The investors’ funds used for their EB-5 applications could come from a large variety of sources, including employment earnings and bonuses, sales of business assets, inheritance, gifts, stocks, home equity loans, loans from financial institutions secured by investors’ assets. Funds from the above-mentioned sources could all be deemed “lawfully gained” as long as investors can provide adequate and convincing documentation. The demonstration of the legal source of funds is a challenging task and needs strategic planning. Investors should consult with their immigration attorneys to work out a suitable strategy.