Jobs in TEA area only?

Question from another immigration attorney:

EB5 Question regarding the targeted employment areas – the regs require that the investment must be made in a new commercial enterprise in a “targeted investment area”. And the definition of targeted investment area is defined by having a high unemployment rate or you also have rural area. Question – for the 10 employees – do they have to be in the same area or if the business in located in the TEA or Rural but jobs are somewhere else? I am thinking that by the definition of TEA and Rural, this would be circumventing the intent of the law?