Accounting
Former IRS commissioners warn of tax season delays
Published
1 month agoon

A group of former commissioners at the Internal Revenue Service is sounding the alarm about the thousands of layoffs at the agency in the midst of tax season.
Last week, the IRS
“I think it’s clear that, to any rational analysis, this makes no sense at all,” said John Koskinen, who was IRS commissioner from 2013-2017, in an interview with Accounting Today.
The IRS spent a year or more training probationary employees, who were hired after the IRS received more funding under the Inflation Reduction Act of 2022.
“A lot of these people have been there a year to two years, and are revenue agents and revenue officers, but also customer service,” said Koskinen. “And after a year of training with senior IRS people, they are now doing productive work on both customer service and filing. They can do more standard work, so the more senior people can handle a more complicated issue. So when you wipe them out, the more senior people then have to fill the gaps to the extent they can.”
Another former IRS commissioner, Chuck Rettig, who headed the agency from 2018-2022, pointed out in an email to Accounting Today that many IRS employees are military veterans.
“Almost 10% of current IRS employees (including ‘on probation’ new hires) are military veterans, more are proud members of the military reserves, many have volunteered to be deployed to war zones in defense of our country, numerous others are proud military families of active duty military personnel,” he wrote. “Many IRS filing season employees are spouses of current military personnel. A blanket reduction in force will disproportionally harm those who serve or have served our country and supported our military. I’m not advocating that every IRS employee remain in their current position, but IRS employees can be reskilled to help the IRS and taxpayers where such assistance is most needed.”
President Trump
“If they redesignate people away from investigatory activity to support the border, that will most certainly have an impact on the operations of the agency,” said Mark Everson, who was IRS commissioner from 2003-2007 and is currently vice chairman of tax consulting firm Alliant, in an interview late last month.
Koskinen, Rettig and Everson were among seven former IRS commissioners, along with Lawrence Gibbs, Fred T. Goldberg Jr., Charles Rossotti and Danny Werfel, who co-authored a
“If you were to ask the top chief executives in the world to name the best strategy to attack waste in their organizations and balance the books, there is one answer you would be very, very unlikely to hear: Take an ax to accounts receivable, the part of an organization responsible for collecting revenue,” the former commissioners wrote. “Yet the private sector leaders advising President Trump on ways to increase government efficiency are deploying this exact approach by targeting the Internal Revenue Service, which collects virtually all the receipts of the U.S. government — our nation’s accounts receivable division.”
Koskinen made a similar point. “I think it’s a high risk with limited rewards,” he told Accounting Today. “And the irony is this is an administration that claims to be worried about the deficit and claims to be looking for $2 trillion in savings. And it seems to be nonsensical to think that one good way to do that is to hamstring your revenue arm, your accounts receivable division.”
He spent 20 years in the private sector working on turning around failed companies. “The last thing we ever did was say, well, let’s deny funds to our revenue side, to the accounts receivable, and see how we do,” said Koskinen. “Our whole goal was to protect revenues and grow them, and so you protected accounts receivable, you protected sales. You wanted things to succeed and expand. To think that you’re going to help solve the deficit problem by collecting less revenue, I don’t know any business who thinks that’s the way to go. So I’m a little bit in disbelief with the timing and theory behind it. It just seems to me the net result of this is going to be fewer revenues are going to be collected than they would have otherwise.”
Tax season impact
He also believes the layoffs will have an impact on tax season. “What those new people do is free up the more experienced people who spend time training them to continue to pursue both improved taxpayer service and improved revenue collection,” said Koskinen. “It’s really going to hamstring the agency, and that’s assuming it doesn’t screw up the filing season. It just seems to me that this, together with the idea that people are going to go barefoot through the complicated systems in the middle of filing season, they just think that people don’t understand at all how the process at the IRS works and how important it is.”
He expects wait times to increase once again this tax season for taxpayers calling the IRS by phone for assistance after improvements last year. “We’ve gone from not being able to get through or having to wait 30 or 45 minutes to last year during the filing season you could get through in less than five minutes if you had a question,” said Koskinen. “And a chunk of those employees were brought in to expand the number of people answering the phones. I said at the time, it’s a no brainer. You want to improve phone service? Hire more people to answer the phones and train them. So a lot of these people have been hired over the last couple years and trained about answering the phones and answering the questions and being able to be helpful. And so when they disappear, it is not as if everybody else can answer phones faster. The phone service is going to decline.”
