How to Compare a Bank Jumbo Quote on Asset Depletion Income

The Quick Read: A bank jumbo quote built on asset depletion converts your liquid assets into monthly qualifying income, so two quotes on identical statements can differ more in the income they credit than in price, and you compare them by lining up the divisor, the haircuts, and the funds subtracted before the division.

• The divisor does the heavy lifting. A shorter depletion period produces far more monthly income from the same assets.
• Haircuts vary by account type. Retirement accounts are usually discounted more than cash or brokerage funds.
• Your down payment and closing costs come out first. The same dollars cannot qualify you and also pay for the purchase.
• Ask for the breakdown in writing. A quote that shows only a loan amount hides the assumptions that produced it.
• Compare qualifying income and total cost together. A lower price on a smaller loan is not a better deal if it does not fit your plan.

What Is Asset Depletion Income on a Jumbo Loan?

Asset depletion is an underwriting method that turns a pile of liquid assets into a monthly income figure. The lender divides your eligible assets over a set number of months. The result stands in for paycheck or tax-return income.

A jumbo loan is simply a mortgage above the conforming loan limit, which is set each year by the federal housing finance regulator. Banks and wholesale lenders write jumbos under their own rulebooks. That freedom is why asset depletion quotes vary so much.

One misconception comes up constantly. Asset depletion does not mean you sell the investments or draw the account down. The assets stay in your name. The lender only uses them to calculate what you could sustain.

Tax treatment varies by situation, so consult a qualified professional before you sell anything to fund a purchase.

What Does a Bank Jumbo Quote Built on Assets Actually Contain?

A good quote contains more than a loan amount and a price. It contains a chain of assumptions, and the loan amount is the last link. Most banks show you the end of the chain and leave out the middle.

Here is what sits underneath a typical asset-based jumbo quote:

• The accounts counted. Checking, savings, money market, brokerage, and often retirement accounts.
• A haircut on each account type. This is the percentage of the balance the lender credits.
• Funds netted out first. Down payment, closing costs, and required reserves.
• A depletion period. This is the number of months the net assets are spread across.
• A debt-to-income test. The imputed income goes into a DTI calculation or a residual-income test, and the quote should say which.
• File overlays. Credit score, appraisal, loan size, and reserves still apply on top of the income math.

Home equity is not on that list. Equity in the property you are buying cannot count as an asset for qualifying. The federal ability-to-repay rule lets a lender rely on income, assets, or both, and it excludes the value of the dwelling securing the loan, per the CFPB’s text of 12 CFR 1026.43.

How Does the Formula Work, Step by Step?

The formula is the same sequence at nearly every lender, even though the numbers differ. Across Lendmire’s wholesale network, this is the order that shows up on file after file.

1. List accessible assets. Use documented checking, savings, money market, brokerage, and retirement accounts.

2. Verify them. The lender relies on account statements. The rule requires third-party records that give reasonably reliable evidence for any assets relied on, as laid out in the eCFR text of the same section.

3. Apply haircuts. Each lender decides what percentage of each account counts.

4. Subtract money already spoken for. Down payment, closing costs, and required reserves leave the pool first.

5. Divide by the depletion period. This step moves the result more than any other.

6. Add other income, then test. The total feeds a DTI or residual-income test.

7. Check the rest of the file. Credit, appraisal, loan size, and reserves all still apply.

Here is the divisor effect in plain numbers. This is illustrative math, not a program figure. Say one lender spreads net assets over a period one-third as long as another lender’s. The first lender credits three times the monthly income from identical assets.

That is why a portfolio does not translate directly into a loan size. The divisor and the haircuts drive the result.

Reserves are a separate test. Network programs commonly look for around six months of the housing payment in reserves. A large portfolio can satisfy reserves and still fall short on qualifying income if the income calculation is conservative.

Why Do Two Quotes From the Same Statements Differ?

Two quotes differ because each lender chooses its own inputs. No regulation sets a divisor or a haircut. These are lender policy.

Five inputs explain nearly every gap:

• The depletion period. Shorter periods produce more income.
• Haircuts by asset type. One lender may credit brokerage funds heavily and retirement funds lightly. Another may reverse the emphasis.
• What gets netted out first. Some quotes subtract down payment, closing costs, and reserves. Others show a headline income figure before the subtraction.
• The test applied. DTI and residual income reward different borrowers.
• Whether asset income can stand alone. Some lenders let it be reviewed on its own. Others want it combined with other income.

