What source of funds requirements are there for the project administration fee?

It is advisable to authenticate the lawful source of the administration fees paid by the investor.

Though not technically required, most attorneys will include the administration fee in the source of funds analysis.

Proof of the lawful source of funds should not be required for the administrative fee. That being said, the USCIS has required documentation to prove the lawful source of funds of that fee in some cases.

You are only required to show lawful source of funds for the required investment amount of either $500,000 or $1 million depending on the required amount of investment through your regional center project. Most regional center based investments are $500,000. If you wire transfer the investment amount together with the regional center administration fee in a single wire, then it is advisable to demonstrate that you have lawful source of funds for the full amount.

If the funds to pay the administration fee come from the same source and same bank account as the investment and they are transmitted together to the project bank account, then the USCIS takes the position that the source of funds evidence must cover both the investment amount and the admin fee.

It appears that opinions differ, and there is no clear guidance on the authentication of the source of funds applying to both the capital investment and any administration fee paid. The amount and use of the administration fee is often disclosed in the EB-5 project documentation. If you are able to authenticate the extra amount, a conservative approach would be to do so.

You must demonstrate the lawful source of all funds including the administration fee.

This is an interesting question. There are no regulations or guidelines regarding lawful source of funds for the administrative fees that are paid, as long as they are not a part of or included in the minimum requisite investment amount ($500,000 or $1 million).

The USCIS does not monitor how you pay the administration fee for the project, if it is not a part of the investment itself.