We have a commercial loan, booked on our system as a commercial loan, where the note itself indicates that the borrowers are the Company AND two owners of that company.

The financials relied upon to make the credit decision were those of the company, not of the individuals.

Because the note indicates the owners are co-borrowers, do I need to report their information for government monitoring? I'm afraid if I do so it will create a data flag on the income, since we've entered it as NA.

Any ideas on this?

It sounds like the Company is the primary borrower and the individuals are co-borrowers. You need to collect the monitoring information on both individuals and report it for the first co-borrower (for the borrower, enter 4/7/4).

If you did not rely on the income of either individual in making the credit decision, income should be NA.

You should get quality warnings for the monitoring information and the income, but all you need to do is verify that the information is correct - you shouldn't have any problems with your submission.

Thanks, Hmdagal!