Trump Gold Card or Pyrite Card Program – Which Is It?

Kathleen Campbell Walker
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On September 19, 2025, the Trump Administration created, via Executive Order, new immigrant options for investors to acquire permanent residence via the Trump Gold Card program, which is overseen by the U.S. Department of Commerce (DOC). The Secretary of the DOC coordinates with the Secretary of State and Department of Homeland Security (DHS) to establish and implement the program. The options do not create new employment-based immigrant visa categories, but instead are subsets (aka barnacles) of the existing Employment-Based (EB) First Preference category for extraordinary ability applicants (EB-1), as well as the self-sponsored EB Second Preference category (EB-2) for national interest waivers (NIW). The official website for the new options can be found here, and the email for information is goldcard@doc.gov. The three alternatives are as follows:

  TRUMP GOLD CARD TRUMP CORPORATE CARD TRUMP PLATINUM CARD
Applicant Individual who may provide a substantial benefit to the U.S.  No proof of job creation in U.S.  Corporate Sponsor for one or more of the sponsoring company’s employee(s), who will substantially benefit the U.S. No proof of job creation in the U.S. Individual applicants who may reside in the U.S. for up to 270 days per year without being subject to non-U.S. income taxation. No proof of job creation in U.S.
Qualifications Applicants are eligible for permanent residence, admissible to the U.S., and available for an immigrant visa pursuant to the Visa Bulletin. The I-140G form is filed online only after registration online using trumpcard.gov and receiving confirmation that the submission is accepted. Then, USCIS contacts the applicant to create or log in to their USCIS account online to file the Form I-140G. Applicants are eligible for permanent residence, admissible to the U.S., and available for an immigrant visa pursuant to the Visa Bulletin. The I-140G form is filed online only after registration online using trumpcard.gov and receiving confirmation that the submission is accepted. Then, USCIS contacts the applicant to create or log in to their USCIS account online to file the Form I-140G. Not applicable since it is not a permanent residence pathway. (The I-140G might be used as well, but not confirmed yet.)
Processing fee $15,000.00 (applies to each applicant and family member) Nonrefundable.  Paid via U.S. /international credit card or ACH debit card (U.S. bank accounts only). $15,000.00 (applies to each applicant and family member) Nonrefundable.  Paid via U.S. /international credit card or ACH debit card (U.S. bank accounts only). N/A
Application Process/Data Online via myuscis.gov account. The I-140G form requires current and prior 20 years of employment history, as applicable, in addition to any position with the government or military at any time. In addition, the I-140G contains detailed information as to source and path  of funds for the gift. For those requesting classification under the EB-2 category, an uncertified Form ETA-9089 is required as well. In addition, it appears the normal EB-1 or EB-2 evidence is necessary, but the form itself does not address this point in greater detail. Online via myuscis.gov account. The I-140G form requires current and prior 20 years of employment history, as applicable, in addition to any position with the government or military at any time. In addition, the I-140G contains detailed information as to source and path of funds for the gift. For those requesting classification under the EB-2 category, an uncertified Form ETA-9089 is required as well. In addition, it appears the normal EB-1 or EB-2 evidence is necessary, but the form itself does not address this point in greater detail. Program has not started.
Expedited Processing Yes  (no idea what that means – weeks is stated). It does not do away with immigrant visa availability. It requires a visa interview and the timely submission of required documents. Yes  (no idea what that means – weeks is stated). It does not do away with immigrant visa availability. It requires a visa interview and the timely submission of required documents. Program has not started, but it is possible to join a waitlist.
Gift to the U.S. $1,000,000.00 upon completion of individual’s vetting (applies to each applicant and family member) $2,000,000.00 for the principal and $1,000,000.00 per accompanying family member upon completion of individual’s vetting. A corporate sponsor may decide to end sponsorship of one employee and use the “gift” for a different employee. $5,000,000.00   – assume the same terms as the other two programs regarding the intake of the gift amount.
Family Members Yes – Spouses and unmarried children under 21 years of age included in original petition. Yes – Spouses and unmarried children under 21 years of age included in original petition. Assuming Yes – Spouses and unmarried children under 21 years of age included in original petition.
Maintenance Fees None 1% annual maintenance fee and a 5% transfer fee, which includes the cost of a new DHS background check. Unknown
Consular Application Fees, as applicable as well as Medical Exam Yes – Currently $345 Yes – Currently $345 Consular Application Fees- No idea as to Medical – usually no but perhaps like K fiance.
Immigrant Visa Fee to USCIS, as applicable Yes? Currently $235 Yes? Currently $235 No? Not an immigrant visa.
Taxation in U.S. Same as U.S. citizens and legal permanent residents. Same as U.S. citizens and legal permanent residents. Presence of up to 270 days per year without being subject to taxation on non-U.S. income. Does not address estate tax.
Revocation Yes, as applies to all visa holders. Yes, as applies to all visa holders. Yes, as applies to all visa holders.

Why apply for a Gold Card versus using the existing EB-5 Immigrant Visa[1] options?            

