Asset Depletion Loans In Naples — The Quick Read: An asset depletion loan turns your liquid savings and investments into a monthly income figure a lender can underwrite, instead of pay stubs or traditional personal-income documentation. Underwriters take your eligible assets, apply a discount to the riskier ones, and divide what’s left by a set number of months. The result stands in for income on the application. It’s built for people who are asset-rich but whose traditional personal-income documentation doesn’t tell the real story.
Key Takeaways
- Asset depletion converts savings, brokerage holdings, and retirement accounts into an imputed monthly income figure — the money itself is never touched or sold.
- The divisor (36, 60, or 84 months, depending on the program) is the single biggest lever in the math — shorter divisors produce more qualifying income from the same asset pool.
- Retirement accounts typically count at a discount, and that discount often improves once the borrower crosses age 59½.
- Investment-property eligibility for asset depletion is program-specific — some structures cover primary and second homes only.
- Asset depletion is a distinct qualification path from DSCR (which qualifies off the property’s rental income) and bank-statement lending (which qualifies off business cash flow).
Key Terms Defined
Asset depletion (or asset dissipation/utilization): an underwriting method that divides a borrower’s liquid assets by a set number of months to produce a stand-in monthly income figure.
Divisor: the number of months a lender divides your eligible asset total by — a shorter divisor produces a bigger monthly income number from the same pool of money.
Haircut: the percentage discount applied to a volatile or restricted asset (like a brokerage account or a 401(k)) before it counts toward the depletion math.
DTI (debt-to-income ratio): the share of a borrower’s monthly obligations against their monthly income — asset depletion feeds its imputed figure into this same calculation.
Non-QM: a regulatory label for loans that fall outside the Qualified Mortgage rules — it describes how a loan is classified, not how risky the borrower is.
How the Math Actually Works, Step by Step
The mechanics run the same way across most programs, even though the exact numbers differ.
Step one: total the eligible assets. Depository accounts, brokerage and investment holdings, and vested retirement balances are the usual categories. Source of funds and how long the money has sat in the account both matter before anything counts.
Step two: apply the haircut. Cash in a checking or savings account is usually counted close to full value. Securities and retirement funds are not — lenders discount them because their value moves and, in the case of retirement accounts, early withdrawal can trigger a penalty.
Step three: subtract what’s already spoken for. Down payment, closing costs, and any reserves the lender requires come out of the pool first. Only what’s left over goes into the income calculation — the same dollar can’t do double duty.
Step four: divide by the program’s divisor. This is where programs diverge the most. Across the wholesale network Lendmire places files through, the asset allowance path uses a 36-month divisor when the depletion income is supplemental and overall debt-to-income sits at or below 60%, a 60-month divisor when it’s supplemental above that DTI threshold, and an 84-month divisor when the depletion income stands alone or the loan amount runs above $3,500,000. A shorter divisor spreads the same balance over fewer months, which produces a bigger monthly figure — useful for a borrower who needs more qualifying income, but it also means the asset drains faster on paper.
Step five: feed it into underwriting like any other income. The imputed figure goes straight into the debt-to-income calculation, same as a pay stub would. Credit, reserves, and the rest of the file still have to hold up on their own.
Nothing here requires the borrower to sell anything. The account stays exactly where it is — the calculation only measures what’s already there.
The Structures Investors Actually Use
Across select lenders in Lendmire’s wholesale network, two distinct asset-based paths show up on files, and they solve different problems.
Asset allowance works as a supplement to other income or, at higher loan amounts, as the sole qualifying source. It uses the 36/60/84-month divisor structure described above, tops out at 80% loan-to-value, and is limited to primary residences and second homes — it does not extend to investment property on this path.
Assets-only skips the debt-to-income calculation altogether. It requires U.S.-based liquid assets equal to the full loan amount, plus closing costs, plus 60 months of any net loss the borrower is carrying on other residential real estate. That’s a much higher liquidity bar, but for a borrower who’s genuinely asset-heavy and wants a clean file with no ratio math, it removes DTI from the conversation entirely.
