Write A Cpa Letter For A Super Jumbo — The Quick Read: A CPA letter for a super jumbo bank statement loan works only when it states a fact the accountant already knows from preparing the return — the real business expense ratio, ownership percentage, years in operation. It cannot say the borrower can afford the loan, is solvent, or will keep making payments. Get that boundary wrong and the letter gets rejected, or worse, puts your CPA’s license at risk.
Most borrowers ask their accountant for the wrong thing. They want a letter that reassures the underwriter everything will be fine. That letter doesn’t exist, and no CPA who understands their own liability will write it. What they can write — and what actually moves a super jumbo file — is a narrow, factual statement that corrects the lender’s default assumption about how much of the borrower’s business deposits are real expense versus real income.
Key Terms Defined
Expense ratio — the percentage of gross business deposits a lender assumes goes to operating costs before what’s left counts as qualifying income.
Bank statement loan — a loan that qualifies a self-employed borrower using 12 or 24 months of bank deposits instead of traditional personal-income documentation.
CPA letter (expense-ratio letter) — a narrow, factual statement from a licensed CPA or Enrolled Agent documenting a business’s actual expense ratio, used to replace a lender’s generic default assumption.
Enrolled Agent (EA) — a tax practitioner federally licensed by the IRS with unlimited rights to represent taxpayers, distinct from a CPA but often accepted for the same letter purpose.
Super jumbo — a lender-defined loan size tier above standard jumbo, with no federal definition; each program sets its own line and its own overlays.
Reserves — liquid assets left in the bank after closing, measured in months of housing payment, required as a cushion separate from income documentation.
What A CPA Letter Actually Is
A CPA letter is a factual statement, not an opinion. It confirms something the accountant already knows — the real cost structure of a business — and stops there. This boundary isn’t a lender preference. It comes from the accounting profession’s own ethics rules. Under AICPA Interpretation No. 1, CPAs are barred from providing any assurance that a client is solvent, has adequate capital, or can make debt payments, according to The Tax Adviser. A companion breakdown from LaPorte puts it plainly: CPAs can confirm they prepared a return or verify an ownership percentage, but they cannot answer questions about a client’s creditworthiness or ability to meet obligations.
That’s why every workable CPA letter template in bank statement lending has the same shape. It states a number the accountant already knows from doing the tax work — the expense ratio for that specific business — and it stays silent on everything forward-looking.
Key Takeaways
- The letter certifies a documented fact (expense ratio, ownership %, years in business) — never a prediction about repayment
- It must come from a licensed CPA or Enrolled Agent, identified by name and license or PTIN number
- It has to reference the exact bank statement period the loan file covers
- Any language implying the accountant is vouching for solvency or creditworthiness gets the letter rejected
- On files above roughly $3.5 million, underwriters scrutinize the letter’s internal consistency far more closely
Why It Matters More At Super Jumbo Size
A small correction to the expense ratio moves qualifying income by a bigger dollar amount on a large deposit base than on a modest one. That’s the whole reason a CPA letter is worth commissioning on a high-value file — the same percentage-point fix carries far more weight when the deposits behind it are seven figures.
Lendmire places files through a wholesale network. Bank statement qualification uses the same math no matter the loan size. You take gross eligible deposits and divide by the number of statement months. Then you subtract an expense ratio. Most lenders use default fixed ratios. These ratios are tiered by business type and employee count. Service businesses with no employees get the lowest ratio. Higher ratios apply as staffing increases or if the business sells products. The exact percentages vary by lender and program guidelines. A CPA-supplied ratio can replace that default. So can a profit-and-loss method, capped at 80% of deposits. This works when the accountant’s documentation supports a different number.
On a $400,000 loan, shaving ten points off an assumed expense ratio might shift qualifying income by a modest amount. On a file sized into the multi-million-dollar range — where portfolio non-QM programs in Lendmire’s network carry bank-statement files to $6,000,000 and a separate bank portfolio jumbo program carries twelve-month-statement files as high as $30,000,000 on its own leverage ladder — that same ten-point correction can be the difference between clearing a debt-to-income threshold and not. Leverage on that bank program steps down as size increases: roughly 65% to $5,000,000, 60% to $10,000,000, and 55% up to $30,000,000, with interest-only capped at 60% or the applicable ceiling, whichever is lower. Every figure above $4,000,000 gets reviewed case by case before submission, and clearing that review may still be subject to further underwriting conditions rather than treated as a given.
