The Quick Read: Usually, but not in one step, and the answer turns on what “AUM-based” means for the borrower. A fund manager or advisor paid fees out of managed assets typically is reviewed on deposits, which fits the bank statement lane. A borrower who simply holds large investment accounts typically is reviewed on assets instead. Whether one file can combine both with a fixed structure depends on the program, subject to lender guidelines.
- A fixed structure is a product choice, separate from how income is documented.
- Fee deposits count as business income after an expense ratio of 20%, 40% or 50%, or an accountant-provided ratio.
- Liquid assets can qualify a borrower on a primary or second home, but not a pure rental.
- Everything above $4,000,000 is reviewed case by case before submission.
- Nothing here is a commitment to lend. Through select wholesale programs, every file is underwritten individually.
What Does “AUM-Based” Actually Mean to a Lender?
Lender guidelines typically do not define the term. Lenders see two different borrowers behind it, and each follows a different documentation path, subject to lender guidelines.
The first is the manager or advisor whose firm earns fees on assets under management. That money arrives as business deposits, so the file runs like any self-employed file. The second is the investor whose wealth sits in brokerage, managed or retirement accounts. That borrower may show modest deposits and a very large balance sheet.
The distinction matters because the wrong lane produces the wrong answer. A fee-earner pushed into an asset program wastes income. An asset-holder pushed into a deposit program shows income that understates real capacity. Federal rules leave room for both: under CFPB Regulation Z § 1026.43, a lender may base its repayment decision on income, on assets other than the home being financed, or on both. Which one a given lender accepts is a guideline question, not a legal barrier.
Where Does the AUM Borrower Fit Among Documentation Paths?
Pick the path that matches where the borrower’s capacity actually shows up. Scotsman Guide describes bank statement loans and asset-qualifier programs as the standard non-QM toolkit for borrowers the agencies cannot serve.
| Profile | Typical lane | What gets counted |
|---|---|---|
| Fee-earning manager or advisor | Bank statements | Eligible deposits after expense ratio |
| Investor with large liquid accounts | Asset allowance or assets-only | Liquid assets, with haircuts |
| Both: fees plus large holdings | Deposits plus asset allowance | Deposits first, assets supplement |
| Pure rental buyer | Property cash flow (DSCR) | Rent against the payment |
Across the wholesale network, most programs treat these as separate doors. A few let assets supplement deposit income when the debt-to-income ratio runs tight. Not every program does, so the combination is worth testing before an offer goes in.
How Do AUM Deposits Become Income?
Eligible deposits are totaled over 12 or 24 consecutive months, reduced by an expense ratio, then divided by the months reviewed. The result runs against debt-to-income, which can go up to 50% through select wholesale programs.
The expense ratio is where fee-earners find room. Programs commonly apply fixed ratios of 20% for a service business with no employees, 40% for one to five employees, and 50% for six or more employees or any product business. An accountant-provided ratio is an alternative. A profit-and-loss method exists too, capped at 80%. Business statements generally require at least 25% ownership of the business.
Two details matter for AUM borrowers:
- Transfers from your own business into a personal account count in full. If the advisory firm pays you through owner draws or distributions, the personal statements can carry the file.
- Transfers between your own accounts do not count as income. Moving money from a brokerage sweep into checking looks like a deposit but is a shuffle. Underwriters strip it out. Large one-time transfers draw questions, so label and source them.
Statements must be consecutive. A transaction history never substitutes.
How Are Assets Counted on the Asset Route?
Assets are counted only if they are the borrower’s own, liquid, and documented. Two structures exist through select wholesale programs.
Asset allowance divides liquid assets by 36, 60 or 84 months to create supplemental income. The 36-month divisor applies when debt-to-income is at or below 60%, the 60-month divisor when it is above 60%. The 84-month divisor applies to a standalone asset file, or to any loan above $3,500,000. It is limited to primary and second homes, at an 80% maximum.
Assets-only needs no debt-to-income calculation. It qualifies when U.S. liquid assets equal the loan amount plus closing costs plus sixty months of any net loss on other residential property.
What counts and what does not:
- Retirement accounts count at 70%, or 80% at age 59.5 and older.
- Business funds never count. Neither do gifts, unvested stock or cryptocurrency.
- Trusts other than a revocable living trust do not count.
- Client money held in custody or pooled vehicles is not the borrower’s asset.
That last point trips up fund managers. Assets under management and assets owned are different things. The underwriter wants the borrower’s own balance sheet, and the lender must verify whatever it relies on through third-party records, per the eCFR text of § 1026.43(c)(4). Custodian statements do that job.
Assets are also not double-counted. Dollars used for the asset allowance cannot also serve as reserves or funds to close.
