Freddie Mac's New Assets as Income Rule, and Why You Don't Have to Wait for 2027

A lead reached out recently who had found me in an unusual way. He asked ChatGPT which lenders were already using Freddie Mac's new assets as income guideline, rather than waiting for the mandatory date.

That is a specific question from someone who had clearly read the bulletin and understood that the rule is optional now and required later. It also tells you something about where this sits: the change is real enough that people are searching for lenders who have implemented it, and there are few enough of them to make the search worth running.

So here is what actually changed, what it produces, and why the lender you pick matters more than usual for the next several months.

What Freddie Mac changed

Bulletin 2026-10, issued August 5, 2026, rewrites Guide Section 5307.1. The industry calls this asset depletion. Freddie calls it using accumulated assets as qualifying income. Same idea: convert documented savings, brokerage, and retirement balances into monthly qualifying income when a borrower does not have conventional employment income to show.

Four changes matter more than the rest.

The division factor dropped from 240 months to 180. Net eligible assets are divided by that number to produce monthly qualifying income. Going from 240 to 180 produces roughly a third more income from identical assets.

The age 62 requirement is gone. The prior rule required at least one borrower who owned the account to be 62 or older before depository and securities accounts could be used. That restriction is removed entirely.

The 80 percent LTV cap is gone. The method previously capped LTV, TLTV, and HTLTV at 80 percent regardless of what the underlying loan would otherwise allow. Maximum ratios now follow standard requirements.

Investment properties are eligible. The old language limited this to one and two unit primary residences and second homes. All occupancy types now qualify.

It is mandatory for settlement dates on or after February 3, 2027. Sellers may implement immediately.

The math

The divisor change is the headline and it is simple arithmetic.

Net eligible assets divided by 180 rather than 240:

• $600,000 produces $3,333 a month, up from $2,500
• $900,000 produces $5,000 a month, up from $3,750
• $1,500,000 produces $8,333 a month, up from $6,250
• $1,800,000 produces $10,000 a month, up from $7,500

Roughly 33 percent more qualifying income in every case, without the borrower earning another dollar, selling an investment, or increasing a retirement distribution.

One important caveat before anyone runs their own numbers. Net eligible assets are not your account balance. The lender first subtracts funds needed to close, borrowed funds, gift funds, and any portion pledged as collateral elsewhere, then applies the account eligibility tests below. The divisor applies to what survives that process.

Who this newly reaches

The age change is the one that expands the pool most, and it gets less attention than the divisor.

Under the old rule, a 55 year old with a seven figure brokerage account could not use it. A 48 year old who sold a business and was living off the proceeds could not use it. Their wealth was real and documented and sitting in exactly the kind of account the program contemplates, and the guideline said no because of their age.

That restriction is gone for depository and securities accounts. Retirement assets never carried an age condition in the first place.

The people this opens up:

• Early retirees who left work before 62 and are living on savings
• Business owners who sold and are between ventures
• Financially independent borrowers whose assets substantially exceed their reported income
• Younger investors with significant brokerage holdings and modest W-2 income
• Anyone whose tax returns understate their real position but who has the balances to demonstrate capacity

Combined with the removal of the 80 percent LTV cap, a borrower in this category can now put less down than the method previously allowed.

The guardrails

Freddie did not simply loosen this. The bulletin adds real documentation requirements alongside the expansions.

• Minimum $30,000 in net eligible assets. A floor that did not previously exist.
• LPA Accept required. The loan must be an Accept Mortgage, so there is no manual underwriting path. In practice this is rarely the binding constraint, since manually underwritten conventional loans are uncommon to begin with.
• Purchase or no cash out refinance only. A true cash out refinance cannot use this method.
• 12 months of seasoning on depository and securities accounts, unless the account was funded from a documented eligible source such as a retirement transfer, a lump sum distribution, or proceeds from the sale of a business or real property.
• The 20 percent balance tests. An account whose balance dropped more than 20 percent over 12 months is ineligible, unless the decrease is documented as a transfer into securities or retirement. An account that grew more than 20 percent is capped at 120 percent of the balance from 12 months prior, with carve outs for documented transfers, lump sum distributions, and business or property sale proceeds.
• Third party verification reports required for depository and securities accounts.
• Business sale proceeds must have been held in the account for at least 90 days as of the current statement.

