The Quick Read: Fannie Mae’s version is a narrow agency policy for owner-occupied homes and second homes that counts mainly employment-related assets, while a non-QM asset depletion loan (a mortgage outside agency guidelines) is a lender-defined program that accepts a wider range of assets, reaches investment property, and sets its own haircuts and divisor. Pick by property use, asset type, and loan size, not by which name sounds safer. The program figures below are the same for a Texas borrower as anywhere else. Only local costs and title questions change.
- Fannie Mae’s policy does not cover investment property. A rental purchase on assets alone has to go non-QM.
- Fannie’s method tops out at 70% loan-to-value, or 80% if the asset owner is at least 62 at closing.
- Through select programs in Lendmire’s network, assets either cover the whole loan (the qualifier path) or divide by 60 months into income (the depletion path). You qualify on one path at a time.
- Both routes document your assets. Neither skips documentation, and every file is underwritten individually.
Side-by-Side
The first column shows published agency rules. The other two columns show the parameters the brokerage sees across select programs in its wholesale network, subject to underwriting. Pricing is deliberately absent. Rates, points, and payments belong in a personalized quote, not a comparison table.
| Factor | Fannie Mae policy | Non-QM, qualifier path | Non-QM, depletion path |
|---|---|---|---|
| Reviewed on | Assets turned into income, then DTI | Assets alone cover the entire loan | Assets ÷ 60 months, then DTI |
| Assets counted | Employment-related, such as retirement accounts | Brokerage, CDs, savings 100%; 401(k) 90% or 100% | Cash, CDs 100%; securities 80%; retirement 70% |
| Property use | Principal home, second home | Principal home, second home | Also investment property |
| Leverage | 70%; 80% if owner is 62+ | 80% purchase, 75% refinance | Home 80%, rental 65% on a purchase |
| Loan purpose | Purchase or limited cash-out | Purchase or refinance | Purchase, rate-and-term, cash-out |
| Loan amount | Agency loan limits apply | Up to $4,000,000 | $125,000 to $3,500,000 |
| Statements | Document-age rules apply | 60 days seasoning, 2 months | 120 days old plus one within 45 days |
| Credit | Standard agency credit rules | 600 minimum | Lender’s matrix; 700 for first-time investors |
| Reserves | Confirm in the guide | None at or below 75% LTV | No published reserve months |
| Vesting | Individual; co-owners must co-borrow | Individual borrower | Individual borrower |
DTI means debt-to-income, the share of monthly income that goes to debt payments. LTV means loan-to-value. Fannie’s leverage figures come straight from Fannie Mae Selling Guide topic B3-3.4-06. The network figures are ceilings and floors, never offers.
Same Name, Two Different Loans
Fannie Mae has no free-standing asset depletion product. Asset depletion is a market label. The agency policy is titled “Employment-Related Assets as Qualifying Income,” and the title tells you most of the story.
The policy has a short checklist. The loan must be a purchase or limited cash-out refinance. The property must be a principal residence or second home. The assets must belong to the borrower, or any co-owner must be a co-borrower. If an early-withdrawal penalty would apply to a full distribution today, Fannie subtracts it before computing income. Document-age rules apply as well. The guide governs the divisor and the order of subtraction, so confirm both there.
Non-QM asset depletion works differently. Each program writes its own rules, so the divisor, the haircuts, and the eligible-asset list vary from lender to lender. Across Lendmire’s wholesale network, the pattern is consistent enough to describe in two paths:
- Qualifier path. Eligible assets, after the credit percentages in the table, must equal or exceed the entire loan amount. No employment or income is documented.
- Depletion path. Eligible assets, after haircuts, are divided by 60 months. The result is a monthly qualifying income that must carry the housing payment and other debts through the DTI test.
The word “documented” matters here. Income is not documented on the qualifier path. Assets are documented on both.
When Fannie Mae’s Method Is the Better Fit
Fannie’s method fits a borrower buying a home to live in, or a second home, whose wealth sits in retirement accounts or a lump-sum distribution. It is built for that person, and only that person.
Consider a retiree buying a principal residence on a purchase. Most of the money sits in a 401(k) and IRA. The borrower is at least 62 and wants the 80% tier. The agency route has a practical advantage here: the rules are published, and lenders working in the agency channel generally follow the same guide. You can read B3-3.4-06 yourself and get a clear picture of what the underwriter is likely to check.
