The rules define 'Gold Card' broadly, encompassing not just the specific name but any new program established after Feb 26, 2025, exchanging funds for status. While inclusive, this introduces ambiguity: for instance, would minor modifications to the existing EB-5 program count as a 'new program'? Or if multiple tiered programs exist, how are they aggregated? Furthermore, potential opacity in official data may force reliance on media consensus, which might differ on the definition of 'sales' (actual payment vs. letters of intent).