Highlights of EB5AN’s Investor Interview Series: “Strategies for I-526E Source of Funds Documentation”

Source of funds is one of the most important parts of an EB-5 I-526E filing. USCIS reviews every investor’s funding path closely and expects a complete, consistent paper trail. When your documentation is clear and organized, you reduce the risk of a long pause while USCIS asks for more evidence. When it is incomplete or confusing, the process can slow down fast—sometimes for months—or create serious risk for the petition.

For investors who want to start the immigration process and receive their Green Cards as quickly as possible, that reality matters. A strong project and a strong regional center are essential, but they do not replace a clean source of funds package. The best outcome is a filing that answers USCIS’s questions before they are asked: where the funds came from, how they moved, why the records match, and how the story holds together from first document to final transfer.

That is why it is so useful to learn from investors who have already completed this step successfully. In our investor interviews, people share the practical choices that made their filings smoother—how they selected attorneys, what responsiveness looked like in real life, how they handled documentation from multiple countries or years, and what they wish they had prepared earlier. These are the details that can save time, reduce stress, and help you avoid expensive refilings.

EB5AN has built a testimonial library with over 20 full-length investor interviews—real conversations about real decisions. No other EB-5 firm has gone to these lengths to educate investors with this level of candid, practical insight.

This post is the ninth installment in our new series that revisits some of the most compelling interviews in that library, each one focused on a key part of the EB-5 process. Here, the focus is source of funds: how successful investors approached documentation, how they worked with their attorneys, and what strategies helped them present a clear, credible package. Below, you will hear their words directly—and we will explain the lessons you can apply to your own filing.

We also invite you to watch these highlights in the following compilation video featuring our investors’ key responses.

Watch All EB-5 Investor Testimonials

Make Your Source of Funds Clear

I would say the one thing to consider is to kind of put yourself in the shoes of the person evaluating the application, specifically in terms of the source of funds. They are looking exactly where that money came from. And when I say exactly, I mean exactly. I mean yes, I’ve been investing over the last 25 years. It’s very easy to say that the money came from the gains that I’ve had over the 25 years, but that just is not necessarily good enough. We had to track it back to one specific—say an extract from the company that I’m running right now—and kind of trail it through the whole banking system until it got in the hands of EB5AN and the ONE Tampa project. (Mike — ONE Tampa Urban)

Mike’s framing is the right starting point for any EB-5 source of funds plan. You want your documentation to read the way a good audit file reads: clear origin, clear ownership, clear movement, and no unexplained gaps. If you treat the reviewer as your audience from day one, you naturally build a packet that answers questions before they are asked.

It also helps to think in categories USCIS already expects to see, because many investors are combining salary, business income, investment proceeds, and asset sales. The source of funds FAQ library is a useful way to plan early and make sure you are not missing a standard piece of evidence

Mike is pointing at a common mistake: investors assume that a reasonable explanation will substitute for the underlying documents. It usually will not. Your file is stronger when it is grounded in the kinds of materials USCIS is used to weighing, like tax filings, pay records, bank statements, contracts, and closing documents, with a clean exhibit structure. If you are not sure what “enough” looks like, review the list of specific documentation USCIS often expects and map each document to a step in your story.

USCIS also tends to focus on consistency across documents. Dates, names, account numbers, and transaction amounts need to line up. A single mismatch can trigger questions that slow the case down. This is why a careful approach to additional source of funds considerations matters even when the source itself is lawful.

Even if the money is unquestionably yours, the movement still needs to be explained. Transfers between accounts, currency conversions, brokerage liquidations, and staged wiring can all be legitimate, but they create more steps to document. USCIS does not “assume” a transfer makes sense. Your attorney’s job is to make each step easy to verify, and your job is to supply the records that prove the step actually happened.

