The purpose of collecting the GAR is so that examiners can determine how my of your small business loans really were extended to truly small businesses. This information is used in the "borrower characteristics" test during CRA exams and is an important factor in your CRA rating performance. So doing some remedial work is worth the effort IMO. You just need to show some documentation to support the number you report. I don't mean an audited financial statement. But you do need something from the borrower representing the GAR for the business. Typically 50% to 70% of small business loans are extended to businesses with GAR <= $1 mllion. This is the parameter that is one of the 2020 OCC's "comparators" (65% of market avg. penetration rate). If you don't collect the data your penetration rate will drop precipitously; I am certain examiners will take that into consideration for the PPP loans (make sure you segregate them),. but I would rather look like a hero with high penetration rates rather than someone beneath water having to explain how the PPP's adversely affected your penetration rate.
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