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APPLICATION ANSWERS · EB-5 FIELD GUIDE

How should a Hamilton investor with a complex funding history organize their records?

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THE DIRECT ANSWER

Start from the original event that generated the funds and document the ownership, transfers, account movements and any currency conversions from that point through to the actual investment, preserving the real dates and amounts.

Explain any gaps with documents, not narrative alone

Identify who holds any missing records and exactly what fact each document is meant to establish. Where gifts, loans, or asset sales are part of the funding chain, provide their actual terms for review rather than simplifying the history to make it read more cleanly. Original transaction documents, banking evidence, project records, and the job methodology establish these issues better than balances or sales material.

Identify the custodian and date for every supporting record. For documents, annotate each link in a sale, gift, loan, inheritance, or business-distribution chain with the document proving it. The decision is whether a reviewer can follow the money without guessing at an unexplained deposit or intermediary account.

Hypothetical example: An investor uses proceeds from a printing-company estate sale; the file must link ownership, sale, estate distribution, account credits, and final transfer in sequence.