The Quick Read: The best asset-based program for a commission-paid agent depends on how large the loan is relative to the agent’s liquid assets: if eligible assets cover the whole loan, the asset qualifier path applies, and if they do not, the asset depletion path turns them into monthly income.
- Asset qualifier path: eligible assets must equal or exceed the entire loan. No employment or income is documented.
- Asset depletion path: usable assets divided by 60 months become qualifying income, and that income runs through the debt-to-income test. This is the path with published cash-out leverage.
- Cash-out proceeds never count toward the assets used to qualify.
- Privately held company stock is not an eligible asset on either path.
- A borrower is qualified on one path at a time, subject to underwriting and lender guidelines.
Lendmire is a mortgage broker. It places asset-based files with select lenders in its wholesale network and does not lend or approve anything itself. The sections below show how each path treats a commission earner, which assets count, and where the rules break.
Key Terms Defined
Asset qualifier path: a program that drives lender review on assets alone, with no income documented.
Asset depletion path: a program that divides usable assets by 60 months to create a monthly qualifying income.
Haircut: the share of an account’s balance a program refuses to count, such as the 20% cut on securities.
Seasoning: how long funds have sat in an account before the lender will count them.
Cash-out refinance: a new first mortgage that pays off the old one and returns the difference as cash.
Loan-to-value (LTV): the loan amount divided by the appraised value.
Why Does Commission Pay Strain Standard Underwriting?
Conventional underwriting wants a long, steady earnings record. Commission income guidelines from Gustancho describe the usual approach: lenders look for roughly a two-year history and average it. A falling trend gets treated cautiously.
That is hard on agents. Closings cluster. A great quarter can follow a dry one. Brokerage splits, desk fees and business write-offs also lower the income that shows up on a tax return, even when the agent’s real cash flow is strong.
Asset-based programs sidestep that problem. They do not ask what you earned in each of the last two years. They ask what you hold today, how long it has been there, and whether it covers the loan or supports the payment. For an agent who has banked a strong year, that is often the cleaner story.
It is not the right fit for everyone. An agent with thin savings and steady monthly deposits may do better on the bank statement program, which documents income through deposits.
How Do the Two Asset-Based Paths Work?
Both paths document assets rather than pay. They differ in what the assets must do. On the qualifier path they must cover the loan. On the depletion path they must produce enough monthly income to carry the payment. Lendmire’s asset-based mortgage programs are placed with select lenders, and each file is underwritten individually.
Asset qualifier path. Eligible assets, after the credit percentages below, must equal or exceed the entire loan amount. The borrower documents no employment or income. That means no traditional personal-income documentation, pay stubs or employment verification. The assets themselves are fully documented with statements. Loans go up to $4,000,000. Leverage runs up to 80% on a purchase and 75% on a refinance of a principal residence or second home. Whether cash-out proceeds are allowed on this path, and at what leverage, is set by the individual lender and is not published. Ask before you plan around it.
Asset depletion path. Usable assets are divided by 60 months. The result is a monthly qualifying income that must carry the full housing payment and other debts through the debt-to-income test. Loans run from $125,000 to $3,500,000. Leverage on a cash-out refinance is up to 60% on a principal residence, a second home or an investment property. Purchases and rate-and-term refinances run up to 80% on a principal residence or second home, and up to 65% on an investment property.
Consider the arithmetic on each path, shown for illustration only. The lender’s own calculation governs.
- Qualifier: an $800,000 loan with $330,000 in brokerage accounts (100% counts), $300,000 in a 401(k) held under age 59½ (90% = $270,000) and $200,000 in savings (100%) counts $800,000 of usable assets. It is reviewed on assets alone.
- Depletion: $1,500,000 in securities (80% = $1,200,000) plus $300,000 in cash (100%) is $1,500,000 usable. Divided by 60 months, that is $25,000 of monthly qualifying income. That income then carries the housing payment and other debts through the debt-to-income test.
Which Assets Count, and How Much?
