Can an Enrolled Agent Letter Replace a CPA Letter on a Bank Statement Loan?

The Quick Read: Usually yes, where the program’s guidelines list an enrolled agent (EA) as an accepted signer of the expense-ratio letter, and most bank statement programs across Lendmire’s wholesale network do. Acceptance is set by each lender’s guideline, not by a universal rule, so a few programs still say CPA only.

• Ask for the program’s signer list before you order the letter.
• The signer must have reviewed your actual financials. You cannot self-certify.
• The letter is optional on most files. The default expense factor works without it.
• The letter only helps when your real expenses sit well below the default.
• This is a bank statement question. DSCR loans qualify on the property’s rent, so no letter applies there.

Self-employed borrowers hit this question late in the file. The lender says “CPA letter,” and the borrower’s tax preparer is an EA. The borrower wonders whether to pay a second professional. Most of the time, they should not. The rest of this piece covers when that holds, when it doesn’t, and what to do either way.

Key Terms Defined

Expense factor: The percentage of business-account deposits the lender treats as operating costs. The rest counts toward qualifying income.

Expense-ratio letter: A signed letter from a tax professional certifying the business’s actual expense percentage, which can replace the lender’s default factor.

Enrolled agent (EA): A tax professional credentialed by the IRS itself, with unlimited rights to represent taxpayers before the IRS.

CPA: A certified public accountant, licensed by a state board of accountancy.

P&L-only loan: A different product where a third-party-prepared profit-and-loss statement is the income document, instead of bank statement deposits.

What Is the Letter Actually For?

The letter exists to replace a default. On a bank statement loan, the lender averages 12 months of eligible deposits and applies an expense factor to business-account deposits. What remains is qualifying income. Personal-account statements usually skip the factor, since personal deposits aren’t treated as business revenue with costs attached.

The default factor is a blunt number. If your business runs lean, it understates your income. A tax professional can certify the real ratio on letterhead, and the lender may use it instead. That is the whole job of the letter.

Two points get confused here:

• It is not required on most files. Many loans close on the default factor alone.
• It is not a P&L. A letter certifies a ratio. On a P&L-only loan, the preparer’s statement is the income document itself. Those programs often have tighter rules on who can sign, so don’t assume an EA answer for one carries to the other.

How Does an EA Compare With a CPA for This Job?

For tax matters, the two are close peers. The IRS says that attorneys, CPAs, and enrolled agents may usually represent taxpayers before the IRS. The credential comes from the IRS directly. Per the IRS enrolled agents FAQ, the path is a PTIN, passing all three parts of the Special Enrollment Examination, applying for enrollment, and clearing a suitability check on tax compliance and criminal background.

The one real difference is the licensing body. A CPA carries a state accountancy license. An EA carries a federal enrollment. An underwriter who wants a “licensed” professional may look the EA up on the IRS listing. That is a quick check, not a barrier.

Why the Lender Makes the Call

No federal rule says who must sign an expense-ratio letter. The federal consumer-finance regulator’s repayment-capacity rule requires that, on covered consumer loans, a creditor verify the income or assets it relies on using reliable third-party records. It doesn’t name signers or set an expense formula. The signer list lives in each lender’s guideline.

That is why answers differ across the wholesale network. Across the programs Lendmire works with, the usual wording is “CPA, enrolled agent, or qualifying tax preparer.” Some lists add a state-registered preparer or a tax attorney. A few say CPA only, and a few require a CPA for the full P&L product.

Why would a lender say CPA only? Usually it is guideline wording inherited from an investor, or an overlay the lender added. It is rarely a judgment on EAs. Understanding that helps, because the fix is a conversation, not a fight.

Who Cannot Sign

Four signers don’t work on any program:

1. The borrower. Self-certification defeats the purpose. A third party must provide it.

2. A bookkeeper without tax credentials. Keeping books is not the same as certifying a ratio.

3. A software printout. Accounting software reports can support the work. They are not a signed certification.

4. A preparer who never reviewed your records. The signer should have looked at the real financials, and ideally prepared or reviewed the latest filed return.

Unenrolled preparers sit in a gray zone. They can sign traditional personal-income documentation, but the IRS limits their representation rights, as the IRS tax professionals FAQ explains. Whether one counts as a “qualifying tax preparer” is a program-by-program call.

