When revenues weren't used in rendering the credit decision or collected at the time of the loan request; however, revenue information (tax returns) is in the borrower's loan file, it's my understanding we should report the revenue information "on file". If so, and we're relying on the tax returns on file, how old can they be? For example, if we're originating a loan in 2021, could we reference the revenues from the 2019 tax returns contained in the borrower's loan file. Thank you!

"it's my understanding we should report the revenue information "on file"."

On what is that based?

Three years is my limit. So, since the most recent returns would be 2020, I would go back as far as 2018. My examiners have never taken an issue with it.

Why would you report revenue not used in the credit decision?

I am not the original poster but my guessing is : on "A guide to CRA data collection" page 13

" The regulations do not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, they should use the gross annual revenue rather than the adjusted gross annual revenue of their small business or small farm borrowers to report whether the borrower has gross annual revenue of a) more than $1 million dollars; or b) $1 million dollars or less. The purpose of small business and small farm data collection is to enable examiners and the public to judge whether the institution is lending to small businesses and farms or whether it is only making small loans to larger businesses and farms......."

don't know how others interpret this? Thank you!