Consumer complaint received 2018-07-05
Company: CITIBANK, N.A.
State: NY
Product: Mortgage
Sub-product: Home equity loan or line of credit (HELOC)
Issue: Applying for a mortgage or refinancing an existing mortgage

Complaint:
I disagree with Citibanks decision on XX/XX/XXXX, to deny my home equity line of credit application number XXXX. 
I believe Citibank didnt correctly follow the CFPBs regulations, defining what gross income means. 
Researching the Electronic Code of Federal Regulations, and questions and answers listed on the consumer financial protection bureau, gross income is defined as monthly income including taxes and other deductions. 
It is common knowledge that, payroll taxes include : - Social security taxes - XXXX taxes - Local income taxes ( XXXX  in my case ) - Federal income tax Per the documents I already provided Citibank with, my current income is made up of XXXX pension and social security income. Both are exempt from social security, XXXX and of XXXX income taxes. In addition, IRS will consider only 70 % of my security income as subject to federal income taxes. 

In my efforts to convert my net income to gross, I used percentages determined from actual pay stubs I received back in XXXX and XXXX. I did not use the money I earned back then in my current loan application, but rather the percentages representing the taxes deducted from gross income to arrive at net income. I then asked Citibank to increase my net income by the calculated percentages to arrive at the equivalent gross income. From the enclosed XXXX worksheet, the actual percentages of social security, XXXX and XXXX income taxes as related to net income received, totaled 17 % of the net income. In other words, since I dont have to pay any of such taxes, my net income should be increased by 17 % to be at par with other applicants gross income, since Citibank is equal opportunity lender. Not doing so will be in my opinion, discriminatory for people who receive pension and or social security income. That is without even claiming an additional percentage pertaining to the 70 % IRS exemption of my social security income ( I would have had to pay 100 % of the IRS rate had I earned that income through wages ). 
To demonstrate the point, Im enclosing a pay stub I received back in XX/XX/XXXX. The b-weekly stub shows net income of {$1700.00}. Back in XX/XX/XXXX, Citibank approved my mortgage application, based among other things, on acceptable debts to gross income ratio. I now make {$1900.00} and I only pay {$100.00} federal income tax, leaving me with a bi-weekly net income of {$1800.00}, which is more than what I made in XX/XX/XXXX. In other words, if someone with less than my take home pay, with same good credit score and high home equity, applies for a similar loan, that someone would have been  approved by Citibank, but not me or most of those who receive pension and or social security. I do believe such would be a discrimination against a large group of people, and not as claimed by Citibank : Equal opportunity lending. 
To add : Citibank refused to provide me with an explanation of the net to gross income ratio they used ( 11 % ), nor have they made even an effort to explain their definition of gross vs net income!

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation