By the Numbers

Distilling layered risk in non-QM MBS

| March 27, 2026

This material is a Marketing Communication and does not constitute Independent Investment Research.

Despite rapid growth in originations, layered risk broadly remains contained. However, certain layered risk profiles do remain relatively elevated. Borrowers whose debt burdens rise after taking equity out of their homes continue to make up a meaningful amount of loans securitized in non-QM trusts. However, lower FICO borrowers who tap equity may pose the most meaningful risk.

Weighted average credit metrics generally do a poor job of quantifying credit risk in a pool of loans as dispersion away from that average means there can be a larger population of higher risk loans being masked by a large population of pristine ones. Instead, many investors focus on the credit ‘tail’ of a given pool. Borrowers’ LTVs, credit scores, DTIs along with the purpose of the loan can be viewed in isolation. But they are more frequently viewed collectively to show the amount of ‘layered’ credit risk in a given collateral pool. Historically, the presence of a second or third risk in a cohort of loans has signaled substantially worse credit performance than the presence of a single one.

Layered risk was fairly prevalent in non-QM loans securitized prior to 2021. Many borrowers had experienced prior credit events and the primary criteria by which a loan was deemed to be non-QM was based on a borrower’s DTI. As a result, loans with more than one risky attribute often made up 15% to 20% of the collateral backing a given transaction. Changes to the non-QM definition enacted in the first quarter of 2021 coupled with broad tightening in mortgage credit availability during the pandemic both reshaped and strengthened the overall credit profile of the non-QM borrower base.

Sizing up layered risk in recent vintages

Using LTV, FICO, DTI and loan purpose as screening criteria, high DTI cash out refinances are both the largest and most consistent layered risk exposure in non-QM trusts. These loans consistently make up more than 5% of pools securitized since 2021. High LTV, high DTI loans make up the second largest layered risk exposure in pools but have seen the balance of those loans decline more recent vintages. While lower FICO borrowers who have re-levered the equity in their homes consistently make up anywhere from two to three percent of non-QM pools (Exhibit 1).

Exhibit 1: Layered risk across recent vintage non-QM

Source: Santander US Capital Markets, Core Logic LP
Note: High LTV defined as >80 OLTV, Low FICO defined as =<680 FICO, High DTI defined as=>40 DTI, Purpose defined as cash-out refinance. Values are expressed as a percentage of original loan UPB securitized

Loans with more than two layered risks are sparingly found in non-QM trusts. The combination of low FICO, high DTI borrowers who took out cash when they refinanced their home is the most prevalent three-dimensional layered risk in non-QM trusts. At peak, they made up less than 1.5% of loans securitized in the 2021 and 2023 vintages and made up just 0.98% and 0.88% of loans securitized in 2024 and 2025 respectively.

A look at performance of layered risk loans

While high DTI cashout refinances remain the most prominent layered risk in non-QM trusts, there may be good reason why those balances remain relatively elevated. Namely, that DTI has not been particularly predictive of performance across cash out refinancings in these vintages of non-QM loans. In fact, certain cohorts of lower DTI cashout refinances are exhibiting the highest rates of seriously delinquent loans, while delinquencies on higher DTI cuts remain more benign (Exhibit 2).

Exhibit 2: Higher DTI cashouts do not exhibit markedly worse credit performance

Source: Santander US Capital Markets, Core Logic LP
Note: High LTV defined as >80 OLTV, Low FICO defined as =<680 FICO, High DTI defined as=>40 DTI, Purpose defined as cash-out refinance.

There are a couple of plausible explanations for why this may be the case. First and most likely is that the presence of layered risk likely comes along with some offsetting compensating credit characteristics. While these borrowers have increased their leverage and debt burden as a function of income, this does not consider that the borrower may have been able to demonstrate substantial assets or reserves or maintains substantially more equity than lower DTI cohorts even after taking cash out. Secondly, DTI, to date, has been a fairly weak predictor of credit performance, which may be due, in part, to the somewhat subjective nature of calculating a debt-to-income ratio.

The same can be said when looking at higher LTV, high DTI loans where some lower DTI borrowers are flashing substantially elevated delinquency rates. In the middle of last year, 60-day or greater delinquency rates on high LTV borrowers with 20 to 25 DTI ratios and 45 to 50 DTI ratios both hovered around 8.0%. Since then, serious delinquency rates on the low DTI cohort have climbed by roughly another 100 bp, while DQ rates on the high DTI cohort have fallen by roughly the same amount (Exhibit 3).

Exhibit 3: Delinquency rates relatively benign on high LTV, high DTI loans

Source: Santander US Capital Markets, Core Logic LP
Note: High LTV defined as >80 OLTV, Low FICO defined as =<680 FICO, High DTI defined as=>40 DTI, Purpose defined as cash-out refinance.

Conversely, the presence of cash out refinance loans to low FICO borrowers does appear to warrant concern, as lower FICO borrowers are performing substantially worse. Serious delinquency rates on cash out refis to borrowers with credit scores between 640 and 660 are in excess of 11%, while DQ rates on borrowers with FICOs between 660 and 680 are rapidly approaching 9%. This stands in fairly stark contrast to the ‘archetypal’ non-QM borrower whose credit score generally ranges from 720 to 740, where serious delinquency rates are just 5% (Exhibit 4). So, while these loans represent one of the smaller cohorts of two dimensioned layered risk, they may prove to be much more meaningful in terms of fundamental performance.

Exhibit 4: Low FICO cashout refinances are a meaningful layered risk

Source: Santander US Capital Markets, Core Logic LP
Note: High LTV defined as >80 OLTV, Low FICO defined as =<680 FICO, High DTI defined as=>40 DTI, Purpose defined as cash-out refinance.

Chris Helwig
christopher.helwig@santander.us
1 (646) 776-7872

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