California Mortgage Solutions
Two loans side by side

DSCR or bank statement: the rent qualifies one, your deposits qualify the other

A DSCR loan is a business-purpose mortgage on a rental you will not live in, qualified on the property's rent measured against its own debt service, under each lender's own rules. A bank statement loan is a consumer mortgage on the home you live in, qualified on your own income as a run of your monthly bank statements shows it, under Regulation Z's ability-to-repay rule and each lender's own rules. Both exist for a borrower whose tax returns do not tell the story a conventional underwriter needs, and they part on who is being qualified: the property, or you. This page sets the two side by side under the public rules that govern each. California Mortgage Solutions, an independent mortgage broker in San Luis Obispo, wrote it for self-employed investors in San Luis Obispo County weighing the two.

Side by side

DSCR vs bank statement, rule by rule
The ruleDSCRBank statement
What qualifies the loanThe property. The lender compares the rental's income with the payments on its debt, the measure the OCC's Comptroller's Handbook defines as the debt service coverage ratio: cash flow or net operating income divided by the debt service. Each lender sets how it figures the rent and the payment, and the level the ratio must reach.You. The lender reads the deposits in a run of your monthly bank statements, over a period it chooses, as the record of your income. Regulation Z's ability-to-repay rule has it determine, reasonably and in good faith, that you can repay the loan on its terms, and verify the income it relies on from third-party records, among which the rule lists financial institution records.
Whose income is documentedThe property's. The ratio is built from what the rental earns set against what its debt costs, and your own earnings are not what it measures. What else a lender asks of you, from a credit report to reserves, is its own rule.Yours. The rule the loan is written under has the lender consider your current or reasonably expected income or assets, other than the value of the home, and its commentary names self-employment income among the kinds of income a lender may count.
Tax returnsNot what the ratio reads. A return reports a rental's income or loss on Schedule E; the handbook's ratio is figured from the property's income and its debt service instead, and whether a lender also asks for your returns is its own rule.Replaced by the statements as the income record. Regulation Z lets a lender verify income with a tax return transcript, and lists other records it may use, financial institution records among them. A return reports a sole proprietor's profit or loss from the business after its expenses, on Schedule C; the statements show the deposits, and the rule's commentary says a lender that sees money flow into your account must confirm it is income and not, for example, the proceeds of a loan.
Who the borrower may beA person or an organization, as each lender decides. Regulation Z exempts credit extended to anyone other than a natural person, whatever the purpose and even when a person stands behind the loan personally, so a loan to an LLC is outside the regulation on that ground alone.A natural person borrowing for personal, family or household purposes: that is what makes the loan consumer credit under Regulation Z, and the ability-to-repay rule is written for that borrower. Credit for a consumer purpose to a trust you created for tax or estate planning is treated as credit to you.
The property, and whether you live in itA rental you will not live in. Regulation Z deems credit to acquire, improve or maintain a rental that is not owner-occupied to be business credit; if you expect to stay there yourself in the coming year for longer than the short span the rule allows, the property is not treated as non-owner-occupied and that rule does not apply. Which property types a lender accepts is its own rule.The home you live in. A second home, where a lender writes one, is also a dwelling under Regulation Z, which need not be your principal residence, so the ability-to-repay rule reaches a consumer loan on it too. On a rental you will not live in, the loan is business credit under the deeming rule in the other column, and a different product.
Qualified mortgage status and the ability-to-repay ruleOutside Regulation Z altogether, on a rental you will not live in: the regulation does not reach business-purpose credit, so neither the ability-to-repay rule nor the qualified mortgage definition applies, and no safe harbor comes with the loan. The lender's own underwriting is the only rulebook.A covered transaction under the ability-to-repay rule, which the lender must satisfy. It is written outside the qualified mortgage definition, whose general form has the lender consider and verify income or assets, debts and the debt-to-income ratio or residual income and caps how the loan is priced, among other conditions; a loan outside the definition carries no safe harbor, and Fannie Mae's guide ties what it buys to those rules.
Prepayment penaltyEach lender's term, and one to read before signing: Regulation Z's limit on prepayment penalties is written for covered transactions, and a business-purpose loan is not one.Not allowed. Regulation Z permits a prepayment penalty on a covered transaction only when the loan is a qualified mortgage, among other conditions, and a loan written outside that definition is not one.
Federal disclosuresNone of Regulation Z's. A business-purpose loan carries neither a Loan Estimate nor a Closing Disclosure, so the note and the lender's own documents are where the terms live.A Loan Estimate after you apply and a Closing Disclosure before closing, as Regulation Z requires on a closed-end consumer loan secured by real property.
Reserves, and what you bring to closingEach lender sets them. No federal rule reaches the terms of a business-purpose loan.Each lender sets them. The ability-to-repay rule has the lender consider your assets along with your income and sets no reserve count; its commentary says the rule provides no comprehensive underwriting standards and leaves lenders to develop their own.

