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#2277921 - 11/15/22 03:00 PM CRA LR - Report revenue not used in decision?
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
If an institution collects current YE financial documents due to a larger lending relationship, but they don't rely upon them in making a credit decision for a loan we are reporting on the CRA LR, can we report the Borrower's revenue for that loan based on the current YE financial documents we possess, or MUST it be what was utilized in the specific loan's credit decision, which none were considered in this case (renewal of internal brokerage-secured loan)?

Furthermore, does your answer also apply to any Community Development Loans we may report as well?

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#2277931 - 11/15/22 06:06 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 566
Petersburg, VA
We report the revenue in those situations. It's harder to argue that you had it and it played no role whatsoever in your decision to grant credit, rather than just reporting what you have.

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#2277980 - 11/16/22 06:38 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
TMatt87 Offline
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,987
Idaho
Ditto.
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#2278258 - 11/28/22 06:49 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 175
VT
If you have access to revenue information you should report it, regardless of it being used or not in deciding on the loan. When looking at your distribution of small business loans compared to aggregate, anything with a "3" for revenue unknown gets dropped out the calculations and can have a negative effect on your performance.

Revenue information is never used when looking at qualified CD Loans.

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#2282882 - 03/31/23 12:37 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
Luv2run Offline
Platinum Poster
Joined: Jan 2015
Posts: 616
Would the same go for income from Guarantors on a loan?
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#2282884 - 03/31/23 01:15 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Income from Guarantors has nothing to do with revenues generated by the business.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2282932 - 03/31/23 07:22 PM Re: CRA LR - Report revenue not used in decision? Help! Compliance
Luv2run Offline
Platinum Poster
Joined: Jan 2015
Posts: 616
Perfect!!! Thanks very much RL!
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If at first you do succeed....try something harder
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