The Quick Read: The asset qualifier path fits a buyer whose eligible assets cover the entire loan, because it documents no income at all. The asset depletion path fits a buyer who needs assets turned into monthly income to carry the payment through a debt-to-income test. A stock-heavy Bay Area buyer usually lands on one path based on loan size, how much of the portfolio is one stock, and whether the property is a home or a rental.
- Qualifier path: eligible assets after credit percentages must equal or exceed the whole loan, subject to underwriting.
- Depletion path: usable assets divided by 60 months become qualifying income, which must carry the housing payment and other debts.
- Brokerage accounts count at 100% on the qualifier path and securities at 80% on the depletion path, through select programs.
- Non-vested restricted stock units and stock options do not count on the depletion path.
- A borrower is qualified on one path at a time. The two tables are never blended.
Tech wealth in the Bay Area often sits in one employer’s shares. The borrower wants a mortgage without selling and triggering a tax bill. Both paths exist for that reason: they let the portfolio stay in place. They count it in very different ways, and the difference decides which file works.
This piece is for consumer purchases and refinances of a principal residence or second home. Across Lendmire’s wholesale network, the programs below are placed through select lenders, and every file is underwritten individually. Lendmire is a broker, not the lender. Lendmire’s consumer mortgage lending is licensed in 16 states, which include California.
Side-by-Side
The table shows Lendmire-network parameters for both paths. Figures are ceilings and floors, never offers, and all are subject to underwriting.
| Factor | Asset Qualifier | Asset Depletion |
|---|---|---|
| Review basis | Assets cover the entire loan | Assets become monthly income |
| Income documented | None | Derived from assets, plus any other income |
| Debt-to-income test | None run on income | Yes, on derived income |
| Purchase leverage | Up to 80% LTV | Up to 80% home, 65% investment |
| Refinance leverage | Up to 75% LTV | Up to 80% rate-and-term, 60% cash-out |
| Loan amounts | Up to $4,000,000 | $125,000 to $3,500,000 |
| Brokerage and securities | 100% counted | 80% counted |
| Retirement accounts | 90% under 59½, 100% after | 70% at any age |
| 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 |
| Entity vesting | Individual consumer borrower | Individual consumer borrower |
| Property types | Principal residence, second home | Also investment property |
Two notes on the table. Vesting is in the borrower’s own name on both paths, because these are consumer mortgages. Rental purchases held in an LLC belong in DSCR territory, where the property’s rent drives lender review.
Plain-English Definitions
Neither term is a federally defined product. The OCC’s bulletin on asset dissipation underwriting is the closest federal text. It describes using an applicant’s assets to calculate a hypothetical cash annuity stream that is added to other income, a method often used for high-net-worth applicants with significant liquid assets but thin cash flow. That description matches the depletion path.
Lenders use the two names loosely. Some treat them as synonyms. In Lendmire’s network the line is structural:
- Asset qualifier: the assets are tested against the loan itself. No income is documented.
- Asset depletion: the assets are converted into income and run through debt-to-income.
Ask any lender which meaning it uses before comparing offers. The same name can describe different math.
When the Asset Qualifier Is the Better Fit
The qualifier path wins when the portfolio is large relative to the loan and the buyer wants no income conversation. Eligible assets, after the credit percentages, must equal or exceed the entire loan amount. That is a high bar, but the credit percentages are generous.
Brokerage accounts, certificates of deposit, money market and savings all count at 100%. Retirement balances count at 90% under age 59½ and 100% at 59½ or older. Accounts combine.
Run an illustrative case. Say a buyer needs an $800,000 loan and holds $330,000 in brokerage accounts, $300,000 in a 401(k) under 59½ and $200,000 in savings. The brokerage counts at 100%, which is $330,000. The 401(k) counts at 90%, which is $270,000. The savings count at 100%, which is $200,000. Usable assets total $800,000, which matches the loan, so the file is reviewed on assets alone. The lender’s own calculation governs.
Other points where this path helps a concentrated-stock holder:
- Securities count in full. A brokerage account holding vested company shares counts at 100% on this path, subject to the lender’s review of the account.
- No spend-down math. The loan is tested against the balance, so a drop in the divisor-driven income figure is not a concern.
- Higher loan ceiling. Loans go up to $4,000,000, which matters in Bay Area price ranges.
