Commission-Only vs. Base-Plus-Commission
The first distinction lenders make is whether the borrower receives commissions on top of a guaranteed base salary or is paid entirely through commissions. A base-plus-commission borrower has a guaranteed income floor; the base salary qualifies at face value, and the commission component is then averaged and added on top. A commission-only borrower has no guaranteed income, which means the entire qualifying income is subject to the averaging methodology and trend analysis. Commission-only borrowers are often classified as having variable income for the entirety of their earnings, and some lenders apply underwriting standards similar to those used for self-employed borrowers, including requirements for two years of tax returns and potentially a profit and loss statement for the current year.
The Two-Year Commission Average
Lenders calculate commission income by averaging the total commission earnings over the most recent two calendar years. The calculation uses W-2 earnings (specifically the commission portion), year-to-date pay stub data, and tax return information. If the borrower itemizes unreimbursed employee business expenses on their tax returns, those expenses are deducted from the gross commission figure before averaging. The formula is straightforward: total commission earned over 24 months divided by 24 equals the monthly qualifying commission income. If year-to-date earnings are available and cover a meaningful period, the lender may use a weighted calculation incorporating the current-year trajectory. For example, if the borrower has 18 months of commission data (full prior year plus six months of the current year), the lender divides total commissions by 18 to arrive at a monthly figure.
Employer Verification and Structure
The lender verifies commission income through a written Verification of Employment (VOE) that specifically requests a breakdown of base salary versus commission for each of the past two years and year-to-date. The VOE also asks the employer to confirm the commission structure (percentage of sales, tiered rates, draw against commission, etc.), the borrower’s tenure, and whether the commission arrangement is expected to continue. If the employer operates on a draw-against-commission model, the lender must determine whether the draw is a guaranteed minimum or an advance that must be repaid; a non-guaranteed draw complicates the income calculation because the borrower may owe money back to the employer in periods of low production.
Declining and Irregular Commission Trends
Underwriters pay close attention to the year-over-year trajectory of commission income. If commissions declined from one year to the next, the lender must assess whether the decline is temporary (due to a market cycle, territory change, or one-time event) or structural (indicating a long-term reduction in earning capacity). Under conventional guidelines, if commission income declined by more than a nominal amount year over year, the lender should use the lower annual figure rather than the two-year average, unless there is documented justification for using the average . The borrower may need to provide a letter of explanation, and the employer may need to confirm that the decline was caused by specific, non-recurring factors. Irregular commission patterns, where income swings substantially from quarter to quarter, are evaluated for overall annual consistency rather than quarter-to-quarter stability.
Tax Return Adjustments for Commission Earners
Commission earners who report unreimbursed business expenses on their federal tax returns have those expenses deducted from their qualifying income. Prior to the Tax Cuts and Jobs Act of 2017, these expenses were reported on Form 2106 and deducted on Schedule A. Under current tax law, W-2 employees generally cannot deduct unreimbursed business expenses on their federal returns . However, some states still allow the deduction, and if the borrower claims such expenses on a state return, the lender may still consider them. Additionally, if the commission earner operates as an independent contractor (1099) rather than a W-2 employee, the income is treated as self-employment income, and Schedule C business expenses are deducted from gross commission earnings.
Related topics include variable income averaging (overtime, bonus, commission), bonus income mortgage guidelines, overtime income mortgage guidelines, debt-to-income ratio explained (dti), asset and reserve requirements explained, and common income mistakes that cause mortgage denials.