The introduction of the EB-5 Reform and Integrity Act of 2022 (RIA) not only reshaped the EB-5 investment framework but also created a “reserved visa” category, opening a currently visa‑free fast track for applicants. As of 2026, the three reserved categories – Rural, High‑Unemployment Area, and Infrastructure – remain without visa retrogression for mainland‑China‑born applicants.

However, with the September 30, 2026 grandfather clause deadline approaching, evaluating the reasonableness of the funding plan has become the most easily overlooked step – one that directly affects the approval success rate.

Due to time pressure, many applicants rush to file a “place‑holder” petition, only to face Requests for Evidence (RFEs) or even denials later because of unclear source‑of‑funds explanations or insufficient documentation.

Here, the Zhaolong Immigration U.S. Team recommends: when preparing the documentation for the $800,000 investment amount, prioritize a single, clear, and traceable funding plan, and avoid mixing multiple funding paths whenever possible. Complexity in the source of funds significantly increases the likelihood of RFEs.

So, what are the mainstream funding options for new‑law EB‑5 reserved‑visa applicants? And what key points should be noted for each option? This article breaks them down for you.

        The Basics: Investment Threshold and Visa Quota

Before discussing funding plans, it is essential to clarify the new‑law EB‑5 framework.

Investment amount: Currently, the minimum investment for a Targeted Employment Area (TEA, including Rural, High‑Unemployment, and National Infrastructure projects) is $800,000; for non‑TEA projects, it is $1.05 million. Most Chinese applicants choose TEA projects to obtain the same green‑card benefits at a relatively lower cost.

Visa reservation: Each fiscal year, 32% of the total visa quota is set aside for specific categories: 20% for Rural projects, 10% for High‑Unemployment projects, and 2% for Infrastructure projects. Selecting a high‑quality project that falls into one of these categories is currently a key strategy to avoid long backlogs and achieve efficient approval.

Special reminder: September 30, 2026 is the statutory deadline for the grandfather clause. Investors who successfully file their I‑526E petition before this date will have their cases adjudicated under the old rules in effect at the time of filing, even if significant policy changes (e.g., steep investment increases) occur later. This window is irreversible – once missed, it is gone.

        Mainstream Funding Options Explained

EB‑5 investors have traditionally funded their investments through personal savings, asset sales, loans, gifts, inheritance, business income, stock market and investment accounts, among other channels. Below is a breakdown of the major options.

         Option 1: Personal Savings – The Most Direct Path
Personal savings are the most straightforward source of EB‑5 investment funds. Using accumulated personal savings or liquid assets over the years provides the clearest proof of source.

Key points: Although the path is direct, the documentation requirements are not simple. Applicants need to provide detailed evidence of fund accumulation, typically including tax returns, bank statements, pay stubs covering seven years or more, to prove the legality and accumulation process. For applicants whose savings were built over a long period or from multiple sources, tracing the complete “fund chain” can be more time‑consuming than expected.

         Option 2: Property Sale – A Common Choice for Chinese Applicants
Selling real estate is one of the most frequently used funding sources among Chinese EB‑5 applicants. Raising $800,000 through the sale of a property in one’s name is logical and the documentation is relatively standard.

Key points: Documentation for a property sale requires a full set of files, including the original purchase contract, loan records (if any) and proof of the source of those funds, sale contract, and fund receipt records. One critical challenge: if the property was purchased many years ago, you must trace the original source of funds for that purchase – was it from salary accumulation, a parental gift, or another channel? USCIS looks not only at where the $800,000 comes from, but also at the origin of the initial funds. Therefore, applicants are advised to prepare a complete “chain of title” for the property and the corresponding fund flow in advance.

         Option 3: Loans – Flexible but with the Highest Documentation Standards
Loans have long helped investors participate in the EB‑5 program without liquidating major assets. A typical arrangement is to take a loan secured by personal real estate and use the proceeds for the $800,000 investment.

Key points: Loan‑based funding is one of the most demanding options in terms of documentation and scrutiny. The new law requires a dual review of both the source of funds and the path of funds, and the loan must be supported by comprehensive supporting materials. Specifically:
· Bank loans: Documentation is relatively simpler; the investor does not need to trace the bank’s source of funds, only to prove their own ability to receive and repay the loan.
· Non‑bank loans (e.g., from family, friends, or business entities): Require full transparency – documentation of the lender’s legal source of funds, as well as proof of the original purchase of any collateral (if any).
· Loans without tangible collateral: Although courts have clearly allowed them, they are subject to stricter review.
The RIA explicitly states that gifts and loans remain permissible, provided they are made in good faith and accompanied by complete documentation of the legal source of funds for the donor or lender. Every part of the transaction – the lender, the collateral, and the repayment terms – must withstand scrutiny.

         Option 4: Gifts – Support from Family Members
Gifted funds from family members, close relatives, or others are also common. EB‑5 investors, as donees, are not required to repay the gift and are therefore not subject to “repayment capacity” analysis.

Key points: The burden of proof shifts to the donor – the donor must provide evidence of the legal source of their funds. Required documents include: gift affidavit, gift agreement, proof of the donor’s legal source of funds (e.g., tax returns, income records), and transfer records. Additionally, the donor may be subject to gift tax, depending on the tax laws of their country of residence.

         Option 5: Business Income and Investment Returns – For Business Owners and Investors
For business owners or seasoned investors, corporate operating profits, equity dividends, stock trading gains, etc., are also viable funding sources.

Key points: The complexity of documentation for this category depends heavily on the clarity of the asset structure. For business owners with complex asset structures, the fund‑tracing process can stretch significantly, and last‑minute preparation often leads to RFEs and application delays.

        Three Core Principles for Choosing Your Funding Plan

         Principle 1: Simplicity over Mixing
As mentioned, a single, clear, and traceable funding plan is far superior to a patchwork of multiple sources. Each additional funding path adds a full set of documentation and an extra layer of review risk. If conditions allow, prioritize the clearest path to complete your fund preparation.

         Principle 2: Traceability is the Lifeline
USCIS does not just look at the current source of funds; it requires tracing the complete path of funds. The new rules mandate a dual review of both the source and the path – bank statements, tax records, and asset notarizations are all indispensable. Any missing link may trigger an RFE.

         Principle 3: Plan Early, Don’t React at the Last Minute
Source‑of‑funds proof is the most complex and time‑consuming part of the EB‑5 application. Applicants are strongly advised to allocate ample time for funding plan evaluation and document preparation, rather than scrambling after selecting a project. For applicants with complex asset structures, early organisation can greatly reduce subsequent RFE risks.

        Final Thoughts

Currently, the EB‑5 reserved visa categories remain free of retrogression, and with the September 30, 2026 grandfather clause deadline approaching, this is indeed a rare application window. But “fast” does not mean “sloppy” – rushing to file a “place‑holder” petition is far less prudent than filing with a well‑understood funding plan and fully prepared documentation.

There is no one‑size‑fits‑all answer to funding plan selection. The best plan for you depends on your asset structure, tax situation, and family planning. Before making a decision, you are welcome to “send a private message” or click “Read the original article” to schedule a comprehensive consultation with our professional U.S. team.

After all, $800,000 is no small sum. Choosing the right funding plan not only affects the efficiency of your green‑card approval but also concerns the safety of your family assets and long‑term planning.

        Disclaimer: This article is for informational reference only and does not constitute legal or investment advice. EB‑5 laws and policies may change. For specific applications, please consult a qualified immigration attorney.