Asset Depletion Loans In Miami Beach — The Quick Read: An asset depletion loan lets a borrower qualify using liquid savings and investments instead of pay stubs or traditional personal-income documentation. A lender takes eligible accounts, subtracts what’s needed for closing and reserves, then divides what’s left by a set number of months to create an imputed income figure. That figure gets tested against the mortgage payment the same way a paycheck would. The mechanics work the same whether the property sits in Miami Beach, Denver, or anywhere else — this isn’t a local product, it’s a national non-QM structure.
Before going further, here’s an important point: nothing here describes a Miami-specific rule. Asset depletion underwriting is federally shaped and program-driven, not zip-code driven. A high-net-worth buyer with the same portfolio qualifies the same way in South Florida as in any other state where the program is offered.
What This Loan Actually Solves
Asset depletion exists for one specific borrower problem: substantial wealth, thin taxable income. Retirees living off a brokerage account, founders between liquidity events, and people who’ve structured their finances to minimize reported income all show weak numbers on a 1040 even though they could pay a mortgage many times over.
Standard underwriting can’t see that wealth. It’s built around W-2s and traditional personal-income documentation. Asset depletion gives underwriting a second lens. People also call it asset dissipation or asset utilization. Instead of asking “what did you earn,” it asks “what do you own, and how long could it support this payment.” Assets are an explicitly recognized alternative. That’s the regulatory hook that makes the whole product legal.
Key takeaways before the detail:
- Asset depletion converts liquid wealth into an imputed monthly income figure — nothing gets sold or pledged.
- Different asset types get different treatment: cash counts closest to full value, securities and retirement funds get discounted.
- There’s no single mandated divisor. Programs use different month counts, and the choice has to be defensible, not arbitrary.
- This is primarily a personal-qualification tool for primary and second homes — pure rental purchases usually run better through a DSCR loan instead.
- Above roughly $3.5–4 million in loan size, every file gets reviewed case by case before submission, regardless of which program it runs through.
Key Terms Defined
Asset depletion (or asset dissipation): a qualification method that converts a borrower’s liquid assets into an imputed monthly income figure by dividing the eligible balance by a set number of months.
Divisor: the number of months a lender divides eligible assets by to produce the qualifying income figure — common divisors include 36, 60, and 84 months, though the OCC’s Bulletin 2019-36 notes the period just has to be prudent and analytically supported, not tied to a single federal number.
Haircut (or discount): the percentage reduction applied to a volatile asset class — stocks, bonds, retirement accounts — before it counts toward the depletion calculation, meant to account for market swings.
DSCR ratio: a coverage measure that divides a rental property’s monthly income by its full monthly payment; a ratio above 1.00 means the rent covers the payment with room to spare, subject to lender guidelines.
How Underwriting Actually Treats Your Assets, Step by Step
The whole product is arithmetic once the paperwork is in. Here’s the order underwriting actually works through.
Step 1 — Inventory what’s eligible. Every account being counted needs statements and proof the borrower actually owns and can access it. Checking, savings, and money market balances are the cleanest inputs.
Step 2 — Apply asset-class treatment. Not every dollar counts the same. Across the network Lendmire works with, retirement accounts typically count at 70% of value, stepping up to 80% once the borrower is past 59½ — the age where early-withdrawal penalties stop being a real barrier to access.
Step 3 — Net out committed funds. Whatever’s earmarked for the down payment, closing costs, and required reserves comes off the top before any income calculation runs. Reserves aren’t a formality here — they’re typically 3 months of the payment on smaller loans, stepping to 6 months and then 9 months as loan size grows, plus roughly 2 months for every additional financed property, capped around 12 months. First-time investors usually need a full 12 months.
Step 4 — Apply the divisor. What’s left after Step 3 gets divided by a set number of months. That produces an imputed monthly income figure, which then gets treated like a paycheck in the debt-to-income calculation.
Step 5 — Layer with other income if it helps. A retiree drawing Social Security or a pension can often pair that income with partial asset depletion rather than leaning on the portfolio alone — a strategy worth understanding more fully in Lendmire’s piece on staying invested while qualifying on asset depletion.
Step 6 — Underwrite like any other non-QM file. Once the income figure exists, the loan proceeds through standard underwriting — credit, reserves, property review — same as a bank-statement or DSCR file.
