, in turn, the investors' Form I-526E petitions; it is economic work that sits alongside the petition prepared by immigration counsel, not legal or immigration advice.12
Independent demand, penetration, coverage, and a defensible job count.
The engagement was scoped to satisfy two reviewers at once — a senior credit committee and an EB-5 regional center — and, as an independent feasibility consultant, our role is to test the developer's projection against the market rather than restate it. We built demand through STR-style segmentation and a competitive-set penetration index, graded the occupancy and ADR ramp to the observed STR build-up curve rather than assuming stabilized performance from opening, and stress-tested the senior coverage against a competitor opening mid-ramp, ADR softness, and the Las Vegas visitation cycle.
The EB-5 job-creation analysis was built to the same standard of transparency the lender work is. Every input to the RIMS II model — hard construction spend, stabilized revenue, and payroll — is documented and sourced, the Clark County geography is stated, and the multipliers are shown, so the job count survives review with a defensible cushion over the 310-job requirement. One scope boundary is worth stating plainly: the economic impact analysis is economic work that supports the immigration filing prepared by counsel; as the feasibility consultant, we do not provide legal or immigration advice, and the study references but does not perform the Phase I environmental site assessment. That combination — independent demand, penetration, a stressed DSCR, and a transparent job model — is what lets both the lender and the regional center rely on the file.12
Representative engagement
This is an anonymized, illustrative worked example of our methodology, built on market data current to 2026; figures are representative of a typical engagement of this type and do not depict a specific client, site, or completed transaction.
Underwriting a Nevada hotel with EB-5 capital? Start with the feasibility study and the economic impact report.
Feasibility Study Company prepares independent hotel feasibility studies and EB-5 economic impact and job-creation reports, built to the coverage standard a senior lender documents and the transparency standard USCIS requires of a Form I-956F. A methodology briefing walks through the demand, penetration, coverage, and job-creation analysis behind a case like this one, calibrated to your submarket, capital stack, and regional center.
Request a methodology briefingData sources and dates.
The deal figures are illustrative of the engagement type; the market data that grounds each dimension is real and sourced, drawn from our standing Nevada, Hotel & Hospitality, and EB-5 analyses and the primary authorities they cite. Hotel readings are point-in-time and vendor-dependent; EB-5 requirements trace to statute and USCIS policy, and this page is economic analysis, not legal advice.
- CoStar (formerly STR), full-year 2025 U.S. hotel performance (Arlington, VA, January 2026): occupancy 62.3%, ADR $160.54, RevPAR $100.02, the first full-year occupancy and RevPAR declines since 2020; 2019 baseline occupancy 66.1%; as compiled in the firm's Hotel & Hospitality analysis.
- Las Vegas Convention and Visitors Authority via Las Vegas Review-Journal (January 28, 2026): 38.5 million visitors in 2025, down 7.5%; average hotel occupancy 80.3%; twelve straight months of year-over-year declines.
- Nevada Gaming Control Board and American Gaming Association via Casino.org (January 28, 2026): statewide gaming win a record $15.8 billion (fifth straight record year); Strip gaming $8.82 billion; Strip ADR $196.54; Strip RevPAR $163.52 (down 8.2%); downtown record $951.2 million.
- CoStar / STR via PSS (January 2026): Las Vegas recorded the largest RevPAR decline of any top-25 U.S. hotel market in 2025; Las Vegas market-aggregate ADR ~$199.79 and RevPAR ~$149.13 (all chain scales), as compiled in the firm's Hotel & Hospitality analysis.
- Las Vegas Convention and Visitors Authority via Las Vegas Sun (January 28, 2026): convention volume near 6 million attendees against a 2019 peak of about 6.6 million.
- UNLV Center for Business and Economic Research via Casino.org (December 2025) and LVCVA / Nevada Gaming Control Board via InterGame (June 2026): 2026 rebound projection near 40.1 million visitors; May 2026 visitation up ~2%, convention attendance +14.7%, statewide gaming +7.43%. Forecast, not actual.
- U.S. Census Bureau Vintage 2025 population estimates and the Nevada State Demographer: Nevada population ~3.32 million (+1.6%); Clark County ~73% of residents; net in-migration led by ~42,000 gross annual arrivals from California.
- HVS, 2025 U.S. Hotel Development Cost Survey (reflecting 2024 budgets): median cost per key by segment (limited-service ~$167,000; select-service ~$223,000; full-service ~$409,000; all-type median ~$219,000); an FF&E reserve of 3%–5% of revenue; the going-concern income approach.
- STR (2019 Hotel Data Conference) and Cornell University / ISHC: new-construction hotels reach a 100% RevPAR index around month 17, with an occupancy index near 58% in month one; an average occupancy build-up of about three years; brand-managed hotels ramp faster than independents.
- CBRE Hotels Research, Trends survey (2025) and H2 2025 Cap Rate Survey, with CBRE data via Bay Street Hospitality: full-service GOP margin 36.9% (2019) to 33.5% (2024); hotel cap rates ~7.3%–8.1% by mid-2025; late-2025 hospitality debt ~7.11% against cap rates ~8.17%.
- EB-5 Reform and Integrity Act of 2022: standard minimum investment $1,050,000 and targeted-employment-area (rural or high-unemployment) minimum $800,000, subject to the first automatic inflation adjustment on January 1, 2027 and every five years thereafter.
- USCIS Policy Manual, Volume 6, Part G, and USCIS regional-center guidance: at least ten full-time jobs (minimum 35 hours per week) per investor; a regional center may satisfy up to 90% of the requirement with indirect and induced jobs modeled through input-output analysis; Forms I-956F (regional-center offering approval) and I-526E (investor petition) in sequence; the tenant-occupancy methodology retired in 2018. Economic analysis, not legal or immigration advice.
- Recognized input-output models: RIMS II, U.S. Bureau of Economic Analysis (regional multipliers), and IMPLAN; USCIS requires transparent, economically and statistically valid forecasting tools with disclosed inputs, geography, and multipliers rather than a specific named model. Construction jobs count as permanent where the construction period exceeds 24 months.
- U.S. Bureau of Reclamation with the Southern Nevada Water Authority via Las Vegas Sun (June 2026): Lake Mead near 35% of capacity in mid-2026; Nevada's 300,000 acre-foot Colorado River allocation (under 2%); the 2007/2019 operating rules expiring at the end of 2026 with no successor agreement.
- ESPN (May 2026) and Las Vegas Review-Journal (2025–2026): the Athletics' roughly $2 billion, 33,000-seat stadium on the former Tropicana site on schedule for spring 2028; Fontainebleau (3,000+ rooms) opened December 2023.