Where each one fits

DSCR can fit when

  • The property is a rental you will not live in, and its rent clears its own debt service at the level your lender's ratio asks.
  • You want the loan made to an LLC or another organization, and your lender lends to one.
  • You would rather the file rest on the property's income than on your own returns, and you accept that a business-purpose loan comes without Regulation Z's consumer protections, the Loan Estimate and the prepayment penalty limit among them.

Bank statement can fit when

  • You are self-employed and buying or refinancing the home you live in.
  • Your returns are accurate and still understate what the business pays you, and your deposits show that income across the run of statements your lender asks for.
  • You want the protections that come with a consumer loan under the ability-to-repay rule, among them that the loan carries no prepayment penalty.

What the two have in common

  • Both are written to each lender's own rules, with no agency guideline underneath them: each lender sets the rate, any points, the reserves and the equity it asks for, and none of those is priced on this site.
  • Both exist for a borrower whose tax returns do not tell the story a conventional underwriter needs. Fannie Mae's guide reads a self-employed borrower's income from signed federal returns, and a rental's through its own rental income rules.
  • Neither is a qualified mortgage under Regulation Z's definition: the DSCR loan because the regulation does not reach business-purpose credit, the bank statement loan because it is written outside the definition.
  • Both pull your credit, and on both a deposit or a rent the lender cannot document does not count.

Questions

What is the difference between a DSCR loan and a bank statement loan?

A DSCR loan is a business-purpose mortgage on a rental you will not live in, qualified on the property's rent measured against its own debt service, the debt service coverage ratio, under each lender's rules, and outside Regulation Z. A bank statement loan is a consumer mortgage on the home you live in, qualified on your own income as your monthly bank statements show it, inside Regulation Z's ability-to-repay rule and written outside its qualified mortgage definition. One documents the property; the other documents you.

Can a self-employed investor use either?

It depends on the property and the purpose, and each lender's rules decide the rest. A DSCR loan is business-purpose credit on a rental you will not live in, qualified on the property's rent against its own debt service, so your self-employment income is not what the lender measures. A bank statement loan is a consumer loan on the home you live in, qualified on your own deposits under the ability-to-repay rule. The same person can fit one on one property and the other on another, neither is open on the wrong property, and what each would cost on your file is a question for the two lenders' terms.

Does a DSCR lender or a bank statement lender look at my tax returns?

A DSCR lender's ratio is figured from the property's income and its debt service, so your returns are not what it measures; whether it asks for them is its own rule. A bank statement lender verifies the income it relies on from third-party records, and Regulation Z lists financial institution records among those it may use, beside a tax return or a transcript. In both cases the lender sets its own document list, and a deposit it cannot tie to income does not count.

Can I get either loan on a home I will live in?

A bank statement loan, yes: it is a consumer loan on the home you live in, and the ability-to-repay rule applies to it in full. A DSCR loan, no: it is business-purpose credit on a rental you do not occupy, and that purpose is what places it outside Regulation Z. Occupancy is sworn in writing on a mortgage application, and a DSCR loan on a home you mean to live in is a false statement, not a route around the rule.

Which of the two can carry a prepayment penalty?

A DSCR loan can, as the lender's term: Regulation Z's limit on prepayment penalties applies to covered transactions, which a business-purpose loan is not. A bank statement loan on the home you live in cannot, because Regulation Z allows a prepayment penalty on a covered transaction only when the loan is a qualified mortgage, among other conditions, and a bank statement loan is written outside that definition. Read the note's prepayment terms before signing either.

Sources

The publications behind the rules above. Where a row says each lender decides for itself, no publication sets that rule. The figures for the county come from the county's loan limit page, with their own sources.

Tell us which of the two fits your file

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