Transfers the borrower makes from their own business account into a personal account count in full toward qualifying income. No expense-ratio haircut applies there. This is a detail worth knowing. Don’t assume every dollar in a personal account needs the same scrutiny as business deposits.
How To Structure The Letter
Letterhead and identification. The letter needs the firm’s letterhead, the preparer’s name, license or PTIN number, and direct contact information. An underwriter reviewing a super jumbo file will typically verify the preparer’s active license before accepting anything.
Statement of relationship. A sentence establishing that the CPA prepared the borrower’s business or traditional personal-income documentation, and for how many years, gives the letter its factual foundation.
The specific finding. This is the core of the letter — a stated expense ratio, tied explicitly to the business’s filed traditional personal-income documentation, and matched to the exact statement period the loan file covers. Vague language here (“this business operates efficiently”) does nothing; a specific percentage tied to a specific return does.
Ownership and entity facts. If the account is jointly held or the business has multiple owners, the letter should state the borrower’s ownership percentage, since deposits into a co-owned account are typically only attributed to a borrower above a minimum ownership threshold.
Explicit limitation language. The strongest letters include a sentence stating what the CPA is not doing — not auditing, not opining on solvency, not guaranteeing future performance. This protects the accountant and reads as more credible to an underwriter, not less.
Signature and date. Signed, dated, and issued with the client’s written consent — since CPA-client confidentiality rules require authorization before any information goes to a third party not involved in the engagement.
What Loan Officers Should Ask For — And What Not To
Before contacting a CPA, get the exact wording the lender wants. Different wholesale programs phrase the requirement differently. A letter drafted to satisfy one lender’s expectations may need revision for another. It never predicts the future. And it never touches the borrower’s ability to repay.
What to request: a specific expense-ratio figure tied to the filed return, an ownership statement if relevant, and a date matching the statement period. What not to request: any statement about the borrower’s ability to repay, future income projections, or general assurances of financial health. A CPA letter is one of the levers a borrower actually controls before submission. See Lendmire’s discussion of whether a super jumbo bank statement loan requires a CPA. Also see when a CPA letter is genuinely needed versus optional documentation.
Asking a CPA to guess at future stability, or to write anything resembling a comfort letter, puts the accountant’s own liability at risk. Unauthorized third-party comfort letters can fall outside a CPA firm’s errors-and-omissions coverage, leaving the firm exposed if the loan later defaults. A CPA who understands that risk will insist on narrow, factual language — which is exactly the letter an underwriter wants anyway.
Documentation, Credit, And The Rest Of The File
The CPA letter is one input, not the whole file. Across Lendmire’s wholesale network, bank statement qualification generally runs on 12 or 24 consecutive months of personal or business statements. The bank portfolio program specifically uses 12-month files. Business accounts need at least 25% ownership for deposits to count toward that borrower.
Credit typically needs to clear a 660 floor on the portfolio bank-statement program, or 680 on the bank portfolio program, with a 700 floor once a file crosses into the super jumbo overlay tier above roughly $3,500,000 on a primary residence (or $3,000,000 on a second home or investment property). Debt-to-income can run up to 50% depending on compensating factors. Reserve requirements step up with loan size — typically 3 months of housing payment on loans to $500,000, 6 months to $1,500,000, and 9 months above that, plus additional months for other financed properties, subject to lender guidelines. Leverage on a primary residence generally starts near 90% at smaller loan amounts and steps down as size increases — roughly 85% around $1,000,000-$2,000,000, into the 75-80% range through $3,500,000-$4,000,000 at the strongest credit tiers, then case-by-case review above that on the portfolio program before the bank program’s own ladder takes over at higher amounts. Second homes and investment properties typically run about five points lower at comparable sizes.
Borrowers whose traditional income documentation doesn’t tell the full income story also have asset-based paths worth knowing about. An asset allowance can qualify income by dividing liquid assets across 36, 60, or 84 months depending on the debt-to-income picture, and an assets-only path can work with no DTI calculation at all when liquidity covers the loan amount plus closing costs. Neither path needs a CPA letter, since neither runs an expense ratio against business deposits.
For a fuller picture of how documentation choices interact across bank statement qualification, Lendmire’s complete DSCR loans guide walks through the broader non-QM landscape these programs sit inside.
