# Source-of-Funds Document Checklist by Fund Type > Itemized document checklists for the seven most common EB-5 fund sources (salary, business income and dividends, real estate sales, securities, gifts, inheritance, and loans), plus the two universal requirements of path-of-funds and currency exchange documentation. - URL: https://eb5policy.com/guides/source-of-funds-checklist/ - Language: en - Category: guides - Published: 2026-09-25 - Tags: source of funds, checklist, I-526E, practical Source-of-funds (SOF) documentation is the most labor-intensive part of an I-526E petition and the part most likely to draw a Request for Evidence. USCIS requires the investor to prove two things: that the capital has a **lawful source**, and that it followed a **traceable path** from that source to the investment account. This article provides document checklists for seven common fund types and then covers two requirements that apply to every investor: path of funds and currency exchange. The lists are intended to help investors and attorneys organize the file systematically; decisions about what to include in a specific case remain a matter for counsel. For the mistakes seen most often, see [Five Common Source-of-Funds Pitfalls](/guides/source-of-funds-pitfalls/). ## General principles Four principles apply regardless of fund type: 1. **Close the chain.** Every dollar should be traceable from the moment it was earned or received to the moment it reached the investment account, with a statement for every transfer in between. 2. **Enough money, in the right order.** The lawful income shown in the documents should be sufficient to cover the investment, and it should have been earned before it was used. 3. **Prefer third-party documents.** Records issued by banks, tax authorities, registries, and notaries carry more weight than the investor's own statements or private receipts. 4. **Translate everything.** Every non-English document needs a complete English translation with a translator's certification. ## 1. Salary and bonuses For investors whose capital comes mainly from accumulated employment income. The focus is showing that income levels match the growth in savings. - [ ] Employment contract or employment verification letter stating position, start date, and compensation - [ ] Pay slips or payroll deposit records covering the accumulation period - [ ] Personal income tax returns or tax payment records for the same period - [ ] Employer letter confirming income, including bonuses - [ ] Bank statements for the salary account showing deposits and accumulation - [ ] For equity compensation, the grant documents and exercise records **Common problems**: declared taxable income far below the growth in account balances; multiple transfers between the salary account and the investment account without matching statements. ## 2. Business income and dividends For business owners. The adjudicator needs to confirm that the business is lawful, that the investor actually holds the equity, and that the money was distributed from the company to the individual through a lawful mechanism. - [ ] Business license, articles of incorporation, shareholder register, or corporate registry extract - [ ] Evidence of the investor's ownership percentage and any changes over time - [ ] Company financial statements (preferably audited) covering the distribution period - [ ] Company tax returns and tax payment receipts - [ ] Shareholder or board resolutions approving the distributions - [ ] Personal tax receipts for the dividends - [ ] Bank statements showing the dividend payments from the company account to the personal account - [ ] If the investor also draws a salary, the corresponding payroll and tax records **Common problems**: frequent transfers between company and personal accounts with no resolutions or tax receipts, leaving the nature of the funds unclear; the source of the company's original registered capital may also be questioned. ## 3. Real estate sales For investors using proceeds from a property sale. The key is documenting **two layers**: the sale proceeds themselves, and the source of the money used to buy the property originally. - [ ] Original purchase contract and payment records - [ ] Income or source-of-funds documents from the time of purchase (showing the purchase money was lawful) - [ ] If the purchase was mortgaged, the loan agreement and repayment history - [ ] Title certificate or property registry extract - [ ] Sale contract and transfer documents - [ ] Bank statements showing receipt of the sale proceeds - [ ] Receipts for taxes and fees paid on the sale - [ ] If the property was acquired by gift or inheritance, the corresponding gift or inheritance documents **Common problems**: the purchase was long ago and the original payment records are missing; the appreciation cannot be explained; a long gap between the sale and the investment with no statements bridging it. ## 4. Stocks and securities For investors using securities gains. - [ ] Brokerage account opening documents - [ ] Source-of-funds documents for the initial capital invested (salary, dividends, etc.) - [ ] Brokerage statements covering the holding period - [ ] Sale transaction records and withdrawal records - [ ] Tax records for securities gains, where applicable - [ ] Bank statements showing transfers from the brokerage to the bank account - [ ] For private company share transfers, the transfer agreement, valuation report, buyer's payment records, and