The Quick Read: Choose the asset qualifier path when your eligible balances cover the entire loan amount and you want no income or debt-to-income test in the file. Choose asset depletion when your assets are better used as imputed monthly income, or when you are buying an investment property, which only the depletion path covers. Both are subject to underwriting through select programs in Lendmire’s network.
- Qualifier path: eligible assets must equal or exceed the whole loan, and no employment or income is documented.
- Depletion path: usable assets are divided by 60 months to create qualifying income, which then runs through the debt-to-income test.
- Leverage differs: the qualifier path allows up to 80% on a purchase and 75% on a refinance, on a principal residence or second home.
- Credit differs: the qualifier path publishes a 600 floor; the depletion path follows the lender’s matrix.
- One path per file: a borrower is qualified on one path at a time, never a blend.
What Are the Two Paths, Exactly?
The asset qualifier path tests your balances directly against the loan. The asset depletion path turns your balances into monthly income. Different tests, different failure points.
Across the wholesale network, the names get used loosely. Some lenders treat “asset depletion,” “asset utilization,” and “asset qualifier” as one product with three labels. Lendmire’s network keeps them apart, and this article does too. When a lender quotes you a figure, ask which test it describes: assets against the loan, or assets converted to income.
Here is the plain version of each.
Asset qualifier path. Eligible assets, after the credit percentages below, must equal or exceed the entire loan amount. No employment or income is documented. The assets are documented, though. “No income documentation” never means “no documentation.”
Asset depletion path. Eligible assets, after haircuts, are added up and divided by 60 months. The result is a monthly qualifying income. That income must carry the full housing payment and other debts through the debt-to-income test.
The federal ability-to-repay rule allows either approach for consumer-purpose loans. CFPB Regulation Z §1026.43 says a creditor may base its repayment determination on income, on assets other than the dwelling securing the loan, or on both. That is why both paths exist.
How Do the Two Paths Compare Side by Side?
The qualifier path is stricter on the asset-to-loan test but skips the income test. The depletion path is more flexible on asset types and loan size, but it adds a debt-to-income test. All figures are ceilings and floors, subject to underwriting, never offers.
| Factor | Asset qualifier | Asset depletion |
|---|---|---|
| Core test | Assets ≥ entire loan | Assets ÷ 60 = income, then DTI |
| Income documented | None | Derived from assets |
| Purchase leverage | Up to 80% | Up to 80% (primary/second); 65% (investment) |
| Refinance leverage | Up to 75% | 80% rate-and-term; 60% cash-out (primary/second) |
| Loan amounts | Up to $4,000,000 | $125,000 to $3,500,000 |
| Credit | 600 floor | Lender’s matrix |
| Investment property | Not covered | Covered |
| Seasoning | 60 days; two months of statements per account | Statements 120+ days old plus one within 45 days |
Leverage on the qualifier path applies to a principal residence or second home. Whether cash-out is allowed on that path is set by the lender and is not published, so no figure is stated here. On the depletion path, cash-out proceeds never count as qualifying assets.
How Does Each Path Count Your Accounts?
The qualifier path credits more of most balances. Brokerage, certificates of deposit, money market and savings count at 100%. Retirement balances count at 90% under age 59½ and 100% at 59½ or older. Accounts combine.
The depletion path discounts more. Cash and certificates of deposit count at 100%. Securities count at 80%, private stock at 75%, retirement accounts at 70% at any age, and real-estate equity at 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. Federal guidance on consumer-purpose lending lists ordinary examples of countable assets such as savings, vested retirement amounts, stocks, bonds and CDs, per the CFPB small-entity compliance guide. Lender treatment is narrower than that list.
What Does the Same Georgia Borrower Look Like on Both Paths?
Consider a sample borrower. A Georgia buyer wants an $800,000 loan on a primary residence. Holdings: $330,000 in brokerage accounts, $300,000 in a 401(k) at age 55, and $200,000 in savings.
