The Quick Read: Yes, through select asset-based programs, a lender can count your IRA balance toward qualifying without you withdrawing anything, either by treating it as proof you can cover the whole loan or by converting it into monthly qualifying income, subject to underwriting. Nothing gets pledged, frozen, or sold. The catch is that counting an IRA and spending IRA money are two different things.
- The asset qualifier path counts eligible assets against the entire loan amount and documents no employment or income.
- The asset depletion path divides usable assets by 60 months to create qualifying income, which then runs through the debt-to-income test.
- You are qualified on one path at a time, never a blend of both.
- IRA balances count at a discount on one path and at a bigger discount on the other.
- The IRA itself can never be put up as collateral.
The Two Paths, Side by Side
Both paths treat your IRA as evidence of financial capacity. Neither one asks you to take a distribution to qualify. They differ in what the lender does with the balance and in which properties they cover.
| Factor | Asset qualifier path | Asset depletion path |
|---|---|---|
| What it does | Assets must cover the whole loan | Assets become monthly income |
| IRA credit | 90% under 59½, 100% at 59½+ | 70% at any age |
| Income documented | None | Derived income only, or alongside real income |
| Max LTV, purchase | 80% (home) | 80% home, 65% investment |
| Loan size | Up to $4,000,000 | $125,000 to $3,500,000 |
| Property types | Principal residence, second home | Also investment property |
These are ceilings and floors through select programs in Lendmire’s wholesale network, not offers. Every file is underwritten individually.
Does Georgia Change Any of This?
No. The program figures do not change by state. Underwriting here is driven by the lender and the investor behind the loan, not by Georgia law. Lendmire’s consumer mortgage brokerage is licensed in 16 states, and Georgia is one of them.
One thing does differ. State housing agencies run their own down-payment-assistance programs, and those programs set their own asset tests. How they treat a retirement account has nothing to do with the paths described here. If you are stacking one of those programs on top, read its current published rules separately.
How the Asset Qualifier Path Counts an IRA
On this path, your usable assets must equal or exceed the entire loan amount. Your IRA counts at 100% if you are 59½ or older and at 90% if you are younger. Brokerage accounts, certificates of deposit, money market and savings all count at 100%, and accounts combine.
Here is an illustration, and the lender’s own calculation governs. Say you want an $800,000 loan. You hold $330,000 in brokerage accounts, which count at 100%. You hold $300,000 in a 401(k) and you are under 59½, so it counts at 90%, or $270,000. You also hold $200,000 in savings at 100%. That adds up to $800,000 of usable assets, so you qualify on assets alone, subject to underwriting.
The rules around that example:
- Leverage: up to 80% LTV on a purchase and 75% on a refinance, for a principal residence or second home.
- Seasoning: 60 days, with two months of statements for each qualifying account.
- Credit: a 600 minimum score, subject to underwriting.
- Reserves: none required at or below 75% LTV. Above that, the lender sets them. Final terms depend on lender guidelines, property type, leverage, and the borrower’s complete credit picture.
The assets are fully documented. “No income documentation” never means no documentation. (Statements are the whole file here, so expect to hand over every page.)
How the Asset Depletion Path Turns an IRA Into Income
On this path, the lender converts your usable assets into monthly income on paper. It applies a haircut by asset type, divides the result by 60 months, and runs that income through the debt-to-income test with your housing payment and other debts. Retirement accounts count at 70% at any age.
Run the numbers on a portfolio household. Say you hold $1,500,000 in securities and $300,000 in cash. Securities count at 80%, or $1,200,000, and cash at 100%, or $300,000. That is $1,500,000 usable. Divided by 60 months, it produces $25,000 of monthly qualifying income, which then has to carry the housing payment and other debts.
Now swap in an IRA. A $1,000,000 IRA counts $700,000 on this path, no matter your age. Same divisor, same test. Compare that with the qualifier path, where the same IRA could count at 90% or 100%. That gap is why the path you land on matters.
