Yes. Cash proceeds of a bona fide loan may qualify whether or not the loan is secured by the investor's own assets. The loan must be made in good faith and not to evade source restrictions, and the lawful source and path of the proceeds — including required records from a non-bank lender — must be documented.
Whose asset secures the debt is the deciding fact
The current rule treats qualifying loan proceeds contributed to the new commercial enterprise as cash; it does not require Gordon to be personally and primarily liable on a loan secured by assets he owns. A mortgage against retained land can still be a sound source, but the immigration questions are whether the loan was made in good faith, whether it avoids any attempt to circumvent restrictions on permissible capital, and whether the cash is lawfully sourced, owned and controlled by Gordon, and placed at risk in the new commercial enterprise. The loan agreement, advance, mortgage and transfers into the investment account should be documented. If the lender is not a bank, the petition must also include the lender's applicable source-of-funds and related records required by statute. A circular loan from the project or a repayment right against the enterprise would raise different problems and should not be treated as equivalent to an ordinary third-party loan.
Hypothetical example: A Canadian owner of a winery-equipment company proposes to use proceeds from selling shares and a personally secured loan for an immigrant investor project. The first review should separate capital that is personally at risk from debt secured by the new commercial enterprise's assets or otherwise shifting risk away from the investor. Share sale agreements, tax records, loan documents, collateral valuation, and proof of personal liability settle that question. The investment must meet the applicable capital requirement, remain at risk, and support the required job creation; petition approval does not by itself give unconditional residence. A file often falters when a commercially convenient financing term is accepted without checking its immigration consequence. The investor should decide on the financing structure before funds move, because later relabelling cannot change who bore the liability when the money was committed.