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APPLICATION ANSWERS · EB-5 FIELD GUIDE

How should we explain a difference caused by currency conversion?

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THE DIRECT ANSWER

Show the actual conversion and transfer records so the amounts can be reconciled. Do not force equal totals by omitting fees or substituting an estimated rate.

Prepare a transaction-by-transaction reconciliation

List original currency, amount, date, converted amount, charges and recipient for each movement. Link entries to statements and confirmations. Explain any funds retained or returned. A summary can help a reviewer follow the chain, but it does not replace the records or establish lawful ownership by itself.

Build the evidence in chronological folders: source records, intermediary account records, transfer records, and project records. For a business sale, include ownership and sale agreements, financial records, tax evidence, deposits, and wires. For a gift or loan, retain documents that establish the donor or lender’s lawful source as applicable. Hypothetical example: a precision forestry-machinery investor receives funds from a family loan, then moves them through two accounts before subscription. The note, collateral terms, lender’s source records, statements, and transfer confirmations should explain each link. The first review should also collect the project offering, subscription or partnership documents, job methodology, and risk disclosures. A clean closing statement does not replace the history that brought the capital to closing. Translate non-English evidence completely where the filing rules require it.