The conditions that come with it:
- Leverage: up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out for a principal residence or second home. On an investment property it is 65% on a purchase or rate-and-term and 60% on a cash-out.
- Cash-out proceeds: these never count as qualifying assets.
- Minimum assets: the lesser of $1,000,000 or 1.25 times the loan balance, and never below $250,000 liquid when depletion is your only income source.
- Supplementing income: derived income can add to documented income up to a 45% debt-to-income ratio, and the minimum-assets rule is waived when it does.
- Statements: at least 120 days old at application, plus the most recent one within 45 days.
- Credit: the lender’s matrix applies, and a first-time investor needs 700.
Some assets do not count here at all: custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options, and non-vested restricted stock units. Crypto, precious metals, and collectibles 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.
Counting the IRA Is Not the Same as Spending It
Qualifying and funding are separate steps. The paths above decide whether the IRA helps you qualify. They say nothing about where your cash to close comes from. If you pull money out of the IRA to fund the down payment, that is a real withdrawal.
This is where most buyers get tripped up. On the depletion path, the lender takes your down payment, closing costs, and any reserves out of the pot first. It will not count the same dollars twice. Money you plan to spend cannot also be money you plan to count.
Tax treatment varies by how the funds are used, so consult a qualified professional before moving retirement money.
A tempting workaround is taking a distribution and rolling it back later. Skip it. Asset-based qualifying exists so you do not have to improvise like that.
What an IRA Can Never Do
An IRA can be counted. It cannot be pledged. The IRS lists using an IRA as security for a loan and borrowing money from it as prohibited transactions. An IRA custodian explainer adds the consequence: pledging an IRA triggers a deemed distribution of the pledged portion.
So an asset-based mortgage is not a loan against your IRA. The lender looks at the balance, verifies it, and moves on. Federal ability-to-repay guidance backs the counting side. The CFPB’s compliance guide says a creditor may consider amounts vested in a retirement account, and it must verify what it relies on with reliable third-party records. That is why statements and vesting information are the heart of the file.
Buying a Rental? The Rules Change
For a rental, the asset depletion path is usually the only asset-based route, and it comes with the lower investment-property leverage listed above. The qualifier path is limited to principal residences and second homes. Many rental buyers skip both paths and go with a DSCR loan 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. Your IRA does not qualify you there. It matters as a source of cash to close and reserves, and lenders typically season those funds and ask about large deposits. Lendmire’s complete DSCR loans guide covers how that file is built.
Honestly, taxable brokerage money or cash is often the cleaner source for a rental down payment. It keeps the IRA intact and the file simple. Whether that wins for you is a toss-up that depends on your tax picture, which a professional should weigh.
What about buying inside a self-directed IRA, where the IRA is the borrower? That is a niche. The loan has to be non-recourse, and a personal guarantee from the owner is a problem. Most DSCR programs want a personal guarantee or an entity borrower, which collides with that rule. Treat it as a specialist path, not a default.
Which Path Fits You?
Use this to sort yourself before you talk to a lender.
| Your situation | Likely fit |
|---|---|
| Assets cover the whole loan, home purchase | Asset qualifier path |
| Assets are large, loan is bigger than assets | Asset depletion path |
| Buying a rental, assets are large, income is light | Depletion path, 65% LTV on a purchase |
| Buying a rental that rents well | DSCR loan, qualified on the property |
| Real income exists but falls short | Depletion income can supplement it |
Retirees, business sellers, inheritance and settlement recipients, and people living on a portfolio usually fit best. A reader whose balances are modest will probably find that the minimum-asset rules close the door.
What Goes Wrong After Closing
Qualifying on paper is not a plan for paying the mortgage. The depletion path counts your IRA as income you are not actually drawing. If you never touch it, fine. If markets fall after closing, the same balance supports less than it did on application day.
Across the wholesale network Lendmire works with, the files that age well keep a real cash cushion outside the retirement account. The ones that strain are built right at the minimum asset line, with the borrower assuming the portfolio will always grow. The name “asset depletion” invites a bad assumption: it describes a calculation, not an instruction to spend down your IRA.