So just to circle back and answer your question, I think the important thing is don’t take the source of funds lightly, and make sure that you can track the investment properly. And I’m in the middle of it, but I think that at the end of the day, that’s what’s going to get an application to run through smoothly. (Mike — ONE Tampa Urban)

The I-526E petition rises or falls on the strength of what you submit. Source of funds is not a “supporting” component; it is central to the filing. If you want to understand how USCIS views the petition as a whole, it helps to review EB5AN’s investor guide to Form I-526E and then place your source-of-funds narrative inside that broader framework.

Plan Enough Time For Your I-526E Source of Funds Work

I did not know it was going to be this labor-intensive. In fact, when I spoke to an immigration lawyer, and she gave me a sense of how much effort it would require, she said a lot of applications are 3,000-5,000 pages. I did not believe her, honestly, because that just seemed like a lot. And I have been through the H-1B process several times and come to the U.S. as a tourist in the past as well. I thought, “Okay, how much more paperwork can they really ask for?” (Siddarth — Twin Lakes Rural)

Siddarth’s surprise is common. Many investors come into EB-5 with prior immigration experience and assume the paperwork is comparable. It is not. Source of funds is a documentation project. Treat it like one. If you want a realistic view of the level of detail USCIS expects, read the background on I-526 evidentiary standards and RFEs. It clarifies why “more” is often required even when the story is straightforward.

But from USCIS’s perspective, they’re going to permanently admit an individual and family members into the U.S., and the route we are taking is by investing in an entrepreneurial enterprise in the U.S. So, it’s extremely important for the government to get comfortable with the fact that the individual they are admitting has taken an ethical route of earning their funds or taking a loan from friends. (Siddarth — Twin Lakes Rural)

When the funds include loans, gifts, or support from relatives, the file expands quickly. Now you are documenting more than one person’s finances. If you want a clear view of what USCIS expects for these scenarios, the discussion of best practices for gifted and loaned funds is a strong reference point.

It was a bit of an intense process and having time to focus on it was really important. People who are considering this process while also having full-time jobs should allocate 2-3 months to make sure all their paperwork is in order. It could be straightforward if all the income has been sourced within the U.S. and they have $800,000 ready in their account. However, if the money has been sourced from friends and family, there will be things like promissory notes, sources of income, and bank statements to show the legality of the funds, which can take time. (Siddarth — Twin Lakes Rural)

Time matters because the work is not only collecting documents. It is collecting the right documents, translating when needed, and filling gaps before your attorney finalizes the narrative. If you file incomplete, USCIS can still proceed, but it often proceeds by stopping your case and asking for more. The consequences of that approach are laid out in the FAQ on filing an incomplete I-526 and adding documents later.

If Possible, Simplify Your Funding Sources

They sent me all the document checklists, what to collect and then what all I need to upload. And then they went through different source of funds plans. And then they simplified my overall portfolio. I was initially planning to choose the most optimal set of funds so that I don’t need to liquidate most of my stocks, but then that led to too many source of funds, like four or five different sources, because I was trying to optimize the stock sales. But that would create a risk, because you have too many source of funds to evaluate. So they came up with a simplified process, like what makes sense to be liquidated. So that recommendation process and everything was great. Yeah, hopefully that doesn’t raise any red flags. (Prakash — Rocky River Rural)

A plan with five sources may be perfectly lawful, but it creates five mini-cases USCIS must follow. Many investors are better served by choosing fewer sources, even if that means making a less “perfect” financial move, because it reduces the number of moving parts USCIS must verify.

And then time-wise, once I hired them, it probably took me around four to five weeks just to get the source of funds finalized, all the documents finalized. It took me almost a week to download all the documents. I downloaded all the pay slips and bank statements even before I selected the attorney because I knew those are some of the things that are necessary. But then I had to document so many other things, like all the different bank statements, all of my rental property details, HELOCs, etc., investment brokerage. So I downloaded all of those funds and the statements, and then I uploaded them. (Prakash — Rocky River Rural)

This is a helpful starting point. Start gathering what you already know you will need, then fill in the less obvious items once your attorney confirms the plan.

