Skip to content
BELCARRA · EB-5 FIELD GUIDE

What paperwork proves the project's qualifying status?

Sources checked:

THE DIRECT ANSWER

Request the location and classification analysis with its underlying data, the project's own filings and correspondence with the government, the offering memorandum, budgets and any economic report. Ask for the versions actually relied upon, with dates. A brochure map, a press release or a broker's email restating the category is not the analysis itself.

Index the file by date and author

Set the records out chronologically and record who produced each one, because the qualifying question often turns on which version of the data applied when. Flag anything superseded and keep both versions. If a document cannot be produced, note the refusal and who gave it; that pattern is itself evidence about the sponsor.

Store the investor's funding records in a parallel index so the two strands can be reviewed together without being confused. Keep one further record that few investors think to create: a contemporaneous note of what was said. Where a sponsor or promoter answers a question on a call, write the answer down the same day with the date, the participants and the question as asked, then send it to them for confirmation.

Verbal assurances are the part of any record that evaporates first, and a dated note nobody contradicted is worth having if the project's account of itself later changes. Hypothetical example: an investor's file accumulates eleven such notes across four months, two of which record positions the sponsor's written materials no longer reflect, and those two become the most useful pages in the entire folder.