One more risk. Programs change, and each lender sets its own overlays. A figure that works on one file may not hold on the next.
Myths vs. Facts
| Myth | Fact |
|---|---|
| I can pledge my IRA as collateral | The IRS treats that as prohibited |
| Asset depletion means I must withdraw | It is a paper calculation only |
| My IRA counts at full value | Credits are 70% on depletion, 90% or 100% on qualifier |
| Asset depletion only works for a principal residence or second home | Rentals are also allowed on the depletion path |
| No income documentation means no documents | Statements are required either way |
What to Bring to the Conversation
- Full statements for every account, every page, covering the seasoning period.
- Your date of birth and the vesting or access terms for each retirement account.
- Source records for any large deposit.
- Proof that none of the funds are borrowed.
- Your intended property type and occupancy, since that decides the path.
Then ask the lender which path they would place you on, how they treat your IRA, and whether the same dollars are being counted twice.
Key Terms Defined
Asset qualifier path: a method where eligible assets must equal or exceed the whole loan, with no income documented.
Asset depletion path: a method that divides usable assets by 60 months to create monthly qualifying income.
Haircut: the percentage of an account’s balance a lender refuses to count, usually because the money is harder to reach or can lose value.
Seasoning: the time funds must sit in an account before a lender trusts them.
Vesting: your legal right to the money in a retirement account.
Debt-to-income (DTI): your monthly debts divided by your monthly income.
Prohibited transaction: an act the IRS bars an IRA from doing, such as serving as loan collateral.
Frequently Asked Questions
Do I have to be retired to use my IRA this way?
No. Neither path requires retirement. Age matters only for the discount: on the qualifier path an IRA counts at 90% under 59½ and 100% after, while the depletion path counts it at 70% at any age. Programs are subject to underwriting.
Does a Roth IRA count the same as a traditional IRA?
The program figures above apply to retirement accounts as a category, and Lendmire’s published figures do not split Roth from traditional. Ask the lender how it treats each type on your file.
Is the IRA collateral for the mortgage?
No. The home is the collateral. The lender only reviews and verifies your IRA balance. Pledging an IRA is treated as a prohibited transaction.
Can I use my IRA for the down payment without hurting qualification?
Only dollars you actually keep count. Down payment and closing costs come out of the balance before the lender counts what remains, so money you spend cannot also be counted. Taking the money out is a real withdrawal.
Can I combine my IRA with brokerage and savings?
Yes. On the qualifier path accounts combine, and on the depletion path each asset type counts at its own percentage before the total is divided by 60 months.
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’s piece How to Use Retirement Assets to Qualify for a Jumbo Mortgage goes deeper on larger loans. You can reach the team at 828-256-2183.
For current guidelines and terms, see Lendmire’s asset-based mortgage programs page.
Lendmire’s asset-based mortgage in Georgia page presents the program for Georgia 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. IRS – Retirement topics: Prohibited transactions
2. Horizon Trust – Borrowing Against an IRA
3. CFPB – ATR/QM Small Entity Compliance Guide
4. Mountain West IRA – UDFI and non-recourse financing
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 Assets-Only Mortgage Be? · Can Equity in a Rental Property Help You Qualify for an Asset-Based Mortgage? · Can You Get a HELOC With No Income by Qualifying on Assets?
Guides: Asset-Based Mortgage in Georgia
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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- Lendmire LLC · Firm NMLS# 2371349 · Verify firm licensure
Disclosures. The information presented in this article is general market commentary, not financial, legal, or tax advice. Lendmire is a mortgage brokerage (NMLS# 2371349) — not a direct lender or depository institution — and loan placement is subject to lender underwriting. Nothing in this content represents a commitment to lend. Loan terms, pricing, and program availability vary based on borrower qualifications, property characteristics, and state of subject property, and are subject to change at any time. Lendmire complies with Equal Housing Opportunity requirements. Consumer access: nmlsconsumeraccess.org.