Can capital gain distributions inside a retirement account (IRA/Roth) be used as qualifying income?

Gains that stay inside the account aren't income yet. What lenders can count is a documented pattern of money actually coming out to you. Capital gains that simply reinvest inside an IRA or Roth can't be used to qualify, because you aren't receiving the money. Retirement-account distributions can: if you're drawing from the account on a regular, documented basis and the balance supports that draw continuing for at least three years, the distribution income qualifies. Lenders test regularity and continuance rather than your age, so this isn't gated to any IRS penalty age; distributions before 59 and a half can qualify when they're documented and ongoing. Just weigh any early-withdrawal penalty as a real cost before building a plan around pre-retirement draws. Capital gains in a taxable, non-retirement account are their own income category with their own test: lenders generally want a two-year history of realized gains on your returns, plus the underlying assets still in place to keep generating them. A sizable investment account throwing off gains year after year can support a qualifying income figure, provided the balance stays invested. The trap to avoid is double-counting. A given account can't be your income source and your down payment at the same time, because once you pull the funds out to close, they stop producing the gains or distributions you were counting on. One job per pool of money.