The Quick Read: Fannie Mae’s asset route is narrow: it is built around employment-related assets, such as retirement accounts or a lump-sum payout, for a borrower buying to live in the property. A non-QM asset depletion loan counts a wider set of assets and can reach investment property, through select programs and subject to underwriting.
- Fannie Mae’s published policy is titled around employment-related assets, not “any liquid asset.”
- The agency route is generally limited to a primary residence or second home. Confirm that against the current guide.
- A non-QM program, meaning a loan outside agency rules, sets its own asset credit percentages and divisor.
- Non-QM has two paths: assets cover the whole loan, or assets are converted into monthly income.
- Colorado changes none of the program figures. Both products work the same way here as anywhere else.
The Honest Answer First
Fannie Mae’s version suits a borrower who has retired or left a job, holds eligible employment-related assets, and is buying a home to live in. It is a good tool for that person. It is a poor tool for almost everyone else.
A non-QM asset depletion loan suits the asset-rich, income-light borrower whose money sits in brokerage accounts, cash, or a business sale. That includes borrowers who want a rental or who are above the agency’s narrow asset definitions. You pay for that flexibility with a more hands-on review, lower leverage on some property types, and a lender-by-lender spread of guidelines.
Two products share one name. They share the idea of turning a balance sheet into qualifying income, and very little else.
Side-by-Side
The Fannie Mae column reflects the agency’s own published Selling Guide, with secondary commentary where noted in the text below. The non-QM column shows what select lenders in Lendmire’s wholesale network typically offer, subject to underwriting. Figures are ceilings and floors, not offers.
| Factor | Fannie Mae (published guide) | Non-QM depletion path |
|---|---|---|
| Review basis | Assets divided over loan term, then DTI | Usable assets ÷ 60 months, then DTI |
| Assets counted | Employment-related assets | Cash, securities, retirement, equity |
| Occupancy | Generally primary or second home | Primary, second home, investment |
| Max leverage | 70%, or 80% if asset owner is 62+ | 80% on a primary or second-home purchase |
| Borrower type | Natural person, individual title | Individual (consumer mortgage) |
| Underwriting | Automated engine | Manual review of full file |
| Minimum assets | Not a fixed floor in the policy | Lesser of $1M or 1.25x loan |
DTI is debt-to-income, the share of monthly income that goes to debt payments. The non-QM column also has a second path, covered below, where assets cover the whole loan and no income is documented.
How Fannie Mae’s Version Actually Works
Fannie Mae’s Selling Guide section B3-3.4-06 is titled “Employment Related Assets as Qualifying Income.” There is no agency policy simply called asset depletion. The same page caps loan-to-value at 70%, or 80% when the owner of the assets is at least 62 years old at closing. To use the 80% ceiling on jointly owned assets, every owner must be a borrower, and the borrower using the income must be 62 or older.
Commentary from mortgage-industry practitioners describes the eligible assets as accessible retirement accounts and documented lump sums from work, such as severance. An ordinary taxable brokerage balance generally does not count unless it came from such a source. Treat that as secondary reading and check the guide itself.
The same practitioners describe the math as net eligible assets divided by the loan’s amortization term in months. On a 30-year loan that is 360 months. Compare that with the 60-month divisor on the non-QM depletion path, and you see why qualifying income differs so sharply.
Two more limits matter. Agency loans go to individuals, not LLCs. And the route is generally limited to owner-occupied or second-home use, so a pure rental purchase usually does not fit.
How a Non-QM Asset Depletion Loan Works
Across Lendmire’s wholesale network, a borrower is qualified on one path at a time. Name the path before you quote a number.
Asset qualifier path. Eligible assets, after the credit percentages below, must equal or exceed the entire loan amount. No employment or income is documented. Leverage runs up to 80% on a primary-residence or second-home purchase and up to 75% on a refinance, with loans up to $4,000,000. Credit minimum is 600. Brokerage, CD, money market, and savings balances count at 100%. 401(k) and IRA balances count at 90% under age 59½ and 100% at 59½ or older.
