The Quick Read: A jumbo asset depletion mortgage qualifies a borrower on liquid assets instead of paycheck or tax-return income, on a loan too large for the agencies to buy. The lender takes eligible assets, applies its own adjustments, and divides the result over a set number of months to produce imputed monthly income. The borrower keeps the assets and never has to withdraw them.
- Qualifying income is a calculation, not a withdrawal plan.
- Down payment, closing costs and reserves come out of the asset pool first.
- Haircuts by asset type and the divisor decide how much income the pool produces.
- Debt-to-income, credit, reserves and loan size still gate approval, subject to lender guidelines.
- Above $4,000,000, every file is reviewed case by case before submission.
Lendmire is a broker. It places these files with select wholesale programs. It does not lend, and nothing here is a commitment to lend.
What Is a Jumbo Asset Depletion Mortgage?
It is a mortgage above the conforming limit that is reviewed on a portfolio instead of documented earnings. The target borrower has real wealth and a weak paper income: a founder after a sale, a physician with heavy deductions, a retiree, an executive paid mostly in equity.
“Jumbo” means the loan is larger than what Fannie Mae and Freddie Mac can buy. The baseline one-unit conforming limit is $832,750, and the high-cost ceiling for one unit is $1,249,125, per Orrick’s summary of the FHFA announcement. The limit is county-specific, so the jumbo threshold depends on where the property sits.
Because the agencies cannot buy these loans, guidelines come from individual wholesale programs. That is why two lenders can read the same brokerage statement and reach different income numbers.
Key Terms Defined
Asset depletion: a qualifying method that converts liquid assets into imputed monthly income.
Divisor: the number of months the eligible pool is spread across. Shorter divisors produce more income.
Haircut: the percentage a lender discounts an asset because its value moves or access carries a cost.
Eligible assets: the pool left after down payment, closing costs and reserves are subtracted.
DTI: monthly debts, including the new payment, divided by monthly qualifying income.
Seasoning: how long funds have sat in an account before the lender counts them.
How Does Underwriting Treat the Assets, Step by Step?
Underwriting runs in a fixed order. Each step shrinks or grows the number, and a miss at any step can sink the file.
1. Pick the loan path. Asset depletion is a personal-credit tool. It fits a primary residence or second home. A pure rental usually belongs on a DSCR loan, where the property’s rent carries the payment.
2. Document assets, not employment. The file carries statements for bank, brokerage and retirement accounts. The lender checks ownership, vesting, liquidity, withdrawal restrictions and any pledged or borrowed funds. Statements must be consecutive, and a transaction history never substitutes.
3. Net out the cash needed. Money earmarked for down payment, closing costs and reserves is subtracted first. The remainder is the pool that can generate income.
4. Apply haircuts. Cash usually counts at full value. Stocks and bonds are discounted because prices move. On the programs in Lendmire’s network, retirement accounts count at 70%, or 80% for a borrower 59.5 or older. Business funds, gifts, most trusts, unvested stock and cryptocurrency do not count. A revocable living trust is the trust exception.
5. Divide by the divisor. Eligible assets divided by months equals monthly qualifying income. Across the wholesale network, the asset allowance path divides by 36, 60 or 84 months. The 36-month divisor applies as a supplement when DTI is at or below 60%, the 60-month divisor when DTI is above 60%. The 84-month divisor applies as a standalone path or on any loan above $3,500,000. The asset allowance path is limited to primary and second homes, with a maximum of 80% leverage, while leverage on the assets-only path follows the program matrix. Terms depend on the lender’s guidelines, the property type, the leverage, and a full review of the credit profile.
6. Add real income. Social Security, pensions and documented deposit income stack on top of the imputed figure.
7. Run DTI and compensating factors. Imputed income goes into the DTI calculation, which on most files tops out around 50%. Credit, leverage, reserves and property type all gate the file. The divisor and the haircut move together, so judging either one alone misleads. Lendmire’s explainer on the asset depletion divisor on a jumbo mortgage walks through that pairing.
What Structures Exist Besides the Standard Divisor?
