The instinct to move a declined conventional file to non-QM is understandable but sometimes wrong. Non-QM loans carry higher rates, different program costs, and sometimes prepayment penalties that significantly affect the long-term cost. Before switching, the MLO should exhaust every path to qualify the borrower conventionally and understand exactly what they are giving up by going non-QM.
When to Fix the Conventional File First
- ✦DTI borderline: if the borrower is at 52 percent DTI and the DU returned an ineligible finding, identify whether paying down a specific revolving account or removing an authorized user account would fix the DTI before defaulting to non-QM
- ✦Income documentation issue: if the file was declined because the borrower could not produce a specific document, determine whether an alternative documentation path exists within agency guidelines before switching to a bank statement program
- ✦AUS ineligible with a strong profile: run LP if DU declined. The two systems use different risk models and occasionally produce different outcomes for the same file.
- ✦Waiting period question: confirm the actual waiting period from the relevant derogatory event. MLOs sometimes move files to non-QM because of a perceived waiting period that has actually been met.
When Non-QM Is the Right Answer
- ✦Self-employed income that genuinely does not qualify on tax returns: if two years of Schedule C show net losses after deductions, agency cannot help and bank statement is the right product
- ✦Investor properties above the 10 financed property limit: Fannie Mae caps at 10 financed properties. The 11th and beyond require DSCR or portfolio lending.
- ✦Foreign national with no US credit history: there is no conventional path for a borrower with no US FICO score
- ✦DSCR qualifier: investment properties where the rental income covers the payment but the borrower's personal income does not support agency qualification
The Cost of Switching
- ✦Non-QM rates typically run 75 to 200 basis points above comparable conventional rates
- ✦Non-QM closing costs may include lender points that are not present on agency loans
- ✦Many non-QM loans carry prepayment penalties that add exit cost if the borrower refinances to a conventional loan when they become eligible
Aria can walk through whether a specific declined conventional file has a viable path to agency approval or whether non-QM is genuinely the best option. Ask at vicariointel.com.
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