The Quick Read: A retiree who is reviewed on a portfolio is usually not using a true bank statement calculation, because statements read deposits and a portfolio is read by its balances. Through select wholesale programs, subject to full underwriting, a retiree can use an asset allowance or an assets-only path on a super jumbo loan, or a statement path if deposits are steady.
- Bank statements measure deposits. Portfolios feed the asset paths.
- Asset allowance divides liquid assets by 36, 60 or 84 months to create qualifying income.
- Assets-only skips debt-to-income when liquidity equals the loan plus closing costs.
- Retirement accounts count at 70%, or 80% at age 59½ and older.
- Every loan above $4,000,000 is reviewed case by case before submission.
Most retirees with real wealth have the opposite problem from the self-employed borrower. Their balances are large and their paychecks are gone. A lender that wants a W-2 sees almost nothing.
This piece walks through how the loan works from start to finish. It covers which documentation path fits, how a portfolio becomes qualifying income, what counts, and where the rules break. Lendmire is a broker. It shops several wholesale programs, and it does not lend. Programs change, and every file is underwritten individually. For the wider picture of how these non-QM paths fit together, see the complete DSCR loans guide.
What Is a Super Jumbo Bank Statement Loan?
A super jumbo loan is a mortgage above the standard jumbo range, sized and underwritten by the lender rather than sold to an agency. A bank statement loan is reviewed for the borrower on documented deposits instead of traditional personal-income documentation. Together they serve high-balance buyers whose returns understate what they have.
Across our wholesale network, loan amounts run from $300,000 to $30,000,000 through two programs. A portfolio non-QM program carries files to $6,000,000. A bank portfolio program carries twelve-month-statement files to $30,000,000 on its own ladder: 65% to $5,000,000, 60% to $10,000,000 and 55% to $30,000,000. That ladder begins above $4,000,000 and overlaps the first program to $6,000,000.
Above $4,000,000, everything is reviewed case by case before submission. Treat any leverage figure at that size as a starting point, not an offer.
Which Documentation Path Fits a Retiree?
A retiree has three paths: bank statements, an asset allowance, or assets-only. The right one depends on where the file is strongest. Steady deposits point to statements. A large liquid portfolio points to one of the two asset paths.
| Factor | Bank statements | Asset allowance | Assets-only |
|---|---|---|---|
| What is tested | Eligible deposits | Liquid assets ÷ months | Liquidity vs. loan |
| Debt-to-income | Yes, to 50% | Yes, to 50% | — |
| Best fit | Steady deposit activity | Wealth plus some debts | Large pool, simple debts |
A simple way to choose:
- If deposits are large and regular, start with statements.
- If deposits are thin but the portfolio is deep, use the asset allowance.
- If liquidity easily covers the loan, price assets-only against the allowance.
Many retirees have thin deposits. A pension and Social Security often total far less than the portfolio could support. Statement income on that file comes out low, which is why a retiree who says “bank statement loan” often needs the asset path.
How Does Underwriting Treat a Bank Statement File?
The statement path reads 12 or 24 consecutive months of personal or business statements. The lender totals eligible deposits, removes ineligible items, applies an expense ratio, and divides by the months in the window. The result is monthly qualifying income.
Some items never count as income. These include:
- Transfers between your own accounts
- Loan proceeds
- Refunds
- One-time windfalls
A retirement distribution landing in a deposit account is not deposit income either. Balances become income only under the separate asset path.
Business statements need at least 25% ownership. Expense ratios are fixed at 20% for a service business with no employees, 40% for one to five employees, and 50% for six or more employees or any product business. An accountant-provided ratio is another option. Transfers from your own business into a personal account count in full. Statements must be consecutive, and transaction histories never substitute.
How a Portfolio Becomes Qualifying Income
An asset allowance turns liquid assets into notional monthly income. Nothing is sold or pledged. The lender reads the balances and does the division on paper.
The steps run in this order:
1. Pick the eligible accounts: cash, brokerage and vested retirement balances.
2. Apply the haircut to each account type.
3. Subtract cash needed to close and reserves, because those dollars have another job.
4. Divide what remains by the program’s month factor.
5. Add the result to other income and test debt-to-income.
The divisor is 36 months when the file is supplemental and debt-to-income before the asset income is at or below 60%. It is 60 months when that pre-asset ratio is above 60%. It is 84 months when the asset income stands alone or the loan exceeds $3,500,000. The 60% test only picks the divisor. The ratio with the asset income counted must still fit the 50% ceiling. The allowance applies to primary and second homes, at an 80% maximum.
The divisor swings the outcome hard. Holding everything else equal, 84 months gives less than half the monthly income that 36 months does. Super jumbo retirees almost always land on 84.
