The Quick Read: Fannie Mae’s version counts only retirement-type, employment-related assets and applies to a primary home or second home. A non-QM asset depletion loan counts a wider set of assets and can reach an investment property. For a Florida rental, the non-QM route is usually the only one of the two in play.
- Fannie Mae’s published rule covers a principal residence or second home only, not a pure rental.
- Non-QM asset programs are lender-defined, so the divisor, eligible assets and leverage differ from program to program.
- Across Lendmire’s wholesale network, the depletion path divides usable assets by 60 months to create qualifying income.
- Florida does not change the program figures. It changes property-level questions such as condo review and how title is held.
Who Each Option Is Really For
Fannie Mae’s method is for a borrower buying a home to live in, or a second home. That borrower holds a large 401(k), IRA or severance payout and little paycheck income. A non-QM asset depletion loan is for a wider group: retirees, business sellers and portfolio households whose balances are large and whose documented income is small. It is also the only one of the two that can finance a home you plan to rent out.
Neither route requires you to sell your portfolio. Both shrink what the lender counts, though. The real question is which options your assets, your age and your property leave open.
Side-by-Side
The Fannie Mae column shows published industry norms. The non-QM column shows parameters from Lendmire’s wholesale network, which places both kinds of loans. All figures are typical ceilings and floors, subject to underwriting and lender guidelines, not offers.
| Factor | Fannie Mae (published norms) | Non-QM depletion path (network) |
|---|---|---|
| Review basis | Asset-derived income in the DTI test | Asset-derived income in the DTI test |
| Assets counted | Employment-related only | Cash, CDs, securities, retirement, equity |
| Property use | Primary home, second home | Primary, second home, investment |
| Transaction types | Purchase, limited cash-out | Purchase, rate-and-term, cash-out |
| Max leverage | 70%, or 80% if owner is 62+ | 65% on investment purchase |
| Divisor | Generally the loan term in months | 60 months |
| Documentation | Agency documentation set | Asset statements, credit, property file |
| Entity vesting | Individual or co-borrower ownership | Reviewed program by program |
| Reserves | Standard agency reserve rules | No published reserve months |
Leverage on the network side depends on occupancy. The non-QM depletion path allows up to 80% on a purchase or rate-and-term refinance of a primary home or second home. It allows 60% on a cash-out refinance of those homes. On an investment property it allows up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out.
Key Terms Defined
Asset depletion is a method that turns a pile of assets into monthly qualifying income by spreading it over a set number of months.
Divisor is that set number of months. A longer divisor produces less monthly income from the same assets.
Non-QM means a mortgage that does not fit the standard agency-style box. Each lender or investor writes its own guidelines.
Asset qualifier is a second non-QM method. Eligible assets must cover the entire loan, and no employment or income is documented.
Haircut is the share of an asset’s balance a lender discounts. A 70% credit on a retirement account means 30% is haircut.
DTI is the debt-to-income ratio, which compares monthly debts, including the new housing payment, to qualifying income.
How Each Method Turns Assets Into Qualifying Power
Fannie Mae’s method
Fannie Mae’s Selling Guide topic on employment-related assets is the governing rule. It has a narrow lane. Eligible assets are 401(k), IRA, SEP and Keogh accounts, plus severance or lump-sum retirement distributions for borrowers who are not self-employed. Ordinary checking and savings are generally not eligible unless the balance came from one of those employment-related sources.
The guide sets the maximum LTV at 70%, rising to 80% when the asset owner is at least 62 at closing. It limits the loan to a purchase or limited cash-out refinance on a principal residence or second home. Assets must be owned by the borrower alone, or any co-owner must be a co-borrower. If a penalty would apply to a full distribution, that penalty is subtracted before the income is calculated. Each figure is subject to lender guidelines and a complete review of property type, leverage, and credit.
Lenders commonly describe the income stream as spread over the loan term in months, so a 30-year loan means 360. That divisor is the largest structural gap between the approaches. The guide also says a loan outside these parameters may still be considered under other income rules, such as interest and dividend income or retirement income.
The non-QM method, which is really two paths
A borrower is qualified on one path at a time. Never blend the two sets of figures.
The asset depletion path converts usable assets into monthly income. Usable assets are divided by 60 months, and the result must carry the full housing payment and other debts through the DTI test. Across the network, the credit given to each asset is:
- Cash accounts and certificates of deposit: 100%.
- Securities: 80%.
- Private stock: 75%.
- Retirement accounts: 70% at any age.
- Real-estate equity: 60%.
Custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options and non-vested restricted stock units are not eligible. Cash-out proceeds never count as qualifying assets. Loans run from $125,000 to $3,500,000, subject to underwriting.
