True Blue Lending

Non-QM

There's still a loan for you.

Can't show income on your taxes? Write too many expenses off? Self-employed, foreign national, or buying a condotel? Retail lenders pass — we don't.

The short version

Non-QM (non-Qualified Mortgage) loans qualify borrowers using something other than tax-return income — bank statements, profit-and-loss statements, CPA letters, asset balances, or property cash flow. They sit outside the federal Qualified Mortgage box on purpose, which means more documentation flexibility, slightly higher rates, and underwriting that actually fits how self-employed and non-traditional borrowers earn money.

Bank statement loans

12 or 24 months of deposits in lieu of tax returns

For self-employed borrowers whose net taxable income on Schedule C, K-1, or 1120-S does not reflect their actual cash flow. Lender pulls 12 or 24 months of personal or business bank statements, calculates an income figure from average deposits (typically with an expense factor of 25%–50% applied to business accounts), and qualifies the borrower against that number — not against AGI.

Personal bank statement programs use 100% of qualifying deposits. Business bank statement programs apply an expense factor either based on the borrower-attested expense ratio, a CPA-signed letter, or a flat lender-defined percentage by industry. The 24-month version usually prices better than the 12-month version.

This is the single most common non-QM product, and it solves the most common self-employed problem: writing off enough to make a tax bill manageable, then needing to show income to qualify for a mortgage.

Min credit620 (660+ for best pricing)
Max LTV90% purchase, 80% cash-out
Reserves6 months PITI (12 for jumbo)
DTIUp to 50%
Loan amountUp to $4M+
Self-employed history2 years (1 year case-by-case)

Right fit for

  • Sole proprietors and 1099 contractors who write off heavily
  • Business owners with strong gross revenue but low net income on returns
  • Real estate professionals, restaurateurs, contractors, e-commerce operators
  • Anyone whose accountant minimized their tax liability — and minimized their qualifying income with it

Profit & Loss (P&L) loans

CPA-prepared or self-prepared P&L in lieu of returns

Income calculated from a 12- or 24-month profit-and-loss statement instead of tax returns. CPA-prepared P&Ls (signed and dated by a licensed CPA) get the best pricing and the fewest overlays. Self-prepared P&Ls are accepted on some programs but typically require corroborating bank statements and a tighter LTV cap.

The lender uses the net profit figure from the P&L as qualifying income. For business owners who keep clean books mid-year — well before their next tax filing — this is faster and cleaner than a bank statement loan because there is no deposit-to-income calculation to argue about.

Often paired with a bank statement program as a fallback: lender takes whichever method qualifies you for the larger loan.

Min credit660 (CPA-prepared) / 680 (self-prepared)
Max LTV85% purchase, 75% cash-out
Reserves6–12 months PITI
DTIUp to 50%
P&L period12 or 24 months trailing
Self-employed history2 years

Right fit for

  • Borrowers between tax filings who need current-year income recognized
  • Business owners with clean books and a tax-efficient prior-year return
  • Borrowers whose CPA can attest to year-to-date performance

CPA letter loans

CPA attestation in lieu of full returns

A licensed CPA writes a signed letter attesting to the borrower's self-employment, business ownership percentage, length of operation, and net income. The lender qualifies against the income figure stated in the letter — no tax returns or bank statements required for income calculation.

These programs are narrower than bank statement or P&L products and typically sit at lower max LTVs. They're ideal when the borrower's relationship with their CPA is well established and the CPA is willing to put their PTIN behind a signed attestation.

Underwriting will still pull a 4506-C transcript request to confirm filings exist, but the income figure used for DTI is the CPA-letter number.

Min credit680
Max LTV80% purchase, 70% cash-out
Reserves12 months PITI
DTIUp to 50%
CPA license verificationRequired (state board lookup)

Right fit for

  • Long-tenured business owners with established CPA relationships
  • Borrowers who do not want to share full tax returns or bank statements with the lender
  • Cash-businesses where deposit-based income would understate true earnings

Asset depletion / asset utilization

Qualify off liquid assets, not income

Lender divides eligible liquid assets (checking, savings, brokerage, retirement) by a term — typically 60, 84, or 120 months — and treats the result as monthly qualifying income. A $1.2M brokerage account divided by 84 months produces $14,285/month of qualifying income. No employment, no tax returns required for income.

Two variants: pure asset depletion (the divided figure is the only income used) and asset utilization (the divided figure is added to whatever wage or self-employment income the borrower also has). Retirement accounts may be discounted — common haircut is 70% of pre-tax balance for borrowers under 59½.

The right product for retirees, semi-retired professionals, beneficiaries of inheritances or trusts, and high-net-worth borrowers between businesses.

