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Five Common Source-of-Funds Pitfalls

Source of funds (SOF) is the number-one reason for I-526E RFEs. Here are the five mistakes we see most often, from incomplete gift chains to timelines that do not add up.

By EB-5 Policy · October 5, 2026 · 1 min read
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1. The gift chain stops at the donor

Parental gifts are the most common source, but USCIS wants the donor’s funds traced to a lawful origin, not just a gift deed and a wire receipt.

2. The currency path is unclear

How RMB became USD and left the country must be fully documented and lawful. Informal exchanges through friends are a red flag without matching statements on both sides.

3. Property gains without the original paperwork

Sale proceeds are lawful, but you need the original purchase contract, payment proof, and income records from that time to show the purchase money was lawful too.

4. Mixing company and personal accounts

Frequent transfers between business and personal accounts, with no dividend resolutions or tax receipts, make it impossible for the adjudicator to tell whose money it is.

5. Timelines that do not reconcile

Income, taxes, savings, and transfers must line up. The classic problem is declared income far below the growth in bank balances.

Have your attorney run a mock adjudication before filing, and draw every dollar’s path as a single flowchart.

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