The Quick Read: The asset qualifier path fits a retiree whose eligible balances cover the entire loan, because it documents no income at all. The asset depletion path fits a retiree who needs the balances to act as income, because it divides usable assets by 60 months and runs the result through a debt-to-income test. A borrower is qualified on one path at a time, subject to underwriting.
- Qualifier path: eligible assets, after credit percentages, must equal or exceed the whole loan.
- Depletion path: usable assets divided by 60 months become qualifying monthly income.
- Both paths document the assets with statements. Neither is a no-documentation loan.
- Leverage, seasoning and asset credit differ by path, so never blend the two tables.
A North Carolina retiree often has a large portfolio and a small documented income. Social Security, a modest pension and required distributions can look thin on paper next to a seven-figure balance. Income-based underwriting misreads that profile. Asset-based mortgages fix the mismatch, and the two paths fix it in different ways.
The figures below are ceilings and floors from select programs in Lendmire’s wholesale network, subject to underwriting. They are not offers. North Carolina is one of the 16 states where Lendmire’s consumer mortgage lending is licensed, and the program figures do not change by state. Lendmire is a broker. Select lenders review and decide each file.
The Honest Answer: Who Each Path Is Really For
Choose the qualifier path if your eligible assets add up to the full loan amount or more. Choose the depletion path if they do not, or if you want to buy an investment property, which the qualifier path does not cover. Many retirees fit both on paper, and then leverage and asset type decide it.
The labels are not standardized across the industry. Some lenders use “asset qualifier” and “asset depletion” as the same thing. Others use them for two different tests. Here, the terms mean the two paths defined in the network’s guidelines. When you talk to any lender, skip the label and ask two questions: what divisor is used, and is debt-to-income tested?
Side-by-Side
The columns below reflect the network’s program figures. Outside lenders publish their own versions, so treat any outside quote as a different program until you read its guidelines.
| Factor | Asset Qualifier | Asset Depletion |
|---|---|---|
| Review basis | Assets cover the whole loan | Assets become monthly income |
| Divisor | None | 60 months |
| Income documented | None | Derived income, plus any real income |
| Debt-to-income test | Not applied | Applied to derived income |
| Property types | Principal residence, second home | Residence, second home, investment property |
| Purchase leverage | Up to 80% | Up to 80% residence or second home; 65% investment |
| Refinance leverage | Up to 75% | 80% rate-and-term, 60% cash-out on a residence or second home; 65% rate-and-term, 60% cash-out on investment property |
| Loan amounts | Up to $4,000,000 | $125,000 to $3,500,000 |
| Credit | 600 minimum score | The lender’s matrix |
| Seasoning | 60 days, two months of statements | Statements 120 days old, plus one within 45 days |
| Reserves | None at or below 75% LTV | No published reserve months |
| Minimum assets | Assets must cover the loan | Lesser of $1,000,000 or 1.25x the loan; $250,000 liquid floor |
Every figure is subject to underwriting. Each file is reviewed individually.
How Each Path Counts Your Accounts
Account type drives the usable total more than the headline balance does. This is where retirees get surprised.
On the qualifier path, brokerage accounts, certificates of deposit, money market and savings count at 100%. A 401(k) or IRA counts at 90% if you are under 59½ and 100% at 59½ or older. Accounts combine.
On the depletion path, the haircuts are steeper:
| Asset type | Counted on depletion path |
|---|---|
| Cash accounts, CDs | 100% |
| Securities | 80% |
| Private stock | 75% |
| Retirement accounts | 70% at any age |
| Real-estate equity | 60% |
Not eligible on the depletion path: custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options, non-vested restricted stock units, and funds from non-regulated financial companies. Cryptocurrency, precious metals, collectibles, pledged or borrowed funds, and business accounts beyond your ownership share are not published as eligible 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.
Retirement accounts deserve one more note. The age cutoff in the qualifier table mirrors a federal tax line. IRS Topic 557 explains that IRA distributions before 59½ generally carry a 10% additional tax unless an exception applies. Tax treatment varies; consult a qualified professional before drawing on retirement funds.
A Retiree Run Through Both Paths
These examples are illustrative, and the lender’s own calculation governs.
Qualifier path. A retiree seeks an $800,000 loan. Brokerage accounts hold $330,000, counted at 100% for $330,000. A 401(k) under 59½ holds $300,000, counted at 90% for $270,000. Savings hold $200,000, counted at 100% for $200,000. Usable assets total $800,000, which equals the loan. The file is reviewed on assets alone, subject to underwriting.
Depletion path. Another retiree holds $1,500,000 in securities, counted at 80% for $1,200,000, plus $300,000 in cash, counted at 100%. Usable assets are $1,500,000. Divided by 60 months, that is $25,000 of monthly qualifying income. That income must then carry the housing payment and other debts through the debt-to-income test.
The same portfolio can land differently on each path. A retiree whose counted assets fall short of the loan cannot use the qualifier path. The depletion path may still work, because income is tested against payments instead of assets matching the full balance. The reverse also happens: a retiree with modest debts and a loan smaller than usable assets finds the qualifier path simpler, with no debt-to-income test at all.
When the Asset Qualifier Is the Better Fit
The qualifier path wins when your balances are large relative to the loan. It suits a retiree who sold a house or a business and is buying a principal residence or second home in a place like the North Carolina mountains or coast.
- No debt-to-income test. No income is documented, so a small Social Security check does not count against you. The lender’s ability-to-repay review rests on the assets.
