Use the actual role descriptions, schedules and employment records to explain how the business staffs the position. A spreadsheet that adds hours without explaining the jobs may obscure the distinction.
Make the staffing arrangement understandable
Identify the duties and weekly requirements of the shared position, the qualifying employees filling it and the supporting payroll evidence. Separate other part-time roles rather than pooling all hours into a fictional full-time job. Projected and already created positions should also be labelled accurately under the applicable evidence requirements.
Request replacement evidence in layers: a certified policy copy or summary, beneficiary confirmation, claim file, settlement calculation, remittance advice, insurer correspondence explaining unavailable archives, and bank statements matching receipt. Source-of-funds documentation is the other underestimated item: assembling years of corporate records, obtaining a defensible valuation, reconciling accounts and preparing a coherent written explanation is professional work measured in weeks, not hours. When the time comes to remove conditions, the same structure has to be proved with documents: quarterly wage reports filed with the relevant authorities, payroll registers showing hours by employee, tax filings, and the company's financial statements for the period.
- USCIS — EB-5 investor program
- USCIS — business and investment visa overview
- USCIS — Child Status Protection Act
- Department of State — Visa Bulletin
- USCIS — fee schedule
- EB-5 full-time positions, job sharing and qualifying employees — 8 CFR 204.6(e), not obsolete capital figures
- Current EB-5 capital statute — 8 USC 1153(b)(5)
- USCIS I-829 instructions