The Quick Read: Yes, publicly traded stocks held in a documented brokerage account count on both asset-based paths, though the share that counts depends on the path. On the asset qualifier path, brokerage accounts count at 100% of the balance, and eligible assets must equal or exceed the entire loan. On the asset depletion path, securities count at 80% and are divided by 60 months to create qualifying income. Subject to underwriting, through select programs.
- Stocks must sit in a regulated brokerage account in the borrower’s own name.
- Qualifier path: brokerage at 100%, loans to $4,000,000, 80% on a purchase and 75% on a refinance.
- Depletion path: securities at 80%, then divided by 60 months into monthly income.
- Statements are required on both paths. Income is not documented on the qualifier path, but the assets are.
- Unvested restricted stock, stock options, and borrowed or pledged shares do not count.
Which Path Are You On?
Lendmire is a broker. It arranges these loans through select lenders in its wholesale network, and a borrower is qualified on one path at a time. Mixing the two tables is a common mistake on early conversations, so name the path first.
The asset qualifier path covers the whole loan with assets. Eligible balances, after the credit percentages, must equal or exceed the entire loan amount. No employment or income is documented. Leverage runs up to 80% on a purchase and 75% on a refinance, on a principal residence or second home. Loans go to $4,000,000.
The asset depletion path turns assets into income. Usable assets are divided by 60 months. That monthly figure must carry the housing payment and other debts through the debt-to-income test. Loans run from $125,000 to $3,500,000. Investment property is allowed on this path only.
For a reader who lives on a portfolio, the first question is simple. Do your assets cover the loan outright? Then the qualifier path fits. Do they fall short, but throw off enough value to support the payment as income? Then look at depletion.
How Much of a Stock Balance Counts?
The share depends on the path, and the two numbers are not interchangeable.
| Asset | Qualifier path | Depletion path |
|---|---|---|
| Brokerage / securities | 100% | 80% |
| Cash, savings, money market | 100% | 100% (cash accounts) |
| Certificates of deposit | 100% | 100% |
| Retirement accounts | 90% under 59½, 100% after | 70% at any age |
| Private stock | Not published | 75% |
| Real-estate equity | Not published | 60% |
These are this program’s figures through select lenders, not a market norm. Lenders discount differently, and no single industry formula exists. Lenders apply the discount because shares can fall in value, cost money to sell, and may carry tax when sold.
What Federal Rules Say
Consumer ability-to-repay rules allow a lender to rest its decision on income, on assets other than the home being financed, or on both, per CFPB Regulation Z § 1026.43. The CFPB’s small entity compliance guide lists stocks, bonds, vested retirement amounts, and savings among assets a lender may consider. The rule sets no haircut and no divisor. Those come from each program’s guidelines.
Worked Examples
Each lender’s own calculation governs. These show the shape of the math.
Qualifier path. Take an $800,000 loan. The borrower holds $330,000 in brokerage accounts (100% = $330,000), $300,000 in a 401(k) while under 59½ (90% = $270,000), and $200,000 in savings (100% = $200,000). Usable assets total $800,000. That equals the loan, so the file can qualify on assets alone, subject to underwriting.
Depletion path. A borrower holds $1,500,000 in securities (80% = $1,200,000) and $300,000 in cash (100% = $300,000). Usable assets are $1,500,000. Divide by 60 months and the result is $25,000 of monthly qualifying income. That income then carries the housing payment and other debts through the debt-to-income test.
Notice what the depletion example shows. The same securities that count at 100% on the qualifier path count at 80% here. Pick the path that fits the balance sheet, not the one with the bigger number.
Which Stocks and Investments Count?
Eligibility is about ownership and access, not only the ticker.
| Holding | Counts? |
|---|---|
| Public stocks in your own brokerage account | Yes |
| ETFs and mutual funds in a brokerage account | Generally yes, as brokerage assets |
| Private stock | Depletion path only, at 75% |
| Non-vested restricted stock units | No |
| Stock options | No (depletion path) |
| Margined, pledged, or borrowed shares | Not as available assets |
| Crypto, precious metals, collectibles | Not published as eligible |
| Custodial accounts, deferred compensation | No (depletion path) |
Vested RSUs that have been delivered to your brokerage account are ordinary shares at that point. Unvested ones are not. Crypto and similar holdings are not published as counting on either path. The documented route is converting them to a seasoned cash balance in a regulated account, with the source reviewed by the lender.
Edge Cases That Trip Up Stockholders
Shares are not cash to close. A brokerage statement proves value. It does not move money. Down payment funds generally need to arrive as cash, so shares you sell for the purchase leave the pool you qualify on.
No double counting. The same shares cannot fund the down payment and also support qualifying. Closing funds come out first, and what remains is tested.
Margin and pledged shares. A margin balance or a line secured by the portfolio is borrowed money. Borrowed funds do not count. Confirm treatment before drawing on any line.