- Larger loans. Loans run up to $4,000,000, against $3,500,000 on the depletion path. Purchase leverage tops out at 80% on both paths for a residence or second home, but the refinance ceiling is 75% on the qualifier path.
- Retirement money counts more. A 401(k) or IRA counts at 90% under 59½ and 100% after, against a flat 70% on the other path.
- Reserves. None required at or below 75% loan-to-value. Above that, the lender sets them.
- Credit floor. A 600 minimum score, subject to the lender’s review.
The trade-off is real. Your counted assets must equal the whole loan, so a large share of your portfolio is effectively spoken for. Some retirees prefer to keep that money invested and flexible. Seasoning also applies: 60 days, with two months of statements for each qualifying account. Cash-out on this path is set by the lender and is not published, so do not plan around it.
When Asset Depletion Is the Better Fit
Depletion wins when your portfolio is large but the loan is bigger than your counted assets, or when you want an investment property. It treats the portfolio as an income stream.
- Investment property is allowed. Up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out.
- Cash-out is published. Up to 60% on a residence, second home or investment property. Cash-out proceeds never count as qualifying assets.
- It can supplement real income. Asset-derived income may add to documented income, such as Social Security, a pension or required distributions, up to a 45% debt-to-income ratio. When it supplements, the minimum-assets rule is waived.
- The assets stay put. You are not selling holdings to qualify.
The costs: the haircuts are steeper, retirement accounts count at only 70%, and minimum assets are the lesser of $1,000,000 or 1.25 times the loan, never below $250,000 liquid when depletion is your only income source. Statements must be at least 120 days old at application, with the most recent within 45 days. Sale-of-business, inheritance and legal-settlement funds are excused from that seasoning. Credit follows the lender’s matrix, and a first-time investor needs a 700 score. A housing event needs 4 years of seasoning on this path.
What Is Documented on Both Paths
“No income documentation” never means no documentation. Federal ability-to-repay rules let a creditor rely on income or assets, and the CFPB compliance guide says the creditor must consider and verify what it relies on. Expect statements, not self-declaration. Credit and housing history are reviewed too: 0x30x12 is the standard, with one 30-day late in twelve months considered case by case, and multiple bankruptcies are not eligible.
Both paths are consumer mortgages, so consumer disclosure rules apply. That is different from DSCR investor loans, which are business-purpose.
Where Mistakes Happen
Most problems on retiree files are preventable.
- Assuming real-estate equity counts fully. It counts at 60% on the depletion path and is not part of the qualifier credit table.
- Pledging an IRA directly. Assets qualify by being counted, not by being pledged as security.
- Leaving out recent money moves. A large deposit without a paper trail can break seasoning. Keep source documents.
- Mixing the tables. Quoting depletion haircuts on a qualifier file, or the reverse, can produce numbers that lenders may not recognize.
- Skipping the question of what you want to keep invested. The loan can qualify while still leaving you with less liquidity than you want. Run that before you choose a path.
If rental income is part of the plan, note the difference: asset programs qualify the borrower, while DSCR loans qualify primarily on property-level rental income covering the payment, subject to lender guidelines.
The Verdict
Neither path is better in general. The qualifier path is simpler and more generous with retirement balances, but it ties up assets equal to the whole loan. The depletion path stretches a portfolio further and reaches investment property and published cash-out, at the cost of steeper haircuts and a debt-to-income test. Count your usable assets under each table, then compare to the loan you want. The path that fits is usually obvious once the math is on paper.
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 programs based on your statements, the property, credit profile, leverage, and your goals. Reach the team at 828-256-2183.
Frequently Asked Questions
Are asset qualifier and asset depletion the same loan?
Not in the network’s guidelines. The qualifier path counts assets against the whole loan and documents no income. The depletion path divides usable assets by 60 months and tests the result against debt-to-income. Lenders use the labels differently, so ask which math a program uses.
Do I have to sell investments to qualify?
No. The assets stay in your accounts on both paths. They are documented through statements, and the lender counts them at the percentages above.
Can Social Security and pension income be combined with asset income?
On the depletion path, asset-derived income may supplement documented income up to a 45% debt-to-income ratio. The qualifier path documents no income.
Does a retirement account count the same on each path?
No. On the qualifier path a 401(k) or IRA counts at 90% under 59½ and 100% at 59½ or older. On the depletion path, retirement accounts count at 70% at any age.
Can I use either path for a rental property?
Only the depletion path covers investment property, at up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out. Business-purpose rental financing that is reviewed on rent is a DSCR loan, subject to lender guidelines.
Lendmire’s asset-based mortgage in North Carolina page presents the program for North Carolina borrowers.
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
2. CFPB ATR/QM 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: Can You Get an Asset Depletion Loan While Paying Alimony? · How to Buy Before You Sell in Indiana Using an Asset Qualifier Mortgage · Asset Depletion vs DSCR for a North Carolina Rental Purchase
Guides: Asset-Based Mortgage in North Carolina
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Compliance and disclosures. Lendmire (NMLS# 2371349) is a licensed mortgage broker and is not a direct lender, depository institution, financial advisor, or tax professional. Content in this article is general market analysis and educational information — not financial, legal, or tax advice for any specific situation. Lendmire does not guarantee loan approval; every transaction is subject to underwriting by the funding lender. Mortgage pricing and loan program guidelines are subject to change at any time without notice and vary by borrower characteristics, property type, and state regulations. Lendmire complies with Equal Housing Opportunity. Licensure verification: NMLS Consumer Access.