All rights reserved by International Creative Capital (ICC) – ICC teams have 15 years of EB-5 experience and expertise.
Published Date: August 13, 2025
Why We Developed This Guide for EB-5 Investors
Having worked with EB-5 investors from around the world for over 14 years, we’ve observed one issue that consistently generates the most stress: source-of-funds documentation.
You may already have the investment funds, but the challenge is demonstrating to USCIS’s satisfaction where that money came from and how it was legally obtained. 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, Vol. 6, Pt. G, Ch. 2; EB-5 SOF guidance, Sept 19, 2025)
We’ve written this article to guide you on what really counts, not in theory but based on what’s worked in hundreds of successful EB-5 cases under ICC’s direction.
Understanding USCIS Requirements for Source of Funds
What USCIS Expects to See
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. to the investment in the EB-5 project you selected. (USCIS I-526E instructions; EB-5 SOF summaries 2025).
Why the Transparency is Tactful
One of the leading factors contributing to EB-5 backlogs and Requests for Evidence (RFEs) is the presence of inadequate, incomplete, or undocumented 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.
An EB-5 advisor would tell 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 TEA Investment Explained
What Is a Targeted Employment Area (TEA)?
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 instead of the standard $1.05 million. (USCIS Policy Manual; USCIS EB-5 overview updated Apr 1, 2025)
Faster TEA Approval
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, legal funds can come from various sources and that is where we come in.
At ICC, we have helped investors from different backgrounds (entrepreneurs, etc.) get their approvals using entirely lawful funding:
How to Structure and Document Your EB-5 Source of Funds
Options That Work in the Real World
Over the years, we have witnessed investors qualify using these sources of lawfully gained funds:
- Real estate-backed loan or pledged investment portfolio
- Each case is different. The secret is to make the entire money trail, from the start of ownership to the ultimate transfer, traceable and documented.
How We Assist You in Preparation
At ICC, we collaborate with your immigration lawyer to create a USCIS-ready Source of Funds package. A package that’s pre-emptive in addressing examiner questions before they are even posed.
The ICC Method: Our Strategies for Meeting the EB-5 Source of Funds Requirement
Strategic Planning
We figure out which Source of Funds option is the most traceable and compliant. This protects you from risk and delay.
Tracking All Transactions
All transactions are organized and documented in compliance with USCIS requirements, creating a clear money trail.
Streamlined Process
Our staff works hand in hand with your immigration attorney, financial advisor, and project representative to ensure prompt, stress-free filing.
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
Even a perfect set of documentation for your funds will not matter if you choose a poor project. I’ve seen investors with flawless paperwork stuck in the backlog simply because their project wasn’t ready for adjudication.
A Tried and Tested Example: Canopy by Hilton – Minneapolis Mill District
We at ICC only work with projects that are pre-approved by USCIS I-956 and have shown actual job creation through completed projects. In the Canopy by Hilton – Minneapolis Mill District project, the construction was financed using temporary bridge financing. This hotel is now completed; it is up and running and is ready for EB-5 funds to replace the bridge loan. USCIS historically accepts this structure for qualified job creation and is a safe investment option for investors, as the project is already constructed, creating jobs, and does not rely on their funds to start construction. (Industry project disclosures; USCIS job creation rules on bridge financing)
The Canopy by Hilton project provides:
- Increased approvals (12–24 months in recent instances)
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 hold Green Cards after months of stress. We often tell people, “This is the reason we devoted our entire career to this process.”
The outcomes are not coincidental or arbitrary, but a product of careful planning, preparation with the appropriate documentation, and an investment in a Regional Centre that emphasizes compliance and transparency from day one.
My Final Thoughts: Turning Documentation into Your EB-5 Advantage
Your EB-5 experience is an investment in your future, and your Source of Funds documentation is the foundation upon which that experience rests.
Done correctly, it’s not an obstacle; it’s your best evidence of credibility.
Suppose you’re ready to start building your EB-5 investment and would like hands-on support from a team that’s assisted investors to 100% Green Card approval. In that case, we invite you to contact us.
Reach out to us directly at mantone@InternationalCreativeCapital.com
Let’s discuss how we can craft your EB-5 Source of Funds strategy with clarity and confidence.
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 should be verifiable as EB-5 source-of-funds documentation to provide a clear trail of every dollar put 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. You will be required to report the donor’s lawful source of funds, as well as a notarized gift deed and transfer records for your EB-5 Source of Funds documentation.
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 for USCIS submission by conducting detailed tracing, organising the documents to be included in the package, and working with your attorney. We have had 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, for example, the Canopy by Hilton – Minneapolis Mill District, so that your documentation supports a real, USCIS-approved investment.