Picture an $800,000 loan backed by $330,000 in brokerage accounts, $300,000 in a 401(k) held under 59½, and $200,000 in savings. Usable assets are $330,000 plus $270,000 (90%) plus $200,000, which is $800,000. That is reviewed on assets alone, subject to underwriting. Reserves are generally not required at or below 75% loan-to-value.
Asset depletion path. Usable assets are divided by 60 months to create monthly qualifying income. That income must carry the housing payment and other debts through the DTI test. Loans run $125,000 to $3,500,000. Assets must total at least the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 liquid if assets are the only income.
Haircuts here: cash and CDs count at 100%, securities at 80%, retirement accounts at 70% at any age, and real-estate equity at 60%. Privately held stock is not eligible on either path. Take $1,500,000 in securities (80%, or $1,200,000) plus $300,000 in cash (100%). That is $1,500,000 usable, divided by 60, or $25,000 of monthly qualifying income. The lender’s own calculation governs.
Leverage on this path depends on the property. A primary residence or second home goes up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out. Cash-out proceeds never count as qualifying assets.
When Fannie Mae’s Version Is the Better Fit
Choose the agency route when your profile matches what it was built for. Think of a 62-plus retiree buying a Colorado home to live in, holding a rollover IRA and a documented lump-sum retirement distribution, and wanting the agency’s structure.
Three situations favor it:
- Your assets are exactly the type it recognizes. Retirement accounts you can access, and employment-related lump sums, fit cleanly.
- You want the agency framework. Some borrowers value a standardized rulebook and an automated underwriting run over a manual one.
- You are 62 or older and want more leverage. The agency’s 80% ceiling for older asset owners is real. The 70% cap otherwise is not unusual.
If your assets fall outside the agency definition, the page itself notes they may still count under other income sections, such as interest and dividend income or retirement income. Those are different calculations, and they depend on documented income.
The agency route does not help with a Colorado rental in a personal name, and it does not allow LLC vesting. Agency loans go to natural persons.
When a Non-QM Asset Depletion Loan Is the Better Fit
Choose non-QM when your balance sheet is strong and your documented income is not. That covers retirees under 62, sellers of a business, inheritance or settlement recipients, early-retired professionals, and households living on a portfolio.
Here is where it wins:
- Wider asset menu. Securities and real-estate equity count at their stated percentages. The agency approach centers on employment-related assets.
- Investment property is on the table. The depletion path reaches investment property at 65% on a purchase, and 60% on a cash-out.
- No selling required. Assets are evidence of repayment ability, not money you withdraw. You keep the portfolio invested. Tax treatment can depend on how the funds are used and how the property is held; borrowers should keep clear records and speak with a qualified tax professional before relying on any deduction.
- Assets can cover the entire loan. On the qualifier path, no income is documented, though the assets are fully documented.
- Larger loans. Up to $4,000,000 on the qualifier path.
Seasoning is the waiting period an asset must sit in your account. The qualifier path wants 60 days and two months of statements per qualifying account. The depletion path wants statements at least 120 days old plus one within 45 days. Sale-of-business, inheritance, and legal-settlement funds are excused from that seasoning on the depletion path.
Now the costs. Leverage on an investment property is lower than on a primary residence. The minimum-assets floor on the depletion path is high. The review is manual, so statements, credit, and the property are weighed together. A first-time investor on the depletion path needs a 700 score. Housing history is 0x30x12, and one 30-day late in the last twelve months is considered case by case. Multiple bankruptcies are not eligible.
What Counts, and What Does Not
Cash in a regulated account is the cleanest asset on either path. Some assets are not published as eligible on either path: cryptocurrency, precious metals, collectibles, pledged or borrowed funds, and business accounts beyond your ownership share. The documented route is converting them to a seasoned cash balance in a regulated account, with the source reviewed by the lender.
