Use the actual immigrant admission or adjustment-approval event, not the project subscription or petition approval.
Keep the triggering record
Retain the admission or adjustment evidence and calculate the I-829 window from the resulting conditional-residence anniversary. Filing is generally within the 90 days before the second anniversary. The filing itself is not a decision removing conditions, and an investment repayment date should not be treated as interchangeable with either event.
Useful markers include a completed source-of-funds file, signed enterprise documents, the petition receipt, current Visa Bulletin movement for the relevant category and chargeability, and the consular or adjustment stage. The capital must satisfy the sustainment rule applicable to the petition, the enterprise must create the required jobs, the investor must remain engaged in management or policy formulation, and the family must maintain permanent residence rather than abandon it. Keep the commercial calendar of closing dates, capital calls and construction milestones in a record separate from the immigration calendar, so nobody reads a funded escrow as a signal to resign a job or enrol a child in a U.S. school. Records supporting job creation have to exist as events occur rather than being assembled at the end, so the reporting arrangement and the investor's entitlement to receive information should be settled at subscription rather than requested when a filing window approaches.