Where This Doesn’t Apply
None of this applies to a DSCR loan. A DSCR loan is reviewed primarily on the property’s rental income covering the payment, subject to lender guidelines — it never calculates the owner’s personal income in the first place, so there’s no expense ratio to document and no CPA letter to write. For an investor deciding between a bank statement purchase on their own income and a DSCR purchase based on rental cash flow, that’s a real fork worth understanding before picking a program. It’s also why a CPA expense letter satisfying a super jumbo file matters enormously on one path and not at all on the other.
What Sinks A CPA Letter During Underwriting
The most common rejection reason is language that drifts into an opinion — anything implying the CPA believes the borrower can handle the debt. The second most common: an expense ratio the underwriter can’t reconcile against the actual deposit pattern in the statements. If withdrawals or recurring transfers contradict the stated ratio, the letter creates more questions than it answers.
Introducing a full tax return into a bank statement file, just to “back up” the CPA letter, can also backfire — it can trigger a broader re-underwrite of the whole application on tax-return terms instead of bank-statement terms. The letter is meant to stand alone as a documented fact, not open the door to a parallel income calculation.
Timing matters too. A letter dated well outside the statement period the loan file covers, or issued after the file is already in underwriting, tends to generate a condition rather than clear one. Getting it drafted early, matched precisely to the statement dates, avoids that back-and-forth.
Not Legal Or Tax Advice
Nothing here is legal or tax advice. Every CPA letter, expense ratio, and engagement scope depends on the borrower’s specific business and tax history. It also depends on the lender’s individual program requirements. Borrowers and their accountants should work directly with a qualified CPA or tax attorney. Ask what any specific letter can and cannot say. Borrowers should also confirm exact documentation requirements with their loan officer before requesting anything from their accountant.
Frequently Asked Questions
Does a CPA letter guarantee my loan gets approved?
No. A CPA letter corrects one input in the underwriting calculation — the expense ratio — but approval still depends on credit, reserves, leverage, property, and the full file, subject to lender guidelines and underwriting review.
Can my Enrolled Agent write this instead of a CPA?
Often, yes. Many bank statement programs accept a letter from a licensed Enrolled Agent, since EAs hold unlimited practice rights before the IRS similar to a CPA or attorney. Confirm with the specific lender before assuming this applies to your file.
What if my accountant refuses to write the letter?
That’s common, and it’s usually a sign the requested language crossed into solvency or ability-to-repay territory. A CPA who understands professional-standards limits will often still write a narrower, purely factual version once the scope is clarified.
Does the CPA letter replace my conventional personal-income paperwork or bank statements?
No. It supplements the file by documenting one specific fact — the expense ratio or ownership percentage — it doesn’t substitute for the statements themselves or the underlying documentation the program requires.
Is a CPA letter required on every super jumbo bank statement file?
Not always. It becomes relevant specifically when a borrower’s real business expenses differ meaningfully from the lender’s default assumption. Borrowers whose actual costs match the standard ratio may not need one at all.
Are you structuring a super jumbo file? Do you want to compare a documented expense ratio, an asset-based path, or a straight DSCR purchase? Lendmire can help. They compare options across leverage, documentation type, and property income. This is subject to full underwriting.
For current guidelines and terms, see Lendmire’s super jumbo bank statement loan programs page.
Self-employed borrowers can compare both super jumbo programs on Lendmire’s self-employed mortgages page.
About Lendmire
Lendmire (NMLS# 2371349), a non-QM mortgage broker serving investors in 40 markets including Washington, D.C., helps structure DSCR scenarios commonly evaluated around a property’s rental income rather than personal income paperwork, subject to lender guidelines. A Scotsman Guide Top Mortgage Workplace in 2025 and 2026, Lendmire places loans through wholesale investor lenders and is not a direct lender.
Lendmire’s Top Mortgage Workplace recognition is documented by Scotsman Guide 2025 Top Mortgage Workplace and Scotsman Guide 2026 Top Mortgage Workplace.
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References
1. The Tax Adviser (AICPA) — Third-party verification requests
2. LaPorte — Comfort Letters and Third-Party Verification Requests
3. IRS — Enrolled agent information
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Important disclosures. Lendmire (NMLS# 2371349) is a licensed mortgage brokerage. Lendmire is not a direct lender, depository institution, or financial advisor. All loan inquiries are subject to lender underwriting; this article does not constitute a commitment to lend. Rates, terms, and program guidelines are subject to change without notice and vary by borrower profile, property type, and state. Information in this article is general in nature and is not financial, legal, or tax advice. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.