The depletion path also sets asset minimums. You need qualified assets of at least the lesser of $1,000,000 or 1.25 times the loan balance. When depletion is your only income source, you need at least $250,000 liquid. Asset-derived income can also supplement documented income up to a 45% DTI, and the minimum-assets rule is waived in that case. The credit-score requirement follows the lender’s matrix. A first-time investor on this path needs a 700 score.
Here is an illustrative run. Say you hold $1,500,000 in securities, which count at 80% for $1,200,000. You also hold $300,000 in cash at 100%. That is $1,500,000 usable, and divided by 60 months it is $25,000 of monthly qualifying income. That income must then carry the housing payment and other debts through the DTI test. The lender’s own calculation governs.
The asset qualifier path needs no income math. Eligible assets, after credit percentages, must equal or exceed the entire loan amount. Here brokerage accounts, CDs, money market and savings all count at 100%. A 401(k) or IRA counts at 90% under age 59½ and 100% at 59½ or older. Say you want an $800,000 loan and hold $330,000 in brokerage accounts, $300,000 in a 401(k) while under 59½ (90%, so $270,000), and $200,000 in savings. That counts $800,000 and can qualify on assets alone, subject to underwriting.
This path reaches loans up to $4,000,000. Its leverage is up to 80% on a purchase and 75% on a refinance, but only on a principal residence or second home. Reserves are not required at or below 75% LTV. The minimum credit score is 600. Leverage, reserves, and pricing vary by lender and program; the final terms follow the full file review.
Both paths still document the assets. Qualifier-path statements need 60 days of seasoning and two months of statements for each qualifying account. Depletion-path statements must be at least 120 days old at application, plus the most recent statement within 45 days. Sale-of-business, inheritance and legal-settlement funds are excused from that seasoning. “No income documented” never means no documentation.
The federal ability-to-repay framework explains why assets still get checked. The CFPB’s implementation guide lists eight factors, including verification of the income or assets a lender relies on. It does not dictate one underwriting model. That flexibility is the room non-QM asset programs operate in.
When Fannie Mae’s Asset Depletion Is the Better Fit
Choose it if three things line up. The home is your primary residence or a second home. Your wealth sits mostly in 401(k), IRA or similar employment-related accounts. And you want the agency framework with its documentation set.
It also fits a borrower who is 62 or older and holds those retirement assets. The cap rises from 70% to 80% LTV at that age, which can matter on a purchase. If your taxable brokerage balance is large, agency eligibility gets harder. Those accounts generally do not count as depletion income, though they can still support a down payment and reserves.
Say you are 64, recently retired, and own a large IRA. You are buying a Florida second home you will not rent. Fannie Mae’s method may fit you well. Check the loan-term divisor, because a long divisor makes the income smaller than many borrowers expect. The penalty haircut matters too if any account is under 59½.
When a Non-QM Asset Depletion Loan Is the Better Fit
It is the better fit in four situations.
The property is a rental. Fannie Mae’s rule does not cover a pure investment property. A non-QM asset program can, on the depletion path at up to 65% LTV on a purchase. Terms vary by lender guidelines, property type, leverage, credit profile, and full file review.
Your money is not in retirement accounts. Cash, CDs, securities and private stock all count on the depletion path. Brokerage balances count at 100% on the qualifier path.
Your assets cover the whole loan. If eligible assets equal or exceed the loan, the qualifier path skips the DTI test. Retirement balances count at 90% or 100% there, depending on age.
You want a shorter divisor. Dividing by 60 months produces far more monthly income from the same pool than a 360-month spread. Run the same $1,500,000 over 360 months and the income is a fraction of the 60-month result. Non-QM programs vary, though. Benzinga’s reporting notes that some asset depletion programs follow agency guidelines closely while others calculate assets and income more flexibly.
The trade-off is that your assets get discounted differently and the program’s own minimums apply. The depletion path wants at least the lesser of $1,000,000 or 1.25 times the loan in qualified assets. Housing history matters too. The network standard is 0x30x12, and one 30-day late in the last twelve months is considered case by case. Multiple bankruptcies are not eligible. A housing event needs four years of seasoning on the depletion path.
Where a DSCR loan fits instead
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. A DSCR loan is reviewed primarily on property-level rental income covering the payment, subject to lender guidelines. Asset depletion is reviewed on your balance sheet. If the rent is strong and you would rather keep your assets out of the calculation, DSCR may serve a rental purchase better. The complete DSCR loans guide covers the investor side in full.