Retirement accounts count at 70% of their value on both paths. This goes up to 80% once the account holder is past age 59½. At that age, the IRS no longer applies its early-withdrawal penalty. Business funds, gift funds, trusts other than a revocable living trust, unvested stock, and cryptocurrency never count toward either calculation. This detail trips up many high-net-worth borrowers who assume their total net worth is the number that matters.
For a retiree file, this often layers with an actual income stream. The IRS requires most retirement account holders to start taking required minimum distributions at age 73, and many files pair that real distribution with the depletion math rather than leaning on the calculation alone.
Where the General Rule Breaks
Investment property is the biggest exception. The asset allowance path described above covers primary residences and second homes only — it does not reach non-owner-occupied rental property. An investor buying a rental with asset-heavy qualification typically needs a different structure entirely, which is why DSCR financing — qualifying off the property’s own rental income rather than the borrower’s balance sheet — is usually the better-fit path for a straight rental purchase. Lendmire’s complete DSCR loans guide walks through how that income-based math works property by property.
Retirement-account age matters more than people expect. Because pulling from a tax-deferred account before 59½ carries an IRS penalty, the discount applied to those balances shifts at that exact birthday — not a lender preference, but a real difference in how liquid that money actually is.
Sole-source use isn’t universal. Some structures let the depletion figure stand entirely on its own. Others only allow it to supplement documented income like Social Security or a pension. Which bucket a given file falls into depends on the specific program guideline, not a blanket non-QM rule — and confirming this before submission avoids wasting an application cycle on a program that was never going to clear the file.
Above $3,500,000 on a primary residence, or $3,000,000 on a second home or investment property, everything shifts to case-by-case underwriting. Credit floors rise to 700, seasoning on any credit event extends to 48 months, and cash-out proceeds can no longer be used to satisfy reserve requirements. These overlays exist specifically because the file sizes get large enough that automated guidelines stop being a good substitute for a human underwriter’s judgment. Final terms depend on lender guidelines, property type, leverage, and the borrower’s complete credit picture.
Sizing and Leverage: What the Numbers Actually Look Like
Loan sizes across the wholesale network run from $300,000 up to $30,000,000, split across two ladders. A portfolio non-QM program carries files to $6,000,000. A separate bank portfolio program, built around 12-month statement files, carries loans on its own size ladder above that: 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.
Leverage on a primary residence steps down as the loan gets bigger — typically 90% up to $1,000,000, 85% up to $2,000,000, 80% up to $3,000,000, and 75% at the top credit tier up to $4,000,000, before moving into case-by-case review through $6,000,000 and then onto the bank program’s own ladder. Second homes and investment property generally run about five points lower at every size band, and investment-property files on this size ladder go through business-purpose underwriting rather than owner-occupied review.
Credit floors on the portfolio program run from a 660 minimum, stepping up to 700 once a loan crosses the super-jumbo thresholds. Debt-to-income can run as high as 50% where applicable. Reserve requirements scale with loan size too — typically 3 months of payments up to $500,000, 6 months up to $1,500,000, and 9 months above that, plus 2 additional months per financed property beyond the subject, capped at 12 months. First-time real estate investors are generally held to a 12-month reserve requirement regardless of loan size.
Above $4,000,000, every file goes through case-by-case review before submission — that’s a firm line, not a soft guideline, and any leverage figure quoted above that size should always come with that caveat attached.
Asset Depletion vs. the Other Non-Owner-Income Paths
| Qualification Path | What It Measures | Best Fit |
|---|---|---|
| Asset depletion | Borrower’s liquid assets, divided by a set term | Asset-rich borrowers with thin taxable income |
| DSCR | The property’s own rental income against its payment | Rental property purchases and refinances |
| Bank statement | Business or personal deposit history | Self-employed borrowers with strong cash flow |
The most common mistake is treating “non-QM” as one single product. It’s actually a regulatory classification, not a documentation method. A loan can fall into this category because of its structure, its pricing, or how it’s sold. This label alone doesn’t tell you whether a program allows rental property or requires a specific divisor. For a rental-property investor, the real decision usually comes down to this: is the deal qualified based on the buyer’s balance sheet, or on the property’s own rent roll? These are genuinely different types of files. Lendmire’s breakdown of DSCR loans versus asset depletion loans explains this decision in more detail. It’s worth reading before you choose a path. Guessing wrong can waste an entire application cycle on a program that was never right for your file.
