No. The ordinary window is tied to each relevant start of conditional residence, not a single project calendar.
Use the actual immigration event
Conditional residence begins at immigrant admission or adjustment approval. Record the applicable second anniversary and ordinary preceding 90-day filing period. A fellow investor’s filing does not remove this person’s conditions or guarantee repayment.
Check current USCIS processing time data for the relevant EB-5 petition type and the visa bulletin for the applicable category and country of chargeability, and revisit both periodically rather than relying on a one-time estimate, since both can change materially over a multi-year case. The I-829 stage asks for evidence concerning the investment and job-creation requirements, so maintain project reports, bank and subscription records, enterprise records, tax documents where relevant, and communications that explain material business changes. If the closing tranche after tax and distribution meets the threshold for a targeted-employment-area project, the petition can be filed as soon as the path-of-funds evidence is assembled, which often takes longer than investors expect because early corporate records must be found.