The Quick Read: No, not on the asset qualifier path itself, because private shares are not among the assets that path credits, though through select programs the asset depletion path does count them at 75% of the balance, subject to underwriting.
- Asset qualifier path: eligible assets must cover the entire loan, and private stock is not on the eligible list.
- Asset depletion path: private stock counts at 75%, and the lender turns the usable total into monthly qualifying income.
- Private shares are illiquid, so they never help with a required liquid-asset floor.
- Selling the shares and seasoning the cash turns private equity into the strongest kind of qualifying asset.
- Every figure here is a typical ceiling or floor from select programs, not an offer.
Many people hold most of their wealth in a company they own part of, and the question comes up constantly. The answer depends on which path the file runs on. The two paths treat the same shares very differently.
The Two Paths, in Plain English
The asset qualifier path asks one question: do your eligible assets, after the credit percentages, equal or exceed the whole loan? If yes, no employment or income gets documented. The assets are the qualification.
The asset depletion path works differently. The lender adds up your usable assets, divides the total by 60 months, and treats the result as monthly income. That income then runs through the debt-to-income test, which compares your monthly debts to your income.
A borrower is reviewed on one path at a time. Mixing the two tables is a common mistake in this conversation, so every figure below names its path.
Does Private Company Stock Count? Path by Path
On the asset qualifier path, no. The credited assets are brokerage accounts, certificates of deposit, money market and savings at 100%. Retirement accounts count at 90% under age 59½ and 100% at 59½ or older. Private company shares are not on that list. Across our wholesale network, plenty of programs also leave private stock out entirely, even on depletion-style products, so do not assume it counts anywhere without confirming.
On the asset depletion path, yes, at 75%. Through select programs, private stock is credited at 75% of the balance. Compare that with cash and certificates of deposit at 100%, securities at 80%, retirement accounts at 70%, and real-estate equity at 60%. Private stock lands in the middle of the pack.
The reason for the discount is simple. A private share has no daily market price and no ready buyer. Its value is whatever the lender can reasonably support, so the program haircuts it.
| Asset type | Asset qualifier path | Asset depletion path |
|---|---|---|
| Cash, savings, CDs | 100% | 100% |
| Brokerage, securities | 100% | 80% |
| Private company stock | Not on the list | 75% |
| Retirement accounts | 90% under 59½, 100% after | 70% at any age |
| Real-estate equity | Not on the list | 60% |
| Stock options, non-vested RSUs | Not on the list | Not eligible |
Crypto, precious metals, collectibles and business accounts beyond your ownership share are not published as eligible on either path. The documented route for those is converting them to a seasoned cash balance in a regulated account, with the source reviewed by the lender.
Why Private Shares Get Treated Differently
Four things make private stock harder than a brokerage balance.
- Valuation. Nobody posts a closing price. A figure has to come from somewhere, and the lender decides what it will accept.
- Transfer limits. Private shares often carry restrictions on who can buy them and when.
- Liquidity. You cannot sell them on a Tuesday afternoon.
- Verification. A brokerage statement proves itself. A private ownership record takes more work to confirm.
Finance professors know this problem well. NYU Stern’s Aswath Damodaran discusses the illiquidity discount applied to private companies, and he also questions how solid the research behind it is. The takeaway is that private value is soft. A fixed haircut like 75% is the program’s way of dealing with that softness, and it is a lending rule, not a valuation opinion.
The Math on the Depletion Path
Run the numbers on a borrower with $1,000,000 in private company stock and $750,000 in cash. This is an illustration, and the lender’s own calculation governs.
- Private stock at 75% counts $750,000.
- Cash at 100% counts $750,000.
- Usable assets total $1,500,000.
- Divided by 60 months, that is $25,000 of monthly qualifying income.