Each path has its own table, and the two never blend. Every figure here is a share of the balance that counts, subject to underwriting.
| Asset | Qualifier path | Depletion path |
|---|---|---|
| Brokerage / securities | 100% | 80% |
| Certificates of deposit | 100% | 100% |
| Money market | 100% | Cash accounts: 100% |
| Savings | 100% | Cash accounts: 100% |
| Retirement accounts | 90% under 59½; 100% at 59½+ | 70% at any age |
| Real-estate equity | Not listed | 60% |
Several things do not count on the depletion path. These include 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. Cryptocurrency, precious metals, collectibles and pledged or borrowed funds are not published as eligible on either path. The documented route for those is converting them to a seasoned cash balance in a regulated account. The lender reviews the source of those funds.
Agents should pay special attention to three exclusions.
1. Client or transaction funds. Money held in a brokerage trust or escrow account is not yours. It does not count.
2. Business accounts. If commission lands in an LLC or S corporation account, only the borrower’s ownership share is in play, and that is not published as eligible. Moving funds into a personal account early gives them time to season.
3. Pending commissions. A closing that has not funded is a pipeline item, not an asset.
What Does the Process Look Like, Step by Step?
1. Pick the path. Add up eligible assets after the percentages. If they cover the loan, the qualifier path is an option. If not, the depletion path converts them into income.
2. Check the credit. The qualifier path has a 600 minimum score. The depletion path follows the lender’s score and loan-amount matrix. A first-time investor on the depletion path needs 700. Housing history is 0x30x12, and one 30-day late in the past twelve months is considered case by case. Multiple bankruptcies are not eligible. A housing event needs four years of seasoning on the depletion path.
3. Season the money. The qualifier path needs 60 days of seasoning and two months of statements per qualifying account. The depletion path needs statements at least 120 days old at application plus the latest statement within 45 days. Sale-of-business, inheritance and legal-settlement funds are excused from that seasoning on the depletion path.
4. 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 balance. They must never be below $250,000 liquid when depletion is the only income source. Asset-derived income may also supplement documented income up to a 45% debt-to-income ratio. When it does, the minimum-assets rule is waived.
5. Appraisal and underwriting. The appraisal sets the value that drives LTV. Underwriting reviews the whole file, and the lender’s ability-to-repay review on the qualifier path rests on the assets.
6. Disclosures. A consumer-purpose loan on a principal residence or second home carries the standard consumer mortgage disclosures.
Reserves are simple on the qualifier path. None are required at or below 75% LTV, and above that the lender sets them. The depletion path has no published reserve months. Terms depend on the lender’s guidelines, the property type, the leverage, and a full review of the credit profile.
How Do the Routes Compare for an Agent?
| Route | How income is read | Best-fit agent | Main limit |
|---|---|---|---|
| Conventional | Roughly two-year averaged history | Steady, high tax-return income | Write-offs shrink qualifying income |
| Bank statement | Deposits over a set period | Strong deposits, thin savings | Messy or mixed accounts |
| Asset depletion | Assets ÷ 60 months | Large balances, uneven pay | 60% cash-out cap; asset minimums |
| Asset qualifier | No income documented | Assets cover the whole loan | Cash-out terms set by lender |
For a rental the agent owns and wants to tap, business-purpose rental financing is a separate route built on the property’s rent.
Four Agent Profiles, Four Likely Paths
These are illustrations, not approvals. Each depends on the file.
| Situation | Likely path | Watch-outs |
|---|---|---|
| Banked a big year; savings and brokerage cover the full loan | Qualifier, if the lender allows cash-out | Cash-out terms not published; ask first |
| Strong portfolio, but loan exceeds assets | Depletion | 60% cash-out cap; securities haircut |
| Wants cash out of an owned rental | Depletion, investment property | 60% cap; 700 score for first-time investor |
| Thin savings, steady monthly deposits | Likely bank statement instead | Asset paths may not fit |
The timing of a big closing matters. Commission paid last month has not seasoned. On the qualifier path it needs 60 days, and on the depletion path the statement rules apply. An agent planning a cash-out is often better off waiting for the balance to age than rushing a file that will be questioned.