There are three, and they solve different problems.
| Path | How income is built | Typical limit |
|---|---|---|
| Asset allowance, supplemental | Liquid assets ÷ 36 or 60 months, added to other income | 80% max, primary and second homes |
| Asset allowance, standalone | Liquid assets ÷ 84 months | Also used above $3,500,000 |
| Assets-only | No DTI test; liquidity must equal loan plus costs | Primary and second homes |
The assets-only path needs U.S. liquid assets equal to the loan amount, plus closing costs, plus sixty months of any net loss on other residential property. There is no income test at all. It is the most asset-hungry structure, and it suits a borrower whose portfolio dwarfs the loan.
Some borrowers have the opposite problem: income exists but sits in a business. For them, the network also runs bank-statement paths. These use 12 or 24 months of personal or business deposits after an expense ratio. Transfers from the borrower’s own business into a personal account count at 100%. That is a different product, and many high-net-worth files mix the two ideas, using assets for reserves and deposits for income.
Why Two Lenders Reach Different Income From the Same Statements
The divisor and haircut are program choices, not industry standards. A broker sees this every week. The same brokerage portfolio can produce a workable DTI under one program and a failing one under another, purely from the divisor, the haircut on equities and how the program treats retirement money.
Agency-style divisors are long, commonly 360 months. Non-QM and portfolio programs run much shorter. The figures above are the ones that apply to the network’s programs, subject to full underwriting.
That spread is why comparing headline leverage alone is a mistake. Compare divisors and haircuts first.
What Leverage and Size Limits Apply?
Leverage steps down as the loan grows. The ceilings below are for a primary residence through select wholesale programs, subject to underwriting.
| Loan size | Purchase ceiling | Credit floor |
|---|---|---|
| To $1,000,000 | 90% | 680 |
| To $2,000,000 | 85% | 700 to 720 |
| To $3,000,000 | 80% | 720 |
| To $4,000,000 | 75% | 720 to 760 |
Above $4,000,000, leverage is reviewed case by case before submission. A bank portfolio program carries twelve-month-statement files to $30,000,000, running 65% to $5,000,000, 60% to $10,000,000 and 55% to $30,000,000 on review. Second homes and investment property run about five points lower at each size. A portfolio non-QM program carries files to $6,000,000, so the two ladders overlap between $4,000,000 and $6,000,000.
Pricing and available terms vary by lender, borrower profile, property type, and full underwriting review. Minimum credit score requirements rise to 700 above the super-jumbo line, which sits at $3,500,000 on a primary residence and $3,000,000 on a second home. Reserves run 3, 6 or 9 months depending on loan size. Super-jumbo files also carry overlays: a 0x30x24 housing history, 48 months of seasoning after a credit event, U.S. citizen or permanent resident status, and no rural property. Cash-out proceeds cannot satisfy reserves.
Where the General Rule Breaks
The tidy model has edges. These are the ones that actually derail files.
Cash used at closing cannot also be income. The same dollars cannot do both jobs. A larger down payment shrinks the pool and the income it generates. Borrowers who plan a big down payment and then discover their DTI fails have usually missed this.
Entity-held and business funds do not count. A portfolio sitting in an LLC, or sale proceeds still parked in a business account, is not eligible. Move the money into personal accounts early, and let it season.
Concentrated or volatile holdings. A pool that is mostly one stock gets treated harshly and can swing between application and closing. Keep assets in place and avoid trades during the file.
Retirement accounts. They count, at a discount. Age matters, because access at 59.5 or older improves the treatment.
Asset depletion on a rental in an LLC. It is a personal-credit product, so personal vesting and personal DTI apply. If rent should carry the loan, DSCR is built for that.
Mixed-use property. A beach house used personally and rented part of the year may not qualify for business-purpose financing at all. Occupancy decides which product applies.
Hybrid structures. Some practitioners use asset income to augment thin rent in expanded DSCR files. That varies by program and is not a standard.
Texas 50(a)(6) home-equity loans. They take a five-point leverage reduction and stop at $3,000,000 on the portfolio program.
Does “No Income Verification” Mean No Underwriting?
No. Asset depletion is fully regulated, though it is not a qualified mortgage. Non-QM loans still have to meet the federal ability-to-repay rule. The CFPB’s small entity compliance guide lists eight factors a lender must consider, and says the lender verifies the income or assets it actually relies on. For asset-qualified files, the lender verifies assets instead of paychecks.
There is a known wrinkle. CFS Review’s analysis notes the rule allows a determination based on assets alone yet still requires considering DTI or residual income. Programs handle that differently, which is part of why assets-only files carry such heavy liquidity tests.
