๐Ÿ“Œ FHA Loan FAQ: Do I Need a Manual Downgrade for a Decline in Self-Employment Income?

Question:
My client has W-2 income and some side self-employment income that declined by more than 20% this year. We’re not using that income to qualify โ€” do I still need to downgrade to a manual underwrite?

Answer:
No โ€” as long as the self-employment income is not used to qualify the borrower, a manual downgrade is not required, even if that income declined by more than 20%.

โœ… FHA Handbook 4000.1 Clarifies the Rule:

According to the FHA Single Family Housing Policy Handbook 4000.1, the requirement for a manual downgrade is tied specifically to โ€œEffective Incomeโ€ โ€” which refers only to income being used for qualification.

โ€œIf the income from businesses shows a greater than 20 percent decline in Effective Income over the analysis period, the Mortgagee must downgrade and manually underwrite.โ€
โ€” FHA Handbook 4000.1, Section II.A.4.c.x(B)(2), p. 229

So if you’re not using the self-employment income (like side business or hobby income) in the DTI or qualifying income, then a decline doesnโ€™t trigger a manual downgrade.


๐Ÿง  Pro Tip for Lenders:

  • Be sure the file clearly documents that the self-employment income is not used to qualify.
  • If the income is showing a loss, treat it appropriately (as a liability or adjustment).
  • Stable W-2 income and strong reserves can carry the file โ€” no need to downgrade just because of a side hustle fluctuation.