Skip to content
BALDWIN · EB-5 FIELD GUIDE

What if the donor used more than one bank?

Sources checked:

THE DIRECT ANSWER

Explain the whole sequence so ownership and amounts can be followed through each account. Missing links should be identified rather than hidden.

Create a dated transfer map

Match statements, conversion records and transaction references. Explain deductions or timing differences and obtain genuine available evidence for older stages. Do not recreate bank records. A clear map helps the reviewer assess gaps but does not substitute for the underlying lawful-source documentation.

Start from the event that generated the funds, such as an asset sale, inheritance, or business distribution, and trace the ownership, transfers, and currency conversions from that point to the investment, preserving actual dates and amounts. Grant agreements, vesting statements, brokerage confirmations for each sale, tax returns showing the reported benefit and gains, bank statements for the receiving account and the wire into escrow, reconciled in a single table. The application, the credit decision, the executed agreement, the security registration, each drawdown advice, each transfer confirmation, and the statements showing both sides of every movement together form a chain, and a chain is only as good as its weakest documented link.