The Quick Read: It depends on the path and the account: on the asset qualifier path, Treasury bills held in a brokerage account count at 100%, while on the asset depletion path they count at 80% as securities unless the lender classifies the bill as a cash equivalent, which counts at 100%, subject to underwriting. The path matters more than the bill itself. A bill that matures and sits as cash is treated as cash.
- Qualifier path: bills in a brokerage account count at 100% toward covering the whole loan. The same bills inside a 401(k) or IRA count at 90% under age 59½ and 100% after.
- Depletion path: plan on 80% for bills held as securities, 100% once they mature into cash, and 70% inside a retirement account.
- Income, not balance: on the depletion path the usable total is divided by 60 months, so the bill’s percentage matters less than the size of the pile.
- Statements decide: lenders count what the statement shows, so maturity dates, face values and ownership need to be clear.
Two Paths, and Why They Give Different Answers
Lendmire arranges asset-based mortgages through select lenders in its wholesale network. Those programs come in two forms, and a borrower is qualified on one at a time. Mixing the two tables can mislead a borrower about how much their bills are worth.
The asset qualifier path uses assets alone. Eligible assets, after the percentages below, must equal or exceed the entire loan amount. No employment or income is documented. Loans run up to $4,000,000, with leverage up to 80% on a purchase and 75% on a refinance of a principal residence or second home, subject to underwriting. Each figure is subject to lender guidelines and a complete review of property type, leverage, and credit.
The asset depletion path turns assets into income. The lender takes usable assets, divides them by 60 months, and treats the result as monthly qualifying income. That income must carry the housing payment and other debts through the debt-to-income test. Loans run from $125,000 to $3,500,000. Leverage goes up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out refinance for a principal residence or second home. On an investment property, the ceilings are 65% on a purchase or rate-and-term refinance and 60% on a cash-out.
If you are reading this because you hold bills and little documented income, you are the intended reader. Retirees, business sellers and people living off a portfolio fit both paths. Which one suits you depends on whether your assets can cover the loan outright.
How Much of Treasury Bills Counts Toward Asset Depletion Income, Path by Path
Bills are not named as their own line on either path, so the lender’s classification does the work. A bill is a government security that matures in one year or less. TreasuryDirect explains that bills are sold at a discount or at par, and you receive face value at maturity. That structure drives how a lender views them.
Here is how Lendmire plans a file around them.
| Holding | Qualifier path | Depletion path |
|---|---|---|
| Bills in a brokerage account | 100% | 80% as securities; 100% if lender calls it cash-like |
| Matured bill, now cash | 100% | 100% |
| Bills in a 401(k) or IRA | 90% under 59½; 100% at 59½+ | 70% at any age |
| Money market fund holding bills | 100% (money market) | Cash account; lender confirms |
| Longer Treasury notes and bonds | 100% in brokerage | 80% as securities |
| Pledged or borrowed bills | Not eligible | Not eligible |
On the qualifier path, the answer is simple. Brokerage balances count in full, and bills in a brokerage account are balances. On the depletion path, the safe planning number is 80%. If the lender’s matrix treats a short-dated bill as a cash equivalent, you get 100%. Ask before you build a plan around the higher figure.
Why Bills Sit Between Cash and Securities
Lenders haircut stocks and funds because prices move. A haircut is the share of a balance the lender will not count. A bill has little price movement, because it matures in a year or less at a known face value. Vanguard’s investor education page describes bills as short-term government bonds used for cash management and for parking money between investments.
That is the argument for cash-like treatment. The argument against it is simpler. A bill sold before maturity trades at a market price, and the statement lists it as a security. Many lenders follow the statement’s label.
And bonds carry real price risk. Expect the securities haircut on them. Do not assume that “government-backed” means “counts like cash.”
Which Value Counts: Face, Price Paid or Market?
Bills are bought below face value, so three numbers can describe one bill. They are the price you paid, the market value today, and the face value you receive at maturity. The gap is small on a short bill. It grows with larger balances and longer terms.
Lendmire’s practice is to plan on the value shown on your most recent statement, not on face value. Agencies handle this differently for their own programs. Fannie Mae’s guidance, for example, values government bonds at purchase price unless the redemption value can be documented. It is a contrast, not a rule for asset-based mortgages, but it shows why clean statements matter. See the Fannie Mae Selling Guide FAQ.
