Underwriting the Bank-Statement Loan With AI: Deposit Analysis That Is Auditable, and the Ability-to-Repay Rule Non-QM Never Escapes
Bank-statement loans qualify a self-employed borrower on deposits instead of tax returns, which makes the income calculation the whole underwrite and the easiest number to get wrong. These are non-QM loans, and non-QM does not mean no ability-to-repay: Reg Z 1026.43(c) still requires a reasonable, good-faith determination on all eight factors. Here is how an AI agent classifies twelve to twenty-four months of deposits, the transfer that double-counted income until we caught it in shadow mode, and the reasonableness call the underwriter still signs.