That income then has to carry the housing payment and other debts through the debt-to-income test. The depletion path also has minimums: qualified assets of at least the lesser of $1,000,000 or 1.25 times the loan balance. When depletion is your only income source, you also need no less than $250,000 liquid. Private shares are not liquid. In this example the $750,000 in cash clears that floor easily. A borrower with $1,500,000 in private stock and almost no cash would not.
Now run the same borrower on the qualifier path. The private stock counts zero, and only the cash counts. The $750,000 in cash covers a loan up to that amount, so the borrower can only use this path for a smaller loan.
What a Lender Reviews on Private Stock
Expect more paperwork than a brokerage statement requires. Under select programs, the lender typically reviews the assets on these points.
- Proof you own the shares and in what form.
- Evidence supporting the value being claimed.
- Any transfer, resale or lockup restrictions.
- How the shares are held, directly or through an entity or trust.
Held through a business, the shares can run into a second exclusion. Business accounts beyond your ownership share are not published as eligible. The lender’s review decides how that is treated, so raise it early.
Statement timing matters too. On the depletion path, statements must be 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. On the qualifier path the rule is 60 days of seasoning and two months of statements per qualifying account.
What If You Sell Some of the Shares?
Selling changes the picture. Once the proceeds sit in a regulated bank or brokerage account, they are cash or securities. Cash counts at 100% on both paths. Brokerage balances count at 100% on the qualifier path and 80% on the depletion path.
Sale-of-business proceeds are excused from the 120-day seasoning rule on the depletion path. The source is still documented and reviewed. Tax treatment varies; consult a qualified professional before you sell.
Two honest notes. First, converting 100% of a stake may cost you more than the 25% haircut you were looking to avoid. Second, a tender offer, buyback or IPO may or may not be on your timeline. The shares only become cash when a real transaction happens. Plan around that, not around a rumor.
Selling also touches the question of what to do with your other assets. If you are weighing whether to sell investments to fund reserves, see Lendmire’s piece Do You Have to Liquidate Assets to Reserve an Asset Qualifier Mortgage?.
The Regulatory Frame, Briefly
Nothing in federal law bars private stock. The CFPB’s ability-to-repay rule lets a creditor rest repayment ability on income, on assets other than the home securing the loan, or both. The creditor verifies what it relies on, using third-party records. The Federal Register rulemaking says the same about verified and documented information.
So the exclusion or haircut is a program choice. Each investor-backed program decides which assets it trusts and how much credit each gets.
Which Path Fits a Private-Equity-Heavy Borrower?
Start with how much of your wealth is liquid.
1. Large cash and brokerage balances, loan no bigger than those assets. The qualifier path fits. No income is documented, and your private stock simply sits outside the file.
2. Meaningful liquid assets plus private stock, and you want the equity to help. The depletion path fits, with private stock at 75%.
3. Mostly private equity, little liquidity. Neither path works well today. Selling a portion, waiting for a liquidity event or documenting income through a different program may be the practical route.
4. You also earn documented income. Asset-derived income can supplement it up to a 45% debt-to-income ratio, and the minimum-assets rule is waived when it does.
Leverage differs by path too. On the qualifier path, a purchase goes up to 80% loan-to-value and a refinance up to 75%, on a principal residence or second home. On the depletion path, a principal residence or second home goes up to 80% on a purchase or rate-and-term refinance and 60% on a cash-out. An investment property on that path goes up to 65% on a purchase or rate-and-term refinance and 60% on a cash-out. Cash-out proceeds never count as qualifying assets. Loan amounts run up to $4,000,000 on the qualifier path and $125,000 to $3,500,000 on the depletion path.
If you are buying a rental and the rent covers the payment, a DSCR loan may fit better than either asset path, because it qualifies primarily on property-level rental income, subject to lender guidelines. Your complete picture is covered in Lendmire’s complete DSCR loans guide. If you document income through deposits instead, read Lendmire’s comparison of an asset qualifier mortgage and a bank statement mortgage.
Common Mistakes
- Counting private stock on the qualifier path. It is not on the list. Check which path your file runs on.
