No. Explain the actual basis for the funds and the genuine transaction path.
Identify ownership and supporting records
A company bank statement may establish a balance without proving the individual’s right to use the money or every source event. Keep the account accurate.
EB-5 regulations require the investor to demonstrate that the capital was obtained through lawful means, and USCIS reads that requirement as covering both the source and the path. A first review should yield separate evidence paths for capital, the lawful source and movement of that capital, the project, the required jobs, and family timing. Review your ownership, the lender’s security and consent rights, the proposed transfer and the value actually contributed under the applicable EB-5 rules. Under current USCIS policy, however, contributed loan proceeds are evaluated as cash, and there is no categorical requirement to prove the full historic source of the collateral merely because it secures the loan. Business plans, economic reports where permitted, payroll assumptions, offering materials, and transfer records must match the selected structure.