Yes. USCIS treats lawfully obtained loan proceeds contributed to the enterprise as cash; they need not be secured by her own asset solely to qualify, but she must trace the proceeds, own or control the contributed cash and place it at risk before filing.
Borrowed capital qualifies when the investor bears the debt
Current USCIS policy treats lawfully obtained loan proceeds invested in the new commercial enterprise as a contribution of cash rather than indebtedness. The former requirements that the investor be personally and primarily liable and pledge investor-owned collateral were removed after the controlling court decision. Her mortgage records remain useful to prove the lawful source and path of the cash, including the lender, draw, receipt and transfer into the enterprise.
The share-sale proceeds require their own complete trail. Together the funds must reach the US$1,050,000 standard amount or US$800,000 amount for a targeted employment area or infrastructure project in force at filing, be placed at risk without a guaranteed return, and support ten full-time direct jobs for qualifying U.S. workers.
She must also be engaged in management or policy formulation. Hypothetical example: a water-quality laboratory owner invests the required amount but projects nine technicians and one part-time receptionist. The capital figure alone does not satisfy a direct case.
The first review should count only qualifying full-time positions, map each to real revenue, and distinguish employees from contractors. The business plan, payroll forecast, and hiring timetable settle the point. If the tenth position exists only on paper, filing before the plan supports it creates a later conditions problem.