Behind The Non-QM Numbers: How Experienced Originators Choose The Right Income-Documentation Path – NMP Skip to main content

Behind The Non-QM Numbers: How Experienced Originators Choose The Right Income-Documentation Path

Oct 30, 2026
Behind the Non-QM Numbers
Senior Vice President and Residential Lending Manager, North American Savings Bank

How choosing the right income-documentation method upfront can help originators avoid costly delays, underwriting setbacks, and missed opportunities in Non-QM lending

The Non-QM segment has recently entered a new phase of growth. According to an August 11, 2026, article in National Mortgage Professional, Optimal Blue reports that non-qualified mortgages accounted for more than 10% of total lock volume in July 2026, up 1.4 percentage points from June and 2 percentage points from July 2025.

This growth can be attributed to several factors, most notably the rise in self-employment and alternative income sources, as well as the high-interest-rate environment. But the key question in most Non-QM files isn’t whether the borrower qualifies. It’s which Non-QM product most accurately tells that borrower’s income story. Get that wrong, and viable files could get declined or repriced unnecessarily. Get it right, and borrowers who would likely get turned away by conventional lenders can move smoothly into closing.

The most important piece is how the originator interviews the potential borrower. The right questions on that first phone call — whether the borrower is self-employed, how long they’ve been self-employed, and how their income is generated — are what determine the product fit. There are many variables that go into choosing the right Non-QM product. A borrower might qualify for a bank statement loan, a 1099 loan, or a profit and loss loan. The real question is which product fits their specific scenario.

Self-Employed Is Not The Only Non-QM Borrower Type

While a majority of Non-QM loans issued are bank statement loans — designed to help self-employed borrowers obtain a loan using 12-24 months of personal or business bank statements — bank statement loan locks account for only 33% of total Non-QM locks, according to an April 14, 2026, Scotsman Guide article. At North American Savings Bank (NASB), bank statement loans make up around 35% of Non-QM production. The types of self-employed professions can vary greatly:

  • A consultant with 1099s and predictable annual income
  • A restaurant owner with seasonal cycles and large cash deposits
  • Owner of a tech company taking a small salary but having large distributions
  • A real estate investor with LLC income and property cash flow
  • A private practice health professional whose business revenue fluctuates
  • High-earning gig economy workers reporting income on a 1099

While all of these borrowers fall under the “self-employed” umbrella, each requires a different qualification approach. For a bank statement loan, lenders typically review at least the most recent 12 months of personal or business bank statements to verify income. The growth in self-employment since the pandemic has expanded the pool of borrowers who benefit from this approach, helping fuel the continued rise in Non-QM lending. 

Other self-employed borrowers may be better served by alternative documentation products, such as a 1099 loan. Other self-employed borrowers may be better served by alternative documentation products. A 1099 loan offers a more streamlined qualification process and relies primarily on the borrower's most recent 1099 forms to document income. For borrowers using a profit-and-loss (P&L) program, a certified public accountant or licensed tax preparer typically provides a 12-month rolling profit-and-loss statement verifying the business's income. Matching borrowers with the documentation method that best reflects how they earn and report income is often the key to a successful Non-QM transaction. 

Matching The Borrower To The Product: Five Questions Originators Should Ask

There are several Non-QM products a borrower can choose from — bank statement loans, 1099 loans, DSCR loans, and asset depletion loans, to name a few. Within each product, a borrower may qualify in several different ways. But two things lenders need to determine are how the borrower earns money and how that income actually flows. Here are five questions originators should ask to match borrowers with the right loan.

1. Where is the borrower’s income actually visible? It’s critical that the originator identifies the type of income and how consistent it is. With a bank statement loan, if the borrower is receiving payments from multiple sources on a consistent basis, we want to confirm those sources are valid and legitimate. There are multiple ways income can come in — Venmo payments, contractor checks, direct deposits — but all of it has to be confirmed.

2. What has the borrower already prepared? For a P&L loan, it’s about what the tax accountant can provide — a profit and loss document that shows self-employed business income. Borrowers who already have a working relationship with a CPA and formally prepared financials are a very different proposition than borrowers who would need to reconstruct records from scratch.

