Lenders will count RSU income toward a HELOC. But they’ll calculate it on a formula most borrowers don’t see coming: the trailing 200-day moving average of the employer’s stock price, multiplied by vested shares received over the most recent 24 months, divided by 24. That math comes from Fannie Mae Selling Guide section B3-3.3-07, which governs restricted stock units as employment income. So a Bay Area engineer whose last two vests landed at $45,000 on today’s price may qualify off a very different figure. This guide walks through what counts, what doesn’t, and how HELOC underwriters handle the quirks of equity comp in 2026.
Short answer: can RSU income qualify you for a HELOC?
Yes, with conditions. You’ll need a 24-month history of vested, distributed RSU income, a vesting schedule that supports at least three more years of similar payouts, and documentation that the employer stock trades publicly. Private-company RSUs almost never qualify as agency income–share value can’t be independently verified without a liquid market–and sign-on or one-time grants generally fail the “stable, continuing income” test regardless of dollar size.
Who this guide covers
Tech, biotech, finance, and senior corporate employees whose W-2 shows an “RSU,” “Supplemental,” or “Imputed Income” line. Typical readers hold $200,000 to $1 million in annual W-2 compensation, with a meaningful share delivered through RSUs. Most sit in Bay Area, Seattle, NYC, Boston, Austin, or San Diego tax jurisdictions and are sizing a HELOC between $100,000 and $500,000 against a jumbo primary residence.
The 60-second eligibility test
Four questions. Is the employer public? Have you received at least 24 months of vested RSU distributions? Does your grant schedule show future vests continuing at a similar rate for 36 months? And is your stock trend flat or up over the trailing 12 months? Four yeses, and the income is almost certainly usable. One or two nos, and you’re in overlay territory, where portfolio banks and credit unions set the terms.
The 24-month history and 200-day moving average
Agencies use the 200-day moving average to smooth stock-price volatility. A borrower whose vest shares are worth $200 today but traded at $160 on average over the prior 200 days gets qualified on the lower figure. The rule protects both sides from pricing a credit line against a short-lived spike.
Worked example
Consider a borrower with $180,000 W-2 base and $120,000 average annual RSU income over the last two years. Over 24 months she received 1,500 vested shares. The stock traded at $200 near her most recent vest but has drifted to a 200-day moving average of $160 after an industry selloff.
Her qualifying RSU income under the agency formula: 1,500 shares × $160 ÷ 24 = $10,000 per month, or $120,000 annualized. Had the underwriter used the current $200 share price, the same calculation would produce $12,500 per month, or $150,000 annualized. And that $30,000 gap is often the entire difference between a borrower who qualifies for the line she wants and one who comes in short.
Continuity and trend tests
Vesting has to continue at a similar rate for at least three years from the application date. A grant that fully vests in month 20 after closing fails this test, even if historical receipts look strong. Underwriters read the grant agreement (and any refresh grants documented by the employer letter) to confirm the forward view.
Declining RSU income gets handled asymmetrically. If year-two income runs below year-one income, Fannie Mae permits using the lower, more recent figure, or disqualifies the income entirely if the decline is material. Rising income doesn’t get a forward-looking credit. The haircut runs one direction.
Fannie Mae and Freddie Mac in plain English
Fannie Mae B3-3.3-07 is the governing text for conforming loans. Freddie Mac addresses equity compensation under Single-Family Seller/Servicer Guide topics 5303 and 5305, with similar but not identical wording. Both agencies require shares to be vested and distributed without restriction. Lockups, blackout windows, and clawback-subject grants don’t count.
Sign-on RSUs sit outside this framework entirely. Agencies treat a one-time grant as non-recurring regardless of how the vesting is structured. Borrowers routinely misread this. So a $400,000 sign-on grant that vests 25% annually over four years is still non-qualifying income, because the grant itself doesn’t repeat.
Private-company RSUs almost never qualify. Without a liquid trading market, the agency verification requirement can’t be met. A pre-IPO engineer with $300,000 in paper vested RSU income will see $0 counted by any agency-eligible lender.
Documents HELOC underwriters ask for
The package is standard but long. Underwriters request the most recent 30-day pay stub with YTD RSU vesting income and two years of W-2s, along with the grant agreement showing vesting schedule and an employer letter (or HR portal screenshot) confirming future vesting tranches. They also want brokerage statements from E*TRADE, Fidelity, Schwab, Shareworks, or Carta covering historic distributions, plus proof the employer stock trades on a recognized exchange. Some workflows add Form 1005, a Verification of Employment completed by HR.
Here’s the practical reality: the RSU line on a pay stub is labeled differently across payroll systems. Workday reports it as “Supplemental Earnings,” while ADP displays it as “Imputed Income.” Flag the correct line for the processor before the file ever reaches underwriting, not after it comes back with conditions attached, so it doesn’t get miscategorized somewhere downstream as a bonus.
How each equity type is treated
RSUs are the baseline: 24-month history, 200-day moving average, treated as W-2 income at vest. RSAs with an 83(b) election follow similar mechanics but require extra documentation of the election itself.
ISO and NSO exercises only produce qualifying income on shares actually exercised and sold–paper options don’t count, ever. Lenders read the W-2 line (Code V for NSOs) and typically average 24 months of exercise history, often haircut heavily or excluded entirely when the exercise pattern looks sporadic.
