Requesting clarification on the gross up of public assistance income for unsecured personal loan. If during the application process the applicant is asked to include "income" (and there is not an option to select "employment", "retirement", etc.), is the creditor obligated to gross up benefits if discovered when requesting bank statements and/or pay stubs income source reveal public assistance income? I have looked to Reg B for rules concerning requests for information (1002.5) and evaluation of applications (1002.6) but cannot locate anything specific to this ask.

Thank you.

There isn't a requirement to gross-up, but you should follow your policy. Do any of your policies address grossing up? If your policies don't address grossing up, it would be highly beneficial from a fair lending perspective to be consistent in how you handle non-taxable income.