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APPLICATION ANSWERS · EB-5 FIELD GUIDE

Which records explain staged funding?

Sources checked:

THE DIRECT ANSWER

Provide the actual governing agreements, amendments, payment records and conditions for each stage.

Use the real transaction

Do not rely solely on a marketing timeline. The review needs to understand what the investor must do and what has actually occurred. Hypothetical example: a Canadian commercial-linen business owner plans to use proceeds from a company sale, a secured personal loan, and savings accumulated over several years for an EB-5 subscription.

Prepare a traceable source-and-path file rather than a summary of net worth. Start with the event that generated each source—sale, salary, dividend, loan, inheritance, or gift—then connect it through tax records, contracts, bank statements, account histories, and transfer receipts to the enterprise. The first review should mark every unexplained deposit, currency conversion, intermediary account, or shortfall between the claimed source and the amount invested.

The relevant project records include the subscription or offering documents, escrow terms, business plan, job-creation materials, fees, capital deployment schedule, and evidence of the commercial enterprise. Do not let a marketing brochure stand in for the agreement that binds the investor. If a loan is involved, establish the lawful source of loan proceeds and the collateral facts; do not assume any borrowed funds receive identical treatment.

Certified translations and complete copies matter when a transaction occurred abroad. Sequence the work by gathering primary evidence first, writing a timeline second, and only then preparing explanatory declarations. Problems arise when the story is plausible but the bank trail jumps over a corporate account, family transfer, or tax year.

A document bundle should permit a reviewer to follow the money without filling gaps through inference.