3. How consistent are the deposits? A borrower with consistent documented deposits is a much easier approval. But there are cases where somebody is paid seasonally, with the bulk of their business happening in three or four months of the year. That inconsistency has to be confirmed, documented, and typically explained with a letter from the borrower.

4. What does the borrower’s balance sheet look like independent of current income? This is where asset depletion applies. It’s a good product for individuals who may be retired or not currently employed but have a large brokerage account with stocks, bonds, or mutual funds that can be drawn from over a set period. This product has become increasingly popular for borrowers who’ve planned accordingly over time.

5. Is the borrower qualifying on property cash flow rather than personal income? A DSCR loan — debt service coverage ratio — is for investment property only. For this product, we don’t look at the individual’s personal income. We only look at the cash flow of the specific property they’re purchasing. To qualify, we obtain rent comps with the appraisal to confirm what the going market rent is for that property.

Where Loans Can Go Wrong

Even with sufficient documentation, clean, organized files, and an apparent loan-type match, Non-QM loans can still develop problems. Here are the common scenarios where the process grinds to a halt.

  • Wrong product selected up front. A borrower may have only 10 months of bank statements when the minimum required is 12 — that eliminates them from that product. With the profit and loss loan, if the borrower isn’t currently working with a CPA, most lenders aren’t going to accept a profit and loss statement because there’s no track record of professional preparation.
  • Insufficient deposit consistency for bank statement analysis. If the underwriter determines the income is insufficient or inconsistent over the 12 months, they’ll ask for a letter of explanation for the peaks and valleys. Most lenders use a designated expense ratio for bank statement loans by industry. If the file changes industries mid-review, that expense ratio can rise and disqualify the borrower.
  • P&L preparation quality. For a P&L loan, everything must be submitted by a certified tax accountant or tax professional. If the borrower doesn’t have a history with a tax accountant, they typically won’t qualify. It’s imperative to confirm upfront that they’re already working with a tax professional who can provide 12 months of documentation.
  • Asset seasoning and documentation gaps. If an asset isn’t seasoned properly — less than 60 days — it may be excluded from the calculation, which can disqualify the borrower from an asset depletion loan. A large deposit less than 60 days old needs to be sourced to determine where it’s coming from and whether it’s consistent with their income.
  • DTI miscalculation from misidentified income. There are cases where initial review included income for the business, and then it was determined that some of that income was going toward paying salaries for other individuals within the company — not actual revenue to the borrower.
  • Documentation not matched to what the underwriter will verify. Everything has to be documented to match what was disclosed by the borrower upfront. Any misinterpretation or gap in that documentation means it could be excluded, which can push the debt-to-income ratio higher than the program allows.
  • DSCR changes after appraisal.  A DSCR loan is evaluated based on the cash flow of the subject property and lower rental comps can impact an approval.  For example an investor is expecting $2,500 in monthly rent, but the appraiser confirms the going market rent is only $2,000. That lowers the DSCR, and the property may no longer qualify.

What This Means For The Current Lending Market

The Non-QM market has become more relevant over the past five years, driven largely by the growth in self-employed borrowers and others who don’t fit the conforming lending box. It’s not that the products are more complex than conventional. They’re just different. Each one serves a borrower with a somewhat unique situation — borrowers who may have had trouble getting answers from lenders that only offer conventional products.

Lenders have adapted to these products over the last five years, and the strong performance of the loans has validated that adaptation. Non-QM is becoming more mainstream, borrowers are becoming familiar with it, and the growth potential from here is significant. At roughly 10% of lock volume currently and climbing, the segment is on track to become a standard part of how qualified borrowers get financed when their income doesn’t fit a conforming template.

The most critical piece, in my experience, is the discovery call. Product knowledge matters, but it comes second to the originator’s ability to identify why a borrower doesn’t fit the conforming mold — and to ask the right questions to determine which non-QM product tells their income story accurately. Non-QM isn’t one-size-fits-all. Each product exists because borrowers earn income differently, and the originators who understand that distinction are the ones whose files close.
 

About the author
Senior Vice President and Residential Lending Manager, North American Savings Bank
Matt Allen is Senior Vice President and Residential Lending Manager at North American Savings Bank (NASB), where he oversees the bank’s nationwide residential lending operations. With more than 25 years of industry experience, he…
Published
Oct 30, 2026
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