Assets-only works differently. There is no income calculation and no debt-to-income test. The test is whether U.S. liquid assets equal the loan amount, plus closing costs, plus sixty months of any net loss on other residential property.
What Counts and What Doesn’t
Cash and brokerage balances are the cleanest assets. Retirement accounts count at 70% of value, or 80% at age 59½ and older. Revocable living trust assets are acceptable.
Some funds never count:
- Business funds
- Gifts
- Trusts other than a revocable living trust
- Unvested stock
- Cryptocurrency
Market surveys report that some lenders discount cryptocurrency instead of excluding it. Our network excludes it. A portfolio heavy in crypto or in one concentrated unvested position can look large on a statement and shrink fast once the haircuts are run.
Don’t Spend the Same Dollar Three Times
A single dollar cannot be the down payment, the reserves and the income base. Dollars used to build qualifying income cannot also satisfy reserves. The file must assign each dollar one job.
Picture a retiree with a large brokerage account who plans to put down a sizable share of a purchase. Every dollar that goes to the down payment leaves the asset pool. Reserves come out next. What remains is the base the divisor works on. Running that net worksheet before you shop prevents the most common surprise: a portfolio that looked ample until it was assigned three jobs.
Reserves run 3 months to $500,000, 6 months to $1,500,000 and 9 months above. Each additional financed property adds 2 months, to a 12-month maximum. First-time investors carry 12 months.
A portfolio pledged to a securities-backed line adds another wrinkle. The lender will want the file qualified net of the line balance. Bring that balance to the first conversation, not the last.
How the Super Jumbo Tier Changes the File
Credit, reserves and leverage tighten as the loan grows. Above $3,500,000 on a primary residence, and above $3,000,000 on a second home or investment property, super-jumbo overlays apply. These include a 700 credit floor, a 0x30x24 housing history and 48-month seasoning on any credit event. Borrowers must be U.S. citizens or permanent residents, and non-occupant co-borrowers are not allowed. Rural property is out, ten acres is the maximum, and cash-out proceeds cannot satisfy reserves.
On a primary residence, leverage steps down with size, through select wholesale programs, subject to underwriting:
| Loan band | Purchase | Program |
|---|---|---|
| $300K–$1M | 90% | Portfolio |
| $1M–$1.5M | 85% | Portfolio |
| $1.5M–$2M | 85% | Portfolio |
| $2M–$2.5M | 80% | Portfolio |
| $2.5M–$3M | 80% | Portfolio |
| $3M–$3.5M | 75% | Portfolio |
| $3.5M–$4M | 75% | Portfolio, super-jumbo overlays |
| $4M–$5M | 65% | Bank portfolio, on review |
| $5M–$6M | 60% | Bank portfolio, on review |
| $6M–$10M | 60% | Bank portfolio, on review |
| $10M–$20M | 55% | Bank portfolio, on review |
| $20M–$30M | 55% | Bank portfolio, on review |
The bands are loan amounts, not purchase prices. Multiply price by leverage first, then read the band for that loan. The top cell in each band needs a stronger score. The $3.5M–$4M band, for example, needs 760 at its best leverage, while a lower score takes a lower cell in the same band. Those are the scores top leverage needs, not floors. The floors are 660 on the portfolio program to the super-jumbo line and 700 above it, while the bank portfolio program keeps its own 680 floor at every size.
Second homes and investment property take their own ladders. The purchase ceiling matches the primary figure in some bands and sits as much as 15 points under it in others, so read each occupancy’s own ladder.
Mixed Income: Pension, Social Security and Portfolio
Most retirees have some paper income. Pension and Social Security can sit alongside the asset allowance as supplemental income. That is the situation where the 36-month divisor can apply, provided debt-to-income before the asset income is at or below 60%.
The lender documents each stream. Expect award letters and account statements for every source used. Qualifying income is built from what the file shows, and a source the file does not document does not count.
Documents, Timing Risk and the Verification Standard
Expect complete statements for every account used, every page. Lump sums and unusual deposits need a letter of explanation. If a business account is used, add ownership proof and entity documents.
Market moves matter too. A portfolio that falls between application and closing shrinks the base the lender is reading. Large recent transfers draw questions about sourcing. Keep funds where they are and keep records clean.
Verification is not optional. Federal ability-to-repay rules require a lender to make a good-faith determination that a consumer can repay, and a borrower’s own statement does not satisfy that test, per CFPB Regulation Z, 12 CFR 1026.43. The eCFR text says the lender must verify the income or assets it relies on. The CFPB’s compliance guide lists vested retirement balances, stocks and bonds among the assets a lender may consider. That is why “no documentation” is the wrong picture: the file simply documents balances instead of paychecks.
Where the General Rule Breaks
- Retirement distributions. A distribution in a deposit account is not statement income. The asset path is the only way to count the balance.
