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EB-5 Source of Funds Tracing

EB-5 source of funds, stacked source by source into the money in escrow, with every hop cited and a loan counted only once its collateral is proven.

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Walk the bridge from the first bar to escrow ↓

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The problem

A paralegal rebuilds years of salary, sales and loans before anyone signs

An EB-5 trail runs back years: tax returns for the whole look-back, plus the history of each asset sold or pledged. It crosses two or three countries, mostly in the investor's language. The paralegal chases it by email and rebuilds it in a spreadsheet, and the attorney rechecks it before filing.

The surprises come late: a savings jump the salary does not explain, an account in a third country, a loan whose collateral was not sourced, a property bought before the window. Source of funds is the leading cause of Requests for Evidence, and one that arrives years later finds donors and lenders harder to reach.

Built forEB-5 partnersSenior paralegalsAssociate attorneysInvestors' accountants

The Problem Today

Investor money comes from years of salary, sales and loans, and each hop to escrow has to be proven.

6,660: EB-5 petitions, fiscal year 2025, the most on record published
7 years: of tax returns asked for on each new petition published

Rebuilt by hand today

Tax returns
Statements
Transfers
Translation

Loans questioned laterCollateral whose own source was not shown in the file
Hours the flat fee does not coverParalegal hours on one trail eat into a fixed fee

The Solution

Each source mapped to its proofSales, salary years and loans each get their papers, in any language
Each hop matched to escrowEach transfer matched in two statements and converted at the day's bank rate
Loans tested before countingCollateral must be the investor's own, valued, lien-free and lawfully held
The bridge closes, citedSources stack to the money in escrow, and the signing partner approves

Built-in controls

A loan counts only after the partner approves
Nothing filed or sent without a named person
Every output masks account and tax numbers

What You Get

Firms file a source of funds an officer can follow, with each loan proven on the investor's own assets.

10 hours: of paralegal work a file, against 40–80 today our estimate

One request to the accountantJust the missing papers, each with why it is needed
Likely RFE questions answeredThe officer's likeliest questions, each with its evidence
Records in any languageRead in the original, with English beside each page

From declared source to filed report

How EB-5 source of funds tracing builds the bridge, bar by bar

Nine features in the order the file gets built, and who uses each.

01Sources to escrow
A sources-to-escrow bridge where a bar counts only once it is proven
How it works
- Each declared source stacks as a bar toward the investment plus the administrative fee
- Apartment sale USD 412,000, salary savings USD 296,000, loan USD 157,000
- The loan bar stays hatched and unproven until its collateral test passes
- A click on a bar opens its document chain and its hops
Senior EB-5 paralegalSees that USD 708,000 of USD 865,000 is proven, and which bar holds up the file, without a spreadsheet.
02Declared sources
Each declared source opened into its evidence, read in the original language
How it works
- Three declared sources mapped to 31 required documents
- Each document shown with its language, pages, status and exhibit cite
- The purchase contract behind the sale is marked with its payment proof missing
Senior EB-5 paralegalKnows which papers each source still lacks before writing to the investor, so the ask is short and specific.
03Savings accumulation
Salary and dividends set year by year against the growth in savings
How it works
- Net salary, dividends, spending and savings laid out year by year from the tax finalizations
- VND 10.33 billion net salary and VND 2.06 billion dividends earned, VND 7.29 billion saved
- A year where savings outgrew the salary sweeps is flagged and matched to its cause
- Here a VND 310m gap, explained by a dividend paid straight into savings
Associate attorneyCan say where the savings came from before an officer asks, with a tax finalization page behind each year.
04Path of funds
A hop-by-hop path of funds, each transfer found on both statements
How it works
- Seven hops in date order, laid out in three country lanes
- Each hop opens its sent and received sides, with the statement page cited on each
- USD 865,000 sent and USD 865,000 received into the project escrow
Senior EB-5 paralegalProduces the path-of-funds chart the petition needs, drawn from the statements themselves rather than retyped across seven accounts.
05Conversions at dated rates
Each currency conversion checked against the central-bank band for its day
How it works
- Each conversion at the bank's own rate, taken from its confirmation
- The central rate fetched for each date, with a band of 5% either side
- 26,352, 26,380 and 26,370 all sit inside the band
- Wire charges paid in VND by the sender, so USD 865,000 arrives to the cent
Associate attorneyShows why each rate is what it is, before an odd-looking conversion turns into an officer's question.
06Loan collateral test
A five-check collateral test before any borrowed money counts
How it works
- Personal liability, the pledge, the valuation, the lien search and the collateral's own source
- Each check cited to its page, beside a loan-to-value gauge
- Loan-to-value 65.1% against a limit of 80%
- All 5 pass, and the loan still waits for the signing partner
EB-5 partnerApproves a loan knowing it rests on the investor's own, lawfully acquired assets, which is what a Request for Evidence asks about a loan.
07RFE risk before filing
An RFE-risk list that puts each officer question beside its answer
How it works
- Seven risks, each pairing an officer's probable question with the evidence on file
- Each raised by a named agent, with its next action
- The account abroad explained: the investor's own, holding the money 7 days
Associate attorneyCloses likely Requests for Evidence before filing, while donors, lenders and the accountant are still easy to reach.
08Request to the accountant
One request to the investor's accountant for only what is still missing
How it works
- Drafted from the open risks, asking only for what is missing
- Each item says why it matters: older salary statements behind the sale, and certified translations
- Goes out on the paralegal's approval; agents do not send
Senior EB-5 paralegalAsks the accountant once, in plain terms, and skips the string of emails for papers that turn out not to matter.
09Source-of-funds report
A cited source-of-funds report, approved for filing by the signing partner
How it works
- The investment, each source, the loan and the path, every figure pinned to its exhibit and page
- Checks beside it: loan approved, 7 hops matched, 2 items requested
- A 9-page report over 46 exhibits and 388 pages
- A person files the petition, and agents never file
EB-5 partnerCan click any dollar in the report through to its source page before approving it.