Is a Fixed Structure Available at Super Jumbo Size?
Often yes, though the answer shifts with the program and the loan amount. Fixed versus adjustable is a separate decision from documentation, and no rule bars a fixed term on a non-QM jumbo.
Two wholesale programs shape the choices. The portfolio non-QM program carries files up to $6,000,000. A bank portfolio program takes twelve-month-statement files up to $30,000,000 on its own ladder, which begins above $4,000,000 and overlaps the first program until $6,000,000.
| Structure | Where it appears | Tradeoff |
|---|---|---|
| Fixed term | Available on many files | Payment certainty for long holds |
| 10-year fixed-period adjustable | Bank program, fully amortizing | Fixed early years, then resets |
| 5- or 7-year fixed-period adjustable, interest-only | Bank program, to 60% LTV | Lower qualifying burden, later variability |
| 40-year term, 10-year interest-only | Portfolio program, to 85% LTV with 700 credit | Lighter early carry, full payment later |
The interest-only ceiling applies to purchase and rate-and-term files only. It never lifts a cash-out ceiling. And a point worth saying plainly: at the biggest balances, adjustable and interest-only structures are common because they can help a borderline file qualify, so a fixed request may meet more resistance as size grows.
For the deeper comparison, Lendmire’s piece on how a super jumbo lender weighs ARM versus fixed covers the structural decision.
How Does Size Change Leverage and Reserves?
Leverage steps down as the loan grows, and above $4,000,000 every figure is reviewed case by case before submission. These are ceilings through select wholesale programs, subject to full underwriting, for a primary residence on a purchase:
| Loan size | Max purchase LTV | Credit floor |
|---|---|---|
| $300K–$1M | 90% | 680+ |
| $1M–$2M | 85% | 700+ |
| $2M–$3M | 80% | 720+ |
| $3M–$4M | 75% | 720+ |
| $4M–$5M | 65%, on review | 680+ |
Second homes and investment property run about five points lower at most sizes. Never assume 90% above $1,000,000.
Above $3,500,000 on a primary residence, and above $3,000,000 on a second home or investment property, extra overlays apply. These include a 700 credit floor, a clean 0x30x24 housing history and 48-month seasoning on any credit event. Cash-out proceeds cannot satisfy reserves.
Reserves run 3 months to $500,000, 6 months to $1,500,000 and 9 months above. Each extra financed property adds 2 months, to a 12-month maximum. Credit starts at a 660 floor on the portfolio program, 680 on the bank program, and 700 above the super-jumbo line.
A Worked Illustration: Same Borrower, Two Paths
Consider a registered advisor buying a primary residence priced at $2,400,000. The numbers below are modeled, not market data.
Deposit route. Her firm pays her through distributions into a personal account. Twelve months of statements show strong deposits, and the firm has six employees, so a 50% expense ratio applies to business deposits. Her personal-account transfers from the firm count in full. At 80% LTV on a purchase, debt-to-income lands comfortably under the 50% ceiling. Reserves at this size run 9 months. These specifics are subject to lender guidelines and a full review of property, leverage, and credit.
Asset route. Suppose the same borrower also holds a large liquid brokerage portfolio. Under asset allowance, those assets divide by 36 months while debt-to-income stays at or below 60%. The assets supplement income and may push a tight ratio under the limit. The same dollars cannot then also count as reserves.
The lesson: deposits usually carry the file, and assets act as the backstop. If distributions are lumpy, the asset allowance may close the gap. If assets are mostly client capital, only the deposit route is open.
Should You Stay With Your Existing Lender or Shop the Network?
It depends on the file. An existing custodian or lender relationship may offer familiarity, but one program carries one set of overlays. The reason to shop is that guidelines differ sharply: expense ratios, asset divisors, interest-only limits and leverage ladders vary program to program. Lendmire, as a broker, compares multiple wholesale programs against the same file rather than fitting the file to one lender’s rules.
The flip point: if a single lender already holds the portfolio and offers a structure that fits, there is little reason to move. If the asset-based divisor or expense ratio leaves the file short, a second program can change the answer. For borrowers who also own rentals, the complete DSCR loans guide explains how rentals can stand on their own rent.
Should You Borrow Against the Portfolio or Preserve It?
Qualifying on assets does not mean selling them. The assets only demonstrate capacity. That is the appeal for a borrower who would rather keep the portfolio invested than liquidate it for a down payment.
The tradeoff is concentration. If the same liquid dollars cover reserves, closing costs and the asset allowance, the file can thin out fast, and a market drop between application and funding can shrink the counted balance. Borrowers with volatile holdings may prefer the deposit route and keep assets as reserves.
