No. Under the current published framework the gift is made to the United States government and produces no return, no equity and no repayment. The processing fee paid to the Department of Homeland Security is separately nonrefundable.
Correcting the conflation before anything else
Cecile has been given a description that would change every calculation she makes. An investment implies capital that remains hers in some form, whether at risk or not, and it implies a possible return. The Gold Card gift implies neither.
Comparing it with EB-5 makes the difference plain: EB-5 capital is invested in a commercial enterprise, must remain at risk, must create at least ten full-time jobs, and can in principle be returned after conditions are removed. The Gold Card gift is transferred and gone. Whether the framework suits her is a legitimate question, but it can only be answered once the money is understood as expenditure rather than allocation.
An intermediary who blurred that line has either misunderstood the program or is selling it, and neither is a reason to continue with them.