Possibly. The Child Status Protection Act does not simply freeze age; it generally subtracts the I-526 or I-526E petition's pending time from the child's age when a visa becomes available, and the child must seek to acquire residence within one year. Have the calculation reviewed before filing, not after.
Run the age calculation before choosing the filing date
EB-5 derivatives are the spouse and unmarried children under 21 at the relevant date. The Child Status Protection Act subtracts the time the I-526 or I-526E petition was pending from the child's age when a visa becomes available, and requires the child to seek residence within a year of that availability. Hypothetical example: a Boischatel couple's daughter is nineteen and a half when the family begins preparing; if the petition takes two years to adjudicate and a visa is immediately available, her CSPA age could still be under 21, but a Visa Bulletin backlog can change that outcome.
The calculation should be run with current processing estimates before the petition is filed. Once conditional residence is granted, the daughter holds it in her own right and ordinarily may be included on the principal investor's Form I-829; a separate filing is available in specified circumstances. A child who marries before conditional residence is granted loses derivative eligibility.
Each family member's actual nationality should be recorded, since a non-citizen permanent resident of Canada qualifies as a derivative as long as the relationship is proven.