This article started with a discussion on #TaxTwitter, that corner of Twitter (it will always be Twitter, sorry Elon) known for its sometimes contentious debates. Whether it’s pancakes versus waffles (spoiler: croissants are the real winners), #PumpkinGate IYKYK, or obscure sections of the tax code, tax pros rarely agree on much. (Special thanks to Deb Fox, CPA for bringing this to my attention and suggesting an article.)
But there’s one topic that unites us faster than anything else: mortgage comfort letters.
If you’ve been in practice long enough, you’ve probably had a client call you in a panic:
“My lender says they just need a letter from my CPA (which we know they really mean tax pro, EA, CPA, attorney, tax preparer) confirming my income. Can you write that up real quick?”
And just like that, you’re no longer their trusted tax professional — you’re suddenly being drafted into mortgage underwriting.
Where Comfort Letters Came From
Comfort letters really took off during the era of “stated income” loans, when self-employed borrowers didn’t fit neatly into W-2 boxes. Lenders started asking tax professionals to confirm facts: self-employment, reported income, years in business.
That was bad enough. But over time, those requests grew into something else entirely. Instead of simple confirmations, lenders began fishing for assurances like:
“Can you verify this borrower’s solvency?”
“Can you guarantee they’ll keep earning this much?”
“Can you vouch for the authenticity of all financial documents?”
In other words: they wanted us to be fortune-tellers and auditors rolled into one.
I actually remember this firsthand. Back in the early 2000s, when I worked in mortgage banking, we’d request these letters and then verify that the person signing it was a real professional. Once that box was checked, the file moved on. That was the whole process. Looking back, it feels almost absurd compared to the liability those same letters now try to push onto tax professionals.
Why Tax Pros Hate These Requests
Here’s the short version: the risk is all ours, the benefit is all the client’s, and the lender shrugs if things go sideways.
Liability risk: These letters often push us into promising things we can’t possibly know.
Violation of standards: Both the AICPA and state boards are clear — you can’t provide assurance outside the scope of an actual audit or review engagement.
Ethical conflicts: You’re caught between helping a client and protecting yourself, with the lender putting all the pressure on you.
I once had a lender ask me to certify that a client’s business would still be profitable five years down the road. Five years! Another time, I was asked whether it would “financially impact the client” if they withdrew $50,000 from their business account for a downpayment on their primary residence. Like seriously?
Requests like these are exactly why we need a strategy when clients call in a panic.
How to Handle Requests Without Burning Bridges
So what do you do when your client calls begging for help?
Set expectations early: Let clients know ahead of time you cannot provide certifications beyond factual info already on their filed tax returns.
Standardize your response: Keep a template letter handy confirming only the basics (e.g., “I prepared the 2023 tax return reporting X income” or “This taxpayer has been a client of mine for X years”). Always include disclaimers.
Lean on the rules: Reference professional standards and the policies of your insurance provider. The AICPA has even published guidance for comfort letters, which makes it clear what we should and should not say. Pointing clients and lenders to that guidance helps take the heat off you.
Make the lender own their job: Remind clients (and sometimes brokers) that lenders are responsible for their own due diligence. Your role is not to underwrite a mortgage — it’s simply to state the facts you can verify.
Always get authorization: Before sending anything to a lender, always, always obtain written authorization from the client. Protect yourself first.
Price for risk: If you do draft a letter, charge a meaningful fee. Risk and liability should never be “free.”
To make this real, here’s the type of mortgage comfort letter I provide, factual, minimal, and well within professional standards. (In this example, John Smith is a consultant who owns 100% of Smith Consulting, Inc.)
To Whom It May Concern:
This letter confirms that my firm has been engaged to prepare the tax returns for John Smith and Smith Consulting, Inc. for tax years 2019 through 2024. Mr. Smith is the 100% owner of Smith Consulting, Inc. All relevant information concerning income and expenses are reported on the tax returns that have been provided. Any lending decisions are the responsibilities of the lender and it is outside the scope of services to opine beyond our engagement letter.
Breaking it down: I’m simply stating the obvious. My firm prepared the returns, the client owns the entity, and that’s it. I have encountered the occasional pushback and wanting some “assurance” but in the end I stay firm and this suffices and every client has still made it to the closing table.
When You’re Cast as the Villain
Here’s the part nobody tells you about: sometimes the mortgage broker or real estate agent frames us as the reason the deal might fall apart.
I’ve had it happen more than once. In one case, a mortgage broker even drafted a comfort letter themselves, sent it over to me, and dropped it into DocuSign as if I’d just sign off. Needless to say, I did not.
The client, of course, was told I was the holdup. That’s one of the hardest parts of this whole issue: you’re trying to protect your license and follow professional standards, but you risk looking like the bad guy standing between someone and their new home.
I’ve also noticed that some mortgage brokers get downright insistent. My response is always the same: “Sorry, no.” There are plenty of reasons, as I’ve outlined here, but let’s be honest — who likes being told what to do by someone who doesn’t even understand our job?
Which is exactly why we have to stay firm: your license is worth more than their closing table.
Mortgage comfort letters are not part of your job description. They put your license and reputation on the line for the sake of a lender’s convenience.
Stick to the facts, protect your boundaries, and don’t be afraid to channel a little Rose Nylund from The Golden Girls energy when the request goes too far. Sometimes, the most professional thing you can say is:
“Blow it out your tubenburbles.”
We’ve all seen some wild asks in this business — so I’ll leave you with this: what’s your craziest comfort letter request?
There is something within the fannie and freddie rules where it says if they don't get a comfort letter that the lender can use alternative methods to gather this information. Like due diligence. lol
Thinking about sending a request to the lender for a comfort letter stating that by them granting this loan it will not impede the client from paying my fee for the next 5 years.
There is something within the fannie and freddie rules where it says if they don't get a comfort letter that the lender can use alternative methods to gather this information. Like due diligence. lol
Thinking about sending a request to the lender for a comfort letter stating that by them granting this loan it will not impede the client from paying my fee for the next 5 years.