How can I apply for EB-5 direct investment by forming a company with a group of Americans?

No, you have to invest your own money; you can have partners but you need to prove your source of funds and how you earned or received this money.

What you are suggesting is entirely possible since there are no restrictions on having non-EB-5 investor partners in your new commercial enterprise. You must document the lawful source of funds of all investment sources, however, not just your own investment. Forming an LLC and having other members is allowed; you should contact an experienced immigration attorney who can advise you on the specific steps.

Everything you say here can work but I am more concerned with the loan; but the Zhang decision was upheld again last year so it may work, depending on the details.

EB-5 requires your investment; your money from investments here or from outside the U.S. Loans secured by the investment itself will not work.

This basically sounds like the majority of EB-5 projects. You are all funding the same project. They put up some money and you put up EB-5 funds. The wrinkle is how you want to structure it. Maybe, have the NCE have you as a shareholder with the EB-5 portion and the non-EB5 folks contribute capital from their own sources. Should be simple enough.

Forming a company is easy. But the investment must be yours and not a loan secured by credit/collateral of other people. You can obtain a loan for your investment but the rules are strict and involve your assets/collateral.

The co-investor would have to sign personal guarantees for the loan or pledge assets as security.