The CPA Letter on a Bank-Statement Loan: What It Has to Say

Almost every bank-statement file needs a letter from the borrower's CPA or tax preparer. Depending on the lender, that letter can confirm ownership, prove the business exists, or support a lower expense factor. When it's missing one line the lender needs, it comes back as a condition, and the borrower's CPA has to be chased again.

Here's what published guidelines ask for, so you can request the right letter the first time.

Why lenders want a third party

Under the federal ability-to-repay rule, income must be verified with reasonably reliable third-party records. The official commentary gives a direct example: a P&L prepared by a self-employed consumer and reviewed by a third-party accountant is a third-party record; one reviewed by the consumer's non-accountant spouse is not. [1] The CPA letter plays the same role: an outside professional standing behind the numbers.

The three jobs a CPA letter can do

1. Confirm ownership percentage

• Angel Oak's broker checklist lists a business ownership-percentage letter from a third-party CPA or tax preparer. [2]
• Silver Hill requires a CPA letter confirming ownership percentage. [3]
• Plaza accepts a CPA letter, tax preparer letter, operating agreement or equivalent. [4]

2. Confirm the business exists and the borrower is self-employed

• Plaza accepts a CPA or tax preparer letter as one way to show the business has existed for at least two years. [4]
• Silver Hill requires a CPA, accountant or tax preparer letter verifying self-employment. [3]

3. Support a lower expense factor

This is the most detailed letter. Arch Mortgage Funding's calculator instructions list what its expense-factor statement must include [5]:

• business name
• expense percentage of gross annual revenue
• a statement that the preparer filed the borrower's most recent tax return
• the preparer's license verification
• signatures from both the preparer and the borrower(s)

Arch's minimum custom factor is 10%. [5] Other programs:

• Plaza: an expense statement specifying business expenses as a percent of gross annual sales/revenue (minimum 10%), prepared and signed by a CPA/accountant, IRS Enrolled Agent or tax preparer, with evidence of the preparer's business in the credit file. [4]
• Newfi (correspondent matrix, eff. Jan 13, 2025): a signed and dated statement of expenses as a percentage of gross annual sales/revenue, covering the 12- or 24-month statement period. The preparer, or their firm, must have prepared the most recent tax returns, and verification of the preparer's business and a current license is required. [6]
• Angel Oak: a lower factor requires a statement from a third-party CPA, tax preparer or bookkeeping company. [7]

Who can sign

Not every preparer qualifies. Arch's preparer must [5]:

• have filed the borrower's most recent tax return
• have audited or reviewed the business financials
• not be related to or affiliated with the borrower's business
• be licensed, with the license verified

Plaza and Newfi accept CPAs, accountants, tax preparers and (Plaza) IRS Enrolled Agents. [4][6] Angel Oak's page also mentions bookkeeping companies for expense statements. [7] Check your lender before the borrower asks their bookkeeper.

A request you can send the borrower's CPA

Ask for one letter on firm letterhead that includes, as the lender requires:

1. Business legal name and the borrower's name
2. Borrower's ownership percentage
3. How long the business has existed and that it's currently operating
4. That the preparer prepared/filed the borrower's most recent tax return
5. Expense ratio as a percentage of gross annual revenue, if using a custom factor, and the period it covers
6. Preparer's name, credential, license number, firm address and phone
7. Signature and date, plus the borrower's signature where the lender requires it

Then verify the license before submission. Arch and Newfi both require license verification. [5][6]

Common CPA-letter conditions

• No statement that the preparer filed the most recent return
• Expense ratio given in dollars, or without a time period
• Missing borrower signature (Arch)
• Preparer is a relative or works for the business
• Letter is older than the lender accepts. Ask your AE how recent it must be.

Sources (checked 2026-10-15)

Lender rules as published on the sources_verified date; check the current guide before relying on them.

1. Consumer Financial Protection Bureau, Regulation Z § 1026.43 and official interpretation, comment 43(b)(13)(i)-1 ("Reviewed record"): https://www.consumerfinance.gov/rules-policy/regulations/1026/43/
2. Angel Oak, Broker Loan Submission Checklist (PDF, form MS_A036_0521): https://angeloakms.com/wp-content/uploads/Loan-Submission-Checklist-Broker.pdf
3. Bank Statement product sheet (© 2025 Silver Hill Capital), hosted at https://www.lakeviewcorrespondent.com/wp-content/uploads/2025/07/Bank-Statement-.pdf
4. Plaza Home Mortgage, Solutions Non-QM 1 Product Snapshot (PDF, © 2025): https://www.plazahomemortgage.com/DownloadFile.aspx?FileName=Solutions+Non-QM+1+Product+Snapshot.pdf&FilePath=%5CDocuments%5CPlazaPrograms%5CSolutions+Non-QM+1+Product+Snapshot.pdf
5. Arch Mortgage Funding, Bank Statement Income Calculator (XLSX, © 2026), Calculation Instructions tab, linked from https://mortgage.archgroup.com/arch-mortgage-funding/calculators/ (file: https://mortgage.archgroup.com/wp-content/uploads/sites/4/MCUS-1531AMF-23J-AMF-Bank-Statement-Income-Calculator.xlsx)
6. Newfi Correspondent, Delegated Plus NQM Product Matrix, effective January 13, 2025 (PDF): https://newficorrespondent.com/wp-content/uploads/2025/01/Correspondent-Delgated-Plus-NQM-Product-Matrix.pdf
7. Angel Oak Mortgage Solutions, Bank Statement Loan program page: https://angeloakms.com/programs/bank-statement-mortgage-program/

Sources 3, 4 and 6 are correspondent or product documents. Wholesale (broker) guidelines from the same companies may differ.

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