Privately held company stock is not eligible on either path. If you own a closely held business, the route is a sale or buyout converted into a seasoned cash balance.
The depletion path also excludes 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.
Asset-derived income can also supplement documented income, up to a 45% DTI. When it does, the minimum-assets rule is waived.
The Entity and Rental Question
If you own rentals through an LLC, this decision may not be an asset depletion decision at all. Lending to an entity rather than a natural person falls outside consumer-credit rules under the federal business-purpose provisions, and business-purpose rental financing is DSCR territory. A DSCR loan is reviewed primarily on property-level rental income covering the payment, subject to lender guidelines.
The choice comes down to which is stronger in your file: the property’s rent or your balance sheet. Strong rent and an LLC point to DSCR. A big portfolio, low income, and a personal-name purchase point to asset depletion. Some borrowers sit in both camps, so it is worth comparing.
Borrowers in other states weighing the same two options can read Lendmire’s Fannie Mae asset depletion vs. a non-QM asset depletion loan in Georgia. The program figures are the same.
Where Colorado Fits
Not much changes. Lendmire’s consumer mortgage lending is licensed in 16 states, and Colorado is one of them. State facts, such as local prices, are context rather than program parameters. A Colorado borrower in a high-cost county will mostly feel the difference in loan size, where the qualifier path’s $4,000,000 ceiling and the depletion path’s $3,500,000 ceiling matter.
Key Terms Defined
- Non-QM: a mortgage that falls outside the agency standard, with guidelines set by the lender or investor.
- Haircut: the percentage of an asset’s balance a lender discounts when counting it.
- Divisor: the number of months a lender divides usable assets by to create monthly income.
- Seasoning: how long funds must have been in your account before they count.
The Verdict
Use Fannie Mae’s version if you are buying a home to live in, your assets are the employment-related kind, and the agency framework suits you. Use a non-QM asset depletion loan if your wealth sits in broader asset classes, you want a second home or investment property, or you need larger loan amounts. Use DSCR if the property’s rent is the strongest part of the file.
Neither is easy. Both document your assets in full, and “no income documentation” never means no documentation. Every file is underwritten individually, and programs change.
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 I use any brokerage account for Fannie Mae asset depletion?
Generally no. Fannie Mae’s policy centers on employment-related assets, such as accessible retirement accounts and documented work-related lump sums. An ordinary taxable balance may not count unless it came from such a source. Confirm against the current guide, or look at a non-QM program that counts securities at 80%.
Do I have to sell my investments to qualify?
No. On both non-QM paths, assets serve as evidence of repayment ability and stay where they are. You do need to document them, with statements that meet the seasoning rules.
Can I buy a rental with a non-QM asset depletion loan?
Through select programs, yes, on the depletion path. Leverage is lower: up to 65% on a purchase or rate-and-term refinance, and up to 60% on a cash-out. Qualification is subject to underwriting and credit review.
Can I use my 401(k) or IRA?
Both non-QM paths allow it, but they count it differently. The qualifier path counts it at 90% under age 59½ and 100% at 59½ or older. The depletion path counts retirement accounts at 70% at any age.
Does Colorado change any of this?
No. Program figures are the same in every state where the lender is licensed. Colorado is one of Lendmire’s 16 consumer-lending states.
Lendmire’s asset-based mortgage in Colorado page presents the program for Colorado borrowers.
About Lendmire
Lendmire — NMLS# 2371349 — is a mortgage broker that arranges bank statement, P&L-only, 1099-only and asset-based home financing in 16 states through wholesale lenders, on primary residences, second homes and investment properties. Every option is subject to the lender’s guidelines and full underwriting. 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. eCFR 12 CFR 1026.3: Exempt Transactions
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 Much Money Do You Need in Assets for an Asset Depletion Mortgage? · Can You Take Cash Out of a Texas Homestead on an Asset Depletion Loan? · How to Buy Before You Sell in Colorado Using an Asset Qualifier Mortgage
Guides: Asset-Based Mortgage in Colorado
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.