The Quick Read: Fannie Mae’s version is narrow: it counts employment-related assets such as retirement accounts or a lump-sum distribution, and it applies only to a principal residence or second home, while a non-QM asset depletion loan accepts broader asset types and, through select programs, can reach investment property. Neither path is better in general. The right one depends on what you own, what you are buying, and how you hold title.
- Fannie Mae’s route is for owner-occupied or second-home purchases and limited cash-out refinances, not pure rentals.
- A non-QM asset depletion loan converts a wider mix of assets into qualifying income.
- A separate non-QM asset qualifier path skips income entirely when assets cover the whole loan.
- Both paths document your assets in full. Neither one skips underwriting.
The Honest Answer First
Start with the agency route if your assets fit its definition. Those are retirement accounts or a lump-sum distribution tied to employment, and the home is where you will live or a second home. If your wealth sits in brokerage accounts, cash, or the proceeds of a sale, or if the property is a rental, expect to end up in non-QM.
“Asset depletion” is industry shorthand. The Fannie Mae Selling Guide files this under employment-related assets as qualifying income. It is a narrow rule inside a conventional loan. The non-QM version is a lender-defined product with its own asset list, haircuts, and divisor. They share an idea but not much else, so comparing them is really comparing two different tools.
A Washington borrower faces the same rules as anyone else. The program figures below do not change by state. What changes is your own mix of assets, your age, and the property.
Side-by-Side
The Fannie Mae column reflects published agency guidelines. The non-QM column reflects Lendmire’s network figures for its asset depletion path, which a borrower can compare with the separate qualifier path described later. Every figure is subject to underwriting and lender guidelines.
| Factor | Fannie Mae route | Non-QM asset depletion |
|---|---|---|
| Review basis | Eligible employment-related assets become income | Usable assets divided by 60 months |
| Eligible assets | Retirement accounts, severance, lump-sum distributions | Cash, CDs, securities, retirement, equity, more |
| Occupancy | Principal residence, second home | Primary, second home, investment (select programs) |
| Transactions | Purchase, limited cash-out | Purchase, rate-and-term, cash-out |
| Leverage ceiling | 70%, or 80% if the owner is 62+ | 80% primary or second home; 65% investment (purchase) |
| Joint ownership | All asset owners must be borrowers | Set by the program and the lender |
| Documentation | Tied to Fannie Mae’s document-age rules | Statements 120 days old plus one within 45 days |
| Reserve expectations | Per agency guidelines | No published reserve months |
How Each Calculation Works
Fannie Mae starts with assets in a few categories. According to a mortgage insurer’s training deck, these are a severance package or lump-sum retirement distribution, plus 401(k), IRA, SEP, and Keogh accounts. The guide subtracts any penalty that a full distribution would trigger today. It then turns the balance into monthly income that feeds the debt-to-income test. If you do not fit the rule, the guide points to other income sections, such as interest and dividend income or retirement income.
The non-QM depletion path works from a broader list, and it applies a haircut to each asset type. Across Lendmire’s wholesale network, the figures on this path look like this:
- Cash and certificates of deposit count at 100%.
- Securities count at 80%.
- Private stock counts at 75%.
- Retirement accounts count at 70% at any age.
- Real-estate equity counts at 60%.
The program divides usable assets by 60 months. Take $1,500,000 in securities and $300,000 in cash. Securities at 80% give $1,200,000, and cash at 100% gives $300,000. That is $1,500,000 usable, or $25,000 of monthly qualifying income. That income then has to carry the housing payment and other debts through the debt-to-income test. The lender’s own calculation governs, and this is illustration only.
A second non-QM path exists, and it works differently. The asset qualifier path ignores income. Eligible assets, after credit percentages, must equal or exceed the entire loan. Brokerage, CDs, money market, and savings count at 100%. Retirement balances count at 90% under age 59½ and 100% after that. An $800,000 loan with $330,000 in brokerage, $300,000 in a 401(k) under 59½ (counted at $270,000), and $200,000 in savings counts $800,000 of usable assets. That file is reviewed on assets alone, subject to underwriting. A borrower uses one path at a time, never a blend.
When Fannie Mae Asset Depletion Is the Better Fit
The agency route is the stronger choice when your situation lines up with its narrow definition. It tends to suit these borrowers:
- A retiree buying a primary residence with most wealth in an IRA or 401(k), no rental plans, and who wants conventional-loan structure.
- An owner who is 62 or older. The leverage ceiling rises from 70% to 80% at that age, per the Selling Guide. That is a real advantage over a borrower of 55 using the same account.
- A borrower who has just received a documented severance or retirement lump sum, deposited to a verified account.
- A borrower who wants to stay inside conventional underwriting, with standard agency documentation rules and no non-QM structure.
Be honest about the edges. Fannie Mae restated this policy during a restructuring of its guide, and its own page says the move was made for clarity without altering its original intent. So the rule is not loosening. Jointly owned assets require every owner to be a borrower. Any early-distribution penalty comes off the top. An ordinary taxable brokerage balance is not among the listed categories, so expect it not to count. Tax treatment varies, so consult a qualified professional before relying on any retirement-distribution assumption.
If any of those conditions trips, do not force the fit. A file that almost qualifies under the agency rule costs time and then moves anyway.
When a Non-QM Asset Depletion Loan Is the Better Fit
Non-QM is the stronger choice when your assets are varied, your documented income is thin, or the property is not your home. It usually pencils for these borrowers:
- A business seller or inheritance recipient holding cash and securities. On the depletion path, sale-of-business, inheritance, and legal-settlement funds are excused from the statement-age requirement.
- An early-retired professional living off a portfolio of brokerage holdings, not retirement accounts.