- Reserves are light. None are required at or below 75% loan-to-value. Above that, the lender sets them.
- Credit floor of 600. That is the published minimum, and approval still depends on the full file.
The catch is the coverage test itself. The assets must match the whole loan, not just the down payment. A buyer with $1,000,000 in company stock and a $2,000,000 loan does not pass, no matter how rich the stock looks.
Assets are documented, always. No income documentation never means no documentation. Expect two months of statements per account and 60 days of seasoning.
Do not expect cash-out proceeds on this path to be spelled out. Whether cash-out is allowed, and at what leverage, is set by the lender and is not published.
When Asset Depletion Is the Better Fit
Depletion wins when the portfolio is large but not large enough to cover the loan, or when the buyer wants an investment property. It turns assets into income, so a smaller portfolio can support a loan through the debt-to-income test.
The formula is usable assets divided by 60 months. Run the sanctioned example: $1,500,000 in securities counts at 80%, which is $1,200,000. Add $300,000 in cash at 100%, which is $300,000. Usable assets are $1,500,000. Divided by 60 months, that is $25,000 of monthly qualifying income. That income then carries the housing payment and other debts through the debt-to-income test.
The haircuts matter for a stock-heavy buyer:
- Securities count at 80%. A brokerage account loses a fifth of its value in the formula.
- Private stock counts at 75%.
- Retirement counts at 70% at any age.
- Real-estate equity counts at 60%.
- Cash and CDs count at 100%.
Several asset types are not eligible on this path: stock options, non-vested restricted stock units, custodial accounts, deferred compensation, escrow accounts, foreign funds and cash on hand. That list matters for a tech employee. Unvested RSUs and options, often the largest piece of Bay Area paper wealth, do not count. Only shares that have vested and sit in an eligible account can be used.
This path also has more minimums. Qualified assets must be at least the lesser of $1,000,000 or 1.25 times the loan balance. When asset depletion is the only income source, liquid assets can never fall below $250,000. If the asset income only supplements a salary, it can supplement documented income up to a 45% debt-to-income ratio, and the minimum-assets rule is waived.
Leverage is tighter on investment property, which is the main reason to choose depletion for a rental. It allows up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out. Principal residences and second homes go up to 80% on a purchase or rate-and-term, and 60% on cash-out. Cash-out proceeds never count as qualifying assets.
Credit follows the lender’s matrix, and a first-time investor needs 700. Housing history runs 0x30x12, and a housing event needs four years of seasoning.
Where Concentrated Stock Changes the Answer
Concentration is a planning problem for the borrower first and an underwriting problem second. A single stock can swing sharply between application and funding, and the usable-asset number moves with it. Advisors describe a “double concentration” for employees whose paycheck and portfolio rely on one company, and they note that the full value of vested RSUs is taxable as wages (Lido Advisors). Advisors also point out that tax friction is what keeps many people holding (Raymond James).
Here is how that plays out on a file:
1. Vested and unvested shares are different assets. Vested shares in a brokerage account are eligible. Non-vested RSUs and options are not on the depletion path.
2. Statements show the value on the statement date. A stock that drops after the statement can change the file, so a thicker cushion is safer.
3. The qualifier path has no haircut on brokerage. That helps a concentrated holder who clears the full-loan test.
4. The depletion path takes 20% off securities. The haircut is on the account, regardless of how concentrated it is.
5. Pledged or borrowed funds are not published as eligible on either path. A margin balance or pledge can complicate which assets count. See Lendmire’s piece Pledged-Asset Mortgage vs PAL vs Margin Loan for a Concentrated-Stock Buyer for that route.
Whether a given lender applies extra scrutiny to single-stock accounts is lender-specific. Ask before relying on the number. Selling some shares can improve the file by raising cash, which counts at 100% on both paths, but the tax cost is a separate decision for a qualified tax professional.
Which Path for Which Buyer
Match the path to the loan size against the portfolio, then check the property type.
| Buyer situation | Likely path |
|---|---|
| Eligible assets cover the whole loan | Asset qualifier |
| Assets smaller than the loan, strong credit | Asset depletion |
| Buying an investment property on assets | Asset depletion (65% purchase) |
| Wants no income test at all | Asset qualifier |
| Has salary plus a large portfolio | Depletion as a supplement |
| Loan above $3,500,000 | Asset qualifier, up to $4,000,000 |
A few practical rules sit under that table. If the numbers pass the qualifier test, the buyer avoids the debt-to-income calculation. If they fall short, depletion often still works because the income test only needs the monthly figure to carry the payment.
