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APPLICATION ANSWERS · EB-5 FIELD GUIDE

How should an investor with a complicated funding history organize the records?

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THE DIRECT ANSWER

Start from the specific event that generated the funds and trace ownership, payments, account transfers, and any currency conversions all the way to the actual investment. Keep the real dates and amounts rather than smoothing over gaps or inconsistencies.

Fill gaps with records, not with a cleaner narrative

Identify who holds any missing documents and exactly what fact each one is meant to establish. Where gifts, loans, business distributions, or asset sales are part of the funding chain, provide their actual terms for review rather than simplifying the description.

A supporting narrative can explain a record, but it cannot substitute for a transfer or event that has not actually been documented. Gifted or borrowed funds require lawful-source evidence and a good-faith arrangement that is not used to circumvent restrictions on permissible capital sources.