As a nonrefundable fee and an outright gift, never as an investment. Neither produces a return, neither is recoverable on demand, and neither is capital placed in an enterprise, which is what separates the program from EB-5 in every accounting and legal sense.
Two payments, both gone
Hypothetical example: Ignatius owns a steel-supply business near East Ferris and has asked his controller to book the amounts as a long-term investment. That characterization is wrong twice over. The processing fee is nonrefundable and is paid before vetting concludes, so it can be spent on an application that does not succeed.
The gift, as its name in the official material indicates, is a transfer to the U.S. government: it is not placed in a business, it is not measured against a business plan, it creates no jobs anyone counts, and it is not returned. Comparing it to EB-5 confuses two entirely different transactions, since EB-5 capital is invested, remains at risk in an enterprise, and must be attributable to at least ten qualifying full-time jobs.
Ignatius should also decide deliberately whether the company or he personally pays, take advice on that question, and confirm the current published amounts before any transfer.