EB-5 Source of Funds: Our Guide to Document Your Lawful Investment and Faster U.S. Residency

Published Date: August 13, 2025

Part 2: Complexity of Source-of-Funds Documentation

Why ICC developed this guide for EB-5 Investors

Having worked with EB-5 investors from around the world for over 15 years, we have found that investors experience significant stress in compiling proper source-of-funds documentation that meets USCIS scrutiny. USCIS requires investors to have a well-documented source of funds from the origin to the investment in the EB-5 project. 🔗USCIS Policy Manual

We’ve written this guide to advise you on what really works — not in theory, but based on what’s worked in all of our EB-5 cases, with a 100% approval rate and no requests for evidence under ICC’s direction.

Understanding USCIS Requirements for Source of Funds

USCIS Compliance

The EB-5 application process involves the United States Citizenship and Immigration Services (USCIS) reviewing your application not only for the invested capital, but also for the source of every dollar invested. The documentation should show a trail of how the funds originated —whether from salary, business income, real estate sales, etc. —for the investment in the EB-5 project you selected. 🔗USCIS I-526E instructions

Why Transparency is Important

One of the leading factors contributing to EB-5 backlogs and Requests for Evidence (RFEs) is the presence of inadequate, incomplete, or undocumented fund transfers. Producing a transparent, documented financial trail is not only complying with the law, but it will also create confidence for your adjudicator in approving your case.

A seasoned EB-5 advisor would advise a client to keep all records of every financial transaction, including bank statements, loan approvals, and gift letters, to prepare for USCIS questioning and avoid RFEs. (Lexology compliance alert, Oct 13, 2025; industry attorney guidance)

The $800,000 Targeted Employment Area (TEA) – TEA Investment Explained

A TEA is an area that USCIS has categorized as high-unemployment, a specific infrastructure project, or a rural designation. Projects in a TEA are eligible for the reduced EB-5 investment amount of $800,000, rather than the standard $1.05 million. 🔗USCIS Policy Manual; USCIS EB-5 overview updated Apr 1, 2025

Faster TEA Approvals

These categories have reserved visas and are currently receiving priority processing; some sources report approvals in as little as 12 months. The reported average is 6-15 months, much less than the standard cases, which take 12-24 months. 🔗 IIUSA processing report Sept 23, 2024; I-526E timelines June 26, 2025

How ICC Helps You Qualify

Most of our investors are surprised to learn they don’t have to provide the full $800,000 in cash. With proper structuring, funds can come from many different sources. That is where ICC comes in, with 15 years of experience in helping investors navigate the best possible financial solution for each investor. This hands-on approach enables us to work with investors from diverse backgrounds, including students, business owners, and entrepreneurs.

How to Structure & Document your EB-5 Source of Funds – Options that Work in the Real World

Over the years, we have guided investors using these sources of lawfully gained funds:

- - Loans secured by real estate or other personal property (e.g., investment portfolio or a family home)
- - Gifts or loans from family members (documented and properly transferred)
- - Proceeds from the sale of a business, property, or other lawful assets
- SBA loans for established business owners

How ICC Assists You in Preparation

At ICC, we collaborate with your immigration lawyer to create a USCIS-ready Source of Funds package, backed by our team’s 15 years of success helping investors achieve a 100% Green Card approval rate for both I-526 and I-829 petitions, with zero source-of-funds RFEs. This protects you from risk and delay.

The ICC Method: Our strategies for Meeting the EB-5 Source of Funds Requirement

- - Strategic Planning
    We strategize with you and your attorney to determine which Source of Funds option is the most traceable and compliant, thereby moving your case along more efficiently with no Requests for Evidence (RFEs) that could cause delays.
- - Tracking All Transactions
    All transactions are organized and documented in compliance with USCIS requirements, creating a clear money trail.
- Streamlined Process
  Our staff works closely with your immigration attorney, financial advisor, and project representative to ensure a prompt and stress-free filing process. With this attention to detail and teamwork, ICC has maintained a 100% approval rate for green card applications for both I-526E and I-829 petitions.