It is important to remember that the Gold Card was created by an Executive Order and not via a bill passed by Congress. In addition, this executive action will probably be subject to litigation challenges as to how far executive authority may be stretched in the complex field of immigration law. Of course, the EB-5 program has been in existence for decades (since 1990) via statutory authority. In addition, the ability to obtain an immigrant visa under the EB-1 or EB-2 categories is still subject to availability based on the monthly Visa Bulletin based on the applicant’s country of chargeability. For example, the EB-5 immigrant visa wait times are shorter or current (immediately available) versus backlogs in EB-2 and EB-1 categories (India and China) in the January 2026 edition of the Visa Bulletin. An expedited processing time by USCIS for an I-140G petition does nothing to reduce those related delays tied to a priority date.

As to filing fees, the I-140 EB-5 filing fees are substantially less than the filing fees for the new Gold Card program. For example, for a family of four the comparison is $4,675.00 (Base Fee of $3,657.00 plus an additional $1,000 under the EB5 Reform and Integrity Act of 2022) for the EB-5 category versus $60,000.00 for that same family under the Gold Card requirements.

In reviewing the amount of the investment between the two options, the investment for a Targeted Employment Area (TEA) EB5 application is $800,000.00 ($1,050,000.00 for non-TEA) versus the $1,000,000.00 Gold Card gift amount for individuals. In addition, the Gold Card program increases the investment amount required on a per qualifying family basis. So, if we use the Gold Card program for a family of four, applicants face a $4,000,000.00 Gold Card program gift and $5,000,000.00 for that same family, if the principal receives a Corporate Gold Card. While the EB-5 immigrant visa category allows a return of the at-risk capital investment, the Green Card program offers no return.[2]

A big benefit of the Gold Card program is that there is no conditional resident interim step for the Gold Card program versus the EB-5 immigrant category. In addition, the Gold Card program unlike the EB-5 immigrant category does not require proof of job creation in the U.S.

The Secretary of Commerce, Howard Lutnick, announced in September of 2025 that an initial 80,000 Trump Cards will be available[3] and that the Gold Card is supposed to “replace” the existing statutory EB-5 category. That would be an overreach at the least, if we apply our current legal protections and restrictions against the immediate disappearance of statutes. According to the Administration, approximately $1.5 billion in Gold Card gifts have been received as of December 19, 2025.[4]  Back in June of 2025, allegedly 70,000 people signed up for the Gold Card (equating to 70 billion and change). [5] With the mercurial nature of the administration in the immigration area, it is very challenging to advise clients whether to consider this new program as pyrite or not, while also assessing the potential new risks related to the ongoing availability of the EB-5 category.[6] While direct EB-5 investments were permanently authorized by the Immigration Act of 1990,[7] the EB-5 Regional Center program has always been a temporary program requiring reauthorization.[8] At present, its expiration is set for September 30, 2027.[9]

[1] See “EB-5 immigrant Investor Visa Program, “ published by the National Immigration Forum (Aug. 19, 2025)

[2] See “When do EB-5 investors get their invested capital back?” published by EB5AN https://eb5visainvestments.com/overview-history/, https://iiusa.org/wp-content/uploads/2025/08/IIUSA-Frequently-Asked-Questions_FINAL_8.5.2025.pdf ,  and  https://www.civitascapital.com/eb-5/.

[3] See Frank, Robert, “The global wealthy are lining up for Trump’s $1 million Gold Card after price cut,” (Sept. 26 2025) https://www.cnbc.com/2025/09/26/trump-gold-card-visa-wealthy.html#:~:text=He%20said%20he%20expects%20his,than%20an%20official%20fee%20change. .

[4]See Scripps News Group, “Trump claims over $1 billion in immigration ‘gold cards’ have been sold, (Dec. 19, 2025) https://www.scrippsnews.com/politics/immigration/trump-claims-over-1-billion-in-immigration-gold-cards-have-been-sold.

[5]See Farberov, Snejana, “Trump’s $5M ‘Gold Card’ Visa Attracts Nearly 70,000 Applicants,” (June 20, 2025) https://www.realtor.com/news/trends/donald-trump-gold-card-visa-applicants/.

[6]See “One Year Left to Invest in a EB-5 Regional Center Project,” noting that EB-5 Regional Centers will lose protection after September 30, 2026 unless the file I-526E petitions before that date, since the program may lapse in 2027. https://goaiia.org/blog/one-year-left-to-invest-eb5-with-regional-center/.

[7] See https://www.congress.gov/crs-product/IF13040#:~:text=Congress%20established%20the%20program%20as,The%20program%20and%20its%20requirements.

[8] See https://www.uscis.gov/working-in-the-united-states/permanent-workers/employment-based-immigration-fifth-preference-eb-5/eb-5-immigrant-investor-regional-centers/approved-eb-5-immigrant-investor-regional-centers.

[9] See “The State of EB-5 Today — Progress and Challenges Since the Reform and Integrity Act, “ by CanAm Marketing (Nov. 19, 2025) https://www.canamenterprises.com/2025/11/19/the-state-of-eb-5-today-progress-and-challenges-since-the-reform-and-integrity-act/.

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