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Mortgage Monitor | January 21
January 21, 2026

At A Glance

  • Non-QM lending has risen steadily over the past 18 months.
  • Growth reflects more Americans earning income outside traditional W-2 structures.
  • Non-QM loans use alternative, fully documented income verification.
  • Growth reflects evolving borrower needs rather than changes in credit standards.
As the housing market moves into 2026, As the housing market moves into 2026, Non-QM loans are appearing more frequently in national mortgage data and analysis. According to a recent report from Optimal Blue, Non-QM loans accounted for roughly 9% of mortgage activity at the end of 2025, continuing a steady upward trend that has been building for the past 18 months.1


What Non-QM Means — and Doesn’t Mean

A Non-QM loan is simply a mortgage that does not use the standard documentation rules required for a Qualified Mortgage. This has nothing to do with whether a borrower is “qualified” for the loan. Non-QM loans are fully underwritten and must show that the borrower can repay the loan. They just allow for different income documentation methods, such as bank statements, 1099s, rental cash flow, or assets, instead of relying only on W-2s or tax returns.

Non-QM loans are designed for qualified buyers whose finances are strong but do not fit traditional W-2 documentation. This includes people who work for themselves, receive income from multiple sources, or earn money through project-based or variable work. These situations can reflect solid financial strength but often do not align neatly with the paperwork required for agency-backed programs.

“More buyers today have income structures that don’t follow the traditional mold,” said Brett Hively, Senior Vice President and Mortgage Capital Markets and Financial Strategist at Ameris Bank. “Non-QM provides a way to responsibly evaluate those borrowers using the complete picture of their finances.”

Activity in the Non-QM segment appears across several borrower groups, including self-employed buyers who verify income with bank statements, investors who qualify using rental cash flow, and retirees who rely more on assets than wages. These patterns align with broader shifts in how households earn and document income today.


How the Industry Is Responding

The increasing visibility of Non-QM has prompted a wide range of opinions across the housing industry. Some analysts have raised questions about the pace of growth and how these loans may perform in different economic environments. Others view them as a practical solution for borrowers whose financial lives do not fit conventional documentation requirements.

Hively notes that today’s Non-QM landscape is very different from lending cycles before the financial crisis.

“These loans are fully underwritten and fully documented and are designed within today’s regulatory standards,” Hively said. “It is not a return to past practices. It reflects how people actually earn and report income today.”

Ameris offers a range of Non-QM solutions — including bank statement, 1099, rental cash-flow qualification, and asset-based options — that support these buyers while maintaining full documentation and regulatory standards.

“The goal is always the same,” Hively said. “Understand the borrower’s full financial picture and deliver a solution that fits responsibly.”


Bottom Line

Non-QM loans remain a small share of the mortgage market, but their steady rise signals a meaningful shift in how buyers document income and how lenders evaluate financial strength. As 2026 continues, the segment’s growth will be an important indicator of how well mortgage products are adapting to the modern economy.


Sources:
1 https://engage.optimalblue.com/hubfs/Market-Advantage/December2025.pdf

The opinions voiced in this material are for general information only and are not intended to provide specific advice or recommendations for any individual. Ameris Bank does not endorse nor is affiliated with the companies listed in this article.