10 minutes

How to Analyze the Non-QM Market with Loan-Level Data

February 2, 2026
Author:
Val Buresch, CMB

Analyzing the Non-QM market requires more than national statistics. According to our estimates, the Non-QM lending reached $182 billion in 2024, representing 9% of total mortgage originations. Unlike FHA or conventional loans, there is no standard flag or universal definition for Non-QM in public data sources.

Different vendors and investors have developed their own definitions based on varying methodologies. Some focus on securitization pathways. Others use product feature proxies. Many rely on incomplete datasets.

We provide a loan-level classification methodology grounded in the complete ATR/QM regulatory framework from 12 CFR §1026.43. By applying these regulatory definitions to every HMDA record, we identify the 2024 Non-QM market at $182 billion across 558,979 loans.

This guide shows you how to analyze Non-QM using loan-level data to answer critical business questions:

Where are Non-QM loans concentrated geographically? Which product features trigger volume in specific markets? How does your market share compare to competitors by MSA or county? What are the growth trajectories in your footprint?

Loan-level HMDA data provides answers with census-tract precision.

Step 1: Understand Why Loan-Level Non-QM Data Matters

Non-QM evolved from specialty lending into mainstream mortgage origination. The market now represents 9% of total originations by loan count and 8.9% by dollar volume. DSCR loans, bank statement programs, and investor products drive growth across different geographies.

Analyzing the Non-QM market effectively requires local market precision. Calculating market share needs competitor benchmarks. Product development demands feature-level analysis. Fair lending compliance requires census-tract visibility.

Aggregate market statistics cannot provide this granularity. Loan-level mortgage data is essential for strategic analysis.

Step 2: Analyze Geographic Non-QM Concentrations

Map Non-QM Originations by MSA, County, and Census Tract

Loan-level Non-QM data reveals concentration patterns by MSA, county, and census tract. Detroit MSA originated 3,195 Non-QM loans in 2024, representing 43% year-over-year growth. Each loan maps to a specific census tract, showing exactly where origination volume concentrates.

This geographic precision supports resource allocation. Marketing budgets follow actual demand patterns. Branch locations target high-opportunity corridors. Underwriting capacity scales to regional volume. Broker recruitment focuses on markets with demonstrated Non-QM activity.

Step 3: Identify Non-QM Product Mix and Classification Triggers

Understand What Drives Non-QM Classification in Your Markets

Understanding what triggers Non-QM classification matters for product strategy and competitive positioning. Our analysis of 558,979 Non-QM loans in 2024 shows:

  • 58.7% driven by purchaser type (loans sold to private securitizers)
  • 23.1% triggered by multiple classification factors
  • 9.7% due to balloon payment features
  • 8.5% from elevated pricing above QM thresholds

These distributions vary significantly by geography. Some markets show heavy DSCR loan concentration for investor properties. Others lean toward bank statement underwriting for self-employed borrowers or pricing-driven classifications for jumbo loans.

Product development teams can use this intelligence to design offerings that match local demand rather than national trends.

Step 4: Benchmark Your Competitive Position

Track Lender Market Share and Fair Lending Patterns

Loan-level data identifies the top Non-QM lenders in any geography. You can track their volume trends, analyze their product characteristics, and measure market share with precision.

Census tract mapping reveals fair lending patterns. You can overlay originations on income classifications and measure exactly where your footprint has gaps relative to market opportunity.

Step 5: Track Historical Non-QM Trends

Analyze Seven Years of Market Momentum

HMDA loan-level data covers 2018 through 2024. You can track how Non-QM evolved through regulatory changes including the Temporary GSE Patch expiration in October 2022 and the transition to price-based QM standards.

This historical view shows structural trends rather than quarterly volatility. Growth trajectories become measurable. Regional market maturity becomes visible. Product feature adoption patterns emerge clearly.

How We Classify Non-QM Loans: The Methodology

We classify every HMDA record from 2018 through 2024 using the complete ATR/QM regulatory framework from 12 CFR §1026.43.

Each loan receives evaluation against year-specific criteria:

- Price-based thresholds (APR vs. APOR by loan amount tier)

- Points and fees caps with annual adjustments

- Product feature restrictions (balloon, interest-only, negative amortization)

- Purchaser type and secondary market execution

The classification logic follows regulatory definitions precisely while remaining transparent and reproducible. Every loan's Non-QM designation can be inspected to understand the specific triggering factors.