Do not assume a bigger income number means a stronger quote. A bank may show a higher figure because it left out a deduction a stricter lender takes openly. The quotes are only comparable once you rerun them on the same assumptions.

Bank Portfolio Jumbo or Wholesale Channel: What Does Each Build In?

A portfolio bank holds many of its jumbos on its own books. It writes its own rules, so no single published standard exists. That can work in your favor. A bank that knows your deposits and investments may count them generously.

The tradeoff is narrowness. A bank gives you one rulebook. If that rulebook discounts your retirement funds heavily, you have no second opinion inside that bank.

A broker sees many lenders’ guidelines at once. Lendmire arranges financing through select lenders in its wholesale network. A few of them let asset income stand alone, and a few want it combined. The strictest overlays on account seasoning (how long funds must sit in an account) and entity-held assets can change which quote fits.

Neither channel is automatically better. A bank’s relationship pricing can beat an outside quote on cost. An outside quote can beat a bank on qualifying income. You only learn which is true by comparing the inputs.

Leverage and size differ by program. Asset depletion through select lenders in the network runs up to about 80% LTV on a primary residence, subject to lender guidelines. Network loan amounts run roughly $125,000 to $3,500,000. Individual programs set their own limits, and every file is underwritten individually.

How Do You Compare the Quotes? A Four-Step Method

The method is to normalize the inputs first, then compare the outcomes. Do it in this order.

Step 1: Ask for the breakdown in writing. Request these from each lender:

• the depletion period or divisor;
• the haircut for each asset class, retirement accounts especially;
• whether down payment, closing costs, and reserves are subtracted before the division;
• whether DTI or residual income is the test, and the DTI cap;
• whether only assets in your name count, or trust and entity accounts too;
• loan-size and cash-out limits;
• any account-seasoning rule;
• whether the loan is non-QM, and the prepayment and pricing terms that come with that.

Step 2: Reconstruct the income. Take the quote’s stated qualifying income and work backward. Use your own statements and the lender’s stated haircuts and divisor. If you cannot reproduce the lender’s number, something is missing from the quote.

Step 3: Rerun both on the same assumptions. Give both lenders the same net assets, the same subtraction of closing funds, and the same other income. Compare the resulting qualifying income and loan amount.

Step 4: Compare total cost and fit. Now look at pricing, fees, prepayment terms, and whether the quote is locked or unlocked. A compared estimate should be on the same closing basis. Total cost over the years you plan to hold the loan matters more than the headline figure.

Use this grid to line up two quotes side by side:

Fill in every cell. A blank cell is an unanswered question for the lender.

Side-by-Side Example

Consider a borrower buying a primary residence with one portfolio of brokerage, savings, and retirement accounts. This example is illustrative, with modeled assumptions and no program figures.

Quote A comes from a portfolio bank. It subtracts the down payment, closing costs, and reserves before dividing. It discounts retirement funds heavily and spreads the result over a long period. Qualifying income looks modest.

Quote B comes from a wholesale lender. It shows qualifying income before subtracting closing funds. It credits retirement funds more lightly and uses a shorter period. Qualifying income looks about twice as high as Quote A.

On a first read, Quote B looks far stronger. Then the borrower asks Quote B’s lender to rerun the math with closing funds subtracted. The gap narrows sharply, because the first number overstated the available pool.

Next the borrower reruns Quote A on Quote B’s divisor. Now the two are close, and the decision shifts to cost and fit. Maybe the bank’s relationship pricing wins. Maybe Quote B’s haircut on retirement funds fits this portfolio better.

The lesson: the quote with the highest income figure is not always the one with the best assumptions. Normalize first, then choose.

What Are the Red Flags in a Jumbo Asset Quote?

Some quotes look good only because of an aggressive assumption. Watch for these:

• No breakdown offered. If the lender cannot or will not show the divisor and haircuts, you cannot compare.
• Closing funds not subtracted. The income figure counts dollars you will spend at closing.
• Down payment counted as qualifying assets. A down payment cannot be treated as an asset for the ability-to-repay determination, according to CFS Review’s summary of CFPB guidance.
• Unlocked pricing next to a locked one. The two are not the same offer.
• Conditions buried in fine print. Account retitling, seasoning, or liquidation of certain holdings can change the file between quote and underwriting.
• Fees and prepayment terms omitted. A non-QM loan can carry both.

