The Quick Read: It depends on the program, and an HSA is not on the published eligible-asset lists for either asset-based path in Lendmire’s wholesale network, so you should not plan on it counting until a lender confirms it for your file. The asset qualifier path lists savings, money market, CDs, brokerage and retirement balances. The asset depletion path lists cash, CDs, securities, private stock, retirement and real-estate equity. Health savings accounts appear on neither list.
- An HSA is not automatically excluded, but it is not a standard asset either.
- Any treatment would be decided by the lender on your file, not by a universal rule.
- A small HSA rarely changes whether you qualify.
- Do not drain an HSA to improve a file before you have asked.
- Rental purchases usually fit DSCR financing better than either asset path.
Does an HSA Count on the Asset Qualifier Path?
Probably not as a counted asset, and certainly not at full value by default. The path asks a simple question: do your eligible assets, after the credit percentages, equal or exceed the entire loan? Through select programs, the answer comes from a published list of account types. An HSA is not on that list.
That does not make it worthless. Lenders sometimes review unlisted accounts case by case. A lender might accept an HSA at a reduced percentage, accept it only as cash held in the account, or leave it out entirely. Nothing is standard here.
This is why borrowers get conflicting answers. One loan officer is thinking about reserves. Another is thinking about income conversion. A third works for a program that simply never listed HSAs. All three can be right for their own program.
How an Asset Qualifier Mortgage Counts Assets
Two asset-based paths exist, and a borrower is reviewed on one at a time. Keep them apart, because the percentages differ.
The asset qualifier path covers the whole loan with eligible assets. Employment and income are not documented, but the assets are fully documented. Through select programs, leverage runs up to 80% on a purchase and 75% on a refinance of a principal residence or second home. Loan amounts run up to $4,000,000, with a 600 minimum credit score, subject to underwriting.
On this path, brokerage accounts, CDs, money market and savings count at 100%. A 401(k) or IRA counts at 90% under age 59½ and 100% at 59½ or older. Accounts combine.
The asset depletion path turns assets into monthly income. The lender takes usable assets, divides by 60 months, and runs the result through the debt-to-income test. Cash and CDs count at 100%, securities at 80%, private stock at 75%, retirement accounts at 70% at any age, and real-estate equity at 60%. Loan amounts run from $125,000 to $3,500,000. Leverage is up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out for a principal residence or second home, and up to 65% and 60% on those transactions for an investment property.
Neither path requires you to sell the assets. The money stays where it is, and the lender uses it in a calculation. If you wonder what that means for your portfolio, Lendmire’s piece Do You Have to Liquidate Assets to Reserve an Asset Qualifier Mortgage? walks through it.
What Test Does Every Asset Have to Pass?
Every counted asset has to be verifiable, accessible, and owned by you. Lenders also care whether it is liquid, meaning it can be turned into cash without a long wait or a big loss in value.
Seasoning matters too. Seasoning is how long the money has sat in your account. On the qualifier path, expect 60 days of seasoning and two months of statements for each qualifying account. On the depletion path, statements must be at least 120 days old at application, plus one statement dated within 45 days. All of this is subject to underwriting.
An HSA passes some of these tests easily. It is verifiable, because the custodian issues statements. It is owned by you, and it is portable if you change jobs. The harder questions are about access and purpose, which is where the next section picks up.
Where Does an HSA Fit?
An HSA sits in an awkward middle. It looks like cash, but its withdrawals are tied to a purpose. It resembles a retirement account because of its tax treatment, but it has no retirement-age wall in the same way. Under IRS Publication 969, distributions for qualified medical expenses are tax-free, the account is portable, and earnings inside it grow tax-free. Those features are the main reason an underwriter might treat an HSA as restricted rather than as plain cash.
Four things decide how a lender would see yours:
- Cash or invested. An HSA held in cash is easy to value. An HSA invested in funds has a balance that moves, so it looks like a securities account and may be treated like one.
- Purpose-restricted access. A lender wants to know you can reach the money. An HSA can pay for non-medical items, but not without tax consequences, so access is not free.
- Age. Lenders already treat retirement accounts differently under and over 59½. Ask whether any age line applies to an HSA, and do not assume the answer.