Business-purpose loans including DSCR products are flagged separately since they fall outside ATR/QM scope but represent a significant market segment.

2024 Non-QM Market Profile

The 558,979 Non-QM loans originated in 2024 demonstrate these market characteristics:

  • Total origination volume: $182 billion
  • Market share: 9.0% by loan count, 8.9% by dollar volume
  • Average Non-QM loan amount: $325,366
  • Average interest rate: 7.538%
  • Average applicant income: $277,371

These national statistics mask substantial regional variation. High-cost coastal markets show different loan amounts than Midwest metros. Investor-heavy Sun Belt regions demonstrate distinct income profiles. Markets with high self-employment concentration show different product preferences.

Understanding your specific market requires local loan-level intelligence rather than national averages.

How Different Teams Use Non-QM Loan-Level Data

Loan-level Non-QM analysis supports different organizational needs:

Executive leadership measures total addressable market and competitive market share at strategic geographic levels.

Product development analyzes which features drive volume and how pricing affects demand in specific segments.

Sales and marketing identify high-opportunity markets and allocate resources based on actual local demand rather than national trends.

Compliance teams demonstrate fair lending across census tract income classifications with precise geographic overlays.

Secondary market teams understand pool composition and geographic concentration before securitization.

All these applications require loan-level granularity for accurate analysis.

What You Gain from Loan-Level Non-QM Analysis

Loan-level data makes market share measurable rather than estimated. You can calculate your competitive position in any MSA, county, or census tract with precision instead of relying on industry estimates or samples.

Competitive intelligence becomes actionable when you can identify which lenders operate in your markets, track their origination volume trends, and analyze their Non-QM product mix and pricing strategies at the local level.

Product strategy becomes evidence-based. You can measure exactly which underwriting features and pricing approaches generate volume in your geographic footprint. This reveals whether DSCR products, bank statement programs, or interest-only features actually drive demand in your markets.

Fair lending compliance gains precision through census tract mapping. You can overlay your Non-QM originations against market benchmarks across income classifications and identify gaps in LMI (low-to-moderate income) communities before regulatory review.

Secondary market execution improves when you understand pool composition and geographic concentration before securitization. Loan-level analysis lets you benchmark your Non-QM production against market standards for investor appetite.

Moving Beyond National Non-QM Statistics

National market trends provide context. Local market data drives decisions.

You compete in specific geographies with specific customer segments, not nationally.

Knowing that Non-QM grew to 9% market share nationally matters less than knowing it grew 43% in Detroit while showing different patterns in other metros.

Understanding that purchaser type drives 58.7% of Non-QM classifications nationally matters less than knowing how that distribution varies in your primary markets.

Loan-level HMDA data provides the local precision that aggregate statistics cannot deliver for Non-QM market analysis.

Watch Our Non-QM Market Intelligence Webinar

We show how Polygon Research identifies and classifies Non-QM loans using public data, and what that reveals about market structure, pricing, competition, and borrower profiles nationally and locally.

Joined by mortgage consultant Dana Georgiou, who advises small and mid-sized lenders on Non-QM strategy and operations, we walk through a repeatable framework for analyzing Non-QM in your market—loan-level characteristics, pricing patterns, competitive positioning, and the demographic factors driving demand.

Explore the Data

Polygon Vision provides interactive access to loan-level Non-QM intelligence across all U.S. markets in its HMDAVision and CensusVIsion. Filter by geography, lender, product features, and time period. Map census-tract concentrations. Track historical trends.

Download the Methodology White Paper →

Request a Demo →

Start a Free Trial →

How to Analyze the Non-QM Market with Loan-Level Data

Learn how to analyze the Non-QM market using loan-level HMDA data. Discover geographic trends, competitive positioning, product mix analysis, and growth opportunities across all U.S. markets.

Analyzing the Non-QM market requires more than national statistics. According to our estimates, the Non-QM lending reached $182 billion in 2024, representing 9% of total mortgage originations. Unlike FHA or conventional loans, there is no standard flag or universal definition for Non-QM in public data sources.

Different vendors and investors have developed their own definitions based on varying methodologies. Some focus on securitization pathways. Others use product feature proxies. Many rely on incomplete datasets.

We provide a loan-level classification methodology grounded in the complete ATR/QM regulatory framework from 12 CFR §1026.43. By applying these regulatory definitions to every HMDA record, we identify the 2024 Non-QM market at $182 billion across 558,979 loans.