Concentrated positions. A portfolio that is mostly one stock still counts under the published percentages, but expect closer review of the file. Underwriters look at what the balance would be after a drop.
Market moves before closing. Values are taken from statements. A large drop between statements can change the usable total, so keep a cushion above the loan amount on the qualifier path.
Dividends. On the depletion path, assets already producing income that you use in another calculation are not counted twice. Raise this early.
Trust and joint accounts. Titling matters. Bring the account agreement so ownership is clear.
Seasoning and Statements
Both paths document the assets. “No income documentation” never means no documentation.
On the qualifier path, funds need 60 days of seasoning, with two months of statements for each qualifying account. On the depletion path, statements must be at least 120 days old at application, plus the most recent statement within 45 days. Funds from the sale of a business, an inheritance, or a legal settlement are excused from that seasoning. Large recent deposits or transfers into the account draw questions, so have the source paper trail ready.
Credit still matters. The qualifier path has a 600 minimum score. The depletion path follows the lender’s matrix, and a first-time investor there needs 700. Housing history is 0x30x12, one late in twelve months is reviewed case by case, and multiple bankruptcies are not eligible.
Depletion Path Minimums
Depletion carries asset minimums. Qualified assets must reach the lesser of $1,000,000 or 1.25 times the loan balance. When assets are the only income source, liquid assets must be at least $250,000. If asset-derived income supplements documented income, it can do so up to a 45% debt-to-income ratio, and the minimum-assets rule is waived.
Leverage on depletion is lower than most people expect. A principal residence or second home goes up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out. Investment property goes up to 65% and 60%. Cash-out proceeds never count as qualifying assets.
On the qualifier path, no reserves are required at or below 75% loan-to-value. Above that, the lender sets them.
Stocks and Rental Investors: A Different Question
Many investors asking this really mean a DSCR loan. Those are business-purpose loans on non-owner-occupied rentals, and they qualify primarily on property-level rental income covering the payment, subject to lender guidelines. There, stocks usually matter as reserves rather than income, and brokerage balances are commonly accepted as documented liquid assets. Read the complete DSCR loans guide for how that works.
Asset qualification is the alternative when rent does not carry the payment or when you want the borrower, not the property, to drive the file. The portfolio stays invested rather than being sold. Tax treatment varies; consult a qualified professional.
Common Mistakes
- Assuming stocks count at the same percentage on both paths.
- Planning to use unsold shares as the down payment.
- Counting unvested RSUs or options.
- Drawing on a margin line before the application.
- Moving money between accounts without a paper trail.
- Treating retirement and brokerage balances the same way.
For related questions, see Lendmire’s piece Do You Have to Liquidate Assets to Reserve an Asset Qualifier Mortgage?.
Key Terms Defined
Asset qualifier: a path where eligible assets must cover the whole loan and no income is documented.
Asset depletion: a path that divides usable assets by 60 months to create monthly qualifying income.
Credit percentage (haircut): the share of an account balance that counts toward qualifying.
Seasoning: the length of time funds must have been in an account before they count.
Third-party verification: records from the custodian, such as account statements, that prove ownership and value. The federal ability-to-repay text requires this for assets a lender relies on.
Frequently Asked Questions
Do I have to sell my stocks to qualify?
No. Statements prove the balance, and the shares stay invested. The exception is cash to close, which generally needs to be cash in your account, so shares sold for that purpose leave the qualifying pool.
Do ETFs and mutual funds count?
Generally yes when they sit in a regulated brokerage account, since they are treated as brokerage assets. Confirm the specific holdings with the lender during review.
Do restricted stock units count?
Only once vested and delivered to your brokerage account. Non-vested units and stock options do not count on the depletion path.
Can I use margin or pledged stock?
Not as available assets. Borrowed funds and shares securing a loan are not treated as your own unencumbered balance.
Is a 401(k) treated like a brokerage account?
No. On the qualifier path, retirement accounts count at 90% under age 59½ and 100% at 59½ or older. On the depletion path they count at 70% at any age.
If you are qualifying on assets rather than income and want to see how the numbers work, Lendmire can help you compare asset-based mortgage options based on your statements, the property, credit profile, leverage, and your goals. Figures are ceilings and floors, not offers, and every file is underwritten individually. Consumer mortgage lending through this program is licensed in 16 states.
About Lendmire
Lendmire (NMLS# 2371349) is a mortgage broker licensed for consumer lending in 16 states. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
1. CFPB Regulation Z § 1026.43
2. CFPB ATR/QM Small Entity Compliance Guide
This article is part of Lendmire’s asset-based mortgage program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: How Asset Qualifier Mortgage Loan Limits Work · Asset Qualifier vs Asset Depletion for a Cash-Out Refinance · How to Qualify for an Asset Qualifier Mortgage
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.