- Assuming a big net worth qualifies. Programs count verified, accessible assets, not net worth.
- Forgetting the liquidity floor. The $250,000 liquid minimum on the depletion path cannot be met with private shares.
- Moving money right before applying. Large deposits need sourcing, and seasoning clocks start over.
- Double-counting. Assets used for the down payment, closing costs or reserves are not also available to qualify.
- Presenting private equity as liquid. Lenders see through it, and it slows the file.
- Skipping the credit side. The qualifier path has a 600 minimum score. The depletion path follows the lender’s matrix, and a first-time investor on that path needs 700. Housing history of 0x30x12 is the standard, with one 30-day late in the last twelve months considered case by case.
Key Terms Defined
Asset qualifier path: the route where eligible assets, after credit percentages, must cover the entire loan amount, with no income documented.
Asset depletion path: the route where usable assets divided by 60 months become qualifying monthly income.
Haircut: the share of an asset’s balance a program does not count, such as 25% off private stock.
Seasoning: how long funds must have sat in an account before they count.
Debt-to-income (DTI): your monthly debts divided by your monthly income.
Illiquid: hard to sell quickly at a known price.
Frequently Asked Questions
Do vested RSUs from a private company count?
Not directly. Non-vested restricted stock units and stock options are not eligible on the depletion path, and neither appears on the qualifier path. Vested shares you hold may be reviewed as private stock on the depletion path at 75%, subject to the lender’s review of ownership and transfer restrictions.
What if my company is about to go public?
Until it happens, the shares are still private. Once they are public, vested and sitting in a regulated brokerage account, they are treated like other securities: 100% on the qualifier path and 80% on the depletion path. Anticipated value does not count.
Can founder shares count?
On the depletion path, founder shares can be reviewed as private stock at 75%, subject to underwriting. How the shares are held, directly or through an entity, affects the review. On the qualifier path they do not count.
Do private shares help with reserves?
No. Reserves and closing funds need to be liquid and documented. On the qualifier path, no reserves are required at or below 75% loan-to-value. Above that the lender sets them.
Does my stock have to be sold or pledged?
Not as a general rule on the depletion path, where the shares are counted as owned. Pledged or borrowed funds are not published as eligible, so shares you have pledged elsewhere need a conversation first. Whether a program asks for more depends on the lender.
Next Step
Lendmire is a mortgage broker, and its consumer lending is licensed in 16 states. It places asset-based files with select lenders in its wholesale network. 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.
Programs change, and every file is underwritten individually, so treat the figures here as typical ranges, not commitments to lend.
About Lendmire
Lendmire (NMLS# 2371349) is a mortgage brokerage serving self-employed and high-net-worth borrowers in 16 states. Bank statement, P&L-only, 1099-only and asset-based mortgages are arranged through wholesale lending channels; Lendmire brokers the financing and the lender underwrites each application. Scotsman Guide named Lendmire a Top Mortgage Workplace in both 2025 and 2026.
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References
1. Damodaran, Private Company Valuations
3. Federal Register: Ability-to-Repay and Qualified Mortgage Standards
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 Asset Qualifier Mortgage Loan Limits Work · Asset Qualifier vs Asset Depletion for a Cash-Out Refinance · How to Qualify for an Asset Qualifier Mortgage
Brandon Miller
Founder & CEO, Mortgage Loan Originator, Lendmire LLC
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Important disclosures. Lendmire (NMLS# 2371349) is a licensed mortgage brokerage. Lendmire is not a direct lender, depository institution, or financial advisor. All loan inquiries are subject to lender underwriting; this article does not constitute a commitment to lend. Rates, terms, and program guidelines are subject to change without notice and vary by borrower profile, property type, and state. Information in this article is general in nature and is not financial, legal, or tax advice. Equal Housing Opportunity. NMLS Consumer Access: nmlsconsumeraccess.org.