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APPLICATION ANSWERS · EB-5 FIELD GUIDE

Is a subscription signature enough to prove my policy rights?

Sources checked:

THE DIRECT ANSWER

The signature establishes an act of agreement, but the operative documents must show the rights and obligations the investor receives. Review the partnership or other governing provisions and any amendments. A summary that omits those terms may not establish the participation being relied on.

Connect the documents to the legal interest

Identify the investor, entity and class of interest and explain which provisions govern that interest. Preserve current and historical versions appropriately. Do not claim voting or policy rights that the signed arrangement does not provide.

Begin with executed offering materials, entity records, transfer evidence, source documents, reports, and each amendment. The first review should produce a version-controlled file showing which instrument governs and what every record proves.; each conclusion should point to the record that settles it. Next, trace funds from the first source event through the enterprise transfer. This order keeps a later explanation from being asked to repair a missing fact. What commonly goes wrong is a subscription receipt cannot establish a lawful path. Preserve dated source material and identify the unresolved issue instead of using a confident generalization. Hypothetical example: A marine-equipment distributor sells shares through staged payments before wiring capital. The review retains sale documents, confirmations, and account records for every movement. The decision is whether the actual record supports the proposed activity now, requires a different sequence, or calls for a separate route. EB-5 requires qualifying capital exposed to risk and the required employment creation under the applicable framework. Residence begins conditionally, so removing conditions later calls for separate evidence.