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RURAL MUNICIPALITY OF ROCKWOOD · EB-5 FIELD GUIDE

Does an adviser’s summary replace the investor’s source records?

Sources checked:

THE DIRECT ANSWER

No. Provide genuine underlying evidence of lawful source and path.

Separate assistance from proof

An adviser can organize information without creating missing facts. Identify the relevant original transactions and supporting records rather than relying only on a prepared narrative.

Far enough to show that the funds were lawfully obtained by the deceased, using the records that reasonably exist: the estate grant and distribution, and evidence of the deceased's employment, property sales or savings from which the estate was built. The signed loan agreement, the bank's disbursement record, statements showing the investor received and then transferred the proceeds, the currency-conversion record, and the escrow or enterprise receipt establish the core source-and-path chain. How the capital was generated: financial statements over the relevant years, corporate records, tax filings, and the specific transaction that produced the funds, whether retained earnings, an asset sale or a distribution. Where funds come from a second source, that source needs the same treatment, so a matrimonial property settlement is evidenced by the separation agreement or court order and by the transfer records, not by an explanation.