The Quick Read: It depends on the path, because no fixed dollar minimum exists. On the asset qualifier path, eligible assets must equal or exceed the entire loan amount, and on the asset depletion path the assets must total at least the lesser of $1,000,000 or 1.25 times the loan, never below $250,000 liquid when assets are the only income source.
- Asset qualifier path: usable assets after the credit percentages must cover the whole loan, and no income is documented.
- Asset depletion path: usable assets divided by 60 months become qualifying income that runs through the debt-to-income test.
- A borrower is qualified on one path at a time, never a blend of the two.
- Both paths document the assets with statements. “No income” never means “no documentation.”
- These are program ceilings and floors through select programs, subject to underwriting. They are not offers.
A retiree in Asheville, Wilmington or Cary often looks the same on paper: a seven-figure balance sheet and a tax return that shows very little. A conventional underwriter sees the thin income line and stops. An asset-based mortgage reads the balance sheet instead. Lendmire arranges these consumer loans for North Carolina borrowers as a broker, placing files with select lenders in its wholesale network.
Which Path Fits a Retiree?
Pick the path by asking one question: can your assets cover the whole loan, or do they need to become income? If the answer is the whole loan, the asset qualifier path fits. If you want to keep some leverage and still hold a large portfolio, the asset depletion path fits.
On the asset qualifier path, the loan is qualified on assets alone. Eligible assets, after the credit percentages below, must equal or exceed the entire loan amount. No employment or income is documented. Leverage runs up to 80% loan-to-value on a purchase and 75% on a refinance, on a principal residence or second home. Loan amounts go up to $4,000,000, subject to underwriting.
On the asset depletion path, usable assets divided by 60 months produce a monthly qualifying income. That income must carry the full housing payment and your other debts through the debt-to-income test. Loan amounts run from $125,000 to $3,500,000.
Across the wholesale network, the qualifier path suits a retiree with a large, liquid, mostly cash-and-brokerage balance sheet buying a modest-to-mid-priced home. The depletion path suits someone with a bigger portfolio who wants more flexibility on price and wants to keep assets invested.
What Counts, and at What Percentage?
Each path applies different credit to each account type. Do not mix the two tables. Here is how they compare.
| Asset type | Qualifier path | Depletion path |
|---|---|---|
| Brokerage accounts | 100% | Securities 80% |
| Cash, savings, money market | 100% | Cash accounts 100% |
| Certificates of deposit | 100% | 100% |
| 401(k) and IRA | 90% under 59½; 100% at 59½ or older | 70% at any age |
| Private stock | Not published | 75% |
| Real-estate equity | Not published | 60% |
On the qualifier path, accounts combine. On the depletion path, several account types are not eligible at all: custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options, non-vested restricted stock units, and funds from non-regulated financial companies.
Cryptocurrency, precious metals, collectibles, pledged or borrowed funds, and business accounts beyond your ownership share are not published as eligible on either path. The documented route is converting them to a seasoned cash balance in a regulated account, with the lender reviewing the source. Cash-out proceeds never count as qualifying assets on the depletion path.
Worked Example: Qualifier Path
This is illustrative. The lender’s own calculation governs.
Say a retiree is seeking an $800,000 loan. The balance sheet holds $330,000 in brokerage accounts, $300,000 in a 401(k) and $200,000 in savings. The retiree is under 59½.
- Brokerage at 100%: $330,000.
- 401(k) at 90% under 59½: $270,000.
- Savings at 100%: $200,000.
Total usable assets: $800,000. That equals the loan, so the file is reviewed on assets alone, subject to underwriting. At 59½ or older, the same 401(k) counts at 100%, so the cushion grows. No reserves are required at or below 75% loan-to-value. Above that, the lender sets them.
Worked Example: Depletion Path
Again, this is illustrative.
Picture a household with $1,500,000 in securities and $300,000 in cash.
- Securities at 80%: $1,200,000.
- Cash at 100%: $300,000.
Usable assets: $1,500,000. Divided by 60 months, that is $25,000 of monthly qualifying income. That figure then carries the housing payment and other debts through the debt-to-income test. Taxes, insurance and any HOA dues sit inside that payment, so a coastal home with higher insurance needs more qualifying income than a Piedmont home at the same price.
Reverse Your Own Number
No page can hand you one asset figure, but you can work backward from a target home.
1. Pick a purchase price and the leverage you want. Purchases run up to 80% on either path for a principal residence or second home, subject to underwriting. 2. On the qualifier path, the loan amount is the asset target. Add your cash to close, because the down payment and closing costs come from assets too. 3. Apply the credit percentages to each account. A 401(k) under 59½ gives up 10% on this path. 4. On the depletion path, multiply the monthly income you need by 60. That is the usable-asset total required. Then check it against the minimum: the lesser of $1,000,000 or 1.25 times the loan, never below $250,000 liquid if assets are your only income. 5. Compare the result with your haircut balance sheet. A shortfall means a lower price, more leverage on the other path, or converting assets to seasoned cash.
