The Quick Read: Business-titled accounts, gift funds, borrowed funds, cryptocurrency, unvested stock, foreign funds and real-estate equity are the holdings that usually do not count, and cash-out proceeds from the loan itself never do. Cash and CDs count in full on both paths, while brokerage and retirement balances count at a discount that depends on the path.
- Cash, savings, money market and CDs count at 100% on the asset qualifier path. CDs and cash count at 100% on the asset depletion path.
- Retirement accounts count at 90% under age 59½ and 100% after on the qualifier path. They count at 70% at any age on the depletion path.
- Business accounts, crypto, collectibles and pledged or borrowed funds are not published as eligible on either path.
- Real-estate equity counts at 60% on the depletion path only. It is not part of the qualifier path.
- Large or unexplained deposits stay out until they season and the source is documented.
“Asset-based mortgage” covers two different structures, and the exclusion list changes a little between them. Lendmire is a broker. It arranges these consumer mortgages through select lenders in its wholesale network, and every figure below is a ceiling or floor, subject to underwriting. Consumer mortgage lending is licensed in 16 states: Alabama, California, Colorado, Florida, Georgia, Indiana, Michigan, Montana, New Mexico, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia and Washington.
What Does “Counts” Mean on an Asset-Based File?
An account counts when it is yours, you can reach it, the source is documented, and it is not already spoken for. Anything that fails one of those tests is excluded, or it counts at a reduced share of its balance. Three tiers show up on real files: counted in full, counted at a discount, and excluded.
The five tests an underwriter applies are these:
1. Owned. The account is titled to the borrower, not to a business or a third party.
2. Accessible. The funds can be withdrawn without someone else’s approval.
3. Sourced. The money has a paper trail, and the statements show it.
4. Liquid. The balance can be turned into cash at a known value.
5. Not already used. Down payment, closing costs and proceeds from this loan come out of the pool first.
The two paths use those tests differently. The asset qualifier path covers the entire loan with eligible assets and documents no employment or income. The asset depletion path divides usable assets by 60 months to produce a monthly qualifying income, and that income runs through the debt-to-income test. A borrower is qualified on one path at a time, so never blend the two tables.
The Master Exclusion Table
Here is the quick lookup. The status column reflects the network’s published program figures, subject to underwriting and the lender’s own calculation.
| Account or asset | Qualifier path | Depletion path | What could change it |
|---|---|---|---|
| Cash, savings, money market | 100% | Cash 100% | Seasoning, sourcing |
| Certificates of deposit | 100% | 100% | Statement history |
| Brokerage accounts | 100% | Securities 80% | Margin balances removed |
| Retirement (under 59½) | 90% | 70% | Vested, withdrawable |
| Retirement (59½ or older) | 100% | 70% | Vested, withdrawable |
| Private stock | Not published | 75% | Valuation review |
| Real-estate equity | Not part of path | 60% | Depletion path only |
| Business accounts | Not published | Not published | Move to personal, season |
| Crypto, metals, collectibles | Not published | Not published | Convert to seasoned cash |
| Gift or borrowed funds | Not published | Not published | None on most files |
| Foreign funds | Not published | Not eligible | Move to a regulated account |
| Stock options, unvested RSUs | Not published | Not eligible | Vest and sell first |
“Not published” means the network’s guidelines do not list the asset as eligible. Treat it as out unless a lender in the network confirms otherwise in writing.
Borrowed, Gifted and Pledged Funds
Gift funds and borrowed money are not your assets. A gift can disappear, and a loan has to be repaid, so neither supports a mortgage built on assets. That includes margin balances, personal loans, a 401(k) loan taken out for the purpose, and any account pledged as collateral for another debt.
The exclusion also reaches funds that need a third party to release them. On the depletion path, custodial accounts, escrow accounts, deferred compensation and funds from non-regulated financial companies are all off the table.
Cash-out proceeds from the subject loan never count either. It is circular. You cannot borrow against the house and then call the proceeds the asset that qualifies you for the house.
Business Accounts and Entity Money
A business account is the most common surprise. The balance looks like yours, but it belongs to the company, and pulling it out can weaken the business the lender is relying on.
