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APPLICATION ANSWERS · EB-5 FIELD GUIDE

Can the sponsor’s diligence report prove the investor’s source of funds in Saskatoon?

Sources checked:

THE DIRECT ANSWER

No. The individual funding history needs its own authentic evidence.

Trace the actual money through each relevant event

Identify ownership, sale proceeds, distributions, transfers and conversions as applicable. A project’s legal or financial report does not explain where this applicant obtained the capital. Prepare a source-and-path ledger that starts with how the investor acquired the money and follows every sale, loan, gift, distribution, account and currency conversion into the investment.

Keep project materials in a separate folder. Hypothetical example: a specialty-ceramics owner receives dividend income through a holding company before wiring funds from a personal account. Corporate resolutions, financial statements, tax material, bank records and transfer receipts explain the chain.

The project’s subscription paperwork cannot prove those earlier events. If a record is unavailable, describe the gap and seek a reliable alternative rather than inventing continuity. The review should also itemize fees so administrative charges are not misdescribed as capital at risk.

Reconcile the ledger against actual statements before filing, and explain a discrepancy in plain terms. Source analysis is often weakened by unexplained account movements, even when the investor’s overall financial position is substantial.