It can, because a loan secured by Sana's personal residence places her personally at risk if the business fails, which is the relevant test described in State Department guidance for debt-financed E-2 investment, distinct from financing secured by the business's own assets.
Test each financing source against the personal-risk standard
Review each source of funds separately: cash savings are straightforwardly Sana's own capital; the home-equity loan is personally secured debt that counts; an unsecured personal loan also counts because she remains liable regardless of the business outcome. Any future financing secured by the franchise's equipment or receivables would need to be evaluated on its own terms.
A first review should make a four-part decision: whether the applicant has the necessary treaty nationality, whether the business is real and non-marginal, whether the capital is committed beyond ready withdrawal and exposed to loss, and whether the applicant will direct the enterprise. Start with the ownership chain and source-of-funds chronology, then examine the actual transaction and operating plan. Hypothetical example: A specialty bicycle-frame manufacturer wires a deposit to a seller but retains a contractual right to reclaim every dollar at will if the visa is not issued. The transaction may be commercially careful, yet the arrangement must be examined to see whether the money is genuinely committed under the applicable E-2 standard. A credible business plan alone cannot cure a revocable investment. The review should say exactly which condition is supported and which needs redesign or better evidence.
Use a written go-or-no-go list before paying the next business expense. It should identify nationality evidence, money-source documents, actual exposure to loss, operating evidence, and the investor’s control. That list prevents a polished forecast from masking an unfinished transaction structure.