New Full Counties Qualify as TEAs Based on Latest 2020 BLS Employment Data

by Samuel Silverman and Michael Schoenfeld

The EB-5 investment program requires a capital commitment of $1.8 million from an immigrant investor seeking permanent residency in the United States. However, investors can reduce the minimum investment requirement to only $900k if they choose an investment located in a targeted employment area (TEA). An area is considered a TEA if it is located in either (i) a rural area or (ii) an area experiencing high unemployment.

The COVID-19 pandemic has resulted in dramatic increases in national unemployment, with impacts to specific regions differing greatly. Employment data reflecting the impacts of the COVID-19 pandemic was released by the Bureau of Labor Statistics (BLS) in April 2021. EB5AN’s free national EB-5 TEA map, which allows project developers to instantly check whether an address qualifies as a TEA, has been updated to reflect the most current BLS data.

Prior to the latest BLS data release, entire counties qualifying as TEAs were mostly limited to smaller, or more rural, counties. However, as a result of impacts of the COVID-19 pandemic, counties now qualify as TEAs in more populous urban areas such as Los Angeles County, California, and Brooklyn County, New York.

Read below to learn how TEAs are designated and to see a complete list of the full counties that now qualify as high-unemployment TEAs.

How Are TEAs Designated?

A rural TEA must be located outside of a metropolitan statistical area (MSA) and outside of a town or city with a population above 20,000 people. A high-unemployment TEA must have an unemployment rate at least 150% of the national average. High-unemployment TEA designations are made for individual census tracts, a combination of directly adjacent census tracts, or at the county-wide level. If the area is a combination of adjacent census tracts, the weighted average of that group’s unemployment must reach at least 150% of the national average to qualify as a TEA. Additionally, an entire county can qualify as a TEA if the county-wide unemployment rate is greater than or equal to the unemployment rate requirement for the given period.

What Are the Different Methodologies to Determine a Project’s TEA Status?

The burden falls on EB-5 projects themselves to prove that their site qualifies as a TEA. When calculating unemployment rates for high-unemployment TEA designation, projects use one of three methodologies: (i) ACS, (ii) census share, or (iii) county level.

Updated data from the American Community Survey (ACS) is published by the U.S. Census Bureau each December. Updated data from BLS is published each April and applies to the census share and county-level methodologies. This means that the effects of the COVID-19 pandemic on TEA status were only revealed in April 2021.

What Does the 2020 Report from the BLS Reveal?

The BLS publishes unemployment data at the national, MSA, and county levels. Although entire counties have always qualified as TEAs, these counties were typically less populous counties located in more rural areas. However, economic shutdowns in many major cities in response to the COVID-19 pandemic have increased unemployment rates in many urban areas in the United States. As such, many full counties that now qualify as TEAs include those encompassing large cities with high populations.

Below is a list of the counties that now qualify as high-unemployment TEAs based on the most recently published BLS data. The 2020 national unemployment rate according to the BLS was 8.10%, and high-unemployment TEAs must exhibit an unemployment rate at least 150% of the national average. Therefore, for a full county to qualify as a TEA, it must have an unemployment rate above 12.15% (8.10% x 1.5).


  • Wilcox County (14.73%)
  • Lowndes County (13.33%)


  • Skagway Municipality (21.45%)
  • Kusilvak Census Area (19.36%)
  • Denali Borough (15.74%)
  • Haines Borough (15.62%)
  • Hoonah-Angoon Census Area (13.52%)


  • Yuma County (17.13%)
  • Apache County (12.78%)


  • Imperial County (22.49%)
  • Colusa County (15.95%)
  • Tulare County (13.21%)
  • Los Angeles County (12.80%)
  • Kern County (12.52%)
  • Merced County (12.19%)


  • Osceola County (13.54%)


  • Clay County (12.39%)


  • Maui County (17.83%)
  • Kauai County (16.18%)


  • Magoffin County (16.08%)


  • Orleans Parish (12.17%)


  • Cheboygan County (14.58%)
  • Wayne County (13.81%)
  • Mackinac County (13.35%)
  • Montmorency County (13.14%)
  • Lapeer County (12.49%)


  • Mahnomen County (13.01%)


  • Jefferson County (18.40%)
  • Holmes County (16.20%)
  • Tunica County (14.86%)
  • Humphreys County (14.74%)
  • Claiborne County (14.43%)
  • Wilkinson County (13.36%)
  • Coahoma County (12.53%)


  • Taney County (12.92%)


  • Clark County (14.73%)

New Jersey

  • Atlantic County (17.76%)
  • Cape May County (13.82%)
  • Passaic County (12.60%)

New Mexico

  • Luna County (15.86%)

New York

  • Bronx County (16.03%)
  • Brooklyn County (12.53%)
  • Queens County (12.53%)

North Dakota

  • Rolette County (13.43%)


  • Cameron County (12.57%)
  • Philadelphia County/City (12.37%)
  • Elk County (12.30%)


  • Starr County (17.32%)
  • Maverick County (15.00%)
  • Presidio County (14.73%)
  • Zavala County (14.11%)
  • Crane County (13.61%)
  • Jim Wells County (12.98%)
  • Zapata County (12.41%)


  • Petersburg City (13.95%)

West Virginia

  • Calhoun County (16.06%)
  • Mingo County (14.25%)
  • McDowell County (12.59%)
  • Clay County (12.50%)
  • Roane County (12.44%)
  • Logan County (12.17%)


  • Menominee County (15.34%)
  • Forest County (12.42%)

This post originally appeared on EB Aaffiliate Network . Reprinted with permission.

About The Author
If you would like EB5AN to research and monitor a specific project location for you, please send an email with your request to or schedule a call.

Samuel B. Silverman Sam has extensive real estate development, management, financing, and brokerage experience in Florida, Pennsylvania, California, Georgia, and internationally in the People's Republic of China. Prior to EB5AN, Sam served as the Director of Corporate Strategy and Expansion for Professional Golfer Jack Nicklaus in the People's Republic of China, living full time in Beijing. Sam was also previously employed by the Boston Consulting Group, one of the top management consulting and business strategy firms in the world where he worked directly with Fortune 500 Companies in the food service, media, manufacturing, hospitality and real estate spaces in the U.S., Europe, and Middle East. Sam is also a Forbes Magazine 30 Under 30 National Winner for Social Entrepreneurship. Sam holds a B.A. in Economics with a concentration in Mandarin Chinese from Yale University, a Certificate in Financial Accounting from the London School of Economics and Political Science, and an M.B.A. from the Stanford Graduate School of Business.

Michael Schoenfeld Mike has extensive private equity investment, business diligence, management consulting, and entrepreneurship experience. Prior to EB5AN, Mike worked for AEA Investors, a leading middle-market private equity firm with $6B under management, focused on making control-oriented investments in consumer goods, industrial goods, and business services companies. He invested out of their current $2.5B middle market private equity fund. His completed transactions include the $2B LBO of 24 Hour Fitness, the leading fitness club operator with over 400 clubs nationwide, and the minority investment in Brand Networks, a leading social media marketing solutions provider. Mike was previously employed by the Boston Consulting Group, one of the top management consulting and business strategy firms in the world where he worked directly with Fortune 500 Companies in the transportation, financial services, industrial goods, information technology, and real estate spaces. Mike is also a Forbes Magazine 30 Under 30 National Winner for Social Entrepreneurship. Mike holds a B.A. in Economics and B.S. in Business Administration from the University of North Carolina at Chapel Hill.

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