Non-QM loans are defined as home loans that do not comply with the specific rules and prohibitions set by the Consumer Financial Protection Bureau (CFPB) for Qualified Mortgages. While QM standards were designed to provide safer loans, their strict requirements can unintentionally exclude highly solvent borrowers whose finances do not fit the conventional mold. Such loans fit borrowers with pristine credit and a strong financial profile.
Key Indicators of Borrower Quality:
The primary driver for high-credit, high-asset individuals utilizing Non-QM loans is often the inability to verify income using the standardized documentation (W-2s, pay stubs, tax returns) required for QM loans.
1. Self-Employed and Gig Economy Workers
High-income self-employed individuals, independent contractors, entrepreneurs, and small business owners frequently rely on Non-QM financing.
2. High-Asset, Limited Income Borrowers (Asset Qualifiers)
Retired professionals and high-net-worth individuals often have substantial investment portfolios but little or no verifiable monthly income via traditional sources.
A financially strong borrower may seek a Non-QM loan because they desire specific loan features that are explicitly prohibited or restricted under QM rules.
| Feature | QM Restriction | Non-QM Allowance |
| Interest-Only (IO) Payments | QM loans cannot have risky loan features such as interest-only payments. | IO loans are common Non-QM features, often sought by prime borrowers. IO loans can help manage retirement cash flow. |
| High Debt-to-Income (DTI) Ratio | QM loans generally require the borrower’s DTI ratio to be 43% or less. | Non-QM loans often allow higher DTI ratios, typically limited to 50%, or even up to 55% in certain premium programs. |
| Loan Size (Jumbo Loans) | Conforming QM loans are constrained by GSE loan limits. | Non-QM loans have no loan limit caps. Jumbo loan borrowers often rely on Non-QM products. For example, some programs offer loans up to $5,000,000. |
| Loan Term | QM loans cannot have terms beyond 30 years. | Non-QM products may offer 40-year fixed terms or 40-year fixed interest-only options. |
Even with pristine credit, using a Non-QM program means adhering to certain risk mitigation criteria set by the lender:
Non-QM loans typically have higher interest rates than comparable QM loans, which compensates the lender for the perceived risk associated with the flexible underwriting. In 2024, the average initial 30-year interest rate for Non-QM loans was 6.7%, compared to 6.4% for qualified mortgages.
Non-QM loans have shown historically low delinquency rates, comparable to those of QM loans. For loans originated in 2023, both Non-QM and QM loans remained at the lowest levels since at least 2001, both at 0.3%.
Lenders generally compensate for the risks associated with limited documentation or high DTI ratios by focusing on borrowers with higher credit scores and lower Loan-to-Value (LTV) ratios.
Self-employed borrowers who utilize significant tax write-offs can qualify using 12 or 24 months of their personal or business bank statements to document their actual cash flow, rather than their low taxable income reported on tax returns.
Qualified Mortgages (QM) typically limit the borrower’s DTI ratio to 43% or less. In contrast, Non-QM programs often allow borrowers to carry higher levels of debt, typically up to 50% of their total monthly income.
Interest-only (IO) payments are explicitly prohibited under the Dodd-Frank Act’s mandates for Qualified Mortgages. IO loans accounted for 17% of the reasons Non-QM loans did not meet QM standards in 2024.
The Asset Depletion mortgage, also known as an Asset Qualifier loan, calculates an imputed monthly income using the borrower’s savings, investments, and retirement accounts for qualifying purposes.
These borrowers often need Non-QM solutions because their portfolio-based income is difficult to verify under traditional lending guidelines, which rely on W-2s, tax returns, or employment verification. Non-QM loans are specifically designed for borrowers with significant assets but limited income.
In 2024, the average credit score for Non-QM borrowers was 776, which is comparable to the 781 average for conventional QM borrowers.
Prime non-QM borrowers are individuals with pristine credit and substantial assets or income who are seeking specific loan features, such as interest-only payments or a DTI limit above the standard 43%. These borrowers may have significant income or assets but do not meet the stringent underwriting standards of Qualified Mortgages (QM).
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