Thanks for your insights.

Just wanted to clarify that I would not be able to say “yes” that my income decreased because it had not decreased on a monthly basis despite being paid on a different schedule.

That is a really tricky question Derek.

First, I think it is important for me to point out that while I am a lawyer, I am not your lawyer. In a situation like this, I think the best answer would be to quote the language right from the IDR application.

Question 11 asks the following:

Has your income significantly decreased, or your marital status changed since you filed your last federal income tax return?

For example, have you lost your job, experienced a drop in income, or gotten divorced, or did you most recently file a joint return with your spouse, but you have since become separated.

I’d also note that the application includes the following statement: Any person who knowingly makes a false statement or misrepresentation on this form can be subject to penalties including fines, imprisonment, or both.

I won’t tell you what to do here, but I will say that if you talk to your servicer and they tell you to pick YES, your income has decreased, it is a good idea to document that interaction so that you have proof should it become an issue at a later date.

The pay structure of my current W4 job recently changed from a salary-based position to a basically “100% commission-based position.” This has resulted in a increase in yearly compensation, however, my pay is not “guaranteed.”

So now I am paid on a monthly “draw” schedule where my paystub is based on a percentage of my previous months production, with quarterly salary adjustments.

What ends up happening is that my monthly draw salary ends up being about ~50% of my total yearly compensation.

So, it seems unfair to me that if I were to recertify my income for IDR, my monthly loan payment would be based on my AGI despite almost half of my income not even being paid out per month.

Would it be reasonable to submit my paystubs instead of my tax returns for IDR recertification? Would this be considered a misrepresentation of my income?