Your net worth is real and it is complicated. Some of it sits in a family trust. Some arrived through an estate. Some is in a wallet.
And every lender you speak to either does not ask the right questions about it or asks them in week four.
Here is how each category is actually treated, from CMG Financial's Non-QM Sharp Series guidelines (NMLS #1820, revised 09/21/2026).
Trust assets
Within the qualifying asset list for the asset based programs, alongside checking, savings and money market accounts counted at 100%:
Trust assets must fully meet FNMA guidelines.
That is the standard, and it is a real standard rather than a formality. In practice it means the trust documentation has to establish that the assets are genuinely available to the borrower: who the trustee is, who the beneficiary is, what the distribution provisions say, and whether the borrower actually controls the assets or merely benefits from them at someone else's discretion.
A revocable living trust where you are grantor, trustee and beneficiary is the common case and is generally workable, because you control the assets.
A trust with an independent trustee and discretionary distributions is a harder conversation, because the question is whether the money is yours or whether someone else decides.
The practical move is to produce the trust document early and let it be read, rather than assuming a balance on a statement settles the question. Trust files that fail usually fail on control, and control is visible in the document from day one.
Worth noting a related restriction elsewhere in these program families: physician program guidelines list non-revocable trusts, life estates, guardianships and land trusts other than an Illinois land trust among ineligible borrowers. Titling is not a neutral detail across mortgage programs.
Inherited property, and the buyout provision
This is the section most people have never heard of, and it solves a very common family situation.
Refinances of inherited properties and properties legally awarded to the borrower, including DSCR loans, are allowed. This includes divorce, separation and dissolution of a domestic partnership. Seasoning requirements do not apply, and the following must be met:
- A written agreement signed by all parties stating the terms of the buyout and property transfer must be obtained
- Equity owners must be paid through the subject loan's settlement
- The subject property has cleared probate, and the property is vested in the borrower's name
- Current appraised value is used to determine loan-to-value
Take those one at a time, because each solves a real problem.
Seasoning does not apply. Normally a cash-out requires six or more months of ownership. On an inherited property buyout it does not. You do not wait half a year to buy your siblings out.
Current appraised value is used. Not the value at date of death, not the price you are paying your co-heirs. The current appraisal. If the house appreciated, that works in your favour on leverage.
Equity owners must be paid through settlement. The money goes to your siblings through the closing, not from you privately afterward. Structure it that way from the start.
Probate must be cleared and title vested in your name. This is the gate, and it is the one with a timeline you do not control. Start the estate work early, because the loan cannot outrun it.
The same provision covers divorce, separation and dissolution of a domestic partnership, which is the other common buyout. Same four conditions, same waiver of seasoning.
Cryptocurrency
Counted, at a discount, with documentation that is unusually specific:
60% of the borrower's current valuation from Bitcoin or other cryptocurrencies.
- The loan file must include documentation proving ownership of the crypto assets
- The current valuation must be sourced exclusively from Coinbase, and the valuation must be dated within 30 days of the note date
Three things follow.
Sixty percent is the steepest haircut on the schedule. Compare: 100% for checking, savings, money market, life insurance and annuity cash surrender value; 80% for stocks, bonds and mutual funds; 70% for vested retirement. Crypto is counted at 60%.
The valuation source is named. Exclusively Coinbase. Not a wallet screenshot, not an aggregator, not the exchange you actually use. If your holdings sit elsewhere, plan for how a Coinbase-sourced valuation will be produced.
The window is 30 days from the note date. So the valuation cannot be obtained at application and reused at closing if the file runs long. Expect to refresh it, and expect the number to move.
For a borrower with meaningful crypto exposure, there is an obvious alternative worth pricing: converting a portion to cash before the 120 day seasoning clock starts, where it counts at 100% rather than 60%. That is a tax conversation as much as a mortgage one, and it should involve your accountant. But the arithmetic difference is large enough to be worth the conversation.