What the Letter Must Contain

Programs differ on formatting, but a clean letter generally carries these items:

• The preparer’s name, credential, and license or enrollment details
• The certified expense percentage, stated plainly
• The business name and the period it covers
• A period that matches the bank statements being used
• Letterhead and a signature
• No exculpatory disclaimer that undercuts the certification

Underwriters also test reasonableness. A certified ratio far below what the deposit pattern suggests draws questions. A lender can apply a higher factor if the statements show heavier costs than the letter claims. The letter is evidence, not a guarantee.

How to Find Out Whether Your EA’s Letter Will Work

Run it in this order. Skipping step one is how borrowers pay twice.

1. Ask your loan officer for the program’s signer list in writing. Don’t ask “is an EA okay?” Ask which credentials the guideline names.

2. Ask for the lender’s wording on the letter. Get the required elements and the period rules.

3. Confirm your EA will certify the ratio. Some preparers hesitate to certify beyond what they reviewed. That’s reasonable. The letter should rest on their actual review.

4. Match the period. The letter’s window should line up with the statement period you are submitting.

5. Send the letter with the full file, not after the underwriter has already run the default.

Lendmire’s piece Does the Expense Factor Replace a CPA Letter on a Bank Statement Loan? covers the default-versus-letter decision in more depth.

If the Lender Says CPA Only

Don’t assume the file is dead. Work the options in this order:

• Ask for the guideline wording. Sometimes the loan officer is repeating habit, and the guideline lists EAs.
• Ask about an exception. Some lenders will review one when the EA prepared the filed return.
• Have a CPA review and reissue. A CPA can co-review the EA’s work and sign. Expect a modest fee.
• Move to another program. With many lenders in the network, a different program may list EAs.
• Skip the letter. If the default factor still qualifies you, the letter may not be worth chasing.

Choosing by the letters after the preparer’s name is the wrong approach. Choose by what the lender accepts.

A Worked Example

Consider a self-employed borrower with steady business-account deposits. Under the default factor, a large share of those deposits is treated as expense. Their EA reviews the filed return and certifies that actual expenses run much lower. If the lender accepts the letter, qualifying income rises, and so does the borrower’s room on the debt-to-income math.

Now flip it. A contractor with heavy material costs may find that the real ratio is at or above the default. The letter then adds nothing, or lowers income. Order the letter only when your real expenses sit well below the default. Ask your preparer for a rough read of your actual ratio first.

EA Letter Versus P&L-Only Documents

This is where borrowers get tangled. On a bank statement loan, the preparer’s document adjusts the expense factor. On a P&L-only loan, the preparer’s statement is the income. Self-prepared P&Ls aren’t accepted in either lane.

EAs are often accepted for the P&L product too, but guidelines vary more there. Treat each document as its own question and ask the signer-list question separately.

Where This Fits in Lendmire’s Bank Statement Program

Lendmire is a mortgage broker that arranges bank statement financing through select lenders in its wholesale network. The program reviews the file on documented income under the applicable program, subject to lender guidelines. Typical features include:

• 12 months of business or personal bank statements, with income from deposit averaging
• Up to 90% LTV on a primary-residence purchase or rate-term refinance, for stronger files
• Up to 80% LTV on an owner-occupied cash-out (primary or second home), using a fixed expense ratio, or 75% with an accountant-prepared ratio, by loan size and credit
• Up to about 75% LTV on investment-property cash-out
• Loan amounts of roughly $125,000 to $3,500,000, with reserves commonly around 6 months

That 75% accountant-prepared ratio on an owner-occupied cash-out is worth noting. A signed ratio can change the leverage tier, so the signer question matters beyond income alone. Investment purchase leverage on bank statement documentation varies by lender.

Consumer mortgage licensing for this lane covers 16 states. Occupancy decides the disclosure regime. An owner-occupied file is a consumer mortgage. A bank statement loan on a non-owner-occupied rental, including a short-term rental, is business-purpose. For investors, the complete DSCR loans guide explains the alternative that is reviewed on rent and needs no signer at all. Lendmire’s article How to Use a CPA Letter for a Bank Statement Jumbo Loan covers the larger-balance version.

Qualification, leverage, and terms are subject to lender guidelines and individual underwriting. This is not a commitment to lend. Tax treatment varies; consult a qualified professional.

About Lendmire

As a mortgage broker (NMLS# 2371349), Lendmire helps self-employed and high-net-worth borrowers in 16 states qualify on bank statements, a profit-and-loss statement, 1099s or liquid assets instead of traditional personal-income documentation, through wholesale lenders. Lendmire is never the lender; program terms are set by the lender and its guidelines. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.

References

1. IRS Publication 947

2. IRS Enrolled Agents FAQ