The Quick Read: There is no published reserve count for a loan this size, so the number is set file by file, on review, before the file is submitted. The standard ladder in Lendmire’s wholesale network runs 3 months to $500,000, 6 months to $1,500,000 and 9 months above that, and an eight-figure file sits at or beyond the top of it. Reserves are counted in months of the full housing payment, after cash to close is deducted. Plan for liquidity well above the down payment.
- The top published tier is 9 months, and a $15 million file is reviewed case by case on top of it.
- A $15 million loan is above the $6,000,000 portfolio non-QM program. It falls to the bank portfolio jumbo program, which carries twelve-month-statement files to $30,000,000 on its own ladder.
- Cash-out proceeds cannot count toward reserves on super-jumbo files.
- Retirement accounts count at 70% of value (80% at age 59.5 or older). Business funds, gifts and cryptocurrency never count.
- Each additional financed property adds 2 months, to a 12-month maximum. First-time investors are held to 12 months.
All figures here run through select wholesale programs, subject to full underwriting. None is a commitment to lend.
Key Terms Defined
Reserves: liquid assets left in your name after closing, measured in months of the housing payment.
PITIA: the full monthly housing payment: principal, interest, taxes, insurance and association dues.
Funds to close: the down payment, closing costs and prepaids. These come out of your assets before reserves are counted.
Liquid assets: cash and near-cash you can document today. Home equity and business value are not liquid assets.
Seasoning: how long funds have sat in an account, which tells the lender they are yours and not borrowed.
Super-jumbo overlays: the tighter rules that apply above $3,500,000 on a primary residence and $3,000,000 on a second home or investment property.
Why Is There No Single Number?
No federal rule sets a reserve count. The federal consumer-finance regulator’s repayment-capacity compliance guide lists eight factors a lender must consider. The first is income or assets. Reserves are not on the list, and the guide says lenders must verify what they rely on using reliable third-party records. That leaves each program to set its own month count, and Scotsman Guide’s non-QM coverage names post-close reserves as a program variable, along with which asset types may be used.
That matches what the brokerage sees across the network. Two programs rarely ask for the same thing. One wants 9 months and counts only cash. Another wants fewer months but haircuts everything that isn’t cash. At $15 million, the answer is never a number you can read off a chart. It is a conversation about your balance sheet.
How Is the Month Count Built?
The network’s ladder is simple at the low end and open-ended at the top. Here is how the pieces stack on files through select wholesale programs.
| Loan size or profile | Typical reserve requirement |
|---|---|
| Up to $500,000 | 3 months |
| Up to $1,500,000 | 6 months |
| Above $1,500,000 | 9 months |
| Each additional financed property | Add 2 months, 12-month cap |
| First-time investor | 12 months |
| Above $4,000,000 | Case-by-case review before submission |
Read that table the way a processor would. The 9-month tier is a floor for large files, not a ceiling for them. Once a file crosses $4,000,000, the figure is reviewed individually, and on a $15 million balance the reviewer is looking at the whole picture: credit, leverage, occupancy, other debts and the quality of the assets.
Credit and overlays matter too. Above the super-jumbo line, the credit floor is 700, with a 0x30x24 housing history and 48-month seasoning on any credit event. Those overlays do not change the month count directly, but a thinner file in one area tends to draw a harder look at liquidity.
Where Does a $15 Million File Actually Sit?
The $6,000,000 ceiling on the portfolio non-QM program means a $15 million loan is not a standard-ladder file at all. It moves to the bank portfolio jumbo program. That program uses twelve months of statements and its own size ladder. Its reserve months are not part of the published parameters, so the honest answer is that the count is set on review.
Leverage on that program tells you how much equity is in the deal. On review, a primary residence in the $10M-$20M band runs about 55% on a purchase and 50% on a cash-out. On a second home or investment property, the same band runs about 50% on a purchase and 45% on a cash-out. Those are ceilings, not promises. At a 55% purchase, you are already bringing close to half the price as a down payment, and reserves come on top of that, not out of it.
