Is a rotating savings club/scheme/ROSCA which pays out regularly, treated as income for UC?

My colleague’s client is a taxi driver and homeless. My colleague wants to try and establish if he is entitled to UC in order to assess affordability for housing. Client’s bank statements show regular income from a source other than his self-employment.
On exploration, it transpires this is an interest free rotating savings scheme based on mutual trust. The client pays £100pcm to a friend in his community and then gets regular variable payments from this. It’s a form of money pooling, similar to what is described here: https://debtcamel.co.uk/pardners-friends-save-borrow-club/

The client has had on average, £500pcm over the last 4 months from the scheme. I can see that this doesn’t fall under the definition of unearned income falling to be taken into account under UC in UC Regs 2013 reg 66.
But there is also 46 (3), which is detailed in the ADM,
“H5100 Any sums that are paid
1. regularly and
2. with reference to a period of time
have to be treated as income even if they would normally be regarded as capital or as having a capital
element.”

Do his payments from the savings scheme fall to be counted as income for UC (which he has not yet claimed)?

I don’t think that Reg 46(3) is what you need to consider. UC has a list of what counts as unearned income, and if a type of income is not in this list, then it does not count

See Reg 66 UC regs for the list

I don’t think a payment like you’re describing is listed?

I thought the same, but wondered if it is something that would be viewed as ‘having a capital element’ as it’s a savings scheme.
My gut says it’s not counted as income but wanted to check!