This guide shows you how to analyze Non-QM using loan-level data to answer critical business questions:

Where are Non-QM loans concentrated geographically? Which product features trigger volume in specific markets? How does your market share compare to competitors by MSA or county? What are the growth trajectories in your footprint?

Loan-level HMDA data provides answers with census-tract precision.

Step 1: Understand Why Loan-Level Non-QM Data Matters

Non-QM evolved from specialty lending into mainstream mortgage origination. The market now represents 9% of total originations by loan count and 8.9% by dollar volume. DSCR loans, bank statement programs, and investor products drive growth across different geographies.

Analyzing the Non-QM market effectively requires local market precision. Calculating market share needs competitor benchmarks. Product development demands feature-level analysis. Fair lending compliance requires census-tract visibility.

Aggregate market statistics cannot provide this granularity. Loan-level mortgage data is essential for strategic analysis.

Step 2: Analyze Geographic Non-QM Concentrations

Map Non-QM Originations by MSA, County, and Census Tract

Loan-level Non-QM data reveals concentration patterns by MSA, county, and census tract. Detroit MSA originated 3,195 Non-QM loans in 2024, representing 43% year-over-year growth. Each loan maps to a specific census tract, showing exactly where origination volume concentrates.

This geographic precision supports resource allocation. Marketing budgets follow actual demand patterns. Branch locations target high-opportunity corridors. Underwriting capacity scales to regional volume. Broker recruitment focuses on markets with demonstrated Non-QM activity.

Step 3: Identify Non-QM Product Mix and Classification Triggers

Understand What Drives Non-QM Classification in Your Markets

Understanding what triggers Non-QM classification matters for product strategy and competitive positioning. Our analysis of 558,979 Non-QM loans in 2024 shows:

  • 58.7% driven by purchaser type (loans sold to private securitizers)
  • 23.1% triggered by multiple classification factors
  • 9.7% due to balloon payment features
  • 8.5% from elevated pricing above QM thresholds

These distributions vary significantly by geography. Some markets show heavy DSCR loan concentration for investor properties. Others lean toward bank statement underwriting for self-employed borrowers or pricing-driven classifications for jumbo loans.

Product development teams can use this intelligence to design offerings that match local demand rather than national trends.

Step 4: Benchmark Your Competitive Position

Track Lender Market Share and Fair Lending Patterns

Loan-level data identifies the top Non-QM lenders in any geography. You can track their volume trends, analyze their product characteristics, and measure market share with precision.

Census tract mapping reveals fair lending patterns. You can overlay originations on income classifications and measure exactly where your footprint has gaps relative to market opportunity.

Step 5: Track Historical Non-QM Trends

Analyze Seven Years of Market Momentum

HMDA loan-level data covers 2018 through 2024. You can track how Non-QM evolved through regulatory changes including the Temporary GSE Patch expiration in October 2022 and the transition to price-based QM standards.

This historical view shows structural trends rather than quarterly volatility. Growth trajectories become measurable. Regional market maturity becomes visible. Product feature adoption patterns emerge clearly.

How We Classify Non-QM Loans: The Methodology

We classify every HMDA record from 2018 through 2024 using the complete ATR/QM regulatory framework from 12 CFR §1026.43.

Each loan receives evaluation against year-specific criteria:

- Price-based thresholds (APR vs. APOR by loan amount tier)

- Points and fees caps with annual adjustments

- Product feature restrictions (balloon, interest-only, negative amortization)

- Purchaser type and secondary market execution

The classification logic follows regulatory definitions precisely while remaining transparent and reproducible. Every loan's Non-QM designation can be inspected to understand the specific triggering factors.

Business-purpose loans including DSCR products are flagged separately since they fall outside ATR/QM scope but represent a significant market segment.

2024 Non-QM Market Profile

The 558,979 Non-QM loans originated in 2024 demonstrate these market characteristics:

  • Total origination volume: $182 billion
  • Market share: 9.0% by loan count, 8.9% by dollar volume
  • Average Non-QM loan amount: $325,366
  • Average interest rate: 7.538%
  • Average applicant income: $277,371

These national statistics mask substantial regional variation. High-cost coastal markets show different loan amounts than Midwest metros. Investor-heavy Sun Belt regions demonstrate distinct income profiles. Markets with high self-employment concentration show different product preferences.

Understanding your specific market requires local loan-level intelligence rather than national averages.