Picture a buyer purchasing a $15 million primary residence at the 55% ceiling. The down payment is the first claim on liquid assets. Closing costs and prepaids are the second. Reserves are measured only on what remains, and the reviewer sets the month count against a payment that is very large. Even a modest month count turns into a big cushion.
Is the Income Test Separate From the Reserve Test?
Yes, and mixing them up is the most common planning error on these files. Business statements need at least 25% ownership. Eligible deposits are totaled and divided by the statement months, after an expense ratio. The fixed expense ratios vary with the size and type of the business, with a lower ratio for a service business with no employees and higher ratios for businesses with employees or any product business. An accountant-provided ratio is another route. Transfers from your own business into a personal account count in full.
The reserve test is a different document set. It uses recent asset statements, not the deposit history. Scotsman Guide describes 12-24 months of statements as one of several tools in non-QM lending, alongside profit-and-loss statements and asset-based qualification. For a founder or physician, the pattern is common: deposits prove income easily, and the reserve statements are where the file gets tight, because income and liquidity are different things.
There are also asset-based routes. An asset allowance divides liquid assets by 36, 60 or 84 months. At 84 months it works as a standalone path or on any loan above $3,500,000, on primary and second homes at up to 80%. An assets-only path needs U.S. liquid assets equal to the loan plus costs. Whichever path you take, the same dollars cannot be counted twice.
What Counts Toward Reserves?
Cash counts cleanest. The rest is haircut or excluded. Across the network, the treatment looks like this.
| Asset | Treatment |
|---|---|
| Cash in checking or savings | Counts in full once documented |
| Retirement accounts | 70% of value (80% at 59.5+) |
| Business funds | Do not count |
| Gift funds | Do not count |
| Cryptocurrency | Does not count |
| Unvested stock | Does not count |
| Cash-out proceeds | Cannot satisfy reserves at super-jumbo levels |
| Trust assets | Only a revocable living trust |
Illiquid wealth is the trap. A borrower can have a very large net worth in real estate equity and business value and still come up short, because none of that is liquid. Lenders do not count borrowed funds either. A home-equity advance parked in checking raises both seasoning and borrowing questions.
How Does the Waterfall Work?
Think of it as three steps, in order.
1. Start with documented liquid assets, valued the way the program values them.
2. Subtract funds to close: down payment, closing costs and prepaids.
3. Compare what is left to the required months of PITIA. The difference is a surplus or a shortfall.
Run the numbers on a borrower with plenty of liquidity on paper. Most of it is in a brokerage account and a retirement account, and some sits in the operating company. The business money drops out. The retirement balance comes in at 70% or 80%. The remainder has to cover the down payment before reserves are even measured. This is why a borrower who “has” far more than the loan can still be short on reserves.
What If the File Comes Up Short?
A shortfall has four common fixes, and the brokerage tries them in roughly this order.
- Move liquid assets in early. Funds need to be documented and seasoned. Last-minute transfers between accounts raise sourcing questions.
- Lower the loan amount. A bigger down payment cuts the payment, which cuts the dollar reserve requirement, but it also eats liquidity. Test both sides.
- Change the program or occupancy. A second home or investment property runs about five points lower on leverage at every size, which makes the equity requirement larger, so it rarely helps liquidity.
- Shift the qualification path. A borrower with deep liquid assets may fit the asset allowance or assets-only route instead of deposits.
Another option is a rental-based structure. A rental investor with strong property cash flow might compare a bank statement file with a DSCR loan, which qualifies primarily on property-level rental income covering the payment, subject to lender guidelines. Reserve treatment differs between the two. Lendmire’s piece Bank Statement vs DSCR Loan Reserves on a Jumbo Purchase walks through that comparison, and the complete DSCR loans guide covers the rental-income side.
What Documents Prove Reserves?
