Unless something new has been released that I am unaware of, there is no exemption for reporting the revenues on any business lending. You have a choice of a code 1 for below one million in gross revenues, 2 for above and 3 for revenues unknown or not used in the credit decision. (I'm paraphrasing the last, but that's the gist).
If the revenues of the business were taken into consideration in making the loan, the appropriate code needs to be included on your LR.
If the revenues were not taken into consideration (and if not, you'd best hope there are NO financials on the business in the file) then the 3 is an appropriate code.
In all reality, there is no confidentiality problem with reporting revenues. A business entity is a seperate body in the eyes of CRA from a person. You aren't reporting specific revenues, you're reporting above or below one million. It's probably well known that the business revenues are one or the other if the employee has been with you for more than a few days. My guess being that if he/she were running a multi-million dollar business...they wouldn't have time to be a banker as well. If they wanted this to be a secret, they could easily have gone elsewhere for their loan.
In the eyes of CRA it's important to know how many true small businesses a bank is really lending to. Since the reporting is guided by loan size and not revenues, using the revenues to further sort your data is the only way to get to the information. Hence the lack of an ability to waive reporting.
_________________________
Dawn Coursey VP/CRA Queen
CRA Rating is in...Oh who cares...I'm home with the baby.