Yes, provided the funds are actually withdrawn, are his own after tax and are invested at risk in the project. Money still locked in a pension or sitting in a registered plan is not invested capital.
Capital means cash he controls and has committed
Hypothetical example: a Rothesay executive's pension statement and RRSP together exceed the EB-5 threshold, and he assumes the balance qualifies. The requirement is that the required amount be invested or actively in the process of being invested in the new commercial enterprise, and that it be at risk for the purpose of generating a return. Funds still held in a registered plan or locked-in account are not invested; they are savings.
He must first withdraw or receive the funds, pay the resulting tax, and then transfer the net amount to the project's escrow under the subscription agreement. Only that transferred amount counts toward the threshold. If the after-tax proceeds fall short, he would need another lawful source to make up the difference.
The financial adviser's schedule of net cash by source is therefore the first document the immigration reviewer needs, before any project is chosen.