Min credit680
Max LTV80% purchase, 75% cash-out
ReservesEmbedded in the asset calculation
Eligible assetsChecking, savings, brokerage, IRA/401(k)
Amortization term60 / 84 / 120 months (program-dependent)
Retirement haircut70% of pre-tax balance under age 59½

Right fit for

  • Retirees with substantial savings but limited W-2 or 1099 income
  • Trust-fund or inheritance recipients
  • High-net-worth borrowers between liquidity events
  • Buyers using a recent business sale or stock-comp event to fund the purchase

Written VOE only (WVOE)

Verification of Employment in lieu of paystubs and W-2s

For W-2 borrowers whose employer can complete a written Verification of Employment form, but who don't want to (or can't) supply paystubs and W-2s. Lender contacts the employer directly, gets the form back with current income and employment dates, and qualifies off that.

Common for borrowers with privacy concerns, recent income changes the W-2 hasn't caught up to yet, or unusual compensation structures (commission, bonus-heavy, tipped). Some programs allow WVOE-only without paystubs; others require WVOE plus one paystub.

Min credit660
Max LTV80% purchase
Reserves6 months PITI
DTIUp to 50%
Employment history2 years (same employer or same line of work)

Right fit for

  • W-2 borrowers with privacy or HR-disclosure concerns
  • Recently promoted or relocated employees whose prior W-2 understates current income
  • Commission or tip-heavy roles where averaging gets unfair on standard programs

DSCR investment property

Property cash flow qualifies — not your income

Debt Service Coverage Ratio loans qualify the property, not the borrower. Lender calculates DSCR = gross monthly rent ÷ PITIA (principal, interest, taxes, insurance, association dues). Most programs want 1.0 or above — the rent at least covers the payment. True Blue has access to programs that go below 1.0 with rate add-ons.

No personal income documentation, no tax returns, no W-2s, no DTI calculation. Borrower's credit, reserves, and the property's rent are the entire qualification stack. Closes in an LLC or in personal name.

The default product for non-owner-occupied 1–4-unit residential investments and the most-asked-about non-QM program in 2026.

Min credit660 (700+ for best pricing)
Max LTV80% purchase, 75% cash-out
Reserves6 months PITIA per financed property
Min DSCR1.00 (sub-1.0 with overlay)
Loan amount$100K–$3M+
Property types1–4 unit SFR, condo, condotel, short-term rental
VestingLLC or personal name

Right fit for

  • Buy-and-hold landlords scaling beyond conventional Fannie/Freddie limits (10 financed properties)
  • Short-term rental operators (Airbnb / VRBO) using market-rent appraisals
  • Investors who write rental income down on Schedule E and can't qualify on full-doc
  • BRRRR-strategy refinances out of hard money

Foreign national loans

No US credit, no SSN, no problem

For non-US citizens with no US residency status — typically buying second homes, investment properties, or vacation property. No US credit score required; lender pulls an international credit reference (often a letter from the borrower's home-country bank or two trade lines from a credit reference agency).

Documentation centers on the borrower's passport, a US-bank-account-balance letter, and proof of funds for the down payment and reserves seasoned in a US institution. Some programs allow seasoning in a recognized foreign bank.

These are typically priced 1.5–2.5 points above prime jumbo and require larger down payments and reserves than US-citizen jumbo loans.

CreditNo US credit required; international reference accepted
Max LTV70% purchase (75% case-by-case)
Reserves12 months PITIA, US-seasoned
Down payment30% minimum
VestingPersonal name or US LLC
Eligible visa statusNone required (true non-resident programs)

Right fit for

  • Foreign investors buying South Florida or California vacation property
  • Latin American and European nationals diversifying into US real estate
  • Foreign-owned LLCs purchasing investment property

ITIN borrower loans

Mortgages for borrowers with an Individual Taxpayer Identification Number

ITIN loans serve borrowers who file US taxes under an Individual Taxpayer Identification Number instead of a Social Security Number. Most often these are non-resident workers, foreign business owners with US income, or residents in non-traditional immigration status.

Documentation pattern matches a standard self-employed or W-2 file (returns or paystubs/W-2s) but with an ITIN in place of an SSN. Lender pulls an alternative credit report — typically a 12-month rental history plus 3 trade lines (utility, cell phone, insurance).

These programs are originated through specialty wholesale lenders. True Blue has placement in this channel; most retail banks do not.

Min credit620 traditional or alt-credit (3 trade lines)
Max LTV85% purchase, 80% rate-and-term refi
Reserves3–6 months PITI
DTIUp to 50%
DocumentationTax returns (or P&L / bank statements as alt-doc)

Right fit for

  • Long-time US residents without SSN who pay taxes via ITIN
  • Mixed-status households where the qualifying borrower files via ITIN
  • Self-employed ITIN borrowers using bank statement or P&L variants

Condotel & non-warrantable condo loans

When Fannie says no, the wholesale lender says how much down

A non-warrantable condo is any condominium project that fails one or more agency warrantability tests — too many investor-owned units, ongoing litigation, single-entity ownership above 10%, hotel-like services, short-term rental operations, or commercial space above the agency cap. A condotel is a specific subset: a condominium operated like a hotel, often with on-site front desk, daily rentals, and revenue-share programs.

