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PLYMPTON-WYOMING · EB-5 FIELD GUIDE

How should source-of-funds evidence be organized for EB-5?

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THE DIRECT ANSWER

Organize it chronologically so that a reviewer can follow ownership and movement of the capital without filling gaps by inference.

Create a transaction narrative

Capital derived from a business sale or family transfer should be analysed from the actual proposal, not from an abbreviated label in an email or a planning spreadsheet. The EB-5 record must address the lawful source and complete path of funds, as well as the investor’s qualifying contribution and any financing or gift terms that affect it. Start with the facts that exist today: names of parties, dates, duties, ownership rights, payments, and any condition that could change the arrangement.

A future intention can be useful context, but it should not be presented as an accomplished fact. Preserve contracts, tax records where relevant, bank statements, sale closings, loan or gift instruments, entity records, wire confirmations, and translations where required. Keep originals available and make translations complete where the chosen process calls for them.

If a document is unavailable, explain the gap accurately rather than filling it with an assumption. Family funding and family immigration eligibility are different subjects; a donor does not become an accompanying beneficiary simply through the transfer. That person’s nationality, status record, age, planned study, and planned activity may require a separate review.

Government fees, filing locations, visa availability, and procedural instructions can change, so confirm them from the current official source before money is committed or travel is booked. Use a numbered chronology with account names, dates, amounts, and a citation to the supporting page for each movement. The purpose of preparation is a clear factual record and an informed route comparison; it is not a promise that an officer will reach a particular result.