ESPP income appears on the W-2 at purchase as the discount component. Most lenders apply a 24-month average and give it supplemental weight. And it’s usually small relative to RSUs, so it often gets set aside when RSU income alone is sufficient.
Performance share units are the hardest category. Payout depends on company metrics. Many underwriters average two or three years of received payouts, or decline PSU income altogether. So treat it as unreliable until a specific lender confirms otherwise in writing.
The three HELOC lender buckets
HELOCs are usually portfolio-held rather than sold to agencies, so many HELOC lenders set their own overlays instead of applying B3-3.3-07 literally. Three broad categories emerge.
| Dimension | Agency-eligible HELOC | Portfolio bank / credit union | Private bank / jumbo HELOC |
|---|---|---|---|
| Minimum RSU history | 24 months | Often 12 to 24 months | 12 months or less with offset |
| Share of RSU income counted | 100% of trailing 24-month avg | Up to 100%, lender discretion | Highly negotiable |
| Private-company stock | Not accepted | Rarely | Sometimes, with liquidity event |
| ESPP income | Averaged, often small weight | Averaged | Often included |
| Volatility treatment | 200-day moving average | 200-day or 12-month avg | Lender discretion |
Credit unions with tech-heavy membership bases tend to publish the most flexible RSU rules, though written policies change often enough that a borrower should request the current guideline in writing before relying on any specific threshold. Private-bank HELOC desks underwrite case by case and frequently extend lines to ultra-high-net-worth borrowers whose income doesn’t fit agency formulas.
Stock-price volatility traps
The 200-day moving average cuts both ways. A borrower whose stock has dropped 20% over three months will see qualifying income track somewhere between the old and new price, because the window still holds older higher prints–the math catches up slower than the market moves. And a borrower whose stock just doubled on earnings will see almost none of that spike show up in the qualifying figure.
Lockups and blackout windows don’t disqualify past vested income, but they can affect the “distributed without restriction” test on recent tranches. A borrower inside a post-IPO lockup should expect underwriters to exclude the restricted portion.
Vested and unvested stock as reserves
Unvested RSUs don’t count as reserves, because the borrower doesn’t own them yet. Vested shares held in a brokerage account typically count at a 70% haircut of current market value under standard agency treatment of stocks and mutual funds. Concentrated single-stock positions in employer stock may receive a deeper haircut under portfolio overlays, because the collateral and the income share the same correlation risk.
Application checklist
Twelve weeks out: pull two years of pay stubs, W-2s, and brokerage distribution histories. Confirm the grant agreement shows at least 36 months of future vesting. And request the employer letter from HR.
Four weeks out: verify the pay stub’s RSU line is correctly labeled. Pull a 200-day moving-average report from the brokerage. Flag any pending refresh grant that could be timed to close before application.
One more thing: make sure the processor categorizes RSU as “W-2 variable income,” not “bonus.” That distinction changes how the income gets treated, and whether the 200-day rule even applies.
When a HELOC is not the right tool
A borrower with $2 million in vested employer stock may find a securities-backed line of credit (SBLOC) faster and cheaper to open than a HELOC. But SBLOCs are callable, aren’t mortgage-interest-deductible, and carry margin-call risk if the pledged stock falls sharply. For a cash-out refinance comparison, the same B3-3.3-07 income rules apply at the first-mortgage level.
HELOC interest deductibility still ties to “buy, build, or substantially improve” use under TCJA as modified. And Regulation Z freeze and reduction rights apply to any HELOC regardless of how the income was qualified.
FAQ
Can I qualify for a HELOC with only 12 months of RSU vesting history?
Agency-eligible lenders require 24 months. Some portfolio banks and tech-focused credit unions will consider 12 months with strong compensating factors, but written confirmation is essential.
Do unvested RSUs count toward HELOC qualification?
No. Unvested shares are neither qualifying income nor reserves. Only vested, distributed shares appear in the calculation.
How do lenders calculate RSU income for a HELOC?
Vested shares received over the trailing 24 months, multiplied by the 200-day moving average share price, divided by 24 for the monthly figure.
Will my HELOC application fail if my employer’s stock price just dropped?
Not necessarily. The 200-day moving average still holds older higher prints, so qualifying income lags both drops and spikes.
Do ESPP and ISO income count the same way as RSUs?
No. ESPP discount income is often averaged and given supplemental weight. ISO and NSO income requires actual exercise and sale history, and it’s often haircut heavily.
Are private-company RSUs usable for HELOC qualification?
Generally no for agency-eligible lenders. Some private banks will consider them where a verifiable secondary market or tender-offer 1099 history exists.
Does a sign-on RSU grant count as income for a HELOC?
No. Agencies treat one-time grants as non-recurring compensation regardless of the vesting schedule.
How many years of RSU income do I need for a jumbo HELOC?
Two years remains the baseline for agency-eligible jumbos. Private-bank desks may underwrite on shorter histories case by case.
Bottom line for 2026
RSU income counts, but the formula is slower and more conservative than most borrowers expect. Pull two years of brokerage history, confirm your grant supports three more years of vesting, and get any lender-specific overlay in writing before you apply.
Educational content only, not mortgage or tax advice. Lender policies change; verify with a licensed loan officer.