- Ownership. The account must be in your own name, with statements that show it.
No published guideline in this network tells you which of these four factors controls. Any treatment, such as a haircut or a cash-only limit, would be a lender decision.
How Do Different Accounts Compare?
The table shows how the published lists treat common accounts. Percentages are share of balance counted, subject to underwriting and through select programs.
| Account type | Qualifier path | Depletion path |
|---|---|---|
| Savings / cash | 100% | 100% |
| Brokerage / securities | 100% | 80% |
| 401(k) or IRA | 90% under 59½; 100% after | 70% at any age |
| HSA | Not published | Not published |
| Crypto, metals, collectibles | Not published | Not published |
Accounts that are not published as eligible are not counted at a percentage. The documented route for those holdings is converting them to a seasoned cash balance in a regulated account, with the source reviewed by the lender. That route has costs for an HSA, covered below.
Is It an Asset, a Reserve, or Cash to Close?
These are three different jobs, and one balance does not automatically do all three.
- Qualifying asset. On the qualifier path, it helps cover the loan itself. On the depletion path, it becomes income.
- Reserve. It is money left over after closing. On the qualifier path, none is required at or below 75% loan-to-value, and above that the lender sets them. The depletion path publishes no reserve months.
- Cash to close. It pays the down payment and closing costs, and it is subtracted before anything else is counted.
The same dollars cannot be counted twice. If an HSA were accepted for one job, a lender could still decline it for another. No guideline in this network says either way, so ask about each use separately.
Should You Drain the HSA to Help the File?
Usually not. Moving HSA money into a savings account moves it out of the HSA, and non-medical withdrawals are generally taxed and, before 65, carry an additional 20% tax under IRS Publication 969, so tax treatment varies and a qualified professional should weigh in before you move money.
There is a second cost. Funds moved into cash start a new seasoning clock, and the lender may ask where they came from. On the qualifier path that means 60 days and fresh statements. You could pay a penalty and still not meet the guideline.
Ask first. Then decide.
Does an HSA Actually Change the Math?
For most borrowers, no. HSAs are usually small next to a mortgage balance, and the asset-based paths are built for large balances.
Take a qualifier-path illustration, with the lender’s own calculation governing. Picture an $800,000 loan. You hold $330,000 in brokerage accounts, which count at 100% for $330,000. You hold $300,000 in a 401(k) at age 55, which counts at 90% for $270,000. You hold $200,000 in savings, which counts at 100% for $200,000. Together that is $800,000 of usable assets, enough to qualify on assets alone. An HSA is not needed.
If that file came up short, an HSA would only help if the lender agreed to count it and its balance were large enough to close the gap. Even then, it would likely count at some reduced share.
Now the depletion path. Say you hold $1,500,000 in securities, which count at 80% for $1,200,000, plus $300,000 in cash at 100%. That is $1,500,000 of usable assets. Divided by 60 months, it produces $25,000 of monthly qualifying income. That income then has to carry the housing payment and your other debts through the debt-to-income test.
Here an unlisted account matters even less. It would only add to the pool if the lender included it, and every added dollar is divided by 60.
Three borrower pictures show when it might matter:
- Small HSA balance. It makes no difference. Leave it alone.
- Large invested HSA, file short on assets. It may be worth asking, but expect a haircut and a lender decision, not a guarantee.
- Borrower under 59½ whose 401(k) already counts at 90%. The HSA is a minor add-on at best.
Paying a Mortgage With an HSA Is a Different Question
Three questions get mixed up online. They are not the same.
1. Counting an HSA balance as a qualifying asset. That is this article.
2. Paying a mortgage payment with HSA money. That is a spending question for you and your tax professional.
3. Buying property through a self-directed HSA. Some custodians allow it, but that is an investing structure, not a way to qualify for a loan.
Mixing them up leads borrowers to expect an HSA to behave like cash in a loan file. It does not, at least not by default.
What Should You Ask and Gather?
Ask your broker for the eligible-asset list before you pull a single statement. Then ask about HSAs directly, because they are rarely listed.
Bring these items to that conversation:
- Recent custodian statements for the HSA, showing the owner’s name.
