The Trump administration’s Gold Card program, established by executive order in September 2025, offers expedited EB-1 or EB-2 residency pathways to foreign investors making a $1 million contribution to the Commerce Department. As of mid-May 2026, uptake remains minimal following application processing that began only in December 2025, with Commerce Secretary Howard Lutnick confirming just one approval by late April. Ongoing legal challenges, processing delays, and skepticism from immigration attorneys have limited interest among high-net-worth applicants despite earlier projections of tens of thousands of sales. These implementation hurdles explain why traders assign the highest probability to the 1-100 range for total 2026 issuances, reflecting the current pace of approvals and the absence of recent policy adjustments that would accelerate demand.