Sometimes, and the security decides it. Funds borrowed against the assets of the business being acquired are generally not treated as the investor's capital at risk, while an unsecured note the investor is personally liable for, or borrowing secured on her own assets, can count.
Who bears the loss is the whole question
The at-risk requirement asks what happens to the investor if the enterprise fails. Where a vendor note is secured on the chip-hauling company's trucks and receivables, the seller looks to those assets on default and Fatima's personal exposure is limited, so that money is not hers at risk in the sense the category means. Where she signs personally, with no recourse to the business assets, the exposure is real and the analysis changes.
This is a drafting question long before it is an immigration question, which is why it should reach a lawyer while the agreement is still in draft. Restructuring after closing is possible but awkward, and a refiled application that relies on a hastily amended note invites scrutiny of why the change was made.