Prakash also highlights that “source of funds” often includes more than investors expect.

Be Ready to Collaborate With Your Immigration Attorney

They took almost another week or so, probably like two weeks, to review all of that and then came up with a simplified next set of questions or simplification recommendations. (Prakash — Rocky River Rural)

Good attorneys review your documentation, spot gaps, and then ask targeted questions to close those gaps. That process can feel repetitive, but it is how you avoid avoidable USCIS questions later. If USCIS does ask questions, your response needs to be organized and complete, which is why it helps to understand the mechanics of responding to a USCIS RFE even if you never want to receive one.

As Prakash takes below, this process can take several weeks.

And it probably took another two to three different weeks to fully finalize on the source of funds, like which account, how much money I should liquidate, which account it should be deposited to so that there’s not too many transactions going in and out. It keeps everything simpler. (Prakash — Rocky River Rural)

Choose an Attorney Who Is Experienced in EB-5 and Thorough

Anahita is very good at that, and I will really recommend her. So even at 10:00 in the night, if I send a SMS that “Okay, what is expected out of this requirement?” she will respond back at 10:00 or in the early-morning hours. She is very responsive, and she replies very quickly about all the queries. She always tried to make sure that we understand the process and we are well-prepared what is expected in the future and what is going to come and what all documentations are a must and why it is required. (Kishore — Bay Creek Rural EB-5 Project)

The right immigration attorney sets expectations, answers quickly, and keeps the filing process moving. If you are evaluating attorneys, the checklist in critical questions to ask before hiring an EB-5 attorney helps you screen for responsiveness and real EB-5 experience.

Responsiveness also matters because EB-5 is a long process. Your attorney needs to function as your guide and advocate, especially at the I-526E stage. That broader role is discussed in our webinar recap on why experienced counsel matters, and it connects directly to source-of-funds success.

She is very thorough with her job. And lot of documentations are required for source of funds. So I will advise that hire some attorney who has very good experience in EB-5 filing. (Kishore — Bay Creek Rural EB-5 Project)

Not every immigration attorney handles EB-5 regularly, and source of funds is one of the areas where that difference shows quickly. EB-5 investors should look for counsel who can explain what USCIS expects and who has built and defended these packets many times. A straightforward overview of what to look for is EB5AN’s guide, How To Choose The Right EB-5 Immigration Attorney.

I think the first key thing would be if there are any international source of funds involved, like gifts from friends or family, or anything coming from outside of the United States, then you need to have an attorney that understands how that money is coming in and being funded for the EB-5 project. For us, it was fairly straightforward with all of it being salaried funds from the U.S., but a lot of times it’s very complicated. And so having an attorney that has an understanding of the cross-border taxation and what’s allowed to be used for EB-5 is really helpful. (Niharika and Ishaan — Rocky River Rural)

This is where general immigration experience is not enough. Cross-border funds create tax, transfer, and documentation issues that vary by country and by funding type. If you want a strong example of how experienced EB-5 counsel thinks about this, the webinar recap on source of funds for Indian EB-5 investors shows the level of detail that often comes into play.

Even when an investor is using U.S. salary, there are still documentation standards that must be met. For many Indian investors in the U.S., this comes up in a very practical way, and the article on using U.S. salary to fund EB-5 is a good reminder that “straightforward” still requires proof.

Getting Started on EB-5

If you want a fast, smooth I-526E filing, treat source of funds like the main work—not a checklist you rush through at the end. Start early, preferably choose a simple funding plan you can document cleanly, and build a packet that shows primary records, a clear timeline, and a complete trail from origin to the EB-5 transfer.

Then work with an attorney who does EB-5 source-of-funds every day and will push for accuracy, consistency, and speed. As EB5AN managing partner Sam Silverman puts it: “USCIS doesn’t approve good intentions—they approve clear records. When your source-of-funds package is organized, complete, and easy to verify, you give your case the best chance to move without delays.”

For personalized guidance, schedule a free consultation with EB5AN.