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How to Structure Your Finances for a Successful EB-5 Source of Funds Review?

Raman Arora • 22nd August, 2025How to Structure Your Finances for a Successful EB-5 Source of Funds Review?

One of the most critical but often misunderstood requirements for the EB-5 immigrant investor visa is proving the lawful origin of your funds. USCIS demands proof of how you got it, where it’s been, and how it’s being transferred. That’s the essence of the EB5 Source of Funds requirement.

Whether you’re funding your investment via personal savings, real estate sales, inheritance, or an EB5 Loan, the way you structure your finances before applying will directly influence whether you get a smooth approval.Let’s break it down.

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What is the EB5 Source of Funds Requirement?

To get approved under the EB-5 program, you must invest $800,000 (in a Targeted Employment Area) or $1.05 million (non-TEA) into a qualifying project. But that’s just the beginning. You must also provide clear, traceable documentation showing that this money comes from lawful, verified sources.

This requirement is designed to:

USCIS will not proceed unless the entire investment amount (plus any administrative fees) is clearly accounted for.

Most Investors Now Use EB5 Loans

As costs rise, many investors are turning to EB5 Loan options to finance their green card. A well-structured loan is a valid source of funds if and only if, it meets certain strict criteria.

USCIS Requirements for EB5 Loans:

Unsecured loans or informal arrangements often lead to denials.

Must read: Top Performing EB5 Projects in 2025: Where Investors Are Putting Their Money

Step-by-Step: How to Structure Your Finances

Let’s walk through how to organize each potential funding source for success:

1. Salary and Personal Savings

This is one of the cleanest forms of funding—but it still requires detailed records.

You’ll need:

Tip: Make sure tax returns match the salary credited. Inconsistencies delay the process.

2. Real Estate Sales

USCIS often scrutinizes these. You’ll need to show both the acquisition and sale were legal.

Provide:

Tip: If the property was inherited, include probate documents and original purchase records.

3. Gifts from Family Members

You can use gifted funds—but you must prove the lawful source of the donor's funds, too.

Required docs:

Common mistake: Not documenting how the donor got the funds. USCIS needs this too.

4. EB5 Loan

This is where structuring becomes especially crucial.

You’ll need:

Big rule: The collateral must be yours. Loans secured by third-party assets are usually rejected.

5. Business Profits

If you’re a business owner or investor, you can use profits or dividends—but they must be traceable and taxed.

Required documents:

6. Crypto and Stock Sales (New in 2025)

Digital and equity assets are now commonly used but they must be clearly traced and legalized.

Submit:

Caution: Self-custodied wallets without third-party validation may be problematic.

Must read: Save $400K: The Strategic Investor's Guide to EB-5 Green Card in 2025

Create a Clear EB5 Source of Funds Table

A structured breakdown not only helps USCIS officers understand your case more easily, but it also signals that your documentation is thorough and well-prepared.

Here’s an example of how a strong source of funds narrative might read in paragraph form:

To fund the required $800,000 investment, the applicant structured their capital from four main sources, each well-documented.

First, $300,000 was accumulated from salary savings over several years of employment in India. The applicant provided consistent payslips, matching income tax returns, and personal bank statements that reflect regular deposits aligning with declared income.

Next, $250,000 was generated from the sale of a property. Supporting documentation includes the registered sale deed, capital gains tax receipts, and records of the bank transfer showing the proceeds from the buyer being deposited into the applicant’s account.

Another $100,000 was received as a gift from the applicant’s father. To meet USCIS standards, the petition includes a notarized gift deed, the father’s tax returns and ID documents to prove the lawful origin of the funds, as well as documents establishing their familial relationship.

Lastly, $150,000 was secured through an EB5 Loan, backed by the applicant’s own residential property. The petition includes a legally binding loan agreement, proof of property ownership used as collateral, a professional valuation report of the asset, and bank records confirming receipt of the loaned amount.

EB5 Fund Structuring:

1. Include Currency Conversion Evidence with Official Rates

Many applicants convert their local currency to USD in documentation but forget to attach an official source for the conversion rate used on the date of transfer. Use RBI, OANDA, or XE.com and attach a screenshot or certificate showing the rate at the time of each major transfer.

2. Show the “Chain of Custody” for Each Fund Source

3. Don't Mix Investment and Personal Funds in the Same Account

Opening a dedicated bank account just for EB5 transactions shows financial clarity and good intent. Avoid transferring your EB5 funds into a joint account or one that also handles routine personal expenses. This makes the audit trail much messier and harder to defend.

4. Document the Accumulation Timeline, Not Just the Amount

USCIS likes to see gradual and logical accumulation of funds, especially in the case of salary savings. Don’t just show that you have $300K, show how you saved it over time, using tax returns and consistent deposits. Random large inflows can appear suspicious if not contextualized.

5. Add a Personal Declaration or “Funds Narrative Letter”

Many investors overlook the value of writing a simple 1–2 page narrative letter explaining how the funds were earned, moved, and structured. This is not legally required but helps USCIS reviewers understand the big picture without hunting through documents. Attach this with your I-526 petition.

6. Use Sworn Affidavits for Non-Documentable Events

In countries where formal documentation is weak (e.g., cash-based cultures or family-run property transfers), use a notarized affidavit explaining what happened, who was involved, and why records may be missing. Have it supported by witnesses or community leaders where applicable. This shows transparency even if documentation is limited.

7. Translate & Localize All Non-English Documents

Every non-English document must be accompanied by a certified English translation. But here’s what’s often missed: translation of handwritten notations, bank stamps, and local acronyms. If your bank statement has a local-language stamp or code, USCIS might misread or ignore it. Add a footnote in the translation explaining the term or stamp meaning.

8. Cross-Check Your Own File

While your immigration attorney plays a critical role, take time to personally review your source of funds documentation to ensure cultural and legal clarity, especially if your country has non-standard banking or tax practices.

9. Explain Dormant or Inactive Accounts Suddenly Used for EB5

If you’ve activated an old or unused account to consolidate funds for EB5, attach a statement explaining why. USCIS may flag sudden large inflows or account reactivation as suspicious. A simple explanation in your narrative or cover letter can solve this.

10. Record Proof of Tax Compliance in Both Countries (If Dual Income)

If you’ve lived in or earned from more than one country, ensure that both sets of tax compliance records are attached. For example, Indian nationals working in UAE often forget to include Indian tax compliance for earlier earnings. This gap can lead to avoidable delays or denials.

Important article: Cut Your EB-5 Cost in Half: How the EB5 Loan Program Saves You $400,000 Upfront

Common EB5 Source of Funds Mistakes to Avoid

Tips for 2025 Investors

Start Preparing:

The EB5 Source of Funds review is not just about having the capital. It's about telling a clear financial story with proof. Think of your case: every dollar has a backstory.

And if you’re using an EB5 Loan: every document, every asset, and every transaction must be legitimate, traceable, and well-explained.

Save $400,000 upfront with our Our EB5 Loan Advantage

🛎️ Take advantage of your FREE call with immigration experts on how the EB-5 Loan Strategy can work for you.

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