Do not assume costs of obtaining records or professional advice are qualifying invested capital. Identify the actual use and treatment of each payment under the rules. The money needed to prepare a case can exceed the required contribution without increasing qualifying capital by the same amount.
Maintain separate budget lines
Record the investment, government charges, project fees and evidence-preparation costs. Confirm the actual threshold and current filing charges when relevant. A paid document invoice proves an expense, not necessarily a contribution satisfying the EB-5 investment requirement.
Nothing spent on assembling the application counts as capital. The qualifying amount is what is irrevocably placed at risk in the new commercial enterprise itself, in an enterprise that has to create at least ten full-time positions for qualifying U.S. workers and give the investor a management or policy role; fees buy none of that. Everything else belongs on its own budget line: a regional centre's administrative fee, the filing charges for the immigrant petition and for the later removal of conditions on the two-year residence, immigrant visa or adjustment charges, counsel, translation, and the retrieval and certification of source records. Take government charges from the official USCIS fee schedule, Form G-1055, and the Department of State fee pages rather than a promoter's summary, since those amounts move independently of the capital requirement.
Hypothetical example: A textile recycler builds a budget in which archive searches, certified translations of a decade of filings, and an accountant's source-of-funds report come to a substantial sum. Folding them into the subscription amount would leave the enterprise short of the required capital while the paperwork looked expensive. Keeping the lines apart also answers the other half of the question, which is who pays. Fees settled by a third party still need explaining where that party is also contributing capital, because source and path evidence follows the money regardless of which invoice it happens to settle.