Buyers who document income through deposits belong in a different program, covered in Lendmire’s piece Asset Depletion vs Bank Statement Loan for a High-Net-Worth Buyer.
Key Terms Defined
Usable assets: the share of each account that counts after the credit percentage or haircut.
Divisor: the 60 months used to turn usable assets into monthly qualifying income on the depletion path.
Seasoning: how long funds have sat in an account, shown through statements.
Haircut: the percentage cut from an account’s balance for volatility or access, such as 80% on securities on the depletion path.
Non-vested RSUs: company stock grants you do not yet own, which do not count on the depletion path.
What Goes Wrong on These Files
The failure points are mostly documentation.
- Stale statements. The depletion path needs statements at least 120 days old plus one within 45 days. A missing recent statement stalls the file.
- Unseasoned deposits. On the qualifier path, funds need 60 days of seasoning. A fresh transfer needs a paper trail.
- Wrong asset bucket. Unvested RSUs, options and cash on hand get listed as assets and then removed.
- Mixing paths. A borrower is qualified on one path at a time. Counting qualifier percentages inside a depletion file is the most common sizing error.
- Alternative assets. Crypto, precious metals and collectibles are not published as eligible. The documented route is converting them to a seasoned cash balance in a regulated account, with the source reviewed by the lender.
- Assuming no ratios. The qualifier path runs no income test, but the lender still reviews the file. The CFPB’s compliance guide says a creditor must consider and verify income or assets, so the assets are documented either way.
Is This the Right Tool for a Rental?
Often it is not. Asset-based consumer loans are built for a home you will live in or a second home. Business-purpose credit is treated differently under federal rules, and the creditor decides the primary purpose case by case (CFPB Regulation Z commentary).
A pure rental usually moves to a DSCR loan, which qualifies primarily on property-level rental income covering the payment, subject to lender guidelines. That structure keeps the borrower’s balance sheet out of the debt-to-income math. Lendmire’s complete DSCR loans guide covers it.
Tax treatment varies; consult a qualified professional before making decisions.
The Balanced Verdict
Pick the asset qualifier path when the portfolio covers the whole loan. It skips the income test, counts brokerage at 100%, and reaches $4,000,000. Pick asset depletion when the portfolio falls short of the loan or the property is an investment. It converts assets to income at 60 months, takes 20% off securities and excludes unvested equity.
For a Bay Area buyer holding one stock, the deciding number is the share of the portfolio that is vested and sitting in an eligible account. Count that first. Everything else follows from it.
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.
Frequently Asked Questions
Do unvested RSUs count toward qualifying?
No, not on the depletion path. Non-vested restricted stock units and stock options are on the ineligible list. Only vested shares held in an eligible account count, and they are subject to the credit percentage or haircut for that path.
Does the loan make me sell my stock?
No. Both paths measure the assets without requiring a sale. The depletion path divides usable assets by 60 months as a measuring convention, and the shares stay in your name. Selling is a separate planning decision with its own tax consequences.
Can I use either path to buy a rental?
Only the depletion path covers investment property, at up to 65% on a purchase and 60% on a cash-out. The qualifier path is for principal residences and second homes. Rentals held for business purposes generally fit DSCR financing better, which is reviewed on the property’s rent.
What documents do I need?
Account statements, not income records. The qualifier path wants 60 days of seasoning and two months of statements per account. The depletion path wants statements at least 120 days old plus the latest one within 45 days. Lenders may ask for more, subject to underwriting.
Which path allows a larger loan?
The asset qualifier path goes up to $4,000,000. The depletion path runs from $125,000 to $3,500,000. Leverage and asset minimums also apply, so the larger ceiling only helps if eligible assets cover the whole loan.
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. Lido Advisors, concentrated stock guide
3. Raymond James, diversifying concentrated equity
4. 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: How Asset Depletion Income Is Calculated From Your Portfolio · How Asset Depletion Counts Income for a Rental Portfolio Buyer · Asset Depletion vs Bank Statement Loan for a High-Net-Worth Buyer
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.