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APPLICATION ANSWERS · EB-5 FIELD GUIDE

How should a Halifax investor organize a complex funding history for EB-5?

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THE DIRECT ANSWER

Start from the event that generated the funds and trace ownership, transfers, conversions and accounts through to the actual investment, keeping genuine dates and amounts rather than presenting a simplified summary.

Explain gaps with documents, not narrative alone

Identify who holds any missing records and what specific fact each one is meant to establish. Where gifts, loans, inheritances or asset sales are involved, provide their real terms, since a narrative cannot substitute for a transfer or agreement that was never actually documented.

Create a source-of-funds chronology that names every account, transfer, entity, sale, loan, tax record, and person involved. Match amounts and dates, and explain gaps rather than leaving a reviewer to infer them. Hypothetical example: proceeds from a vintage-instrument restoration business were deposited into a corporation, distributed to the owner, and later wired from a joint account. The investor should gather the records for each movement and the authority for the distribution. EB-5 capital must be at risk and traceable as required; the file must also support the qualifying employment result that underlies conditional residence.

A reconciliation spreadsheet can flag any transfer whose sender, recipient, date, or amount needs further proof.