A bill that matures during underwriting becomes cash. If you roll it into a new bill, it goes back to being a security. If you hold bills directly at TreasuryDirect, the account statement shows the holding, so keep those statements handy.
How the Math Runs on the Depletion Path
Start with eligible assets. Apply each percentage. Add them up. Divide by 60 months. The result is monthly qualifying income, and it then runs through the debt-to-income test with the new housing payment and your other debts. Every figure here is illustrative, and the lender’s own calculation governs.
Example one: bills held as securities. Say you hold $1,500,000 in bills in a brokerage account plus $300,000 in cash.
- Bills at 80% = $1,200,000.
- Cash at 100% = $300,000.
- Usable assets = $1,500,000.
- $1,500,000 divided by 60 months = $25,000 of monthly qualifying income.
Example two: the lender treats bills as cash-like. Same holdings, but bills count at 100%.
- Bills at 100% = $1,500,000.
- Cash at 100% = $300,000.
- Usable assets = $1,800,000.
- $1,800,000 divided by 60 months = $30,000 of monthly qualifying income.
The classification moves the answer by $5,000 of monthly income. That is why it is worth a conversation before you apply, not after.
Two minimums apply on this path. Qualified assets must be at least the lesser of $1,000,000 or 1.25 times the loan balance. They must also never fall below $250,000 liquid when asset depletion is your only income source. If asset income only supplements documented income, it can be used up to a 45% debt-to-income ratio. In that case the minimum-assets rule is waived.
How the Math Runs on the Qualifier Path
There is no income calculation here. The question is whether usable assets equal or exceed the whole loan.
Say you want an $800,000 loan and hold $800,000 in bills inside a brokerage account. Brokerage balances count at 100%, so $800,000 of usable assets matches the loan. The file is reviewed on assets alone, subject to underwriting. Compare that with a mixed file: $330,000 in brokerage accounts, $300,000 in a 401(k) under 59½ (90% counts, or $270,000) and $200,000 in savings. That also totals $800,000 of usable assets.
Reserves are not required on this path at or below 75% loan-to-value. Above that, the lender sets them. Credit starts at a 600 minimum score on the qualifier path. The depletion path follows the lender’s score and loan-amount matrix. A first-time investor on the depletion path needs a 700 score.
Seasoning and Paperwork for Bills
“No income documentation” never means “no documentation.” The assets are documented on both paths.
- Qualifier path: 60 days of seasoning, with two months of statements for each qualifying account.
- Depletion path: statements at least 120 days old at application, plus the most recent statement within 45 days. Funds from the sale of a business, an inheritance or a legal settlement are excused from that seasoning.
For bills, the useful documents are brokerage or custody statements showing the security, face value, maturity date and market value. TreasuryDirect statements work if you hold directly. Large recent deposits will draw questions, so keep the source trail.
If you are about to move cash into bills, do it in an account you already hold, and keep both statements. Whether a recent purchase restarts any clock depends on the lender, so confirm first. Cash sitting in a regulated account for months is easier to document than money that just moved.
If the cash came from selling a property, Lendmire’s piece How Asset Depletion Counts Property-Sale Proceeds as Income covers that scenario.
Mistakes and Edge Cases With Treasury Bills
Counting the yield twice. Bills pay no periodic interest. Your return is the gap between price paid and face value. On most files the balance counts once, as an asset, and the yield is not added on top.
Assuming a money market fund equals a bill. A fund that holds bills is typically classed as a money market account, not as bills you own. That can help you, since the qualifier path counts money market at 100%.
Forgetting what leaves the pool. Down payment, closing costs and any required reserves come out of your assets before you count them. The same dollar cannot count twice. If you can choose which assets to spend at closing, spend the ones with the lower percentage and keep the higher-percentage ones for qualifying.
Using borrowed or pledged bills. Pledged and borrowed funds are not published as eligible on either path. Pay off the margin or pledge first.
Confusing this with tax terms. Asset depletion income is a lending calculation. It is unrelated to the tax term “depletion allowance” used for oil and minerals. Tax treatment varies; consult a qualified professional.
