You are worth considerably more than the house you are trying to buy. The statement in your hand proves it.
And you were declined, because a brokerage account with seven figures in it is not "income," you have no employer for anyone to call, and the last two years of tax returns show dividends and capital gains rather than a salary. You were told, politely, to sell some positions and come back with a bigger down payment. Which would trigger a tax bill you have spent years structuring around.
Asset based lending converts a portfolio into qualifying income without requiring you to sell anything, liquidate a position, or show employment. The mechanic is plain arithmetic: qualifying assets divided by 84 months, and the result is treated as monthly income.
The part that catches people is that "qualifying assets" is not your account balance. Each asset class takes a haircut first, and knowing the haircut before you shop is the difference between a comfortable approval and a short conversation.
The haircut schedule
From CMG Financial's Non-QM Sharp Series guidelines (NMLS #1820, revised 09/21/2026), net assets are multiplied by these percentages:
- 100% of checking, savings and money market accounts
- 100% of life insurance or annuity cash surrender value
- 80% of the remaining value of stocks, bonds and mutual funds
- 70% of all vested retirement assets
- 60% of current valuation of Bitcoin or other cryptocurrency
That crypto line is newer than most borrowers expect, and it comes with conditions: the file must document ownership, and the valuation must be sourced exclusively from Coinbase and dated within 30 days of the note date.
Proceeds from a sale count too. Sale of real estate owned is permitted with a copy of the final closing disclosure and evidence the funds were deposited. Sale of a business asset works with the final settlement statement and the same deposit evidence. Trust assets must fully meet Fannie Mae guidelines.
Two programs, and the difference matters
These are frequently talked about as one thing. They are not.
Asset Depletion turns the assets into income and then runs a standard debt-to-income ratio. Qualifying assets divided by 84 months becomes your qualifying income, and your file has to pass the DTI limit for whichever program tier it sits in.
Asset Qualifier does not use DTI at all. It divides qualifying assets by 84 months, subtracts your total monthly debt obligations, and the remainder is your residual income, which must meet or exceed the program's residual income requirement. The guidelines are explicit that you do not impute tax deductions when calculating it.
Both are designed to satisfy the ability-to-repay requirement, which is why one uses a ratio and the other uses a residual test. Neither is a loophole.
The thresholds
There are hard floors, and they are not small:
- $450,000 minimum in qualifying assets across both programs.
- For Asset Depletion specifically, you need the lesser of $1,000,000 in qualifying assets or qualifying assets of at least 125% of the original loan amount.
- For Asset Qualifier, total post-closing assets must be at least 125% of the original loan amount.
- Assets used to qualify must be seasoned 120 days unless pre-approved by the investor.
That 125% post-closing requirement is the one that reshapes plans. It is measured after closing, which means after your down payment and costs have left the account.
The sequencing mistake
Here is the rule that costs people houses, stated plainly in the guidelines: if assets or a portion of assets are being used for down payment or costs to close, those assets are excluded from the balance before the portfolio is analyzed for income qualification. Funds for closing should be liquidated and documented.
So the money you are about to spend on the purchase does not also generate your qualifying income. Put $600,000 down out of a $2,000,000 portfolio and the depletion calculation runs on what remains, after haircuts, not on the $2,000,000.
Decide the down payment and the qualifying strategy together. Do them in the wrong order and you watch your approval shrink after you have already committed.
What you give up
Asset based qualification is exclusive. A borrower using Asset Depletion or Asset Qualifier cannot use other sources of employment income. Non-employment income is considered case by case. You are choosing this lane, not adding it to another one.
Several things are not permitted on these programs: non-owner occupied and second homes, cash-out, gift funds, business assets, foreign assets, and a non-occupant co-borrower. Reserves are not required, which is a genuine benefit, and it makes sense given the asset test already proves liquidity.
Program tier matters too. Asset Depletion, Asset Qualifier, third-party P&L and written verification of employment are not eligible on the Sharp Standard tier at all. They run on the Expanded and Premium tiers.
Who this is really for
The retiree with a large brokerage account and no W-2. The founder after a liquidity event, sitting on proceeds with no current salary. The family office buyer whose income statement looks thin and whose balance sheet does not. In Scottsdale, that is a substantial share of the luxury market, and it is why a file that gets declined on income can be straightforward on assets.
Why bring this file to us
- We run the haircuts, not the balances. The number that matters is qualifying assets after the schedule is applied, and it is meaningfully lower than your statement total.
- We sequence the down payment. Money used to close comes out of the pool before the calculation runs, which is the single most common surprise on these files.
- We know when asset depletion is the wrong tool. If you have documentable income, full documentation usually prices better. We compare both.
- Broker model. Multiple investors rather than one bank's shelf, which is what a file like this needs when the first answer is no.
- You talk to the principal. Ricky Khamis is President of EPiQ Lending, NMLS #173141, lending in Arizona since 1999. Direct line: (480) 999-9842.
EPiQ Lending is NMLS #1936984, at 7975 N. Hayden Road, Suite A-101 in Scottsdale. Verify all of it before you trust any of it: Ricky's EPiQ Lending profile, the Scottsdale branch, and the license itself at NMLS Consumer Access. Hold every lender to that standard, including us.
Send me a current statement set and I will run the depletion math before you decide how much house the portfolio actually supports.
Program figures in this post are from the CMG Financial (NMLS #1820) guideline set named above, as published on the revision date given. They describe one investor's program at one point in time. Other investors price and underwrite the same borrower differently, guidelines change without notice, and nothing here is an offer of any specific program or terms. Confirm current eligibility on your own file before you plan around any of it.
Equal Housing Opportunity. This is general information, not a commitment to lend or an offer to extend credit. Rates, terms, and program guidelines change and depend on credit approval, property appraisal, income and asset verification, and other qualifying factors. Not all applicants will qualify. Non-QM, asset-based and business purpose financing carry different pricing, terms and consumer protections than agency financing. Consult your tax advisor regarding the tax treatment of any income or distribution strategy.
Find out which documentation option qualifies you for the most
Bank statements, a third-party P&L and full documentation routinely produce very different qualifying income from the same business. Tell me the shape of yours and I will run all three.
