Original Source-of-Funds Records Missing — A 1,200-Page RFE Response Secures I-526E Approval

Records of a home purchase and mortgage payments from years ago were hard to recover, and Mr. Y.'s I-526E petition received a difficult Request for Evidence. Our team answered it with more than 1,200 pages of supporting material, nine flowcharts, and 52 exhibits tracing where the money came from and where it went. Mr. Y.'s I-526E was approved on September 25, 2026.

Timeline

• July 31, 2023: I-526E filed
• May 29, 2026: RFE received
• August 27, 2026: RFE response filed
• September 4, 2026: RFE response deadline
• September 25, 2026: I-526E approval notice received

Client background

Mr. Y.'s EB-5 investment came from two loans, one secured by his home and one by land. The land documents involved his father's estate, and the initial filing had already documented them fully. For this part, USCIS asked only for the corresponding tax documents.

The home loan was more complicated. Mr. Y. has a high income and had already submitted pay and tax records, yet USCIS still issued an RFE asking for detailed records of how he bought the home years earlier and paid down the mortgage. The source-of-funds review thus reached back to older property transactions and repayment history.

The challenges

Many transactions across many accounts. Over the years Mr. Y. had made a range of financial arrangements involving financial products, several properties, and the purchase and sale of high-value personal property. Explaining the home-related funds meant matching each of these transactions to the purchase money and the monthly mortgage payments.

Old transactions, some original records gone. Some transactions had taken place many years earlier and the original records could no longer be found. We had to explain the source and flow of funds using what was still available.

Strategy

With Mr. Y.'s cooperation, we gathered financial transaction records from multiple accounts, the home purchase funds, details of personal property transactions, and the monthly mortgage payments for each property, and worked through years of fund movements step by step.

Where original records could not be obtained, we used other, mutually corroborating documents to show the lawful source of funds. The final submission ran to more than 1,200 pages, with nine flowcharts and 52 exhibits showing the full path of the funds, so the officer could follow the explanation to the matching documents and clearly understand how each transaction related to the others.

Behind the volume was careful reconciliation of a large number of historical transactions. Our attorneys turned scattered documents into a clear explanation that squarely answered USCIS's questions about the home purchase and mortgage funds.

Result

We filed the RFE response on August 27, 2026, and received the I-526E approval notice on September 25, 2026.

This RFE involved many asset types and accounts, as well as gaps in the original records. Working with the client, the team documented the source of funds with extensive supporting evidence and secured the approval. The complex transaction history and missing historical documents are what make this case representative.

If you are considering EB-5 or have received an RFE, especially one involving a complex source of funds, please contact our team for an end-to-end strategy tailored to you.