When income is noted to in cra is it for the income of the
borrower or the small business revenue?

I'm not quite sure what the question is. When you say "income" are you talking about something a lender has noted?

For CRA purposes, we collect gross revenues of a business (small or large). Income (something people have, not businesses) is never a factor in CRA reporting.

our system has a place for cra income. I can't locate exactly what it is referring to, but from what you said and what I understand it would be the business income side.
Thanks

Are you referring to a "CRA Income" field? If so, it probably is for the CRA income codes, "1" is $1 million annual gross revenues or less, "2" is over $1 million annual revenue, "3" is revenue not considered or "4" is "NA". You must fill in the field when submitting your CRA annual data. The size of the borrower as measured by annual revenues is one of the tests applied during a CRA performance evaluation.

Anon I'd want to get to the root of the "income" field if I were you. Has your bank tracked income on consumer loans? This might be what the field is for (that would be a CRA code 4) or it might actually take an "income" figure. Personally, I wouldn't want to have to stumble my way through explaining the "income" field to an examiner like this:

"Well income really means revenues I think, but I'm not quite sure, so ummmm what we should do is check the numbers and see what they look like and take a guess...."

If the loan is to a "new" business, should the income field populated with a "1" or "NA"? I could not locate any regulatory guidance on this. Is there?

I assume you mean Revenues and not Income. You should report it as a 1 if the revenues are zero. You should not rely on proforma income.

Our CRA lady tell us that she has to have verified income on all borrowers (even consumer). She records (not reports) all consumer loans on the CRA data system.
Is there a requirement to have "verified" income when recording consumer loans? She records the data incase the bank decides to have examiner consider our consumer lending.

Again I'll say..."Income" is CONSUMER ONLY! Be sure to be clear on that

The only requirement would come into play if you decide to use the data during an exam. I addressed this in another post, but basically, any data you give to an examiner should have been through a strong data integrity test. You'll end up with egg on your face if you provide it and they find that it's crap. If she's checking it, you're in a better position than most at this point. I personally don't do data integrity on consumer lending because my small business lending is so strong I don't need the consumer "stuff". I do collect it, but don't expect to see a need for many years.

One thing to consider is...do you need it? I'd hate to be wasting time checking income on lending you probably would never submit for an exam. If you're doing it right, it takes time, and we all can normally use time elsewhere So is it worth your while? Or should you let it go like me and worry about other deals?