Business accounts, beyond the borrower’s ownership share, are not published as eligible on either path. The fix is mechanical. Distributions have to land in the borrower’s personal account, and then they have to season. A deposit that shows up the week before application is a question mark, not an asset.
Picture a business owner with a large operating balance and a modest personal checking account. On paper the household is wealthy. On the file, the usable pool is the personal account plus whatever has been distributed and seasoned. Moving the money early is the whole game.
Crypto, Metals, Collectibles and Foreign Funds
Cryptocurrency, precious metals and collectibles are not published as eligible on either path. Lenders cannot value them against a stable number, and they cannot confirm that the funds sit in a regulated account.
The documented route is conversion. Sell the asset, deposit the proceeds into a regulated account, and let the source be reviewed by the lender. The seasoning clocks apply to the converted balance.
Some programs outside the network may treat these assets differently. Within the network figures above, plan on conversion.
Foreign funds are ineligible on the depletion path. The practical answer is the same: move the money into a regulated account and season it.
Restricted Stock, Options and Unvested Compensation
Non-vested restricted stock units and stock options are not eligible on the depletion path. An RSU you do not yet own is a promise from an employer, not an asset. Once it vests and you sell, the cash counts like any other cash, after seasoning.
Deferred compensation is excluded for a similar reason. It sits with the employer, and release is outside your control.
Private stock counts on the depletion path at 75%, but only after review. A valuation has to hold up, which is why it takes a haircut that public securities at 80% do not.
Retirement Accounts: Where “Counts” Gets Complicated
The haircut reflects volatility, taxes and early-withdrawal penalties.
On the qualifier path, 401(k) and IRA balances count at 90% under age 59½ and at 100% from 59½ on. On the depletion path they count at 70% at any age. The balance must be vested and withdrawable. Any outstanding 401(k) loan comes out of the vested balance first.
Using a retirement account does not mean cashing it out. The calculation is a paper exercise. Nothing is liquidated or pledged. For a deeper walk through reserves, Lendmire’s piece How to Count Retirement Accounts as Reserves on an Asset Depletion Mortgage covers it.
Ownership Problems: Joint, Trust and Non-Borrower Accounts
Titling decides more files than people expect. An account in a spouse’s sole name that is not on the loan is hard to use. An irrevocable trust usually has to show the borrower as a beneficiary with immediate, unrestricted access before anything counts. Revocable living trusts are the cleaner case because the borrower controls the money.
Authorized-signer status is not ownership. Being able to write checks on an account does not make the balance yours. The lender wants your name on it.
Fix titling before you apply. Re-titling creates a new deposit trail, and the seasoning clock may restart.
Real-Estate Equity and Illiquid Assets
Real-estate equity counts at 60% on the depletion path and is not part of the qualifier path. The home being purchased or refinanced cannot also be the asset that qualifies you. Federal Ability-to-Repay language points the same direction. A creditor considers income or assets other than the value of the dwelling that secures the loan.
Vehicles, art, equipment and inventory fall into the same bucket. They have value, but no lender treats them as cash.
Money That Is Real but Still Does Not Count
Some money is yours, liquid and well documented, and it still comes out of the pool. Down payment and closing costs are the obvious ones. Funds used to close cannot also be counted as usable assets. Reserves, where a program requires them, come out too.
Here is a mixed portfolio on the qualifier path. Take an $800,000 loan with $330,000 in brokerage accounts (100%, so $330,000), $300,000 in a 401(k) under 59½ (90%, so $270,000) and $200,000 in savings (100%, so $200,000). Usable assets total $800,000, which covers the loan, and it is reviewed on assets alone, subject to underwriting.
Now the depletion path. $1,500,000 in securities counts at 80%, which is $1,200,000. Add $300,000 in cash at 100%. Usable assets are $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 debt-to-income test. These are illustrative, and the lender’s own calculation governs.
Run the same exercise with a business account or a crypto wallet in the mix, and those lines simply drop to zero.
