While only the EB-5 investment itself requires source of funds documentation, if the investment and the administration fees are paid together, the best practice would be to demonstrate lawful source of funds for the entire amount.
Rural and Urban TEA Regional Center EB-5 Projects at $800K
H-1B / F-1 / E-2 / TN Visa Holders Can Invest Now & Adjust Immigration Status Immediately
While only the EB-5 investment itself requires source of funds documentation, if the investment and the administration fees are paid together, the best practice would be to demonstrate lawful source of funds for the entire amount.