If two quotes disagree, ask each lender to put its assumptions in writing. Then rerun them on a common basis, as in the method above.

Where Does the General Rule Break?

The framework is common, but several situations bend it.

Retirement accounts. Lenders typically discount them, and some also weigh withdrawal-eligibility rules. Treatment varies by lender, so a quote that counts them generously may come from a lender that will scrutinize them later.

Asset-rich, income-poor. A big portfolio can still produce a thin loan amount. The divisor and haircuts set the ceiling, not the balance.

Non-QM does not mean no repayment test. A non-QM loan must still meet the ability-to-repay rule, and the lender must verify what it relies on. A non-QM loan also lacks the safe harbor that a qualified mortgage carries, as CFS Review explains. Many asset-based programs therefore run a DTI or residual-income test on top of the asset calculation.

Joint applicants. If one applicant’s income or assets are enough, the creditor need not consider the other’s, per the CFPB’s official commentary. Quotes differ on whether they combine both borrowers’ assets.

Entity accounts. Some lenders count only assets in your personal name. Others allow trust or business accounts, subject to program guidelines.

Occupancy changes the whole process. A jumbo on a home you live in is a consumer mortgage, so consumer mortgage disclosure rules apply. A loan on a non-owner-occupied rental, including a short-term rental, is a business-purpose loan and is exempt from those disclosures. Decide which one you are shopping for before you compare anything.

Is Asset Depletion the Right Tool at All?

Sometimes the better fit is a different documentation path. Here is how the main options differ:

Bank statement programs review the file on documented income under the applicable program, subject to lender guidelines. They use 12 months of business or personal statements and apply a lender-specific expense factor to the deposits. On a primary residence, select lenders in the network go up to 90% LTV on a purchase or rate-and-term refinance, with the top of that range reserved for stronger files. Owner-occupied cash-out tops out around 80% LTV, and investment-property cash-out around 75% LTV.

DSCR loans are designed for non-owner-occupied investment properties. Because they are business-purpose investor loans, they are reviewed differently from a standard owner-occupied mortgage. A DSCR loan is reviewed primarily on property-level rental income covering the payment, subject to lender guidelines. Credit is still reviewed, and reserves are typically required.

For rental purchases, DSCR usually fits better than a personal-income jumbo. The complete DSCR loans guide explains how the coverage math works.

If you are weighing several paths at once, Lendmire’s piece Bank Statement vs Asset Depletion vs DSCR for a Low-Income Year walks through the tradeoffs. If business income is the weak point, see Asset Depletion vs Bank Statement Loan When Business Income Is Low.

Key Terms Defined

Asset depletion: An underwriting method that converts liquid assets into a monthly income figure for qualifying.

Divisor (depletion period): The number of months the lender divides your eligible net assets across.

Haircut: The discount a lender applies to an account’s balance, so only part of it counts.

Netting out: Subtracting down payment, closing costs, and reserves from your assets before dividing.

DTI (debt-to-income): Your monthly debts as a share of your qualifying monthly income.

Residual income: The money left each month after debts, used as an alternative to DTI.

Seasoning: How long funds must sit in an account before the lender will count them.

Non-QM: A mortgage that falls outside the standard qualified-mortgage box and follows the lender’s own guidelines.

Consumer mortgage licensing covers 16 states, and every file is underwritten individually by the lender, subject to lender guidelines. A quote is not a commitment to lend.

About Lendmire

Lendmire (NMLS# 2371349), a non-QM mortgage broker serving investors in 41 markets including Washington, D.C., helps structure DSCR scenarios commonly evaluated around a property’s rental income rather than personal income paperwork, subject to lender guidelines. A Scotsman Guide Top Mortgage Workplace in 2025 and 2026, Lendmire places loans through wholesale investor lenders and is not a direct lender.

References

1. CFPB – 12 CFR 1026.43

2. eCFR – 12 CFR 1026.43

3. CFS Review – CFPB Prohibits Considering Down Payments for Non-QMs

4. CFS Review – CFPB Addresses Non-QMs Under Ability-to-Repay Rule