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Reporting Revenue on Small Business LAR

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Question: 
When reporting revenue on the small business LAR can you please clarify the following for me: We have a loan program called "Low Doc" in which financials are not used in making the credit decision based on a number of factors, however we do have the revenue information from the customer. In order that these loans are not reported as a code 3 – and not counted in our CRA totals, is it appropriate in using the business revenues that the customer provided?
Answer: 

The best answer is from the CRA Guide. Note that initially it is specific in that if you have it, report it, and not that you report the income relied on to grant the loan. I added " * " for emphasis.

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 collect and report the gross annual revenue,*** rather than the adjusted gross annual revenue, of their small business or small-farm borrowers. 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.

The *** CRA regulations similarly do not require institutions to verify revenue amounts; thus, institutions may rely on the gross annual revenue amount provided by borrowers in the ordinary course of business ***. If an institution does not collect gross annual revenue information for its small-business and small-farm borrowers, it would not indicate on the CRA data collection software that the gross annual revenues of the borrower are $1 million or less. The institution should enter the code indicating “revenues not known” on the individual loan portion of the data collection software or on an internally developed system.

*** Generally, an institution should rely on the revenues that it considered in making its credit decision when indicating whether a small-business or small-farm borrower had gross annual revenues of $1 million or less. *** For example, in the case of affiliated businesses, such as a parent corporation and its subsidiary, if the institution considered the revenues of the entity’s parent or a subsidiary corporation of the parent as well, then the institution would aggregate the revenues of both corporations to determine whether the revenues are $1 million or less. Alternatively, if the institution considered the revenues of only the entity to which the loan is actually extended, the institution should rely solely upon whether gross annual revenues are above or below $1 million for that entity.

However, if the institution considered and relied on revenues or income of a cosigner or guarantor that is not an affiliate of the borrower, such as a sole proprietor, it should not adjust the borrower’s revenues for reporting purposes.

First published on 10/18/2020

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