Why Your Project Choice Matters in Approving Your Application – An Insider’s Perspective

- - Why Your Project Choice Matters
    With your capital investment, proper documentation, and a flawless source of funds, it will not matter if you choose a high-risk project that does not complete. We have heard of investors with well-documented paperwork stuck in the backlog simply because their project wasn’t ready for adjudication, either because it didn’t meet all USCIS requirements, such as job creation in a new commercial enterprise, or because it was never completed.
- A Tried and Tested Example: Canopy by Hilton – Minneapolis Mill District
  At ICC, we work with projects that are pre-approved by USCIS, have an approved I-956, and have demonstrated actual job creation through a completed project. The 🔗 Canopy by Hilton – Minneapolis Mill District Hotel project is financed through temporary bridge financing. The EB-5 funds are used to replace the bridge loan. USCIS has historically approved this structure and has provided bridge loan compliance information in the 🔗 USCIS EB-5 Handbook.

Real Results, Real Families: What Success Looks Like for Our Investors

With each case we handle, there is always a story or experience associated with that approval: a family together in the U.S., an entrepreneur reopening a business, or a student changing from a temporary visa to permanent resident status.

We never tire of watching our clients receive their Green Cards after months of waiting. We often tell people, “This is the reason ICC has devoted our entire company to this process and welcomes so many into the ICC family.” The outcomes are not coincidental or random, but a result of careful planning, preparation with the appropriate documentation, and an investment in a Regional Center that emphasizes compliance and transparency from day one.

Final Thoughts: Turning Documentation into Your EB-5 Advantage

Your EB-5 experience is an investment in your future and your family’s residency, and your Source of Funds documentation is the foundation upon which that experience rests. When it is done correctly, it’s not an obstacle; it’s your best evidence of credibility.

When you’re ready to start building your EB-5 investment and would like hands-on support from a team that’s assisted investors with 100% Green Card approval. We invite you to start the journey now with a trusted partner and welcome you to the ICC family.

Reach out to us directly, and we will start your journey together. 🔗 Contact us.

Frequently Asked Questions

What is EB-5 Source of Funds Documentation?

EB-5 Source of Funds Documentation comprises the financial documentation that shows the funds you are investing in your EB-5 project were legally acquired. The documentation must clearly demonstrate to USCIS a verifiable trail of all funds transferred from the source of funds, such as salary, business earnings, proceeds from the sale of property, or inheritance, showing a clear path to your ultimate EB-5 investment account.

What kind of funds are eligible for EB-5 investment?

Your EB-5 investment could come from various legal sources, such as personal savings, business earnings, real estate proceeds, gifts, or loans from family, or a combination of all the above. All must be verified as your EB-5 source-of-funds documentation to provide a clear trail of every dollar invested into EB-5 from origin to investment.

Can a gift of money be used for an EB-5 Investment?

Gifts are a lawful source of funding for an EB-5 investment, provided they are appropriately documented. ICC will work with you and your immigration attorney to provide you with appropriate documentation that you will be required to submit, including documentation of the donor’s lawful source of funds.

How can International Creative Capital (ICC) assist with EB-5 Source of Funds documentation?

ICC will assist an investor in creating a Source of Funds package together with their immigration attorney for USCIS submission that meets all USCIS requirements. We have a 100% approval rate for both I-526E and I-829 petitions because we ensure the EB-5 documentation submitted is complete and compliant.

Does the choice of EB-5 project influence the timeline and success of my petition?

Yes. The project will always affect the overall timeline and success, even with perfect Source of Funds documentation. ICC only works with pre-approved job-creating projects, like the 🔗 Canopy by Hilton – Minneapolis Mill District, so that your documentation supports a real, USCIS-approved investment.

The Journey begins here. Contact us now to discover what it’s like to be part of the ICC family. 🔗 Contact us today.

In case, you missed earlier parts of this series, you can catch up here:

References:

🔗 USCIS Policy Manual
🔗 USCIS I-526E Instructions
🔗 USCIS Policy Manual; USCIS EB-5 overview updated Apr 1, 2025
🔗 IIUSA processing report Sept 23, 2024; I-526E timelines June 26, 2025
🔗 USCIS EB-5 Handbook

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EB-5 Source of Funds Documentation: Our Guide to Your Lawful Investment and Faster U.S. Residency