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SURREY · EB-5 FIELD GUIDE

Can several investors rely on the same project evidence?

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THE DIRECT ANSWER

Project-level material — the business plan, the economic analysis, the offering documents — can be shared. Investor-level proof cannot. Each participant must show their own qualifying capital at the applicable amount, their own lawful source and path of funds, and at least ten qualifying full-time jobs attributable to that investment.

Split the file into shared and personal halves

Keep one project binder that every participant references and one private binder per investor that nobody else touches. When counsel reviews the group, the shared half is examined once and the personal halves individually. This also prevents a common error: assuming that because one relative's funds are well documented, another's inheritance or business proceeds will be accepted on the strength of the family relationship.

It will be assessed on its own evidence. There is a practical consequence of that split worth planning for. The shared material can be reviewed once and reused, so its cost falls per head; the personal material cannot, and it is the part that most often causes delay.

Where one participant's funds come from a business sale with clean records and another's from an inheritance settled across two jurisdictions, those two files will not be ready at the same time. Sequence the group's expectations accordingly rather than assuming a common filing date, and identify at the outset which participant has the longest personal trail so that work can begin on it first.