The accurate description is qualification on documented assets under the applicable program, subject to lender guidelines.
What Does the Investor Decision Look Like?
Start with occupancy, then work backward.
| Situation | Usual fit |
|---|---|
| Rent covers the payment, held in an LLC | DSCR loan |
| Occupying the property, traditional personal-income documentation understates wealth | Asset depletion |
| Income sits in a business, deposits are strong | Bank-statement program |
| Portfolio far exceeds the loan | Assets-only path |
Consider a founder who sold a company and holds most proceeds in a brokerage account, with little recurring income. Buying a primary residence in the super-jumbo range, the file works only if the pool survives the down payment, closing costs and reserves with enough left to divide. Run the divisor both ways before choosing a program.
Now take a physician with large deductions and steady deposits. Bank-statement income may do the work, and the asset pool can sit untouched as reserves. Reserves can satisfy reserve requirements without fixing a shortfall in qualifying income, so the two roles stay separate. Final terms depend on the lender’s guidelines, the property type, and the borrower’s complete credit picture.
On the file side, the quiet failures are rarely about wealth. They are an account opened last month, a statement page missing, a gift counted as an asset, or a transfer between accounts that nobody can explain. Clean statements, personal vesting and a clear paper trail on large deposits leave fewer gaps for review. Tax treatment varies; consult a qualified professional.
For the full picture across products, see Lendmire’s complete DSCR loans guide.
If you are financing a high-balance property on your assets rather than income documents and want to see how the numbers work, Lendmire can help you compare super jumbo asset-qualification options based on your liquid assets, the property, credit profile, leverage, and your goals.
Frequently Asked Questions
Do I have to withdraw or sell the assets?
No. The income is a qualifying calculation. The assets stay in your accounts, though the lender may want them to stay put through the file, so avoid large moves and trades.
Can retirement accounts count?
Yes, at a discount. On the network’s programs they count at 70%, or 80% for borrowers 59.5 or older. Business funds, gifts, unvested stock and cryptocurrency do not count, subject to lender guidelines.
Can I combine asset income with other income?
Yes. On the supplemental asset allowance path, imputed income is added to documented income such as Social Security, pensions or deposit income. The standalone path uses the longer 84-month divisor.
Does a large portfolio guarantee approval?
No. DTI, credit score, reserves, property type and loan size all still apply. A big portfolio can fail the income math on a very large loan once the down payment and reserves are removed.
Is this a Fannie Mae or Freddie Mac product?
No. Jumbo means above the conforming limit, so these loans run through non-QM and portfolio channels. Eligibility and terms come from the individual program.
For current guidelines and terms, see Lendmire’s super jumbo bank statement loan programs page.
Lendmire’s self-employed mortgages page presents both super jumbo programs, bank statement and DSCR, side by side.
About Lendmire
Lendmire is a non-QM mortgage brokerage (NMLS# 2371349) arranging DSCR investor loans in 41 markets, including Washington, D.C. DSCR eligibility is generally reviewed around property-level rental income rather than personal income, subject to lender and program guidelines, a fit for self-employed investors and LLC-owned portfolios. Lendmire was recognized as a Scotsman Guide Top Mortgage Workplace in 2025 and 2026.
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References
1. Orrick InfoBytes: FHFA announces conforming loan limit increases
2. CFPB ATR/QM Small Entity Compliance Guide
3. CFS Review: CFPB Addresses Non-QMs Under ATR Rule
This article is part of Lendmire’s super jumbo bank statement loan program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: How Actors Qualify for a Jumbo Mortgage With Bank Statements · How to Qualify for a Jumbo Mortgage After a Business Sale · Bank Statement Loan vs Asset Depletion Loan for Attorneys
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Required disclosures. Lendmire (NMLS# 2371349) operates as a licensed mortgage broker, not a direct lender or depository. The discussion in this article is general in nature and should not be relied upon as financial, legal, or tax advice — every investment scenario is unique and should be reviewed by a qualified professional. Any loan inquiry is subject to lender underwriting, and this article is not a commitment to lend or a guarantee of approval. Mortgage rates, loan terms, and program guidelines vary by borrower, property, and state, and may change without notice. Equal Housing Opportunity. Verify licensure at NMLS Consumer Access.