Where Do the Rules Break?
- Brokerage or franchise ownership. Privately held company stock is not an eligible asset on either path. An agent who owns shares in a brokerage cannot use them. The route is documented liquid assets, such as seasoned proceeds from a sale.
- Cash-out proceeds as reserves. The money you pull out cannot be used to qualify. Plan the loan so the assets stand on their own.
- Retirement accounts. The qualifier path counts them at 90% under age 59½ and 100% after. The depletion path counts them at 70% at any age.
- Landing between paths. A file that comes up just short on the qualifier path may work on the depletion path.
- Occupancy. A cash-out on the agent’s own home is consumer-purpose.
What Should an Agent Prepare?
Gather two months of statements for each account, plus older statements for the depletion path. Keep personal and business deposits in separate accounts. Pull a credit report to confirm the score and the housing history. Know the appraised value you expect, because LTV drives how much cash the 60% cap leaves. Expect the lender to ask about any large recent deposit, so keep the paper trail for commission payouts.
A Note on Business Purpose
When the subject is a non-owner-occupied rental, Regulation Z section 1026.3 generally treats credit to acquire, improve or maintain it as business-purpose. Owner-occupied properties follow different unit-count tests. Business purpose also does not mean exempt from every rule. A law-firm alert from Hunton Andrews Kurth notes that HMDA reporting, ECOA and fair housing rules can still apply. Using the cash for personal spending can also muddy the classification, so state the purpose honestly.
This article is for general information and is not legal or tax advice. Readers should consult a qualified attorney or CPA about their own situation.
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. Consumer mortgage lending through this program is licensed in Alabama, California, Colorado, Florida, Georgia, Indiana, Michigan, Montana, New Mexico, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia and Washington.
Frequently Asked Questions
Does my commission income matter on an asset-based loan?
On the asset qualifier path, no income is documented. The loan rests on assets. On the asset depletion path, income is derived from assets rather than from commission. Credit, seasoning and the property still matter, and every file is fully underwritten.
Can I use pending closings or my brokerage trust account?
No. Pending commissions are not funded assets, and money held in a trust or escrow account belongs to clients. Escrow accounts are not eligible on the depletion path. Only seasoned funds in your own name count.
Does stock in my brokerage count?
No. Privately held company stock is not an eligible asset on either path. The route is documented liquid assets, such as seasoned cash from a sale, public securities and retirement accounts at their percentages.
How much cash can I take out?
On the depletion path, cash-out runs up to 60% LTV on a principal residence, second home or investment property. The qualifier path’s cash-out terms are set by the lender and are not published. Both are subject to underwriting. The exact numbers vary by lender and program and follow a full review of property, leverage, and credit.
Should I use an asset-based loan or a bank statement loan?
It depends on where your strength is. Large seasoned balances point toward the asset paths. Strong monthly deposits with thin savings point toward bank statements. Lendmire’s piece Bank Statement Cash-Out Refinance Rules for a Real Estate Agent Paid on Commission explains that side.
A deeper walk-through of investment-property equity extraction lives in Lendmire’s guide to cash-out refinance on an investment property.
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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Informational only. Not a Loan Estimate, approval, or commitment to lend. Program availability and eligibility are subject to lender guidelines, credit approval, property review, and underwriting.
References
1. Gustancho commission income guidelines
2. CFPB Regulation Z section 1026.3
3. Hunton Andrews Kurth, “Beware of Business Purpose”
This article is part of Lendmire’s asset-based mortgage program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: Best Asset-Based Cash-Out Refinance Program for a Founder Before a Liquidity Event · Best Asset-Based Cash-Out Refinance Program With Stock Options as Your Main Asset · Best Asset-Based Cash-Out Refinance Program to Fund Large Philanthropic Gifts
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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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.