How Different Teams Use Non-QM Loan-Level Data

Loan-level Non-QM analysis supports different organizational needs:

Executive leadership measures total addressable market and competitive market share at strategic geographic levels.

Product development analyzes which features drive volume and how pricing affects demand in specific segments.

Sales and marketing identify high-opportunity markets and allocate resources based on actual local demand rather than national trends.

Compliance teams demonstrate fair lending across census tract income classifications with precise geographic overlays.

Secondary market teams understand pool composition and geographic concentration before securitization.

All these applications require loan-level granularity for accurate analysis.

What You Gain from Loan-Level Non-QM Analysis

Loan-level data makes market share measurable rather than estimated. You can calculate your competitive position in any MSA, county, or census tract with precision instead of relying on industry estimates or samples.

Competitive intelligence becomes actionable when you can identify which lenders operate in your markets, track their origination volume trends, and analyze their Non-QM product mix and pricing strategies at the local level.

Product strategy becomes evidence-based. You can measure exactly which underwriting features and pricing approaches generate volume in your geographic footprint. This reveals whether DSCR products, bank statement programs, or interest-only features actually drive demand in your markets.

Fair lending compliance gains precision through census tract mapping. You can overlay your Non-QM originations against market benchmarks across income classifications and identify gaps in LMI (low-to-moderate income) communities before regulatory review.

Secondary market execution improves when you understand pool composition and geographic concentration before securitization. Loan-level analysis lets you benchmark your Non-QM production against market standards for investor appetite.

Moving Beyond National Non-QM Statistics

National market trends provide context. Local market data drives decisions.

You compete in specific geographies with specific customer segments, not nationally.

Knowing that Non-QM grew to 9% market share nationally matters less than knowing it grew 43% in Detroit while showing different patterns in other metros.

Understanding that purchaser type drives 58.7% of Non-QM classifications nationally matters less than knowing how that distribution varies in your primary markets.

Loan-level HMDA data provides the local precision that aggregate statistics cannot deliver for Non-QM market analysis.

Watch Our Non-QM Market Intelligence Webinar

We show how Polygon Research identifies and classifies Non-QM loans using public data, and what that reveals about market structure, pricing, competition, and borrower profiles nationally and locally.

Joined by mortgage consultant Dana Georgiou, who advises small and mid-sized lenders on Non-QM strategy and operations, we walk through a repeatable framework for analyzing Non-QM in your market—loan-level characteristics, pricing patterns, competitive positioning, and the demographic factors driving demand.

Explore the Data

Polygon Vision provides interactive access to loan-level Non-QM intelligence across all U.S. markets in its HMDAVision and CensusVIsion. Filter by geography, lender, product features, and time period. Map census-tract concentrations. Track historical trends.

Download the Methodology White Paper →

Request a Demo →

Start a Free Trial →

Learn more

Frequently asked questions

How does Polygon identify Non-QM loans without an official HMDA flag?
Because HMDA does not include an explicit QM indicator, Polygon Research reconstructs QM and Non-QM status using observable loan-level fields such as interest rate, points and fees, DTI, product features, and pricing thresholds aligned with Regulation Z.
Is Polygon's Non-QM classification a legal determination?
No. Polygon Research's Non-QM designation is a Regulation Z informed analytic classification designed for market intelligence, benchmarking, and strategy. It is not a substitute for lender-side legal or compliance determinations.
Why does Polygon Research's Non-QM market share differ from other industry estimates?
Most industry estimates rely on securitization data, inferred flags from known Non-QM lender names, samples, or lock activity. Polygon analyzes all funded HMDA loans, including portfolio lending, providing a more complete and transparent view of the Non-QM market.
How large is the Non-QM market according to Polygon Research?
Polygon Research estimates that about 9% of closed loans in 2024 were Non-QM, representing approximately $182 billion in production, including both securitized and portfolio loans.
Can I customize how Non-QM is defined in HMDAVision?
Yes. Polygon's Non-QM classification is fully transparent and built on specific, loan-level reason codes (pricing, fees, product features, purchaser type, and more). Users can filter and adjust these factors to focus only on regulatory features or build a custom definition aligned with their strategy, risk, or compliance needs.
Are investor and business-purpose loans included in the Non-QM category?
Yes. For analytical purposes, business-purpose and DSCR loans are incorporated into the Non-QM category and flagged separately, even though ATR/QM rules do not govern business-purpose credit.

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