Use accurate job descriptions, employment arrangements, schedules and payroll records showing how the position operates. The evidence should identify the full-time position and the workers sharing it, while satisfying the applicable qualifying-worker requirements. No single label on a schedule replaces the substantive arrangement.
Keep records from the beginning
Explain changes in duties or staffing as they occur and preserve the supporting records. The business should not manufacture historical employment terms at filing time. Discuss the evidence needed for the particular direct EB-5 case, including the stage at which creation and maintenance of jobs must be demonstrated.
First review creates a funds narrative that links the original asset or income to every account, conversion, transfer, and commitment. The records that usually resolve a gap are complete statements and source documents such as sale contracts, tax records, or gift papers—not a balance screenshot. Sequence the file chronologically and reconcile each amount before the next transfer.
A common failure is documenting the final wire while leaving the earlier lawful source unexplained. Hypothetical example: A Canadian watchmaker funds an EB-5 case from the sale of a design patent and a family gift. The file should keep the sale records and gift trail distinct before showing how both amounts reached the new commercial enterprise.