Approximately 3,500 of the layoffs are reportedly occurring in the Small Business/Self-Employed Division of the IRS, but the impact may go even further. “With the initial focus on terminating Small Business/Self-Employed Division (SBSE) probationary employees (generally, those hired within the past year), there should not be a significant impact on current filing season operations (which are managed by the Wage & Investment Division),” said Rettig. “Most SBSE examiners hired within the past year have likely been in training for much of that time which implies, there will not be much impact on current, open examinations. Much of that training is conducted by experienced examiners and IRS Counsel, who will now return to the field to assist in current examinations and ongoing litigation.”
Koskinen believes the impact will go beyond the Small Business unit, although he acknowledges improvements could be made. “Now, to the extent that some of this is in the Small Business division, they think they’re getting just people dealing with compliance, but a lot of those people are involved in customer service as well,” he said. “They’re not all revenue agents. It just appears to me this is being done by people who have no real understanding of how the process works and the risks that they’re taking. It’s not to say that over time, there aren’t things you could do to improve the operation. Hiring generally takes too long. The procurement system is too complicated, but a lot of private sector companies love that because they understand and they participate in the procurement system, because they know how it works, but you could smooth a lot of that out and speed it up. So I’m not saying you don’t need to improve operations. I’m just saying that firing a lot of people and disrupting the financing isn’t a really good way to go.”
Technology impact
The cutbacks could set back improvements in IRS technology that help with spotting tax evasion and noncompliance. “There will be a significant impact on the ability of the IRS to expand the volume of examinations going forward,” said Rettig. “However, the IRS is in a better position to identify potential noncompliance and conduct meaningful issue-focused examinations as a result of many important technological enhancements that have been implemented over the past five years. The IRS can now identify issues of noncompliance that would not have been remotely possible just a few years ago.”
The IRS has begun using artificial intelligence to detect tax cheats, but it still needs to rely on human beings to examine the returns.
“Fundamental technology upgrades and the onboarding of sophisticated data scientists have significantly enhanced internal and external IRS operating systems,” said Rettig. “The use of AI combined with enhanced Service-wide technology enhancements has greatly improved the ability of the IRS to select appropriate cases for examination and has greatly accelerated the pace of these examinations. However, these upgrades have not kept pace with ever-increasing responsibilities and challenges facing the IRS. Technology helps define the path forward but the ultimate resolution of an issue typically requires an experienced person to be involved. The IRS still needs specialized examiners and related resources to actually conduct examinations and determine deficiencies, as well as others to represent the IRS in administrative appeals and possibly litigation. All of these folks need constant training, and the more experience, the better for both the IRS and the taxpayer.”
The IRS will lose many of the employees it has spent the past few years training on its technology. “It’s one thing to say you’re a probationary employee, but in IT where they’ve been hiring people again, trying to improve the systems, you may have only been there a year or two, but you get hired because you’re an expert, because you know how to deal with all this,” said Koskinen.
The IRS has been able to use the extra funding it gained in recent years to improve its array of digital tools for taxpayers.
“Regarding taxpayer services, the IRS has launched more digital tools in the last two years than in the previous 20 years, including more than two dozen new features and enhancements to individual and tax professional online accounts; the launch of a business tax account; the release of 30 digital mobile-adaptive forms; the ability for taxpayers to receive their refund status via a conversational hotline; a mobile-friendly web tool for Where’s My Refund; and Direct File, which allows taxpayers to file directly with the IRS for free,” said Rettig. “On the horizon, enhanced IRS digital self-service options will provide a private-sector-like experience, allowing taxpayers to interact almost entirely from their mobile phones, in the language most convenient for the taxpayer.”
Cybersecurity and privacy issues
The layoffs could affect the cybersecurity of the IRS’s confidential taxpayer data, which is constantly under attack. “The IT people spend a lot of time not only making sure the systems run, but protecting the systems from cyber criminals,” said Koskinen. “Originally I was told we got pinged a million times a day, and it finally got to 4 million times a day. These are organized crime syndicates around the world. When I started, we were sending almost $6 billion a year in false refunds to criminals everywhere.”
The Security Summit partnership that the IRS started with the tax prep industry and state tax authorities while Koskinen was commissioner managed to reduce that amount of fraud, but it may be at risk now due to the layoffs.