- A borrower buying an investment property. The depletion path reaches investment property through select programs, at lower leverage than a primary residence. The agency route is closed here.
- A borrower under 62 who wants the higher leverage that the agency path reserves for older owners.
- A household with big balances and little income, where assets cover the loan outright. The qualifier path then skips income documentation, though the assets are still fully documented.
Non-QM costs something. Expect stricter asset documentation. The depletion path wants statements at least 120 days old at application, plus the most recent one within 45 days. It requires qualified assets of at least the lesser of $1,000,000 or 1.25 times the loan balance, and never less than $250,000 liquid when depletion is the only income source. Loan amounts run from $125,000 to $3,500,000 on the depletion path, and up to $4,000,000 on the qualifier path. A first-time investor on the depletion path needs a 700 score, and the lender’s matrix sets the score tiers for everyone else. The qualifier path has a 600 floor. Approval is never assured on either path.
Some asset classes do not count at a percentage on either path. These include cryptocurrency, precious metals, collectibles, and pledged or borrowed funds. The documented route is converting them to a seasoned cash balance in a regulated account, with the lender reviewing the source. Stock options and non-vested restricted stock units are not eligible on the depletion path.
Asset income can also supplement documented income, up to a 45% debt-to-income ratio. In that case the minimum-assets rule is waived. This helps a borrower with some pay or pension who just needs a boost.
Is the Property a Rental?
For a pure rental purchase, the agency route is out. A rental investor generally looks at two paths. One is the non-QM depletion path above, which qualifies the borrower’s balance sheet. The other is a DSCR loan, which is reviewed on the property’s rent against its debt. Lendmire’s complete DSCR loans guide covers how rental coverage works. A borrower with strong assets but modest rent coverage sometimes weighs both. Asset depletion suits someone who does not want rent to be the deciding test, while DSCR suits someone whose property carries itself.
Documentation differs too. Asset-based mortgages for homes are consumer loans, so full consumer disclosures apply. DSCR loans are business-purpose and exempt from those consumer disclosure rules. That is a structural difference worth knowing when you pick a path.
If your money came from a business sale or large liquidity event, Lendmire’s piece on super jumbo requirements after a sale covers the larger-loan side. For borrowers comparing document styles, Lendmire also compares bank statement vs 1099-Only vs asset depletion for liquid-asset borrowers.
Key Terms Defined
Asset depletion: Industry shorthand for turning a pool of assets into imputed monthly income, without selling the assets.
Asset qualifier: A non-QM structure where eligible assets must cover the whole loan and no income is documented.
Haircut: The percentage of an asset’s balance a lender counts, such as 80% of securities.
Seasoning: How long funds have sat in your accounts before they can be used.
Non-QM: A loan outside agency guidelines, set by the lender or investor rather than a published agency rulebook.
A Balanced Verdict
Choose the agency route if you are buying a home to live in, your wealth is in retirement accounts or an eligible lump sum, and you fit its age and ownership conditions. It keeps you in conventional underwriting and is the cleaner path when the fit is real.
Choose non-QM if your assets are broader than retirement accounts, the property is a rental, your wealth arrived from a sale or inheritance, or you want the option of skipping income entirely. You accept stricter statements, lower leverage on investment property, and a lender-by-lender process.
Both paths document your assets and review your credit. A mismatch between the product and your asset mix is a common reason a file stalls. 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. Programs are placed through select lenders in its wholesale network, and nothing here is a commitment to lend.
Frequently Asked Questions
Does Fannie Mae offer an asset depletion program for rentals?
No. Its asset-income rule covers a principal residence or second home, and investment property is not eligible for this income type. A rental buyer generally looks at non-QM asset depletion or a DSCR loan instead.
Can I use a regular brokerage account with the agency route?
Usually not. The listed categories center on employment-related assets, such as retirement accounts and lump-sum distributions. On Lendmire’s non-QM depletion path, securities count at 80% and brokerage balances count at 100% on the qualifier path, subject to underwriting.
Do I have to sell my investments?
No. In both structures the assets are documented and seasoned, not liquidated. They need to stay in place through underwriting.
How does age affect each option?
On the agency route, the leverage ceiling rises from 70% to 80% when the asset owner is at least 62. On the non-QM qualifier path, age matters for retirement balances, which count at 90% under 59½ and 100% after.
What if my assets do not meet the minimums?
On the depletion path, qualified assets must be at least the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 liquid when it is your only income. If you fall short, adding documented income may waive the minimum-assets rule, up to a 45% debt-to-income ratio.
Lendmire’s asset-based mortgage in Washington page presents the program for Washington 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. Enact, Assets and Repayment Obligations training presentation
3. Fannie Mae, Income Assessment Simplified
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 Add a Co-Borrower to an Asset Depletion Loan Later? · How to Document a Bank Statement, 1099 or Asset Depletion Loan · Bank Statement Loan vs Asset Depletion Loan for Professional Athletes
Guides: Asset-Based Mortgage in Washington
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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- Lendmire LLC · Firm NMLS# 2371349 · Verify firm licensure
Disclosure information. Lendmire is a state-licensed mortgage brokerage under NMLS# 2371349. Lendmire is not a depository institution, direct lender, or financial advisor — all loans referenced are placed through wholesale lender partners and are subject to each lender's underwriting standards. This article is provided for general informational purposes and is not a commitment to lend, nor does it constitute financial, legal, or tax advice. Loan programs, terms, rates, and qualification standards change without notice and depend on borrower profile, property type, and the state in which the subject property is located. Equal Housing Opportunity provider. NMLS Consumer Access: nmlsconsumeraccess.org.