What do you report for gross annual revenue when the credit analysis shows the business had sales of $800K per the most recent year end tax return (2021) and "interim" sales of $1.2MM in 2022 based off of 10 months of data?

Do you ignore the interim figure even though it's over a million because, technically, we are to report gross ANNUAL revenue?

Thank you!

228.42(b) Loan information required to be reported. A bank, except a small bank or a bank that was a small bank during the prior calendar year, shall report annually by March 1 to the Board in machine readable form (as prescribed by the Board) the following data for the prior calendar year:

(1) Small business and small farm loan data. For each geography in which the bank originated or purchased a small business or small farm loan, the aggregate number and amount of loans:

(iv) To businesses and farms with gross annual revenues of $1 million or less (using the revenues that the bank considered in making its credit decision);

I generally only report annual figures, even if interim are available. For our underwriting, we may consider interim figures from a trend perspective, but run the ratios off of the year end figures. In cases like you describe where the GAR code would be different if we used interim figures, I just make a note that we used the previous full year figures in our underwriting, just in case an examiner picks up that file.

Thanks so much for your thoughts on this!

Our credit team does run ratios off the interim figures and does consider them so we will be reporting a GAR of 2 on these.