The balance variation tests are the ones most likely to surprise someone. An investor who moved a large sum between accounts, or whose portfolio had a strong year, can find the eligible amount capped in ways the raw balance does not suggest.

How this compares to Fannie Mae

Worth knowing, because a borrower shopping two conventional quotes may be getting very different answers depending on which agency the lender is using.

Fannie Mae's version counts employment related assets. An ordinary taxable brokerage account generally does not qualify, which knocks out a large share of the borrowers this method is meant to serve. Fannie also divides by the amortization term, so a 30 year loan divides by 360, and it subtracts required reserves before the calculation.

Freddie counts a wider set of accounts, including ordinary depository and securities balances, and now divides by 180.

On a borrower with a $900,000 IRA and a $400,000 brokerage account, those two rulebooks produce dramatically different qualifying income. Fannie excludes the brokerage account entirely and divides the remainder by 360. Freddie counts both and divides by 180.

That is not a small difference in emphasis. It is frequently the difference between approved and declined on the same file.

How this compares to non-QM

Here is where I want to be straight rather than promotional, because this is the actual decision most borrowers in this position face.

I have offered asset depletion through non-QM lenders for years, and the shortest of those programs go down to 60 months, a third of Freddie's timeline. On qualifying power alone, non-QM still wins.

What Freddie's version wins on is pricing. This is a conventional loan. It prices like a conventional loan, which is meaningfully better than any non-QM program.

So the framework is straightforward:

If the Freddie calculation qualifies you for what you want to buy, use it. Better rate, lower cost, and no reason to pay a non-QM premium for qualifying power you do not need.

If it falls short, non-QM buys you more qualifying income at a price. That tradeoff is often worth making, and it is the reason those programs exist.

If you are close, the gap is worth measuring rather than guessing. The difference between a conventional rate and a non-QM rate over the life of a loan is substantial enough that clearing the Freddie threshold, even barely, is usually the better outcome.

The only way to know which applies is to run both.

Why the lender matters right now

This is the part the lead who found me had already worked out.

The rule is optional until February 3, 2027. Some lenders implemented it within weeks of the bulletin. Others will wait until they are required to. Both are legitimate business decisions, and neither is visible from the outside.

What it means practically is that between now and February, the qualifying calculation available to you depends on which lender you are working with rather than on the guideline itself. The same borrower, the same assets, the same property can produce a 240 divisor at one lender and a 180 divisor at another.

More than ten of the wholesale lenders I work with have confirmed they have already implemented it, with no overlays on top of the Freddie guideline. That is not a permanent advantage. In February it evaporates, because everyone will have it.

It is a temporary one, and this is a case where working across many lenders rather than one produces a concrete difference in the number rather than a theoretical one.

When this is not your answer

The honest counterweight, because a post about a favorable rule change should say where it does not apply.

• When you need a cash out refinance. The method covers purchases and no cash out refinances only. If pulling equity is the goal, this is not the path.
• When your assets are below the floor. The new $30,000 minimum is modest, but it exists, and it applies to net eligible assets rather than gross balances.
• When your accounts fail the seasoning or variation tests. Recently funded accounts, or accounts with large swings in either direction, can be ineligible or capped regardless of the balance.
• When you have documentable income that qualifies you anyway. If standard income documentation works, use it. Asset depletion exists for borrowers where it does not, not as an upgrade.
• When you are buying a rental. Investment properties are now eligible, but a DSCR loan qualifies on the property's rent and ignores your personal picture entirely. That is usually cleaner for an investor.
• When your assets are the only thing holding the file together. Qualifying and affording are different questions. A calculation that produces $10,000 a month of theoretical income does not mean drawing $10,000 a month is a good plan.

What to do with this

If you have substantial assets and income that does not reflect your actual financial position, the calculation available to you changed materially last month, and it may have changed in your favor by about a third.

Two things worth doing. Find out what your net eligible assets actually are after the deductions and the account tests, since that number is usually lower than the balance and occasionally much lower. And find out whether the lender you are talking to has implemented the new guideline, because until February that question has a real answer that affects your approval.

The payment calculator will get you close on what a given qualifying income supports. The rest depends on the specific accounts and how they document.