The Quick Read: Usually yes, because most asset-based programs treat Treasury bills as highly liquid and let them count toward the assets that cover the loan, provided the bills sit in the borrower’s own verifiable account and are not pledged. Final treatment is set by the specific program and underwriter, subject to lender guidelines.
- On the asset qualifier path, the eligible assets after credit percentages must equal or exceed the entire loan amount.
- On the asset depletion path, usable assets are divided by 60 months to produce qualifying income.
- Bills must be in the borrower’s name, documented by statements, and not pledged or borrowed against.
- Bills already earmarked for the down payment or closing costs cannot be counted a second time.
- Rental purchases are usually a DSCR matter, where the property’s rent drives qualification instead.
Which Path Are You On?
Treasury bills matter differently depending on the path, and a borrower is qualified on one path at a time. Across Lendmire’s wholesale network, asset-based consumer mortgages come in two forms, both placed through select programs and underwritten individually.
The asset qualifier path covers the whole loan with eligible assets. No employment or income is documented. Brokerage accounts, certificates of deposit, money market and savings balances count at 100%. Retirement accounts count at 90% under age 59½ and 100% at 59½ or older. Leverage runs up to 80% on a purchase and 75% on a refinance, with loans to $4,000,000, subject to underwriting.
The asset depletion path turns assets into income. Cash and CDs count at 100%, securities at 80%, private stock at 75%, retirement accounts at 70% and real-estate equity at 60%. The usable total is divided by 60 months, and that qualifying income runs through the debt-to-income test. Loans run from $125,000 to $3,500,000.
Neither path lists Treasury bills as a separate line. That is normal. Where a bill lands depends on how the lender classifies it, and that is the question the rest of this article answers.
Why Treasury Bills Usually Count
Treasury bills are about as close to cash as an investment gets. TreasuryDirect says bills are sold in terms from four weeks to 52 weeks, pay interest at maturity as the gap between purchase price and face value, and can be held to maturity or sold earlier. The Treasury also states that its marketable securities are backed by the full faith and credit of the U.S. government.
Underwriters care about four things: is the asset liquid, verifiable, accessible and owned by the borrower? A bill held in your own account passes all four. It can be sold, it shows on a statement, and nobody else has a claim on it.
Here is the catch. Many lenders do not name T-bills at all. Their guidelines say “securities” or “bonds,” and the treatment depends on which bucket the underwriter uses. On the asset qualifier path, a bill held in a brokerage account fits the brokerage line at 100%. On the asset depletion path, an underwriter may place the same bill with cash-like items or with securities at 80%. That is why the honest answer is generally yes, with the exact percentage confirmed against the program before you plan around it.
The Accounting Trap: “Cash Equivalent” Is Not the Mortgage Test
Many borrowers hear that only bills of three months or less count. That comes from accounting, not mortgage underwriting.
Under accounting rules, a Treasury bill is a cash equivalent only if its original maturity is three months or less. Becker notes that a six-month bill does not qualify even when only two months remain, and the Corporate Finance Institute describes the same original-maturity logic. Those tests exist for financial statements.
A mortgage underwriter asks a different question: can this asset be verified and turned into cash? A 26-week or 52-week bill is generally still a liquid, marketable asset. Don’t sell a longer bill just to satisfy an accounting definition that the loan file does not use.
How Bills Are Valued and What Happens at Maturity
Bills are sold at a discount. You pay less than face value and receive face value at maturity, so there is no periodic interest. A statement may show the purchase price, the face value or the current market value. Which figure the underwriter uses is set by the program, so ask before you assume.
Maturity matters too. If a bill matures and you roll it into a new one during the file, the statements show activity that needs a plain explanation. Investors who roll bills weekly or monthly should expect to supply statements that show the balance holding steady. The simplest file shows the same holdings over the full statement window.
Where the Bills Are Held
A brokerage account is the cleanest home. Statements show holdings, ownership and market value, and that is exactly what underwriters read.
A TreasuryDirect account is the Treasury’s own platform, and it can also be documented, though some underwriters want more than a screenshot. Cash management bills are different: TreasuryDirect says they are available only through a bank, broker or dealer. Bills moved between accounts mid-transaction can create sourcing questions, so avoid moving them once you are in contract.
Documentation to gather:
- Statements for each account holding bills. Two months per account on the asset qualifier path, which also carries a 60-day seasoning requirement.
- On the asset depletion path, statements at least 120 days old at application, plus the most recent statement within 45 days.
- Proof the account is in the borrower’s name.
- Confirmation that the bills are not pledged as collateral or bought with borrowed funds.
- An explanation for any large recent transfers.
For more on how the cash side of the file behaves, Lendmire’s piece Do You Have to Liquidate Assets to Reserve an Asset Qualifier Mortgage? covers the same documentation logic.
Worked Illustration: Bills in a Mixed Portfolio
These figures are illustrative, and the lender’s own calculation governs. Programs differ in how they classify bills, so treat this as a shape, not an offer.