registry update **Common problems**: only the statement at the time of sale is provided, without evidence of where the initial capital came from; the difference between gains and initial capital is not supported by transaction records. ## 5. Gifts For investors whose capital was gifted by parents, a spouse, or other relatives. The core requirement is to **trace the donor's funds to a lawful source**. A full discussion appears in [Gifted Funds](/guides/gift-funds-guide/). - [ ] Gift deed or declaration stating that the gift is unconditional, irrevocable, and not to be repaid - [ ] Proof of relationship between donor and recipient (household register, birth certificate, marriage certificate) - [ ] Donor's identity documents - [ ] Complete source-of-funds documentation for the donor (prepared according to the other sections of this checklist) - [ ] Bank statements showing the transfer from the donor's account to the recipient's account - [ ] Gift-related tax documents, if the donor's or recipient's country imposes a reporting or tax requirement **Common problems**: tracing stops at the donor's account; the gift deed is dated after the transfer; the donor's funds themselves came from a third party. ## 6. Inheritance For investors whose capital came from an estate. - [ ] Death certificate of the decedent - [ ] Will or proof of intestate succession, plus the notarized inheritance certificate or court order - [ ] Estate inventory and valuation documents - [ ] Documents on the decedent's source of funds or assets during life, to the extent available - [ ] Estate tax or related tax receipts, where applicable - [ ] Bank statements showing the estate funds entering the investor's account - [ ] If the inheritance was property or shares, documents for the sale process (see sections 3 and 4) **Common problems**: the decedent's source of funds is hard to trace. USCIS generally applies a reasonableness standard here, but the investor should still provide what is available about the decedent's occupation, income, or asset background. ## 7. Loans For investors using borrowed money. The rules are discussed in detail in [Using Loan Proceeds as EB-5 Capital](/guides/loan-funded-investment/). - [ ] Loan agreement naming the investor as borrower and stating the amount, interest rate, term, and repayment schedule - [ ] For a secured loan, title documents and a valuation of the collateral - [ ] Bank statements showing disbursement of the loan - [ ] If the lender is an individual or non-bank entity, complete source-of-funds documentation for the lender - [ ] Evidence of the investor's ability to repay (income, assets) - [ ] Repayment records to date, where applicable - [ ] Source-of-funds documents for the collateral at the time it was acquired, if any **Common problems**: the lender is a relative whose funds are not sourced; the "loan" is a gift in disguise; the investor has no evident ability to repay. ## Universal requirement 1: path of funds Regardless of fund type, the investor must provide **complete path documentation** from the source account to the NCE's receiving account: - [ ] Statements for every account the funds passed through, showing each credit and debit - [ ] A confirmation for each transfer (remittance receipt, SWIFT message, etc.) - [ ] If the funds passed through a third party's account, that person's identity documents, an explanation of the relationship, and their account statements - [ ] Receipt confirmation from the NCE's escrow account - [ ] A flow chart or narrative prepared by counsel placing every account and transfer in chronological order ## Universal requirement 2: currency exchange and transfer abroad For investors from mainland China and other countries with exchange controls, USCIS requires an explanation of how funds were converted from local currency into U.S. dollars and sent abroad. The route must be lawful, complete, and explicable, and **must not use irregular channels**. - [ ] Bank records of the investor's own currency purchases and outbound remittances - [ ] If relatives or friends assisted with exchange, each helper's identity documents, proof of relationship, their own exchange and remittance records, and statements showing the investor's transfer of local-currency funds to them - [ ] If the investment is funded from assets or income already held abroad, the source documents for those assets and the overseas account statements - [ ] A memorandum explaining the exchange method used and its basis under the investor's home-country law Investors should obtain separate professional advice on whether their exchange arrangement complies with home-country law; this article does not evaluate specific arrangements. ## Key takeaways - Source-of-funds proof has two parts: lawful source and traceable path, with the chain closed from the moment funds arose to the NCE's receiving account. - Each of the seven common fund types has its own list: salary, business distributions, real estate sales, securities, gifts, inheritance, and loans. Gifts and loans require tracing the donor's or lender's funds as well. - Real estate and securities require "two layers" of proof: the proceeds themselves and the lawfulness of the original purchase money. - Third-party institutional documents outweigh personal statements; every foreign-language document needs a certified translation. - The currency exchange route must be lawful and complete, and its compliance with home-country law should be verified separately.