One of our loan products is Indirect Auto Loans, occasionally we get an indirect loan for a business, however it is a consumer loan product. My question is if we have a business that is the borrower and the owner is the guarantor, are we required to report these loans to the CRA? We pull credit on the guarantor.

the owner is the guarantor, are we required to report these loans to the CRA?

Simple answer is no.

Personally, I would not be buying consumer dealer paper if the loan was to a business. There are many consumer covenants in consumer documents that I would not want in a business loan.

I agree. These should not be purchased for a consumer portfolio.

Thanks for the input. Is it permissable to report a guarantor to the CRA? The FCRA notice was provided to the guarantor at closing.

Sure, but only if your CRA reporting mechanism can code it properly as a guaranteed loan under the Metro II coding rules.