Should each installment have its own source-of-funds explanation?

The record should support the lawful source and path of the actual capital, including different sources used for later payments.

Connect the transfers without hiding differences

A first payment from savings and a later payment from a sale may need different underlying evidence. Preserve their real histories instead of giving every installment the first payment’s explanation.

Create a source-and-path map for every installment, starting with the asset or income origin and ending at the new commercial enterprise. Savings, sale proceeds, a gift, or permitted borrowing require their own supporting chain; a generic explanation copied from the first payment can conceal gaps. Preserve sale records, tax evidence, gift documents, loan terms, currency conversions, and transfer receipts appropriate to each source. EB-5 capital must be lawful and at risk, already invested or actively being invested. Applicable capital starts at US$1,050,000 and falls to US$800,000 only for an infrastructure project or a targeted employment area that is rural or high unemployment; the enterprise must still produce ten full-time positions for qualifying U.S. workers. A regional-center investor files Form I-526E.

Hypothetical example: A Russell surveying-firm owner funds a regional-center manufacturing project through retained salary, then sells company shares for a later installment. He should give the salary transfer and share-sale document trails, while a master table connects both to the enterprise account and offering obligations. The second payment cannot inherit the first payment’s lawful-source explanation. Counsel should reconcile names, dates, exchange transactions, and intermediary accounts before filing or supplementing, and confirm that the project’s regional-center evidence addresses the job requirement.