Qualifier path. Brokerage counts at 100%, or $330,000. The 401(k), under 59½, counts at 90%, or $270,000. Savings counts at 100%, or $200,000. Total: $800,000 of usable assets. That equals the loan, so the file is reviewed on assets alone, subject to underwriting.
Depletion path, same buyer. The 401(k) now counts at 70% and the brokerage account at 80% as securities. Savings still counts at 100%. The usable total falls well short of the qualifier tally, and the depletion minimum-assets rule also applies. This borrower fits the qualifier path.
Now flip the borrower. Someone holds $1,500,000 in securities and $300,000 in cash. Securities count at 80%, or $1,200,000. Cash counts at 100%, or $300,000. Usable assets: $1,500,000. Divide by 60 months: $25,000 of monthly qualifying income. That income then carries the housing payment and other debts through the debt-to-income test. A buyer with modest debts and a loan well below the asset pool fits the depletion path, and keeps more liquidity afterward.
All arithmetic here is illustrative. The lender’s own calculation governs.
What Is the Five-Question Decision Test?
Run these in order. The first “no” often settles it.
1. Is the property an investment 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. If yes, you are on the depletion path, or on a different product such as DSCR.
2. Do your eligible balances, after the qualifier percentages, equal or exceed the whole loan? If not, the qualifier path is out. This is a hard line, not a ratio.
3. Would spending that many assets leave you thin? The qualifier path counts the full loan amount against your assets. If that leaves little cushion, depletion may serve you better because it needs a usable pool, not one that matches the loan.
4. Do you carry heavy existing debts? Depletion runs a debt-to-income test, so large obligations can cap the loan even with big assets. The qualifier path documents no income and runs no such test, though the lender’s ability-to-repay review still rests on the assets.
5. Do you want to supplement documented income? On the depletion path, asset income can supplement documented income up to a 45% debt-to-income ratio, and the minimum-assets rule is waived then. The qualifier path has no blending.
Outcome: yes on questions 2 and 4 points to the qualifier path. Yes on question 1 or 5 points to depletion. A no on both 2 and the depletion minimums means neither path fits today.
Which Georgia Buyer Profiles Lean Which Way?
The program figures do not change by state. Georgia affects context, not parameters. Consumer lending is licensed in Georgia through the 16-state footprint, and the profiles below are the ones that come up on files.
The relocating retiree. A retiree selling a home elsewhere and buying in the Atlanta suburbs or on the coast, with large savings and brokerage balances, no paycheck and little debt. Lean qualifier, if balances cover the full loan.
The business seller. Sale proceeds sit in cash and brokerage. Sale-of-business funds are excused from the depletion seasoning rule, which helps that path. The qualifier path wants 60 days of seasoning and two months of statements per account. Lean depletion if the proceeds are still new and the loan is small against them. Lean qualifier if they are seasoned and sized to the loan.
The inheritance buyer. Similar logic. Inheritance funds are excused from the depletion seasoning rule. A buyer with a large inheritance and an existing mortgage and car debt may lean qualifier to avoid the debt-to-income test.
The portfolio household. Mostly securities, little cash, and an Atlanta-area purchase. Securities count at 100% only if they are brokerage balances on the qualifier path, and at 80% on depletion. Check the loan against the full pool first. If it clears, qualifier. If not, depletion’s income conversion may help.
The 401(k)-heavy early retiree. Under 59½ the qualifier path counts retirement at 90%. Depletion counts it at 70% at any age. That gap favors the qualifier path, provided total balances still reach the loan amount.
When Is the Qualifier Path the Wrong Choice?
The qualifier path is the wrong choice when it drains too much cushion, when the property is an investment, or when your assets fall short of the whole loan.
If you must pledge nearly everything to meet the test, you may close with little left. Depletion counts a pool that supports income rather than matching the loan, and it may leave more liquid. Depletion also has its own minimum: qualified assets of at least the lesser of $1,000,000 or 1.25 times the loan balance, and never below $250,000 liquid when asset depletion is the only income source.
Strong, well-documented income is another sign. Borrowers who can qualify on income through other programs may do so without drawing on assets at all.