The agency route also suits a borrower who can lean on other income topics. If the loan misses the asset policy’s parameters, Fannie’s guide points to other places where employment-related assets can count. Examples are the topics for interest and dividend income and for annuity, pension, or retirement income. A borrower with steady dividend income may qualify there without the divisor math at all.
The trade-offs are real:
- Leverage is capped at 70%, or 80% for an owner who is at least 62.
- Investment property is out. The policy does not reach rentals.
- The asset definition is narrow. A brokerage account built from a business sale, for example, does not fit the employment-related frame.
- Co-owned assets get strict. The co-owner must be a co-borrower, and the age tier depends on the borrower using the income.
If your profile fits those walls, the agency route is clean and predictable. Many borrowers do not fit.
When a Non-QM Asset Depletion Loan Is the Better Fit
Non-QM is the better fit when your assets are broad, your documented income is thin, or the property is a rental. Most borrowers who reach this route have balances that do not fit the agency definition, not bad credit.
The qualifier path suits the reader who could almost pay cash. Say your loan is $800,000. You hold $330,000 in brokerage accounts (counted at 100%), $300,000 in a 401(k) while under 59½ (counted at 90%, or $270,000), and $200,000 in savings (counted at 100%). That counts $800,000 of usable assets, so the file can qualify on assets alone, subject to underwriting. At 59½ or older, the 401(k) counts at 100%. Leverage runs up to 80% on a purchase and 75% on a refinance of a principal residence or second home. Reserves are not required at or below 75% loan-to-value. The credit floor is 600.
The depletion path suits the reader whose assets are large but who has no loan-sized pile in qualifying accounts. Picture $1,500,000 in securities, counted at 80% ($1,200,000), plus $300,000 in cash at 100%. Usable assets total $1,500,000. Divide by 60 months and you get $25,000 of monthly qualifying income. That income then carries the housing payment and other debts through the DTI test. The lender’s own calculation governs, and the example is illustrative.
Other haircuts on the depletion path:
- Private stock counts at 75%.
- Retirement accounts count at 70% at any age.
- Real-estate equity counts at 60%.
- Custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options, and non-vested restricted stock units are not eligible.
Leverage on the depletion path depends on use and transaction. On a principal residence or second home, it runs up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out refinance. Cash-out proceeds never count as qualifying assets. Minimum assets are the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 in liquid assets when asset depletion is the only income source. A first-time investor needs a 700 score.
Asset income can also supplement a paycheck. Documented income plus asset-derived income can run up to a 45% DTI. When it supplements, the minimum-assets rule is waived. That stacking option is one of the main reasons borrowers move off the agency route.
Here is the regulatory frame, briefly. Non-QM loans sit outside the Qualified Mortgage safe harbor but still require the lender to make a reasonable repayment-ability determination. The CFPB’s compliance guide lays out that structure. In practice it means “non-QM” does not mean easy. The lender reviews your statements, your credit, and your assets either way.
One more note on rentals. Asset depletion qualifies you, the person. A different product is reviewed around the property. 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. They qualify primarily on property-level rental income covering the payment, subject to lender guidelines. Lendmire’s complete DSCR loans guide covers that path. A strong balance sheet points toward asset depletion. A rental that cash flows points toward DSCR.
The Edge Cases That Decide It
The headline numbers rarely decide a file. The edge cases do.
Brokerage accounts. Fannie’s policy is framed around employment-related assets. Ordinary brokerage balances are not the target. Non-QM programs count them: 100% on the qualifier path, 80% for securities on the depletion path.
Crypto, metals, and collectibles. These are not published as eligible on either network path. The documented route is converting them to a seasoned cash balance in a regulated account. The lender then reviews the source of the funds. They never count at a percentage.
Sale of a business, inheritance, or settlement. A cash pile from a business sale does not fit Fannie’s employment-related definition. That borrower is a natural non-QM candidate. On the depletion path, those funds are excused from the 120-day statement-age rule. Lendmire’s piece on super jumbo requirements after a sale covers the larger-loan side of that situation.
Entity vesting. Agency asset rules are written around the individual borrower and the assets they own. The consumer-purpose asset programs in the network follow the same logic. Buying a rental inside an LLC generally points to business-purpose financing, subject to program terms.
