Only if the comparison is honest about what happens to the money. One is a nonrefundable fee plus an outright gift to the U.S. government that is never returned. The other is capital invested and at risk in an enterprise, which may be repaid after conditions are removed. They are not two prices.
Compare what becomes of the money, not the headline totals
Hypothetical example: Yves lines the two figures up in a spreadsheet as though he were pricing equipment. The comparison misleads him in both directions. The EB-5 column understates his exposure, because capital at risk can be lost entirely if the enterprise fails, and it is accompanied by requirements he must satisfy: at least ten qualifying full-time jobs, a documented lawful source and path of funds, engagement in management or policy formulation, and a Form I-829 petition filed in the 90 days before the second anniversary of conditional residence.
The Gold Card column understates nothing about risk but overstates flexibility, because the gift is gone the moment it is made and the fee is gone before that. A more useful table has three rows rather than one: what must be proved, what is recoverable in the best case, and what is lost in the worst. Government charges are separate again and should come from the current fee schedule.