- A note on whether the balance is cash or invested.
- Your other statements, two months each on the qualifier path.
- Your age, since percentages for retirement accounts change at 59½.
Documentation is the common thread. Bank-supervision guidance from the OCC describes asset depletion underwriting as using an applicant’s assets to calculate a hypothetical annuity stream that is added to other income when judging ability to pay. That bulletin is guidance to national banks. It does not list which assets count, and the lenders in a wholesale network follow their own guidelines.
What If You Are Buying a Rental?
Then the asset paths may not be your best fit. The asset qualifier path covers a principal residence or second home. The depletion path is the only asset path that allows an investment property, and it caps leverage at 65% on a purchase and 60% on a cash-out, through select programs and subject to underwriting. It also requires large balances, with qualified assets of at least the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 liquid when depletion is your only income source. Final terms depend on the lender’s guidelines, the property type, and the borrower’s complete credit picture.
Investors buying a pure rental often do better with DSCR financing. DSCR loans are designed for non-owner-occupied investment properties. Because they are business-purpose investor loans, they are reviewed differently from a standard owner-occupied mortgage. Qualification runs primarily on property-level rental income covering the payment, subject to lender guidelines, rather than on a pile of assets. Some select lenders in the network also offer programs below 1.00 coverage, but leverage and terms adjust. Lendmire’s complete DSCR loans guide explains how that works and when it beats an asset-based loan.
Key Terms Defined
Asset qualifier: A path where eligible assets alone must equal or exceed the entire loan amount, with no income or employment documented.
Asset depletion: A path that divides usable assets by 60 months to produce a monthly qualifying income, which is then tested against your debts.
Haircut: The share of an account’s balance a lender does not count, such as counting a retirement account at 70% of its value.
Seasoning: How long funds have been in your account, which lenders use to confirm the money is really yours.
Reserves: Liquid money left over after closing, held as a cushion.
HSA custodian: The bank or provider that holds your health savings account and issues its statements.
Frequently Asked Questions
Do I have to withdraw my HSA to use it?
No. Neither asset path asks you to sell or withdraw assets, because the lender uses a calculation. Withdrawing would only matter if you were converting an unpublished asset into seasoned cash, and that has tax and seasoning costs worth discussing first.
Is an HSA treated like a 401(k)?
Not by any published rule in this network. A 401(k) or IRA is on the published lists, at 90% or 100% on the qualifier path and 70% on the depletion path. An HSA is not listed, so any retirement-style treatment would be the lender’s call on your file.
Will my lender count an HSA as reserves?
Possibly, but ask. On the qualifier path no reserves are required at or below 75% loan-to-value, so the question rarely comes up. Above that, the lender sets reserves, and whether an HSA would count would be decided on your file, subject to underwriting.
Does a cash HSA count differently from an invested HSA?
Yes, it can. A cash balance is simpler to value. An invested balance moves with the market, so a lender may view it like a securities account. Treatment is lender-specific, so ask which version they would consider.
Which asset path fits a rental property?
The asset depletion path is the only asset-based path that allows an investment property, with tighter leverage and large minimum balances. Many investors find DSCR financing a cleaner fit, since it looks at the property’s rent against its payment.
Next Step
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. Lendmire is a mortgage broker placing files through select lenders in its wholesale network, and its consumer mortgage lending is licensed in 16 states: Alabama, California, Colorado, Florida, Georgia, Indiana, Michigan, Montana, New Mexico, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia and Washington. You can reach the team at 828-256-2183, or request a quote. Programs change, every file is underwritten individually, and nothing here is a commitment to lend.
For current guidelines and terms, see Lendmire’s asset-based mortgage programs page.
About Lendmire
Lendmire is a mortgage brokerage (NMLS# 2371349) licensed for consumer mortgage lending in 16 states, arranging bank statement and other alternative-documentation mortgages — P&L-only, 1099-only and asset-based paths — through a wholesale lending network. Eligibility is determined by the lender on each file. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
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 an Asset Qualifier Jumbo Mortgage Works · How an Asset Depletion Mortgage Works · How Big Can an Asset Qualifier Mortgage Be?
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.