Freddie Mac. Freddie’s version is a separate policy with its own divisors and reserve treatment. Never assume Fannie’s rules apply to a Freddie file. Check Freddie’s own guide.
Housing events and credit. The depletion path wants housing history of 0x30x12, though one 30-day late in twelve months is considered case by case. A housing event needs four years of seasoning on that path. Multiple bankruptcies are not eligible.
What Texas Changes (and What It Doesn’t)
Texas changes the surroundings, not the program figures. LTV caps, haircuts, and the 60-month divisor are the same for a Texas borrower as for anyone else.
Local costs still matter on the depletion path. Property taxes and insurance run through the DTI test, so higher carrying costs mean you need more qualifying income. That makes the qualifier path, which documents no income, look better for a high-balance Texas purchase.
Cash-out deserves a careful look. Texas has its own limits on borrowing against a homestead. Talk to your title company and lender before planning a cash-out. This article does not cover those rules.
Relocating buyers should check where their money sits. Foreign funds are not eligible on the depletion path. Assets held elsewhere in the U.S. in regulated accounts are fine, so long as the statements are seasoned.
Short on income documents? Lendmire’s piece Bank Statement vs 1099-Only vs Asset Depletion for Liquid-Asset Borrowers shows where each fits.
Key Terms Defined
Non-QM: a mortgage that falls outside agency guidelines, with the lender setting its own rules.
Haircut: the share of an asset’s balance a program refuses to count, such as counting securities at 80%.
Seasoning: how long funds must sit in an account before they count.
Divisor: the number of months you divide usable assets by to get monthly income. The network’s depletion path uses 60.
Qualifier path: the route where eligible assets cover the entire loan and no income is documented.
The Balanced Verdict
Choose the agency route when you are buying a home to live in, or a second home. It fits when your assets are mostly employment-related and your leverage needs sit at 70% or the age-62 tier of 80%. Published rules are its strength.
Choose non-QM when the property is a rental, the assets are broad, the loan is large, or leverage matters. It also fits when you want the choice between paying the loan off on paper with assets and converting assets to income. Flexibility is its strength, and each program’s own rules are its cost. Read them.
Some borrowers fit neither. If your balance sheet is thin and your rental cash flows well, DSCR may serve you better than either.
Whichever way you lean, compare the file, not the label. Your account types, your age, the property, and the loan size decide the answer.
Frequently Asked Questions
Can I buy a rental property using Fannie Mae’s asset depletion method?
No. The agency policy covers principal residences and second homes only. Investment properties are not eligible under it. A rental purchase on assets alone usually goes through a non-QM program, where the depletion path allows investment property at up to 65% on a purchase, subject to underwriting.
Do crypto and stock options count toward my qualifying assets?
Not directly on either network path. Cryptocurrency is not published as eligible, and stock options and non-vested restricted stock units are excluded on the depletion path. The documented route is converting crypto to a seasoned cash balance in a regulated account. The lender then reviews the source.
Can I combine asset income with a paycheck or pension?
On the depletion path, yes. Asset-derived income can supplement documented income up to a 45% DTI. Agency rules and other programs differ, so confirm your specific scenario.
Which path fits a Texas retiree buying a home?
It depends on the balance sheet. If eligible assets equal or exceed the whole loan, the qualifier path documents no income. If assets are large but short of the loan amount, the depletion path turns them into income. Age 59½ matters because a 401(k) counts at 90% before then and 100% after.
Does non-QM mean less review?
No. Assets are documented on both paths, statements are seasoned, and the lender reviews credit and repayment ability. Non-QM changes what gets documented, not whether anything does.
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 mortgage broker. It arranges these loans through select programs in its network. Programs change, and every file is underwritten individually. This is not a commitment to lend. Tax treatment varies; consult a qualified professional.
Lendmire’s asset-based mortgage in Texas page presents the program for Texas 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
1. Fannie Mae Selling Guide, B3-3.4-06: Employment Related Assets as Qualifying Income
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: Is an Asset Qualifier Mortgage Harder to Get Than an Asset Depletion Loan? · Retirement Account Withdrawals vs Asset Depletion for a Jumbo Loan · Does an Asset Depletion Loan Require Any Income?
Guides: Asset-Based Mortgage in Texas
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.