en-us https://www.intensedebate.com/users/673570 Comments by KirkWylie http://www.feld.com/wp/archives/2009/09/startupvisa-momentum.html#IDComment36704054 The worry with any type of representation like that is that it&#039;s going to be just like the &quot;ultimate-source-of-funds&quot; regulations that are part of current AML rules. They&#039;re toothless, and just cause more paperwork. If they weren&#039;t so easy to get around, there&#039;d be no more money laundering. But they are, and they&#039;re just a PITA for everybody who has to comply with what everybody knows are toothless rules. What about a loan of the money from a non-family member (an issue I addressed in my follow-up post, linked above)? That&#039;s not from the applicant or a family member, but would satisfy the particular concerns above, and is the more likely case. Thu, 1 Oct 2009 08:35:38 +0000 http://www.feld.com/wp/archives/2009/09/startupvisa-momentum.html#IDComment36704054 http://www.feld.com/wp/archives/2009/09/startupvisa-momentum.html#IDComment36626859 Hi, Brad, I&#039;ve made <a href="http:\/\/kirkwylie.blogspot.com\/2009\/09\/startup-visa-sausage-is-half-stuffed.html" target="_blank">Yet Another Foray</a> into the mess. Hope you guys can consider my criticism as at least constructive! Kirk Wed, 30 Sep 2009 17:33:14 +0000 http://www.feld.com/wp/archives/2009/09/startupvisa-momentum.html#IDComment36626859