A loan that counts only once its pledged shares trace back to salary

The collateral test on the investor's VND 4,150,000,000 loan, as the partner reads it before approving.

Check	What proves it	Result
She is personally liable	Loan agreement: sole borrower, liable with all her assets, 36 months at 9.2%	Pass
Her own asset is pledged	Pledge and shareholder register: 118,000 of her 462,000 shares, in her name	Pass
The value covers the loan	Independent valuation at VND 54,000 a share, VND 6,372,000,000 in all; loan-to-value 65.1% against 80%	Pass
The lien search is clean	Registry search a week old: one registration, this pledge, and no project asset	Pass
The collateral has its own lawful source	210,000 founder shares paid for from her salary account; the rest bonus shares by board resolution	Pass

Around the bridge

What sits behind each bar of an EB-5 source of funds file

The loan's chain, one cited page, the stop abroad, the approval, the closed bridge and the record.

Loan bar opened on the bridge: seven exhibits from loan agreement to loan account statement, the registry search marked waiting on the collateral test — **The loan's document chain**Seven exhibits behind the USD 157,000 loan bar, each listed under the name it was issued with. The registry search is read but waits on the collateral test.

Exhibit page opened from a cite: a dividend notice in the original language beside its English reading, VND 310,000,000 paid into savings — **Original and English, side by side**A cite opens its page: the dividend notice in the original beside its English reading, VND 310,000,000, read at 99% confidence.

Path of funds with the sixth hop open: USD 865,000 sent and received between her own accounts, and a note on why the money passed through a third country — **The stop abroad, explained**USD 865,000 rested in her own account abroad, with no other credits that month, and her bank confirmed the transfer purpose.

Approval box for the loan bar: USD 157,000, five passing checks each cited, and the partner's reason written before approving — **The attorney's approval, with a reason**Only the signing partner lets a borrowed source count. The 5 passed checks sit above the reason that goes on the record.

Sources-to-escrow bridge closed: three solid bars reaching USD 865,000 in escrow, the loan marked secured by own assets — **The bridge closed**With the loan approved, the third bar turns solid and the proven total reaches USD 865,000. Two risks stay open before filing.

Record of the file's events: agents reading uploads and matching hops, the paralegal approving a request, attorneys confirming explained risks — **Each event on the record**Each read, check, approval and request, by person or agent, in a record no one can edit. 12 events so far.

A savings jump, a purchase outside the window and a stray cash deposit

What the agents raised on this investor's file, and where each one stands now.

Savings that outgrew the salary

Savings grew VND 0.98 bn in one year while salary sweeps were VND 0.67 bn. The VND 310m gap matches a dividend paid straight into savings and declared in that year's tax finalization.

A purchase older than the look-back

The apartment behind the largest source was bought for VND 4.9 billion before the seven-year window. The older salary statements that show the payment are now asked of the accountant.

A cash deposit nobody relies on

VND 150,000,000 in cash landed in the salary account. It is set aside, and savings still cover the transfer out: VND 8,262,600,000 against VND 7,800,192,000.

A stop in a third country

USD 865,000 passed through her own account abroad for 7 days, with no other credits that month and the bank's remittance letter on file.

Who prepares, who decides

Agents read, match, test and draft; the signing partner decides what counts

Six of them prepare the trail, and each stops where a person has to rule.

Source mapper

Maps each declared source to the evidence it needs: tax finalizations, deeds, contracts and notices.

Does not rule a source lawful; people do

Record reader

Reads statements, contracts and tax forms in the investor's language or English, scanned or digital, with an English reading beside each original.

Below 85% confidence, a person takes the field
Leaves each figure exactly as read

Path tracer

Matches each hop at both ends, converts at the bank's dated rate, and tests that rate against the central-rate band.

Leaves out any money set aside

Collateral tester

Runs the five-check collateral test on each loan in the file.

Counts no loan until the partner approves

Accumulation checker

Compares savings growth with income, year by year, against the tax finalizations, and flags each gap.

Asks, and does not accuse

Report drafter

Drafts the source-of-funds report, the path-of-funds chart, the RFE-risk list and each request.

Sends no request and files no petition

Before an EB-5 source of funds goes out: the questions firms raise

What is EB-5 source of funds tracing?

EB-5 source of funds tracing documents the lawful origin of an investor's money and each hop it took into the project's escrow. This solution maps each declared source to its evidence, reads every statement and deed in the language it was written in, matches each hop at both ends and writes the report, citing each figure to its page.

Can a loan count toward the EB-5 investment?

Yes, once it passes the collateral test: the investor is personally liable, the investor's own assets secure it, their value covers it, the lien search is clean and the collateral has its own lawful source. No project asset may secure it, and the loan bar stays unproven until the partner approves.

Can it read records that are not in English?

Yes. Statements, contracts and tax forms are read in the investor's language, with an English reading beside each original. A field read with low confidence goes to a person, and each foreign-language exhibit stays on the risk list until its certified translation is in.

Who decides what goes into the petition?

People. Each request to the client or the accountant goes out only on the paralegal's approval. Loan bars, exclusions and the report need the attorney of record's approval. Agents do not file, and do not contact the client, the accountant or the immigration agency.

How are the investor's records protected?

Every output masks account and tax numbers. The accountant sees this investor's request list and nothing else, each read, change and approval is logged, and the investor's papers train no model.

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