What Mistakes Break Either File?
Most failures come from the asset pool, not the borrower.
- Counting ineligible assets. Stock options, unvested RSUs, foreign funds and cash on hand are out on the depletion path.
- Skipping seasoning. The qualifier path wants 60 days and two statements per account. Depletion wants statements at least 120 days old plus one within 45 days.
- Double-counting. Down payment, closing costs and cash for the purchase cannot also count as qualifying assets. Cash-out proceeds never count on the depletion path.
- Assuming “no documentation.” Assets are fully documented on both paths.
- Mixing the tables. Quoting the depletion haircuts against a qualifier file, or the reverse, produces wrong numbers.
In practice, the cleanest files consolidate holdings into a few well-seasoned accounts before the application, and keep large transfers explained in writing. Underwriters review the source of any large movement.
What If Neither Path Fits?
Three fallbacks exist, each for a different borrower.
| Situation | Direction |
|---|---|
| Income shows in deposits, not traditional personal-income documentation | Bank statement program |
| Buying a rental that covers its own payment | DSCR loan, business-purpose |
| Assets just under the line | Smaller loan or larger down payment |
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. Rental purchases generally belong there, per 12 CFR 1026.3, which exempts business-purpose credit from the consumer rule. The exemption turns on the loan’s purpose and occupancy facts, not on the word “investment.” Lendmire’s complete DSCR loans guide covers that route.
For loans above the conforming limit, the choice between high-balance and jumbo financing changes the leverage picture.
Key Terms Defined
Asset qualifier path: a way to qualify where eligible assets must cover the entire loan, with no income documented.
Asset depletion path: a way to qualify where eligible assets, divided by 60 months, become monthly qualifying income.
Haircut: the share of a balance that is discounted, so only the remaining percentage counts.
Seasoning: how long funds have sat in your account before they count.
Debt-to-income ratio: monthly debts, including the new housing payment, compared with monthly income.
Usable assets: balances after the credit percentages or haircuts for the path in use.
Frequently Asked Questions
Do I have to sell my investments to use either path?
No. The assets are not liquidated. They are counted and documented, and on the depletion path converted by arithmetic into qualifying income. You keep the holdings, though you should plan for the cushion they provide after closing.
Can I use both paths at once?
No. A borrower is qualified on one path at a time. The depletion path can supplement documented income up to a 45% debt-to-income ratio, but that is still the depletion path, not a blend with the qualifier.
Do retirement accounts count?
Yes on both, differently. On the qualifier path, 401(k) and IRA balances count at 90% under 59½ and 100% at 59½ or older. On the depletion path, retirement accounts count at 70% at any age.
Can I buy a rental with the asset qualifier path?
No. The qualifier path covers principal residences and second homes. Investment property is covered only on the depletion path, at lower leverage, or through a DSCR loan that qualifies primarily on property-level rental income covering the payment, subject to lender guidelines.
Does a Georgia address change the figures?
No. Leverage, credit percentages and seasoning are the same everywhere the program is placed. Georgia is one of the 16 states where consumer mortgage lending is licensed. Local prices and taxes affect the loan size, not the rules.
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 broker, and all programs are placed through select lenders, subject to underwriting.
A Georgia buyer with seasoned balances and few debts should price the qualifier path first, then run depletion as the comparison.
Lendmire’s asset-based mortgage in Georgia page presents the program for Georgia borrowers.
About Lendmire
Lendmire (NMLS# 2371349) is a mortgage brokerage serving self-employed and high-net-worth borrowers in 16 states. Bank statement, P&L-only, 1099-only and asset-based mortgages are arranged through wholesale lending channels; Lendmire brokers the financing and the lender underwrites each application. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
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: Asset Depletion vs Bank Statement Loan for a High-Net-Worth Buyer · How Asset Depletion Income Is Calculated From Your Portfolio · How Asset Depletion Counts Income for a Rental Portfolio Buyer
Guides: Asset-Based Mortgage in Georgia
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.