The mismatch starts with the product itself. IMI Daily reported April 25 that Trump first floated the Gold Card in February 2025 as a $5 million fee for green card privileges plus a path to citizenship, branding it a “green card on steroids,” then formalized the idea by executive order in September 2025 (IMI Daily, April 25, 2026; Fortune, April 24, 2026). But the version now on offer is not the same thing that was pitched from the stage.

The program’s own website, as reported by IMI Daily on April 25, says the $1 million donation is due only after an applicant clears vetting, while the upfront cost before that point is just a $15,000 processing fee (IMI Daily, April 25, 2026). That means much of the money advertised at launch has not actually changed hands yet.

The accounting gets murkier from there. IMI Daily reported April 25 that at the program’s launch, Lutnick stood beside Trump and said the government had already sold $1.3 billion worth of Gold Cards in days, but he never defined what “sold” meant (IMI Daily, April 25, 2026). If the funds were not yet collected, “sold” was doing a lot of work.

One small episode captured the branding problem neatly. IMI Daily reported April 25 that when rapper Nicki Minaj posted a gold-colored card in January and said she had received it free of charge, the Commerce Department told Snopes it was a “memento,” not a visa document, and a DHS official said she had been a legal permanent resident for about 20 years (IMI Daily, April 25, 2026). The card may have been flashy. It was not evidence of a functioning visa market.

At the current pace, the answer is not enough to matter. IMI Daily reported April 25 that one approval in four months works out to roughly three approvals a year, which would put a $1 trillion target about 333,000 years away (IMI Daily, April 25, 2026). Even by Washington accounting, that is a long horizon.

The demand side is constrained before the price is even discussed. Cato said in February 2025 that not even 5,000 people a year are willing to try to get an EB-5 green card when the cost is temporarily tying up $800,000, and that there are only about 2.3 million people worldwide with net assets excluding their primary residence of $5 million or more, with a third already in the United States (Cato, February 2025). That pool is not infinite, and it is not all sitting around waiting for a novelty visa.

The structure matters as much as the price. EB-5 asks applicants to park capital in an investment that is supposed to create jobs; the Gold Card asks them to hand money directly to the government as a non-refundable fee (Cato, February 2025). Those are not close substitutes. One is an investment with an exit, however delayed; the other is a payment.

The Economic Innovation Group sketched a more plausible version of the idea in April 2025, estimating that a 10,000-visa-per-year program selling cards for $1 million could raise $100 billion over a decade, while a $5 million version could raise $500 billion over the same period, though it also said such estimates are “highly speculative” (EIG, April 2025). That is a far cry from the trillion-dollar rhetoric, but at least it lives on the same planet.

Only if the program can legally exist at scale, and that is where the whole thing gets slippery. Cato argued in February 2025 that Trump cannot lawfully eliminate Congress’s EB-5 program or sell green cards beyond statutory caps, because green card categories and limits are set by the Immigration and Nationality Act, not executive order (Cato, February 2025). The administration has not published a legal memo showing how the Gold Card avoids those barriers.

There is a possible workaround, at least on paper: parole authority. Cato noted in February 2025 that Trump could use parole to grant temporary lawful residence to people willing to pay $5 million, but his administration has also argued in other immigration litigation that categorical parole is unlawful, which undercuts the most obvious escape hatch (Cato, February 2025). It is hard to build a durable visa program on a legal theory you are busy attacking elsewhere.

The fiscal claim runs into the wall even faster. Fortune reported April 28 that interest on the national debt has topped $1 trillion a year (Fortune, April 28, 2026). EIG’s upper-bound estimate of $500 billion over 10 years at full $5 million pricing would cover only a slice of that, and only if the program actually reached full capacity (EIG, April 2025). The debt solution was always more slogan than plan.

The real story is not that the program got off to a slow start. It is that the design may never have matched the ambition. IMI Daily reported April 25 that Lutnick said there was one approval, hundreds waiting, and no public explanation for where the money would go beyond vague talk of “the betterment of the United States of America” (IMI Daily, April 25, 2026). That is not much of a fiscal architecture.

There is still a serious policy debate here, just not the one Trump advertised. EIG argued in April 2025 that EB-5 is slow and badly designed, with a median wait of 71 months for a decision and another 17 to 49 months for USCIS to verify that the jobs were created (EIG, April 2025). In that sense, a cleaner fee-for-residency model could be worth discussing, if Congress were willing to write one.

That is the part that actually matters now. EIG said the EB-5 Regional Center program comes up for reauthorization in 2027 (EIG, April 2025). That is where any serious investor-visa reform is likely to happen, because Congress writes the rules that executive orders cannot quietly erase. Until then, the Trump Gold Card program looks less like a debt solution than a branding exercise with one customer.