Every page of every statement needs to be in the file, even the ones marked “intentionally left blank.” Missing pages are the single most common reason these files stall in underwriting.
The Structures and Variations That Exist
Not every asset depletion path looks the same. The differences matter more than most borrowers expect. Across the wholesale network Lendmire places files through, two structures show up most often. The legal groundwork for this comes from the CFPB’s ability-to-repay rule. This rule requires lenders to make a reasonable, good-faith determination that a borrower can repay the loan. But it never says that determination has to run through employment income specifically.
Asset allowance divides liquid assets by 36 months when it’s supplementing other income and the borrower’s overall DTI stays at or below 60%, or by 60 months when DTI runs above that threshold. When asset depletion has to carry the file entirely — or the loan amount runs above $3.5 million — an 84-month divisor typically applies instead. Asset allowance is generally reserved for primary and second homes, maxing out around 80% loan-to-value.
Assets-only works differently and skips DTI math altogether. It requires the borrower’s U.S. liquid assets to equal the full loan amount plus closing costs plus sixty months of any net loss the borrower carries on other residential property. This is a much higher liquidity bar, but it removes income-ratio friction entirely for borrowers who genuinely have the balance sheet for it.
The divisor length itself is a lever, not a fixed rule. A shorter divisor produces a bigger monthly income figure from the same asset pile, which can mean qualifying for more loan or absorbing a higher rate tier — but it also implies the assets get “used up” faster on paper. A longer divisor is more conservative and tends to show up when a lender wants a bigger analytical cushion. The OCC’s bulletin is explicit that there’s no single mandated period here — the standard is that whatever term a bank picks has to be prudent and backed by its own analysis, similar to terms used on other residential mortgages.
Loan size ranges widely on this side of non-QM. A portfolio program in Lendmire’s network carries files from $300,000 up to $6,000,000. A separate bank-portfolio program, underwritten off twelve months of statements, runs on its own ladder up to $30,000,000 — 65% loan-to-value to $5,000,000, 60% to $10,000,000, and 55% up to $30,000,000, with interest-only capped at 60% or the band’s own ceiling, whichever is lower. Anything above roughly $4,000,000 gets reviewed case by case before it’s even submitted — that’s true across every leverage tier at that size, not an exception.
Where the General Rule Breaks
A few edge cases change the math meaningfully, and they trip up borrowers who assume asset depletion works identically everywhere.
Owner-occupied versus rental property. This product was built around primary residences and high-net-worth or retired borrowers, not rental portfolios. An investor adding another unit to an existing portfolio is almost always better served by a DSCR loan, which qualifies off the property’s own rent rather than the borrower’s personal balance sheet. See the DSCR loans complete guide for how that structure works end to end.
Age changes what retirement accounts are worth. A borrower under 59½ typically sees retirement funds counted at a lower percentage than someone past that age, since early-withdrawal penalties are still a real barrier to access. This single variable can shift how much a portfolio actually produces on paper.
Agency rules aren’t the same as non-QM rules. Fannie Mae removed its old 30% haircut on stocks, bonds, and mutual funds for asset-based qualification back in late 2020 — a change plenty of outdated articles still haven’t caught up on. None of this governs non-QM asset depletion programs, which are written to their own investor guidelines entirely — but it’s worth knowing the agency and non-QM worlds genuinely diverge here.
Cryptocurrency is excluded almost everywhere. Whether the file runs through an agency channel or a non-QM lender, crypto holdings are broadly treated as ineligible for asset-based qualification.
Super-jumbo territory adds overlays. Once a loan crosses roughly $3.5 million on a primary residence (or $3 million on a second home or investment property), overlays tighten: a 700 credit floor instead of 660, a clean 24-month housing history, 48-month seasoning on any credit event, and cash-out proceeds can’t be used to satisfy reserve requirements. These specifics are subject to lender guidelines and a full review of property, leverage, and credit.
