Treat it as not refundable. A gift to the U.S. government is not an investment and is not structured to be returned, and a processing fee is consumed by the process. Confirm the current terms on the official programme page before paying, and do not rely on any assurance from an intermediary.
Nothing here is designed to come back
The framework's architecture is the point. An EB-5 investment is capital placed at risk in a business: it can be lost, but it is capital, and in principle it can be returned once the programme's requirements have been met. The Gold Card contemplates a gift, which is a transfer with nothing expected in return, alongside a processing charge that pays for administration.
Neither is a deposit, an escrow or a stake. That has a direct consequence for how the decision should be made: because the money cannot be recovered by changing your mind, all of the analysis has to happen before payment. That means confirming that the objective is actually achieved by the programme, confirming who in the household is covered, and taking tax advice about what becoming resident in the United States does to a Canadian estate and to Ontario company holdings.
It also means using official payment channels only, and re-reading the terms on the day rather than relying on notes taken weeks earlier.