No. The arrangement and supporting history still need assessment. A genuine gift should be documented as such, with the relevant evidence rather than an assumption based on the family relationship.
Explain the money before describing the project
Identify who provided it, the real terms and where the records are held. Give the reviewer the facts needed to determine further evidence. Do not replace a loan with gift wording if repayment remains part of the arrangement.
Hypothetical example: A commercial-laundry operator plans to invest in a U.S. linen-processing company and retain a limited-partner policy role. The first review produces a capital ledger, source-and-path chronology, agreement summary, and job-creation framework. The offering documents and partnership agreement settle the investment and participation rights; bank, tax, sale, and transfer records settle lawful source and movement; the business model settles how qualifying jobs are counted. Start with the project's method and required capital, then trace each funding step, then test the job evidence. A common failure is assuming that money wired to a project automatically meets every condition. EB-5 capital must be at risk, the required jobs must be created under the applicable method, and the investor receives conditional residence only after the later immigrant process. Removal of conditions is a separate future obligation. Keep this EB5 requirements record aligned with final filing facts and issued source materials, then preserve a dated copy internally before formal submission for future reference and review by responsible staff if questions arise later.