“We did a partnership with the private sector and state tax authorities, and I think it’s under a billion now,” he said. “We cut the number of taxpayers adversely affected because somebody had already filed on their behalf by close to 90% now, but that was all because we got much quicker on our feet. That means there are still criminals out there trying to figure out how to defeat the whole system. So it’s not simple. A lot of work has gone into trying to make it as smooth and efficient as possible, and these actions are just totally contrary to those desires.”
The staffing reductions may now encourage fraudsters and identity thieves to cheat on their taxes or steal other people’s tax refunds.
“If you thought that suddenly the IRS is starting to be underfunded again, maybe there’s a good chance that they’re not going to be as quick on their feet as they used to be,” said Koskinen. “They’re literally pinging it millions of times a day. They’re continually trying to reverse engineer what stops, what gets through? If something gets through, that’s what they’ll do. We’ll send you more of those, because they’re very thoughtful and careful not to apply for huge refunds. They apply for a $3,000 refund or $4,000 or $1,500, but they apply for hundreds of thousands of them. They’re always looking for where the weakness is in the system, where they can get in and file for a $2,500 refund and get it done before [the legitimate taxpayer] files.”
Taxpayer privacy could be affected by the cuts. “You need to be exceptionally careful on data analytics and artificial intelligence for two reasons,” said Everson. “One, they’ve got to make sure that they maintain taxpayer privacy. And two, the rules that get embedded in these kinds of exercises can’t have some unintended consequence, and the degree to which they’re going to be relatively more thinly manned, if that’s what happens, then you can get people who aren’t looking at what the contractors are doing, or aren’t very clear on what the rules are delivering. So I do think that this task of deploying the technology gets harder in this environment.”
The IRS also worked to disrupt cybercriminals during Rettig’s term. “During my term as Commissioner (2018-2022), the IRS-CI Cyber Unit significantly disrupted Dark Web terrorist financing arrangements for Hamas, al Qaeda and ISIS, disrupted international child exploitation sites operating in the Dark Web, disrupted financial transactions involving international drug cartels, located concealed assets of sanctioned Russian Oligarchs and performed the largest digital asset financial seizure ($3.6 billion) in our country’s history,” said Rettig.
The reports that Elon Musk’s Department of Government Efficiency team has been able to access sensitive taxpayer data has also
“One of the things the agency feels most strongly about is protecting that data,” said Koskinen. “Employees can’t look at anybody’s return unless they have a clear reason to do so. I never saw anybody’s tax return.”
He acknowledged that some researchers can get access for specific purposes. “A lot of researchers do statistical analysis, which is helpful to the IRS,” said Koskinen.
The Biden administration also set its priorities for the IRS, Everson pointed out.
“What happened in the Biden administration is they made a policy pronouncement to go after the individuals that they felt had income of over $400,000, the higher-income individuals and large corporations,” said Everson. “Not all the research had been updated as to where the tax gap problem is. What I hope is that they take a complete, comprehensive update through the research arm on where the work should be done, and then redevelop the enforcement model. I’m not suggesting that they’re going to back away from everything, but I do think that focusing on those two areas is likely to be much diminished from where it was, in part because there won’t be the extra people coming on board because of the Republican majority view that they don’t want more enforcement. And also, in the world of partnerships, in the higher income or the corporations, it takes a great deal of training and experience before you’re effective. I just don’t think those people will be there.”
Tax refund delays
There is also a danger of delaying tax refunds, which will mean more angst for taxpayers.
“Over 70% of people get refunds, and so if you interfere with that, they’re not going to be pleased if you slow it down,” said Koskinen. “The agency spends a phenomenal amount of time focused on trying to make sure the highest priority is everybody’s treated fairly, the filing season goes smoothly, and people get answers to the questions they have that they need to make sure they’re filing returns correctly, and all of this is now disrupting that.”
Tax professionals will likely be fielding anxious questions from their clients, and the staffing cuts could mean the Practitioner Priority Service won’t be much help.
“In the bad old days, when customer service just declined because of the significant budget cuts, the Practitioner Priority line was an oxymoron,” said Koskinen, who heard complaints about it during a session with the American Institute of CPAs. “You can’t get through on the Practitioner Priority line any faster than if you’re just the public, because you have to have somebody there to answer the phone who knows what they’re doing.”
