You need to invest the money too. From my understanding most people pool the money into a ready-to-go Real Estate Development company which then makes real estate loans. Hence it's an equity investment, meeting the EB5 requirement, but in practice its basically a bond. Real estate money gets refinanced as long as the deal is not terrible.
I think they used a gerrymandering type argument that the fancy place was part of an area including a bunch of poor folk. The drawing of the area was kind of creative. It was taking the piss slightly but they got away with it.