Asset Depletion vs. DSCR: Which Actually Fits
These two products usually solve different problems, not compete for the same borrower. Asset depletion qualifies the person; DSCR qualifies the property.
| Factor | Asset Depletion | DSCR Loan |
|---|---|---|
| What’s evaluated | Borrower’s liquid assets | Property’s rental income |
| Best fit | Primary/second home, high net worth | Rental property purchase or refinance |
| Income docs | None — assets replace income | Property rent covers the payment |
| Typical use case | Retiree, founder, thin 1040 | Investor building a rental portfolio |
Want a full side-by-side? Check out Lendmire’s comparison of DSCR loans versus asset depletion. It covers both in more depth. DSCR loans are business-purpose, non-owner-occupied investment products. That means lenders review them differently from a standard owner-occupied mortgage. This is exactly why these loans don’t need a personal income or asset story at all. A rental property qualifies mainly on whether the property’s rental income covers the payment, subject to lender guidelines.
What a File Actually Looks Like
Picture a borrower with a large brokerage and retirement portfolio. They’re mostly retired, and their 1040 shows almost no taxable wages. Here’s how the numbers might work, purely as a modeled illustration. First, lenders inventory eligible cash and securities. Then they count retirement funds at the applicable percentage for the borrower’s age. Next, they subtract the amount set aside for down payment and reserves. They divide what’s left by the applicable term — 36, 60, or 84 months, depending on how the file is structured. This produces an imputed monthly income figure. Lenders then test that figure the same way they’d test a paycheck.
Across files like this, a clear pattern shows up in Lendmire’s network. The issue usually isn’t a credit problem — it’s a documentation gap. Borrowers with genuinely strong balance sheets often stall in underwriting. Usually a statement page is missing, or an account transfer isn’t sourced cleanly. The assets themselves rarely fall short. To avoid most of this friction, gather every page of every statement upfront, including the blank ones.
Reserves, credit, and leverage still function like any other non-QM file once the income figure is set. Credit typically needs to clear 660 on the standard portfolio program, moving to 700 once loan size crosses into super-jumbo territory. Debt-to-income can run as high as 50%. Leverage steps down as loan size climbs — a primary residence can reach as high as 90% at the smaller end of the ladder, tightening toward the mid-60s and below once the loan crosses into the multimillion-dollar bands, with everything above roughly $4 million reviewed case by case.
Tax treatment on any of this can depend on how funds are used and how the property is titled; investors should keep clear records and talk to a qualified tax professional before relying on any specific deduction.
Frequently Asked Questions
Do I have to sell my investments to qualify this way?
No. The divisor calculation is entirely on paper — nothing gets sold, liquidated, or pledged. The portfolio stays intact and keeps growing while the imputed figure drives lender review work.
Can I combine asset depletion with Social Security or pension income?
Yes, on many programs. Pairing partial asset depletion with a fixed income source like Social Security or a pension can preserve more of the portfolio while still reaching a qualifying total — worth exploring with a broker familiar with how different lenders structure this blend.
Does my age affect how much of my retirement account counts?
Yes. Retirement funds typically count at a lower percentage before age 59½ and step up afterward, since early-withdrawal penalties are less of a practical barrier once that age is reached.
Can I use asset depletion to buy a rental property?
It’s possible on paper, but most investors buying pure rental property get better leverage and a simpler process through a DSCR loan, which qualifies off the property’s rent instead of the borrower’s balance sheet.
Is there one standard divisor every lender uses?
No — there’s no single federally mandated number. Programs commonly use 36, 60, or 84 months depending on the structure, and the OCC’s own guidance confirms the standard is that the chosen period be prudent and supportable, not universal.
For current guidelines and terms, see Lendmire’s super jumbo bank statement loan programs page.
Self-employed borrowers can compare both super jumbo programs on Lendmire’s self-employed mortgages page.
About Lendmire
Lendmire (NMLS# 2371349) is a DSCR-focused mortgage broker that helps arrange investor financing across 40 markets, including Washington, D.C., through wholesale and investor-lending channels. DSCR eligibility is generally reviewed by the lender around the property’s rental income rather than personal income documentation, subject to lender guidelines — which works for self-employed investors, LLC operators, and portfolios above four financed properties. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
2. CFPB – What is the ability-to-repay rule?
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Important disclosures. Lendmire (NMLS# 2371349) is a licensed mortgage brokerage. Lendmire is not a direct lender, depository institution, or financial advisor. All loan inquiries are subject to lender underwriting; this article does not constitute a commitment to lend. Rates, terms, and program guidelines are subject to change without notice and vary by borrower profile, property type, and state. Information in this article is general in nature and is not financial, legal, or tax advice. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.