Staffing cutbacks would compound the problems with employees leaving the IRS due to retirement. “A lack of important staffing and funding may well impact the volume of examinations the IRS can conduct, but those selected for an examination will understand that a traditional tax examination by a modernized agency in a target-rich environment does not represent a significant challenge,” said Rettig.
“A high rate of attrition coupled with an aging workforce and a general hiring freeze from 2011 to 2018 is a significant concern in trying to determine the appropriate level of experienced staffing going forward. The current hiring freeze and terminations of probationary employees will serve to exacerbate these concerns. In the federal government system, it has historically been extremely difficult to compete with the private sector for top talent. Further, the recruitment, onboarding and training programs are somewhat cumbersome, at best. Most IRS employees come onboard with a sense of dedication to serving our country. It remains to be seen how current events might impact that dedication going forward.”
New IRS commissioner
The next IRS commissioner will have to decide what to do with the diminished staff and budget. Trump’s decision to
“There’s no paying much attention to precedent here,” said Koskinen. “Twenty-five years ago, Congress passed a statute for the first time, and the IRS commissioner was given a five-year term for two reasons. One is to encourage commissioners to stay longer than the usual two years or two and a half years for political appointees, so people would sign up for five. And the other reason was to take it out of politics to the extent you could.”
He noted that ever since 1998, every commissioner has been permitted to finish their term, even though some of it often lasted until the next administration. “It was just designed to make sure that people understood these are not political jobs in the formal sense,” said Koskinen.
The job of commissioner has traditionally been assigned to someone with management experience in running a large organization.
“This is the first time that a commissioner has not been allowed to finish,” said Koskinen. “And it’s an unfortunate precedent, because now, when you appoint a commissioner, the assumption will be you’re only going to be there for this president’s term.”
Congress may need to step in to safeguard the IRS and provide oversight. “Given the voluntary compliance nature of our system of taxation, Congress should start helping the IRS earn the trust and respect of the American people rather than attack it for political gain,” said Rettig. “For decades, the IRS has welcomed Congressional oversight at any level or degree desired.”
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Accounting
Senate unveils plan to fast-track tax cuts, debt limit hike
Published
10 hours agoon
April 2, 2025
Senate Republicans unveiled a budget blueprint designed to fast-track a renewal of President Donald Trump’s tax cuts and an increase to the nation’s borrowing limit, ahead of a planned vote on the resolution later this week.
The Senate
Republicans say they are assuming that the cost of extending the expiring 2017 Trump tax cuts will cost zero dollars.
The draft is a sign that divisions within the Senate GOP over the size and scope of spending cuts to offset tax reductions are closer to being resolved.
Lawmakers, however, have yet to face some of the most difficult decisions, including which spending to cut and which tax reductions to prioritize. That will be negotiated in the coming weeks after both chambers approve identical budget resolutions unlocking the process.
The Senate budget plan would also increase the debt ceiling by up to $5 trillion, compared with the $4 trillion hike in the House plan. Senate Republicans say they want to ensure that Congress does not need to vote on the debt ceiling again before the 2026 midterm elections.
“This budget resolution unlocks the process to permanently extend proven, pro-growth tax policy,” Senate Finance Chairman Mike Crapo, an Idaho Republican, said.
The blueprint is the latest in a multi-step legislative process for Republicans to pass a renewal of Trump’s tax cuts through Congress. The bill will renew the president’s 2017 reductions set to expire at the end of this year, which include lower rates for households and deductions for privately held businesses.
Republicans are also hoping to include additional tax measures to the bill, including raising the state and local tax deduction cap and some of Trump’s campaign pledges to eliminate taxes on certain categories of income, including tips and overtime pay.
The plan would allow for the debt ceiling hike to be vote on separately from the rest of the tax and spending package. That gives lawmakers flexibility to move more quickly on the debt ceiling piece if a federal default looms before lawmakers can agree on the tax package.
Political realities
Senate Majority Leader John Thune told reporters on Wednesday, after meeting with Trump at the White House to discuss the tax blueprint, that he’s not sure yet if he has the votes to pass the measure.
Thune in a statement said the budget has been blessed by the top Senate ruleskeeper but Democrats said that it is still vulnerable to being challenged later.