Working backward shows why the depletion path asks for more total assets than the headline loan size suggests. The 60-month divisor and the haircuts both work against you.
Seasoning and Statements
Statements are where files stall. Both paths document the assets.
On the qualifier path, funds need 60 days of seasoning, with 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 on the depletion path.
A retiree selling a house in another state to relocate to North Carolina should sequence it. Proceeds that land in a regulated account and season properly count. Proceeds moved between accounts the week before application create questions.
Credit, Age and Couples
The qualifier path publishes a 600 minimum score. The depletion path follows the lender’s score and loan-amount matrix, and a first-time investor on that path needs 700. Housing history is 0x30x12, though one 30-day late in the last twelve months is considered case by case. Multiple bankruptcies are not eligible, and a housing event needs 4 years of seasoning on the depletion path.
Age matters mainly at 59½. Under that line, retirement balances count at 90% on the qualifier path. At or above it, they count at 100%. On the depletion path, retirement accounts count at 70% at any age.
For couples, accounts combine on the qualifier path, but the lender reviews who holds each account. Ownership documentation should be clean before the file goes in.
Asset-derived income can also supplement documented income, such as Social Security or a pension, up to a 45% debt-to-income ratio. When it supplements, the minimum-assets rule is waived.
Can a DSCR Loan Do This Instead?
Yes, if the home is a rental. A DSCR loan is reviewed primarily on property-level rental income covering the payment, subject to lender guidelines, so personal income is not the test. The CFPB’s Regulation Z commentary treats credit for a non-owner-occupied rental as business purpose, and the owner expecting to occupy it for more than 14 days in the coming year breaks that treatment. So a retirement home you plan to live in does not fit.
For a rental, your assets matter as down payment, closing costs and post-closing reserves, not as qualifying income. Lendmire’s complete DSCR loans guide covers how that product is built. The two products answer different questions. DSCR asks whether the rental pays for itself. The asset paths ask whether you can repay from what you own.
The depletion path also reaches investment property, at up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out, subject to underwriting. That is lower than a primary residence at 80%.
Why the Regulatory Frame Matters Here
The asset paths are consumer mortgages. Under 12 CFR 1026.43, a creditor must consider the borrower’s current or reasonably expected income or assets and verify them with third-party records. That is why statements carry so much weight. The CFPB’s ATR/QM compliance guide lists income or assets among the factors and sets no fixed debt-to-income or residual-income threshold. No regulator publishes a minimum asset number. The figure comes from lender policy, which is why the programs above differ from one another.
Tax treatment varies; consult a qualified professional.
Common Mistakes
- Counting home equity on the qualifier path. It is not published as eligible there.
- Spending the down payment from the same dollars you counted as qualifying assets.
- Letting a statement go stale past the 120-day or 45-day marks on the depletion path.
- Moving large sums between accounts right before applying.
- Assuming a 401(k) counts at full value on the depletion path. It counts at 70%.
- Treating “no income documented” as “no documentation.”
Key Terms Defined
Asset qualifier: a path where eligible assets must equal or exceed the whole loan, with no income documented.
Asset depletion: a path that divides usable assets by 60 months to create monthly qualifying income.
Haircut: the share of an account’s balance that is discounted before it counts.
Seasoning: the time funds must sit in an account before they count.
Debt-to-income test: the comparison of monthly debts, including the housing payment, with qualifying income.
Frequently Asked Questions
Is there a minimum asset amount for a retiree buying without employment income?
Not on the qualifier path, where the rule is that usable assets must cover the entire loan. On the depletion path, the minimum is the lesser of $1,000,000 or 1.25 times the loan, and never below $250,000 liquid when assets are the only income source. Both are subject to underwriting.
Can I use my IRA or 401(k)?
Yes, with different credit. On the qualifier path, balances count at 90% under 59½ and 100% at 59½ or older. On the depletion path they count at 70% at any age. You do not have to withdraw the funds to count them, subject to lender review.
Do I need reserves after closing?
On the qualifier path, none are required at or below 75% loan-to-value, and above that the lender sets them. The depletion path has no published reserve months. Keeping liquidity outside the qualifying pool is still sensible.
Can I buy a second home or a rental this way?
A second home is reviewed on either path. Investment property is reached on the depletion path only, at lower leverage. A pure rental purchase often fits a DSCR loan better, which looks at rent coverage rather than your assets.
Does the loan amount change the path?
Yes. The qualifier path runs to $4,000,000. The depletion path runs from $125,000 to $3,500,000. Check which range fits your target price.
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. Reach the team at 828-256-2183 or request a quote at Lendmire’s quote page. For a related read, see Lendmire’s piece How a Bank Statement Lender Turns Assets Into Income for a Retiree.
Lendmire’s asset-based mortgage in North Carolina page presents the program for North Carolina borrowers.
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
1. CFPB Regulation Z §1026.3, Exempt Transactions
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 Big Can an Assets-Only Mortgage Be? · How to Open a HELOC on Assets Alone as a Retiree · How Much of a Roth IRA Counts Toward Asset Depletion Income?
Guides: Asset-Based Mortgage in North Carolina
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.