Seasoning: Why a Good Account Can Still Fail
An eligible account can still be out if the history is thin. On the qualifier path, the program wants 60 days of seasoning and two months of statements for each qualifying account. On the depletion path, statements must be at least 120 days old at application, plus the most recent statement within 45 days. Sale-of-business, inheritance and legal-settlement funds are excused from that seasoning, though the source is still reviewed.
A big deposit right before application raises questions. So does a sharp drop in balance. Keep a paper trail for any large transfer, and keep your own money moves boring while the file is open. “No income documentation” never means “no documentation.” The assets are documented on both paths.
Which Path Fits, and the Investor Angle
The qualifier path suits a borrower whose assets can cover the whole loan. It tops out at $4,000,000 and allows up to 80% leverage on a purchase and 75% on a refinance of a principal residence or second home. Credit starts at 600, subject to underwriting. Reserves are not required at or below 75% loan-to-value. Leverage, reserves, and pricing vary by lender and program; the final terms follow the full file review.
The depletion path suits a borrower who needs the assets converted to income. Loans run from $125,000 to $3,500,000. Leverage tops out at 80% on a purchase or rate-and-term refinance and 60% on a cash-out refinance for a principal residence or second home. Minimum assets are the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 liquid when depletion is the only income source. A first-time investor needs a 700 score on this path.
One more thing for investors. Wealth is not the same as qualifying assets. Money in a business, an irrevocable trust, crypto or unvested stock gives less qualifying power than the balance sheet suggests. And for a straight rental purchase, the better fit is usually a business-purpose investor loan that qualifies primarily on property-level rental income covering the payment, subject to lender guidelines. DSCR loans are designed for non-owner-occupied investment properties, and because they are business-purpose loans they are reviewed differently from a standard owner-occupied mortgage. On those files, assets show up as post-closing reserves, not as income. The complete DSCR loans guide covers that route.
Can an Excluded Account Be Fixed?
Often, yes. The fixes are plain.
1. Business money. Move distributions into a personal account and let them season.
2. Crypto and metals. Sell, deposit into a regulated account, and document the source.
3. Foreign funds. Transfer to a regulated account and season the balance.
4. Unvested stock. Wait for vesting, then sell. Count only the cash.
5. Titling. Put the account in the borrower’s name before applying.
6. Gifts and loans. There is no fix on most files. Plan the loan without them.
Pre-Application Checklist
- List every account with the owner’s name, balance and statement dates.
- Strike business, crypto, gift, borrowed, pledged and foreign balances.
- Subtract the down payment and closing costs.
- Apply the path’s percentages to what is left.
- Pull two months of statements, and older ones for the depletion path.
- Document every deposit that is not payroll or a transfer between your own accounts.
Key Terms Defined
Asset qualifier path: The structure where eligible assets cover the whole loan and no income is documented.
Asset depletion path: The structure where usable assets divided by 60 months become qualifying income.
Haircut: The share of a balance that is subtracted because of volatility or access limits.
Seasoning: The period an account or deposit has been on statements before it counts.
Vested: Owned outright and available to withdraw, even if you left the employer.
Frequently Asked Questions
Does cryptocurrency count on an asset-based mortgage?
Not as crypto. It is not published as eligible on either path in the network’s guidelines. The documented route is converting it to cash in a regulated account and letting the lender review the source.
Do business accounts count?
Generally not. The funds belong to the company, and withdrawing them can weaken the business. Distributions that land in a personal account and season may count, subject to underwriting.
Does home equity count?
The home securing the loan does not. Other real-estate equity counts at 60% on the depletion path only. It is not part of the qualifier path.
Do I count my 401(k) if I am under 59½?
Yes, at a discount. The qualifier path counts it at 90% under 59½ and 100% after. The depletion path counts it at 70% at any age.
Why was my account excluded?
Usually one of five tests failed: ownership, access, sourcing, liquidity or double use. Business titling, a recent unexplained deposit and money already needed for closing are the common causes.
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.
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
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 to Qualify for an Asset Qualifier Mortgage · How Asset Qualifier Mortgage Loan Limits Work · How Lenders Count Assets Toward an Asset Depletion Mortgage
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.