The biggest differences in the Senate budget from the competing House plan are in the directives for spending cuts, a reflection of divisions among lawmakers over reductions to benefit programs, including Medicaid and food stamps.
The Senate plan pares back a House measure that calls for at least $2 trillion in spending reductions over a decade, a massive reduction that would likely mean curbing popular entitlement programs.
The Senate GOP budget grants significantly more flexibility. It instructs key committees that oversee entitlement programs to come up with at least $4 billion in cuts. Republicans say they expect the final tax package to contain much larger curbs on spending.
The Senate budget would also allow $150 billion in new spending for the military and $175 billion for border and immigration enforcement.
If the minimum spending cuts are achieved along with the maximum tax cuts, the plan would add $5.8 trillion in new deficits over 10 years, according to the Committee for a Responsible Federal Budget.
The Senate is planning a vote on the plan in the coming days. Then it goes to the House for a vote as soon as next week. There, it could face opposition from spending hawks like South Carolina’s Ralph Norman, who are signaling they want more aggressive cuts.
House Speaker Mike Johnson can likely afford just two or three defections on the budget vote given his slim majority and unified Democratic opposition.

Financial advisors and clients worried about stock volatility and inflation can climb bond ladders to safety — but they won’t find any, if those steps lead to a place with higher taxes.
The choice of asset location for bond ladders in a client portfolio can prove so important that some wealthy customers holding them in a taxable brokerage account may wind up losing money in an inflationary period due to the payments to Uncle Sam,
“Thats going to be the No. 1 concern about, where is the optimal place to hold them,” Spranger said in an interview. “One of our primary objectives for a bond portfolio is to smooth out that volatility. … We’re trying to reduce risk with the bond portfolio, not increase risks.”
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The ‘peculiarly bad location’ for a bond ladder
Risk-averse planners, then, could likely predict the conclusion of the working academic paper, which was
“Few planners will be surprised to learn that locating a TIPS ladder in a taxable account leads to phantom income and excess payment of tax, with a consequent reduction in after-tax real spending power,” McQuarrie writes. “Some may be surprised to learn just how baleful that mistake in account location can be, up to and including negative payouts in the early years for high tax brackets and very high rates of inflation. In the worst cases, more is due in tax than the ladder payout provides. And many will be surprised to learn how rapidly the penalty for choosing the wrong asset location increases at higher rates of inflation — precisely the motivation for setting up a TIPS ladder in the first place. Perhaps the most surprising result of all was the discovery that excess tax payments in the early years are never made up. [Original issue discount] causes a dead loss.”
The Roth account may look like a healthy alternative, since the clients wouldn’t owe any further taxes on distributions from them in retirement. But the bond ladder would defeat the whole purpose of that vehicle, McQuarrie writes.
“Planners should recognize that a Roth account is a peculiarly bad location for a bond ladder, whether real or nominal,” he writes. “Ladders are decumulation tools designed to provide a stream of distributions, which the Roth account does not otherwise require. Locating a bond ladder in the Roth thus forfeits what some consider to be one of the most valuable features of the Roth account. If the bond ladder is the only asset in the Roth, then the Roth itself will have been liquidated as the ladder reaches its end.”
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RMD advantages
That means that the Treasury inflation-protected securities ladder will add the most value to portfolios in a tax-deferred account (TDA), which McQuarrie acknowledges is not a shocking recommendation to anyone familiar with them. On the other hand, some planners with clients who need to
“More interesting is the demonstration that the after-tax real income received from a TIPS ladder located in a TDA does not vary with the rate of inflation, in contrast to what happens in a taxable account,” McQuarrie writes. “Also of note was the ability of most TIPS ladders to handle the RMDs due, and, at higher rates of inflation, to shelter other assets from the need to take RMDs.”
The
“If TIPS yields are attractive when the ladder is set up, distributions from the ladder will typically satisfy RMDs on the ladder balance throughout the 30 years,” McQuarrie writes. “The higher the inflation experienced, the greater the surplus coverage, allowing other assets in the account to be sheltered in part from RMDs by means of the TIPS ladder payout. However, if TIPS yields are borderline unattractive at ladder set up, and if the ladder proved unnecessary because inflation fell to historically low levels, then there may be a shortfall in RMD coverage in the middle years, requiring either that TIPS bonds be sold prematurely, or that other assets in the TDA be tapped to cover the RMD.”