Both fall outside Fannie/Freddie eligibility, which is why retail lenders decline them. Non-QM specialty programs underwrite the borrower and the project separately and do close them — at higher rates and tighter LTVs than warrantable-condo conventional pricing.

Common in South Florida (Miami Beach, Sunny Isles, Brickell), the Florida Keys, and resort markets where the entire project is a condotel by design.

Min credit680
Max LTV70% second home, 65% investment
Reserves12 months PITIA
Project reviewLimited / non-warrantable accepted
Property typesCondotels, non-warrantable condos, condo-hotels

Right fit for

  • South Florida beachfront condotel purchases
  • Buyers of units in projects with active rental programs
  • Refinances of condotels currently held free-and-clear

Frequently asked

What people ask before they apply.

Plain-English answers to the questions we hear most often on non-QM scenarios. Have one we missed? Call (707) 583-3666.

What is a non-QM loan?

A non-QM (non-Qualified Mortgage) loan is any mortgage that does not meet the federal Qualified Mortgage definition under the CFPB's Ability-to-Repay rule (12 CFR §1026.43). Non-QM lenders still verify ability to repay — they just do it using documentation other than the QM-standard tax returns, paystubs, and W-2s. Bank statements, P&Ls, asset balances, and property cash flow are all acceptable income-verification methods on non-QM programs.

What's the difference between QM and non-QM?

Qualified Mortgage (QM) loans meet a specific set of CFPB criteria — verified income via tax returns or W-2s, DTI under 43% (or QM Patch equivalents), no risky features like negative amortization or interest-only beyond the QM safe harbor, and points-and-fees inside the QM cap. Non-QM loans can break one or more of those rules — they may use alternative income docs, allow higher DTI, allow interest-only, or carry higher fees — provided the lender still documents the borrower's ability to repay.

What is the Ability-to-Repay (ATR) rule?

The Ability-to-Repay rule (Dodd-Frank, 2014) requires every residential mortgage lender to make a reasonable, good-faith determination that the borrower can repay the loan. The rule does not dictate which documents prove that — it dictates that some reasonable proof must exist and must be in the file. Bank statements, P&Ls, and asset depletion calculations all satisfy ATR even though they do not satisfy QM.

Why use a non-QM loan instead of a conventional or FHA loan?

Use a non-QM loan when your tax returns understate your real cash flow (most self-employed borrowers), when you don't have US credit (foreign national), when you file under an ITIN, when you're buying a property type the agencies won't finance (condotel, non-warrantable condo, short-term rental), or when you're scaling investment property beyond the 10-financed-property Fannie limit. If your scenario fits a QM box, take the QM loan — pricing is better. If it does not, non-QM is the door that's still open.

How much higher are non-QM rates?

Typically 0.75% to 2.5% above comparable conventional or jumbo pricing, depending on program, LTV, credit, and documentation type. Bank statement loans and DSCR loans price tightest; foreign national and condotel loans price widest. The premium reflects the absence of agency take-out and the higher reserve requirements lenders hold against these loans.

What documents do non-QM lenders ask for?

Always: photo ID, asset statements (most recent two months), credit authorization, purchase contract or refinance subject-property data. Income docs depend on program: 12 or 24 months of bank statements, a 12 or 24-month P&L, a CPA letter, brokerage statements for asset depletion, written VOE, or signed leases for DSCR. We send a tailored document checklist after the initial scenario review — no wasted requests.

Can I close a non-QM loan in an LLC?

DSCR loans, foreign national loans, and most investment-purpose non-QM programs allow LLC vesting. Owner-occupied non-QM (bank statement, P&L, asset depletion on a primary residence) closes in personal name. The vesting question is usually answered by occupancy, not by program.

Are non-QM loans regulated?

Yes. Non-QM lenders are subject to the same federal consumer-protection rules as QM lenders — TRID disclosure, RESPA, ECOA, HMDA, and the Ability-to-Repay rule itself. They are also state-licensed under the SAFE Act and report to NMLS. The "non-QM" label refers to one specific CFPB safe-harbor designation, not to whether the loan is regulated.

Authoritative sources

Where the rules come from.

Independent references for everything claimed on this page. We cite primary sources so you can verify before you decide.

CFPB — Ability-to-Repay & Qualified Mortgage rule

Federal rule defining QM and the broader ATR requirement non-QM loans satisfy.

CFPB — What is a Qualified Mortgage?

Plain-English consumer explainer.

IRS — Self-employed individuals tax center

Authoritative reference for self-employment tax treatment that drives non-QM income calculations.

IRS — Individual Taxpayer Identification Number (ITIN)

Eligibility and application path for borrowers using an ITIN in place of an SSN.

NMLS Consumer Access

Verify any loan officer or lender's license — including True Blue Lending (NMLS #2380218).

Ready when you are

Tell us the scenario.

Twenty minutes, no credit pull, real answers about which non-QM program fits — or whether you should just take the QM loan instead. We'll tell you either way.

Prefer to talk first? Call (707) 583-3666