Common Mistakes and Edge Cases
- Treating client capital as your own. Custody and pooled-vehicle balances usually do not count.
- Using asset programs for rentals. Asset paths target primary and second homes. Pure rentals belong in a property cash-flow program, which qualifies primarily on property-level rental income covering the payment, subject to lender guidelines.
- Deposit scrubbing surprises. Internal transfers and loan proceeds are removed before the math runs.
- Mixing occupancy stories. The lender classifies the loan from the application and supporting documents. Misstating occupancy is a fraud risk.
- Skipping the ownership test. Business statements need at least 25% ownership.
Tax treatment varies by situation; consult a qualified tax professional before relying on any deduction.
Key Terms Defined
Super jumbo: a lender-defined tier of very large loans above standard jumbo size, with no single official cutoff.
Non-QM: a mortgage that falls outside agency purchase guidelines and is underwritten under a lender’s own documentation rules.
Expense ratio: the share of business deposits removed as operating cost before income is calculated.
Asset allowance: a method that divides liquid assets by a set number of months to add qualifying income.
AUM: assets under management, meaning money a professional manages, which may belong to clients rather than the borrower.
Frequently Asked Questions
Do I need traditional personal-income documentation for a bank statement loan?
Not for the income calculation. Qualifying income comes from 12 or 24 consecutive months of statements, subject to lender guidelines. The lender still verifies what it relies on, so expect to document deposits, ownership and assets thoroughly.
Can dividends and withdrawals count as income?
Deposits from your own business into a personal account count in full. Movement between your own accounts does not. Dividends and withdrawals are reviewed as deposits and as asset activity, so each program treats them a little differently.
Can I combine assets with deposit income?
Some programs allow an asset allowance to supplement deposits, and the divisor depends on your debt-to-income ratio. Others keep the two paths separate. The combination is program-specific, so confirm it before choosing a lender.
Is cash-out allowed?
Yes, through select wholesale programs. Proceeds are unlimited at or below 60% LTV, with a $1,500,000 cash-in-hand cap above 60% on the portfolio program. Cash-out ceilings sit below purchase ceilings at every size and are reviewed case by case above $4,000,000. Terms depend on the lender’s guidelines, the property type, the leverage, and a full review of the credit profile.
What is the largest loan available?
Through select wholesale programs, loans run from $300,000 up to $30,000,000, with the portfolio program reaching $6,000,000 and the bank program covering the larger balances. Leverage falls with size, and everything above $4,000,000 is reviewed case by case.
If you are financing a high-balance property on business or personal bank statements and want to see how the numbers work, Lendmire can help you compare super jumbo bank statement loan options based on your deposits, the property, credit profile, leverage, and your goals. Consumer mortgage lending is licensed in 16 states: AL, CA, CO, FL, GA, IN, MI, MT, NM, NC, OH, PA, TN, TX, VA and WA. Nothing here is a commitment to lend.
Once the documentation lane is chosen, the fixed-versus-adjustable decision turns on how long you plan to hold the property and how much payment variability you can carry.
Lendmire’s self-employed mortgages page presents both super jumbo programs, bank statement and DSCR, side by side.
About Lendmire
Lendmire (NMLS# 2371349) is a mortgage brokerage focused on DSCR investor financing, helping arrange programs through wholesale and investor-lending channels in 41 markets, including Washington, D.C. DSCR loans are evaluated by the lender on property cash flow rather than personal income, subject to lender guidelines, supporting LLC closings and accommodating investors with four or more financed properties. Scotsman Guide Top Mortgage Workplace in both 2025 and 2026.
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References
1. CFPB Regulation Z § 1026.43
2. Scotsman Guide – Unique Loan Scenarios Demand Specialized Expertise
This article is part of Lendmire’s super jumbo bank statement loan program — full qualification details, guidelines, and scenarios live on the program page.
Related reading: How to Get a Super Jumbo Bank Statement Loan on Sales or Commission · How to Switch From a Private Bank to a Super Jumbo Bank Statement Loan · How to Qualify for a Super Jumbo Bank Statement Loan for a Condotel Unit
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Required disclosures. Lendmire (NMLS# 2371349) operates as a licensed mortgage broker, not a direct lender or depository. The discussion in this article is general in nature and should not be relied upon as financial, legal, or tax advice — every investment scenario is unique and should be reviewed by a qualified professional. Any loan inquiry is subject to lender underwriting, and this article is not a commitment to lend or a guarantee of approval. Mortgage rates, loan terms, and program guidelines vary by borrower, property, and state, and may change without notice. Equal Housing Opportunity. Verify licensure at NMLS Consumer Access.