What Florida Changes (and What It Doesn’t)
Florida changes nothing about the program figures. The LTV caps, haircuts, divisor and seasoning are identical in every state. No Florida-specific rule on asset depletion shows up in either the agency guide or the network’s guidelines. Florida is one of the 16 states where Lendmire’s consumer mortgage lending is licensed, and Lendmire acts as the broker, placing files with select lenders.
Three property-level questions deserve attention instead:
- Condos. Many Florida purchases are condos, and condo eligibility is reviewed at the project level under both options. Ask early.
- How you hold title. Fannie Mae wants the asset owner on the loan. Non-QM treatment of trust or entity vesting varies by program, so each file is reviewed individually.
- Who owns the assets. If a spouse or partner owns part of the pool, the agency rule requires that person to be a co-borrower. Non-QM programs set their own ownership rules.
Mistakes That Cost Borrowers Time
Counting the same dollars twice. Assets used for qualifying income also have to cover your down payment and any reserves. Net them out before you run the math.
Treating crypto or collectibles as eligible. Cryptocurrency, precious metals, collectibles and pledged or borrowed funds are not published as eligible on either path. The documented route is converting them into a seasoned cash balance in a regulated account, with the source reviewed by the lender.
Ignoring statement age. The depletion path wants statements at least 120 days old, plus a recent one. A freshly moved balance can stall a file.
Assuming Fannie Mae covers a rental. It does not, and a plan built on that assumption has to be rebuilt.
Comparing paths by the headline balance. A $1,000,000 retirement account counts as $700,000 on the depletion path. The same balance is also reduced by any penalty under Fannie Mae. Compare usable assets, not statement totals.
For borrowers who live on interest and statements rather than deposits, bank statement vs 1099-Only vs asset depletion for liquid-asset borrowers shows where each documentation style fits.
The Verdict
Use Fannie Mae’s asset depletion if the home is yours or a second home, your wealth is in employment-related retirement accounts, and you value the agency framework. Age 62 or older helps. Use a non-QM asset depletion loan if the property is a rental, your assets are cash and securities, or you want a shorter divisor. If your eligible assets cover the whole loan on a primary or second home, look at the asset qualifier path as well.
Programs change, and every file is underwritten individually. Tax treatment varies; consult a qualified professional. 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
Can Fannie Mae asset depletion be used to buy an investment property?
No. The Selling Guide limits it to a principal residence or second home. A rental purchase needs a different route, such as a non-QM depletion program or a DSCR loan.
Does a non-QM asset depletion loan mean no documentation?
No. Assets are documented on both paths. The qualifier path needs 60 days of seasoning and two months of statements per account. The depletion path wants statements at least 120 days old plus one within 45 days. What you skip is the employment and income paperwork on the qualifier path. Qualification is always subject to underwriting.
Do I have to sell my investments to use either option?
No. Neither route requires liquidation. Your assets are counted, discounted and documented, but they stay invested. Down payment and reserves come out of the same pool, so plan for them.
Which assets count under each option?
Fannie Mae counts employment-related assets such as 401(k), IRA, SEP, Keogh and severance. On the network’s depletion path, cash and CDs count at 100%, securities at 80%, private stock at 75%, retirement accounts at 70% and real-estate equity at 60%. On the qualifier path, brokerage, CDs, money market and savings count at 100%.
Is there a Florida-specific rule for asset depletion?
No Florida-specific rule applies to either option, and the program figures do not change by state. What differs is property-level review, such as condo eligibility and how title is held.
Lendmire’s asset-based mortgage in Florida page presents the program for Florida 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
1. Fannie Mae Selling Guide: Employment Related Assets as Qualifying Income
2. CFPB Ability-to-Repay and Qualified Mortgage Implementation Guide
3. Benzinga: Asset Depletion Mortgage
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 Big Can an Asset Depletion Jumbo Loan Be? · How to Document a Bank Statement, 1099 or Asset Depletion Loan · Bank Statement Loan vs Asset Depletion Loan for Content Creators
Guides: Asset-Based Mortgage in Florida
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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- Lendmire LLC · Firm NMLS# 2371349 · Verify firm licensure
Required disclosures. Lendmire (NMLS# 2371349) operates as a licensed mortgage broker, not a direct lender or depository. The discussion in this article is general in nature and should not be relied upon as financial, legal, or tax advice — every investment scenario is unique and should be reviewed by a qualified professional. Any loan inquiry is subject to lender underwriting, and this article is not a commitment to lend or a guarantee of approval. Mortgage rates, loan terms, and program guidelines vary by borrower, property, and state, and may change without notice. Equal Housing Opportunity. Verify licensure at NMLS Consumer Access.