Clean documentation is where files stall, not the month count. Gather these before submission.
- Two or more consecutive months of statements for every account used for reserves, all pages, with the account holder’s name showing.
- A written explanation and paper trail for any large deposit or recent balance jump.
- Statements from the borrower personally. On loans vested in an LLC, reserves are tested on the guarantor, per program requirements.
- For retirement accounts, the most recent statement showing the vested balance.
- The 12 or 24 consecutive months of bank statements for the income test, kept separate from the reserve file.
Transaction histories never substitute for statements. Skipped months break the consecutive requirement.
Mistakes That Break Reserve Verification
Four patterns show up again and again. First, counting the same dollars as both down payment and reserves. Second, commingled personal and business funds, where the lender cannot tell which balance is yours. Third, stale statements that expire while the file is under review. Fourth, assuming a big cash-out check can cover reserves. At the top tiers it cannot.
One more is worth naming. Tax treatment can depend on how the funds are used and how the property is held; investors should keep clear records and speak with a qualified tax professional before relying on any deduction.
This is also a market with real volume behind it. Scotsman Guide reported bank statement loans at about 37% of non-QM locks in one recent January, citing Optimal Blue. These are mainstream products. The reserve question is a planning question, not a red flag.
Frequently Asked Questions
Do retirement funds count toward reserves on a $15 million loan?
Yes, at a discount. Through select wholesale programs, retirement accounts count at 70% of their value, or 80% at age 59.5 or older. The value must be vested and documented with a recent statement. Business funds, gifts and cryptocurrency do not count at all.
Can I borrow money to meet the reserve requirement?
Generally no. Lenders want reserves that are yours and seasoned. A home-equity advance sitting in checking raises borrowing and seasoning issues, and cash-out proceeds cannot satisfy reserves on super-jumbo files in the network.
Does my down payment count as reserves?
No. Reserves are what remains after the down payment, closing costs and prepaids are deducted. The same dollar cannot be counted twice. At a 55% purchase ceiling on a primary residence in this size band, the down payment alone takes a large share of liquid assets.
Do other financed properties change the count?
Yes. The network’s ladder adds 2 months for each additional financed property, up to a 12-month maximum. At this loan size, the reviewer also looks at the full portfolio, and the final count is set on review.
Is the 9-month tier enough for a $15 million loan?
It is the starting point, not the answer. Above $4,000,000 every file is reviewed case by case before submission, and the bank portfolio jumbo program that carries $15 million files sets its own ladder. Expect the top of the scale or beyond it, subject to underwriting.
Next Step
Lendmire’s piece How Many Months of Reserves Does a Bank Statement Loan Require? covers the smaller-balance ladder in more detail. Consumer lending runs in 16 states: AL, CA, CO, FL, GA, IN, MI, MT, NM, NC, OH, PA, TN, TX, VA and WA.
For current guidelines and terms, see Lendmire’s super jumbo bank statement loan programs page.
Lendmire’s self-employed mortgages page presents both super jumbo programs, bank statement and DSCR, side by side.
About Lendmire
As a non-QM mortgage broker (NMLS# 2371349), Lendmire facilitates DSCR investor loans across 41 markets, including Washington, D.C. DSCR eligibility is generally reviewed around property-level rental income instead of personal income documentation, subject to lender guidelines, serving LLC-structured portfolios and self-employed borrowers who don’t fit conventional boxes. A two-time Scotsman Guide Top Mortgage Workplace (2025, 2026).
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References
1. CFPB ATR/QM Compliance Guide
2. Scotsman Guide: Are We Ready for Non-QM Lending
3. Scotsman Guide: Helping borrowers fit the boxes
4. Scotsman Guide: Non-QM momentum cools
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: Bank Statement Loan vs Asset Depletion Loan for Actors · How to Pick Personal Bank Statement Months on a Super Jumbo Loan · Bank Statement Loan vs Asset Depletion Loan for Attorneys
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.