Counting ineligible accounts. On the depletion path, custodial accounts, deferred compensation, escrow accounts, foreign funds, cash on hand, stock options and non-vested restricted stock units are not eligible. Cryptocurrency, precious metals and collectibles 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 source reviewed by the lender.
Across Lendmire’s network, the files that stall are rarely about the percentage. They stall on paperwork: a statement 130 days old, an account in a spouse’s name only, or bills sold and repurchased in the middle of the file. Keep holdings still while the file is open.
Which Path Fits Your Bills?
If your bills, savings and brokerage balances together equal the loan, the qualifier path is the cleaner fit. No income is documented, and the full brokerage credit applies. If your assets are large but fall short of the loan amount, the depletion path lets them supplement or replace income, at lower leverage.
The tradeoff is leverage versus convenience. The qualifier path reaches 80% on a purchase, but you need assets that cover the whole loan. The depletion path asks for less in assets but caps a principal residence cash-out at 60%. Leverage, reserves, and pricing vary by lender and program; the final terms follow the full file review.
For investment property, asset depletion is available, but at 65% on a purchase and 60% on a cash-out. A rental purchase you want to qualify on the property itself is a different product. 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. They qualify primarily on property-level rental income covering the payment, subject to lender guidelines. Your bills then matter for liquidity, not income. The complete DSCR loans guide walks through that route.
If you document income with deposits instead, Lendmire’s article on how much of your business income counts toward a mortgage, linked here, covers that alternative. Consumer asset-based lending through Lendmire is available in 16 states: Alabama, California, Colorado, Florida, Georgia, Indiana, Michigan, Montana, New Mexico, North Carolina, Ohio, Pennsylvania, Tennessee, Texas, Virginia and Washington.
Key Terms Defined
Asset qualifier path: a program route that drives lender review on assets alone, with no income documented.
Asset depletion path: a route that divides usable assets by 60 months to create monthly qualifying income.
Haircut: the share of an asset’s balance a lender will not count.
Seasoning: how long funds have sat in an account before the lender counts them.
Cash equivalent: an asset so stable and liquid that a lender treats it like cash.
Face value: the amount a Treasury bill pays at maturity.
Debt-to-income (DTI): your monthly debts, including the new housing payment, compared with your qualifying income.
Frequently Asked Questions
Do Treasury bills count at 100% on the depletion path?
Only if the lender classifies them as a cash equivalent. Otherwise plan on 80%, the securities figure. Once a bill matures and the money sits in a cash account, it counts at 100%. Confirm the classification before you move money, since programs differ and each file is underwritten individually.
Do T-bills inside an IRA or 401(k) count the same as in a taxable account?
No. They follow the retirement-account treatment. On the qualifier path that is 90% under age 59½ and 100% at 59½ or older. On the depletion path it is 70% at any age. The account type usually outranks the asset inside it. Agency guides take a similar view for their own programs, as with Fannie Mae’s retirement account rules.
Does the maturity length of the bill matter?
Yes, it can. A short bill is closest to cash, and a longer bill has more price movement before maturity. Notes and bonds usually take the securities haircut. Whether a lender draws a line by maturity depends on its guidelines, so ask for the classification in writing before you buy.
Can I use my bills for the down payment and still count them?
No. Money used for the down payment, closing costs or reserves comes out of the pool first. Only the remainder counts toward qualifying. If you hold cash and bills, consider spending the asset with the lower percentage first.
Is asset depletion the same as a DSCR loan?
No. Asset depletion is a consumer mortgage that converts your assets into qualifying income. A DSCR loan is a business-purpose investor loan that qualifies primarily on the property’s rent covering its payment, subject to lender guidelines. Some investors use both, with DSCR for rentals and an asset-based loan for a home.
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.
About Lendmire
Lendmire — NMLS# 2371349 — is a mortgage broker that arranges bank statement, P&L-only, 1099-only and asset-based home financing in 16 states through wholesale lenders, on primary residences, second homes and investment properties. Every option is subject to the lender’s guidelines and full underwriting. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
1. TreasuryDirect – Treasury Bills
2. Vanguard – U.S. Treasury Securities
3. Fannie Mae Selling Guide FAQ
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 Much Down Payment Does an Asset Depletion Jumbo Loan Need? · Does an Asset Depletion Loan Require Any Income? · How Lenders Count Assets Toward an Asset Depletion Mortgage
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.