Consider an $800,000 loan on the asset qualifier path. The borrower holds $330,000 in brokerage accounts, including Treasury bills held there, which count at 100% as $330,000. A 401(k) of $300,000 under age 59½ counts at 90%, or $270,000. Savings of $200,000 count at 100%. Usable assets total $800,000, which equals the loan, so the file is reviewed on assets alone, subject to underwriting.
Now the trap. If that same borrower also needs cash for the down payment and closing costs, those funds are not available twice. Money committed to closing comes out of the pool first. Many borrowers count every dollar they own and forget this step, and the file comes up short.
On the asset depletion path, take $1,500,000 in securities at 80%, which is $1,200,000, plus $300,000 in cash at 100%. Usable assets total $1,500,000. Divided by 60 months, that is $25,000 of monthly qualifying income, which then carries the housing payment and other debts through the debt-to-income test. If an underwriter files the bills with cash instead of securities, the usable total rises. That one classification decision can move the result.
How Bills Compare With Other Assets
| Asset | Asset qualifier path | Asset depletion path |
|---|---|---|
| Savings, money market | 100% | Cash accounts 100% |
| Certificates of deposit | 100% | 100% |
| Brokerage holdings | 100% | Securities 80% |
| Retirement accounts | 90% under 59½, 100% after | 70% at any age |
| Treasury bills | Held in brokerage, 100% line | Program-dependent: cash-like or securities |
Bonds and bill-based funds are more likely to sit in the securities bucket than a bill held directly. Treat each as a separate question for the lender.
Common Mistakes
- Counting bills already committed to closing. Funds for the purchase come out first.
- Moving bills right before applying. Fresh transfers need sourcing, and seasoning rules apply.
- Pledged or borrowed bills. Pledged assets, borrowed funds and gift money are generally excluded. Even agency rules treat them that way, according to a Freddie Mac guideline summary.
- Counting the interest twice. Income earned on an account is not added on top of the asset calculation for that same account.
- Assuming “no income documentation” means no documentation. Assets are documented thoroughly on both paths.
Tax is a separate question: tax treatment varies by situation, so consult a qualified professional before selling bills to raise cash.
Does This Matter for a Rental Purchase?
Mostly no. Asset-based mortgages are consumer loans aimed at principal residences and second homes. Investment property is available only on the asset depletion path, at up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out, subject to underwriting. Cash-out proceeds never count as qualifying assets.
For a pure rental purchase, the usual route is a DSCR loan, which qualifies primarily on property-level rental income covering the payment, subject to lender guidelines. Bills still help there, as sourced funds for the down payment, closing costs and reserves once documented. Lendmire’s complete DSCR loans guide explains that route. Borrowers who document income through deposits instead can compare asset qualifier and bank statement mortgages.
Key Terms Defined
Asset qualifier: a path that drives lender review when eligible assets cover the entire loan amount.
Asset depletion: a path that divides usable assets by 60 months to create qualifying income.
Haircut: the share of an asset’s value a program does not count.
Seasoning: how long funds must have been in an account before they count.
Cash equivalent: an accounting label for very short-term, highly liquid instruments, which is not the mortgage test.
Frequently Asked Questions
Do Treasury bills I just bought count?
Often yes, but the money used to buy them still needs a paper trail. The asset qualifier path asks for 60 days of seasoning and two months of statements per account. Moving cash into bills just before applying invites sourcing questions, subject to underwriting.
Can the same bills cover the down payment and qualify me?
No. Funds needed for the purchase and closing come out of the pool first, and only what remains counts toward qualifying. Each dollar is used once.
Do bills count before they mature?
Generally yes. Bills can be sold before maturity, and underwriters care about liquidity and ownership, not whether the term has run out. The statement value the lender uses is set by the program.
Are notes, bonds and Treasury funds treated like bills?
Not always. Ask the lender how each holding is classified.
Will I need to sell my bills?
Usually not. Eligible assets generally stay invested and are documented rather than liquidated, provided they are not pledged. Confirm the specifics with the lender before you rely on that.
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. Consumer mortgage lending is available in 16 states, and all figures here are program ceilings and floors, not offers or a commitment to lend.
Bills that mature on a schedule and roll cleanly into the next one make the easiest statements to underwrite.
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. TreasuryDirect – Treasury Bills
2. Becker – Cash and Cash Equivalents
3. Corporate Finance Institute – Cash Equivalents
4. Homebuyer.com – Freddie Mac Asset-Based Qualification Summary
This article is part of Lendmire’s asset-based mortgage program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: Do Cash-Out Proceeds Count as Assets on an Asset Depletion Refinance? · Asset Qualifier Mortgage vs Bank Statement Mortgage · How Lenders Count Assets Toward an Asset Depletion Mortgage
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Legal disclosures. Lendmire (NMLS# 2371349) is a state-licensed mortgage brokerage that arranges financing through wholesale lender relationships. Lendmire is not a direct lender, depository institution, or registered financial advisor. The discussion above is general informational content about real estate financing — it is not financial, legal, or tax advice, and readers should consult licensed professionals for guidance on their individual circumstances. Loan inquiries are subject to lender underwriting; this article does not represent a commitment to lend. Loan terms, rates, and qualification standards vary by borrower, property, and state, and are subject to change at any time. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.