- Down payment. Funds used for the down payment cannot also count as an asset for income.
- Trusts. Only a revocable living trust holds qualifying assets. Other trusts do not.
- Age 59½. The retirement haircut moves from 70% to 80% at that age.
- Cash-out. Proceeds are unlimited at or below 60% LTV. Above 60%, the portfolio program caps cash in hand at $1,500,000. Cash-out proceeds cannot satisfy reserves on super-jumbo files.
- Interest-only. The portfolio program offers interest-only to 85% LTV with a 700 floor, on purchase and rate-term files. The bank program stops at 60%.
- Case-by-case top end. Above $4,000,000, nothing is automatic. Terms vary by lender guidelines, property type, leverage, credit profile, and full file review.
If the file fails on one constraint, such as leverage, credit, reserves or liquidity, the fix is usually targeted. Lower the loan, add a co-borrower with stronger credit where allowed, or move to another documentation path.
Self-employed income in a retiree’s past can complicate the file too. Lendmire’s piece Does Undistributed K-1 Income Qualify on a Super Jumbo Bank Statement Loan? covers that edge. And if the property is a rental, rent may carry its own test: investor loans are designed for non-owner-occupied property and are reviewed differently from a standard owner-occupied mortgage.
What the Decision Looks Like
Start with three questions. Where is the strongest evidence of capacity: deposits, balances or property rent? What is the size of the loan, and which band does it land in? And how many dollars are available after closing costs and reserves are set aside?
Sometimes this path is not the simplest one. A borrower who can document income with full returns, or who has a relationship with a lender holding assets under management, may find that route easier. The asset paths earn their place when balances are large, paper income is small and the buyer wants to keep the portfolio invested.
Key Terms Defined
- Super jumbo: A non-agency mortgage above the standard jumbo range, underwritten by the lender or a portfolio program.
- Asset allowance: A method that divides liquid assets by 36, 60 or 84 months to create qualifying income.
- Assets-only: A path with no debt-to-income test, using liquidity equal to the loan plus closing costs.
- Haircut: The percentage by which a lender discounts an asset, such as retirement accounts at 70%.
- Reserves: Liquid funds left after closing to cover future payments.
- Notional income: Income calculated on paper from assets, not received as a paycheck.
Frequently Asked Questions
Do I have to sell my investments to qualify?
No. The lender reads balances and does the division on paper. Assets stay invested and are not pledged. The exceptions are funds you choose to spend on the down payment or closing costs, which leave the pool.
Can I use my IRA or 401(k)?
Yes, for vested balances. Retirement accounts count at 70% of value, or 80% at age 59½ and older, through select wholesale programs, subject to full underwriting. Distributions deposited in a bank account do not count as statement income.
Do bank statements apply to a retiree with no business?
Rarely. Statement qualification reads deposits, and a retiree’s deposits are often a pension and Social Security. Unless a business or steady deposit stream exists, the asset allowance or assets-only path fits better.
What if my portfolio is pledged to a securities-backed line?
The file is generally qualified net of the line balance. Disclose the line early. Funds already committed elsewhere cannot also serve as income base or reserves.
What if I’m declined?
Find the binding constraint: leverage, credit, reserves or liquidity. A lower loan amount, a different documentation path or a different program in the network can change the answer. Every file is underwritten individually, and nothing here is a commitment to lend.
If you are financing a high-balance property on business or personal bank statements and want to see how the numbers work, Lendmire can help you compare super jumbo bank statement loan options based on your deposits, the property, credit profile, leverage, and your goals.
Lendmire’s self-employed mortgages page presents both super jumbo programs, bank statement and DSCR, side by side.
About Lendmire
Lendmire — NMLS# 2371349 — is a mortgage broker that arranges bank statement, P&L-only, 1099-only and asset-based home financing in 16 states through wholesale lenders, on primary residences, second homes and investment properties. Every option is subject to the lender’s guidelines and full underwriting. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
1. CFPB – 12 CFR 1026.43 (ability to repay)
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 a Super Jumbo Bank Statement Investment Property Loan Works · How a Bank Statement Jumbo Loan Works in Vail · How a Bank Statement Jumbo Loan Works in Vero Beach
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Disclosure information. Lendmire is a state-licensed mortgage brokerage under NMLS# 2371349. Lendmire is not a depository institution, direct lender, or financial advisor — all loans referenced are placed through wholesale lender partners and are subject to each lender's underwriting standards. This article is provided for general informational purposes and is not a commitment to lend, nor does it constitute financial, legal, or tax advice. Loan programs, terms, rates, and qualification standards change without notice and depend on borrower profile, property type, and the state in which the subject property is located. Equal Housing Opportunity provider. NMLS Consumer Access: nmlsconsumeraccess.org.