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MISSISSAUGA · EB-5 FIELD GUIDE

What records should support an EB-5 cost budget?

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THE DIRECT ANSWER

Keep the subscription allocation, written fee schedules, professional engagement terms, invoices and payment receipts. Relevant source-of-funds evidence should explain the money used for administration charges as well as the qualifying capital.

Make the budget auditable

Use separate rows for the recipient, purpose, currency, due stage and refund terms. Connect each completed payment to a bank record and distinguish estimates from actual charges. Preserve the version of official fee instructions checked for filing.

If someone else pays on the investor’s behalf, disclose and document that arrangement rather than leaving the payment outside the financial explanation. The output should be a budget a stranger could audit, with one row per payment carrying the recipient, purpose, currency, due stage and refund terms. Connect each completed payment to a bank record and each pending one to the document that will govern it.

Keep the subscription allocation, written fee schedules, professional engagement terms, invoices and receipts together rather than distributed across advisers, because reassembling them later depends on people who may have moved on. Ask which of these documents the investor is entitled to receive as of right and which are provided by courtesy, since that distinction determines what can be obtained if a relationship deteriorates. Source-of-funds evidence should explain the money used for administration charges as well as the qualifying capital, so build that requirement into the budget from the first version.