Regulators require lenders to make a good-faith effort to check that a borrower can repay the loan. The rule behind this requirement allows assets to count in place of income. This is one factor a lender can weigh under the CFPB’s ability-to-repay rule. This rule is what makes asset-based qualification possible outside the agency world. Fannie Mae has its own version of this idea, but it’s much more conservative. Lenders must document that the depletion income will continue for at least three years, per Fannie Mae’s Selling Guide. If it’s the main income source, lenders must also check the borrower’s ability to repay once the assets run out. Non-QM programs for high-net-worth borrowers generally take a more flexible approach than the agency standard. That’s exactly why these programs exist as a separate option.
DSCR loans are designed for non-owner-occupied investment properties. Because they’re business-purpose investor loans, they’re reviewed differently from a standard owner-occupied mortgage.
Lendmire offers consumer mortgage lending in 16 states: Alabama, California, Colorado, Florida, Georgia, Indiana, Michigan, Montana, New Mexico, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia, and Washington. Lendmire doesn’t fund these loans directly. Instead, it arranges them through select lenders in its wholesale network.
Frequently Asked Questions
Do I lose access to my money if I use asset depletion to qualify?
No. The calculation only measures the balance to produce a qualifying income figure — nothing gets sold or moved as part of underwriting. Reserve requirements may restrict how the money gets used after closing, but the asset itself stays intact. These specifics are subject to lender guidelines and a full review of property, leverage, and credit.
Can I use asset depletion to buy a rental property?
Typically not through the asset allowance path, which is generally limited to primary residences and second homes. Investors buying non-owner-occupied rental property usually get a better fit from a DSCR loan, which qualifies off the property’s own rent rather than the buyer’s balance sheet.
Does my full retirement account balance count?
No — retirement funds typically count at 70% of value, moving up to 80% once the account holder passes age 59½. That discount reflects the real penalty risk tied to early withdrawal, not a lender’s guess.
What’s the difference between asset allowance and assets-only qualification?
Asset allowance divides your assets by a set number of months and feeds that figure into a debt-to-income calculation. Assets-only skips DTI entirely but requires liquidity equal to the full loan amount plus costs — a much higher bar, but a cleaner file for borrowers who clear it.
Is there a maximum loan size for asset depletion borrowers?
Loan sizes across the wholesale network run from $300,000 up to $30,000,000 across two program ladders, though everything above $4,000,000 goes through case-by-case underwriting before it’s even submitted. Terms vary by lender guidelines, property type, leverage, credit profile, and full file review.
If you’re weighing an asset-based qualification path against a rental-income path like DSCR, Lendmire can help compare the options based on your assets, credit profile, leverage needs, and the property itself.
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 non-QM mortgage broker serving real estate investors in 40 markets, including Washington, D.C., through DSCR investor loan programs. Qualification is generally reviewed around the subject property’s rental income, not the borrower’s W-2 history — a practical fit for LLC-titled portfolios and self-employed investors. All scenarios remain subject to lender review and program guidelines. Two consecutive Scotsman Guide Top Mortgage Workplace recognitions (2025, 2026).
Lendmire’s Top Mortgage Workplace recognition is documented by Scotsman Guide 2025 Top Mortgage Workplace and Scotsman Guide 2026 Top Mortgage Workplace.
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References
1. IRS – Retirement Topics: Required Minimum Distributions
2. Consumer Financial Protection Bureau – What Is the Ability-to-Repay Rule
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Legal disclosures. Lendmire (NMLS# 2371349) is a state-licensed mortgage brokerage that arranges financing through wholesale lender relationships. Lendmire is not a direct lender, depository institution, or registered financial advisor. The discussion above is general informational content about real estate financing — it is not financial, legal, or tax advice, and readers should consult licensed professionals for guidance on their individual circumstances. Loan inquiries are subject to lender underwriting; this article does not represent a commitment to lend. Loan terms, rates, and qualification standards vary by borrower, property, and state, and are subject to change at any time. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.