What is never counted
Across the asset based programs:
- Business assets are not permitted
- Foreign assets are not permitted
- Gift funds are not permitted
The first two catch people with complex holdings constantly. Money in an operating entity, a holding company, or an account outside the United States does not count, however clearly it is yours.
If a distribution to personal accounts is possible, the timing of that distribution becomes part of the mortgage plan. Note the 120 day seasoning requirement on assets used for qualifying, unless pre-approved by the investor.
Documented sales that do count
Two specific inclusions worth knowing:
Sale of real estate owned, with a copy of the final closing disclosure and evidence of funds deposited.
Sale of a business asset, with the final settlement statement and evidence of funds deposited.
Both require the same two things: the document and the deposit evidence. Organize them at the start.
The numbers these feed
Asset depletion: qualifying assets divided by 84 months becomes monthly income, then a debt-to-income test. Asset requirement: the lesser of $1 million in qualifying assets or 125% of the original loan amount.
Asset qualifier: qualifying assets divided by 84, minus total monthly debt, produces residual income against a floor of $1,500 for one person, $2,500 for two, plus $150 per additional household member. Asset requirement: total post-closing assets of at least 125% of the original loan amount.
Both: $450,000 minimum in qualifying assets, 120 day seasoning, maximum 85% loan-to-value, minimum 700 FICO, no reserves required, owner occupied only, no cash-out, no other employment income, and not eligible on the Sharp Standard tier.
And before you calculate anything: assets used for down payment or costs to close must be excluded from the balance before analyzing the portfolio for income qualification.
What to gather first
- The trust document, in full, not a summary page.
- For an inherited property: the probate status, the written buyout agreement signed by all parties, and confirmation of how title is currently vested.
- For crypto: ownership documentation and a plan for a Coinbase-sourced valuation within 30 days of the note date.
- For any entity-held funds: a decision on whether and when they are distributed personally.
- A list of every account by type, so the haircuts can be applied correctly.
Common questions
Do assets in a trust count toward qualifying? They can. Trust assets must fully meet Fannie Mae guidelines, which in practice turns on whether the trust documentation shows the assets are genuinely available to and controlled by the borrower.
Can I refinance a house I inherited to buy out my siblings? Yes. Refinances of inherited properties and properties legally awarded to the borrower are allowed, including on DSCR loans, and seasoning requirements do not apply.
What does an inherited property buyout require? A written agreement signed by all parties stating the terms, equity owners paid through the subject loan's settlement, probate cleared with title vested in your name, and current appraised value used to determine loan-to-value.
Does cryptocurrency count as a qualifying asset? Yes, at 60% of current valuation. The file must document ownership, and the valuation must be sourced exclusively from Coinbase and dated within 30 days of the note date.
Do assets held overseas or in my company count? No. Foreign assets and business assets are both excluded from qualifying assets on these programs.
Does the same provision cover divorce? Yes. The buyout provision expressly covers divorce, separation and dissolution of a domestic partnership under the same four conditions.
Related reading
- Asset based and no-income home loans, the full index for this topic
- Asset Based Home Loan FAQ: Qualifying With Assets Instead of Income
- Asset Depletion or Asset Qualifier: Two Programs, Two Completely Different Tests
- After the Business Sale: Buying a Home in the Year You Have No Income
Why bring this file to us
- We look at how assets are titled, not just what they are worth. Trust, entity or personal changes whether a balance counts at all.
- We know the inherited property provision, including that seasoning requirements do not apply to it.
- We document crypto to the exact standard, which names one valuation source and a thirty day window.
- 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 and a Certified Mortgage Planner, NMLS #173141, originating mortgages 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 list of what you hold and how it is titled. Titling decides more of this than balance does, and it is fixable when we find it early.
Program figures in this post come from the CMG Financial (NMLS #1820) guideline set named above, as published on the revision date given. CMG Financial is the parent company of EPiQ Lending. These figures 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.
