Restricted stock units (RSUs) are a form of equity compensation that vests over time. Tech workers, executives, and employees at publicly traded companies often receive significant RSU income alongside their base salary. Qualifying this income requires documenting a history of vesting and an expectation of continued grants.
The 2-Year History Requirement
Fannie Mae and Freddie Mac require a 2-year history of RSU income to use it for qualification. The income is shown on W-2s as taxable compensation when shares vest and are sold or transferred. If the borrower has less than 2 years of RSU vesting history, the income cannot be counted on conventional programs regardless of the vesting schedule or current grant balance.
How RSU Income Is Calculated
- ✦Add total RSU income from the 2 most recent W-2s (typically in Box 1 or separately identified)
- ✦Divide by 24 to get monthly average
- ✦If current-year YTD RSU income is running above the 2-year average, use the lower
- ✦If RSU income has been declining (fewer shares vesting per year due to exhaustion of original grant), declining income analysis applies
- ✦Confirm with employer or via equity award documentation that future grants exist
Employer Continuation Requirement
Unlike salary, RSU income cannot be assumed to continue indefinitely. Fannie Mae requires the lender to document that RSU income is likely to continue for at least 3 years. An equity grant summary showing future unvested shares with a vesting schedule, or a letter from the employer confirming ongoing grant participation, satisfies this requirement. If the borrower is in their last year of a vesting grant with no new grant issued, the income may not be countable.
Tax Withholding Consideration
RSU vesting is a taxable event. The employer typically withholds shares to cover taxes, so the actual cash deposited is less than the full vest value. The qualifying income is the gross vest value shown on W-2, not the net-of-tax amount deposited. This distinction matters when matching income to bank statements during the verification process.
Aria can calculate RSU qualifying income, identify whether the continuation requirement is met, and confirm what documentation is needed for any RSU income scenario. Ask at vicariointel.com.
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