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Asset Depletion

QUICK SUMMARY

Asset depletion treats eligible liquid assets as a source of income by dividing usable assets by a number of months the investor sets. The result is a monthly figure that can support a payment when paycheck income is thin or missing. It is common on non-QM files for retirees, investors, and people with large brokerage or retirement balances. It is not free money, and it is not the same as using assets only for reserves or a down payment.

Sometimes, yes. Asset depletion is a way some loans turn the money you already have into a monthly income figure for qualifying. Instead of asking only what you earn from a job, the underwriter looks at eligible balances in checking, savings, brokerage and sometimes retirement accounts, subtracts what you need to close, and spreads what remains over a set number of months. The result is treated as qualifying income. Most asset depletion loans are non-QM loans, and the rules come from the investor's guide, not from one national standard. Requirements vary by investor and loan structure.

Who asset depletion is for

The borrowers who ask about it usually have real money and a thin paycheck. Common situations:

  • A retiree who lives on savings and has not started Social Security or pension income.
  • A buyer who sold a business or a property and now holds the proceeds in a brokerage account.
  • A household with modest W-2 income and large investment balances, where the W-2 alone does not support the payment.
  • Someone between careers who can document substantial liquid assets but not two years of stable income.

If your income is documented and stable, a standard loan is usually the first thing to check. Asset depletion is a tool for files where the income story does not fit, not a shortcut around documenting the income you have.

How the math works, in plain terms

Every investor sets its own worksheet. The general shape is the same:

  1. Start with eligible account balances, documented with statements.
  2. Apply any reduction the investor requires for certain account types. Retirement and brokerage accounts are often counted at less than face value because of taxes, penalties or market risk. Cash in a bank account is usually counted differently.
  3. Subtract the down payment, closing costs and any reserves the investor requires you to keep.
  4. Divide what remains by the investor's divisor, a number of months, to produce a monthly income figure.
  5. Add that figure to any other documented income and run the debt-to-income ratio.

This article does not print a percentage, a divisor or a minimum balance. Those numbers change by investor and by matrix, and an invented number would mislead you. The worksheet in your file is the number that counts, not a calculation from a social media post.

The rules by layer

  • Federal ability-to-repay rule. For most consumer home loans, Regulation Z requires the lender to make a reasonable, good-faith determination that you can repay, using verified income or assets (12 CFR 1026.43). A non-QM loan does not escape that rule. It just is not using the qualified mortgage safe harbor.
  • Agency loans. Fannie Mae, Freddie Mac, FHA, VA and USDA each have their own asset and income rules. Assets you keep after closing are generally evaluated as reserves, a cushion, rather than turned into income. Ask me how your specific assets would be treated on an agency loan before assuming you need non-QM.
  • Investor guide. On a non-QM asset depletion loan, the investor decides which accounts qualify, the reductions, the divisor, the reserves and the credit and property requirements.

Reserves and depletion are not the same dollars

The same money cannot usually be spent twice in the underwriting story. Money used for the down payment and closing costs comes out first. Money the investor requires you to keep as reserves may also be set aside before the depletion math. Large recent deposits still need a paper trail, the same way they do on any loan (Fannie Mae B3-4.2-02 shows how agency loans handle this, and non-QM investors generally ask similar questions). If you are moving large deposits between accounts, keep the statements that show where the money came from.

Fictional example

Fictional example, not a real borrower: a Fort Worth buyer in her early sixties has a brokerage account and an IRA, a small consulting income, and no pension yet. An agency loan using only the consulting income does not support the payment she wants. An asset depletion worksheet takes her eligible balances, applies the investor's reductions for the IRA and brokerage account, subtracts her down payment, closing costs and required reserves, and divides the rest by the investor's divisor. The result, added to her consulting income, is the qualifying income. Two weeks before closing she moves a large amount from the brokerage account into a new annuity. That changes the account the worksheet counted, so the file has to be reworked. The assets have to still be there, in the form the investor counted, at closing.

Common mistakes

  • Treating the full account balance as usable income without the investor's reductions or divisor. That overstates the number.
  • Confusing asset depletion with reserves. Reserves show a cushion. Depletion creates an income figure.
  • Assuming retirement accounts count the same as cash. Taxes, penalties and access rules affect how they are counted. See using retirement funds.
  • Moving or spending the counted assets between application and closing.
  • Assuming asset depletion replaces credit, appraisal or title requirements. It does not.

What to have ready

  • Recent complete statements for every account you want counted, all pages.
  • Any documentation of other income, even if small.
  • An explanation and paper trail for any large or unusual deposits.
  • Your plan for the down payment and which account it comes from.

If your income is irregular rather than low, compare this with bank statement loans and the broader overview of non-QM loans.

Next step

If you have meaningful savings and a thin income history, the first step is checking whether a standard loan already works, then comparing asset-based options side by side. Book a call and bring your statements, or start an application.

Related questions

Sources

Links checked Oct 21, 2026.

About the author: McKade Lively, NMLS 2704474, American Pacific Mortgage Corporation dba True North Home Loans, NMLS 1850.

Equal Housing Opportunity.

Last reviewed: Oct 2026

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McKade Lively, NMLS #2704474. Equal Housing Opportunity.