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The key takeaways on bond ladders
Other caveats to the strategies revolve around any possible state taxes on withdrawals or any number of client circumstances ruling out a universal recommendation. The main message of McQuarrie’s study serves as a warning against putting the ladder in a taxable brokerage account.
“Unsurprisingly, the higher the client’s tax rate, the worse the outcomes from locating a TIPS ladder in taxable when inflation rages,” he writes. “High-bracket taxpayers who accurately foresee a surge in future inflation, and take steps to defend against it, but who make the mistake of locating their TIPS ladder in taxable, can end up paying more in tax to the government than is received from the TIPS ladder during the first year or two.”
For municipal or other types of tax-exempt bonds, though, a taxable account is “the optimal place,” Spranger said. Convertible Treasury or corporate bonds show more similarity with the Treasury inflation-protected securities in that their ideal location is in a tax-deferred account, he noted.
Regardless, bonds act as a crucial core to a client’s portfolio, tamping down on the risk of volatility and sensitivity to interest rates. And the right ladder strategies yield more reliable future rates of returns for clients than a bond ETF or mutual fund, Spranger said.
“We’re strong proponents of using individual bonds, No. 1 so that we can create bond ladders, but, most importantly, for the certainty that individual bonds provide,” he said.
Accounting
Why IRS cuts may spare a unit that facilitates mortgages
Published
12 hours agoon
April 2, 2025
Loan applicants and mortgage companies often rely on an Internal Revenue Service that’s dramatically downsizing to help facilitate the lending process, but they may be in luck.
That’s because the division responsible for the main form used to allow consumers to authorize the release of income-tax information to lenders is tied to essential IRS operations.
The Income Verification Express Service could be insulated from what NMN affiliate Accounting Today has described of
“It’s unlikely that IVES will be impacted due to association within submission processing,” said Curtis Knuth, president and CEO of NCS, a consumer reporting agency. “Processing tax returns and collecting revenue is the core function and purpose of the IRS.”
Knuth is a member of the IVES participant working group, which is comprised of representatives from companies that facilitate processing of 4506-C forms used to request tax transcripts for mortgages. Those involved represent a range of company sizes and business models.
The IRS has planned to slash thousands of jobs and make billions of dollars of cuts that are still in process, some of which have been successfully challenged in court.
While the current cuts might not be a concern for processing the main form of tax transcript requests this time around, there have been past issues with it in other situations like 2019’s lengthy
President Trump recently signed a continuing funding resolution
The mortgage industry will likely have an additional option it didn’t have in 2019 if another extended deadlock on the budget emerges and impedes processing of the central tax transcript form.
“It absolutely affected closings, because you couldn’t get the transcripts. You couldn’t get anybody on the phone,” said Phil Crescenzo Jr., vice president of National One Mortgage Corp.’s Southeast division.
There is an automated, free way for consumers to release their transcripts that may still operate when there are issues with the 4506-C process, which has a $4 surcharge. However, the alternative to the 4506-C form is less straightforward and objective as it’s done outside of the mortgage process, requiring a separate logon and actions.
Some of the most recent IRS cuts have targeted technology jobs and could have an impact on systems, so it’s also worth noting that another option lenders have sometimes elected to use is to allow loans temporarily move forward when transcript access is interrupted and verified later.
There is a risk to waiting for verification or not getting it directly from the IRS, however, as government-related agencies hold mortgage lenders responsible for the accuracy of borrower income information. That risk could increase if loan performance issues become more prevalent.
Currently, tax transcripts primarily come into play for government-related loans made to contract workers, said Crescenzo.
“That’s the only receipt that you have for a self-employed client’s income to know it’s valid,” he said.
The home affordability crunch and rise of gig work like Uber driving has increased interest in these types of mortgages, he said.
Contract workers can alternatively seek financing from the private non-qualified mortgage market where bank statements could be used to verify self-employment income, but Crescenzo said that has disadvantages related to government-related loans.
“Non QM requires higher downpayments and interest rates than traditional financing,” he said.
In the next couple years, regional demand for loans based on self-employment income could rise given the federal job cuts planned broadly at public agencies, depending on the extent to which court challenges to them go through.
Those potential borrowers will find it difficult to get new mortgages until they can establish more of a track record with their new sources of income, in most cases two years from a tax filing perspective.

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