Consumer Compliance Outlook 2Q 2011 – CRA – When reporting revenue for CRA data, are the terms co-borrower, guarantor, and co-signer used interchangeably when determining whether to include revenue?

Compliance > Regulation BB - CRA
Q:  When reporting revenue for CRA data, are the terms co-borrower, guarantor, and co-signer used interchangeably when determining whether to include revenue?
 
A:     Q&A ___.42(a)(4)-1 (page 11669 of the Federal Register notice ) discusses the revenue to be included in determining whether a small business borrower had gross annual revenues of $1 million or less. Generally, an institution should rely on the revenues that it considered in making its credit decision. The Q&A provides specific examples with affiliated business relationships. The Q&A further clarifies that revenue or income relied on from cosigners or guarantors that are not affiliates of the borrower should not be factored into the revenue determination.
 
 
 
ADDITIONAL INFORMATION:
This information was obtained from the Federal Reserve’s Consumer Compliance Outlook website and related materials from the November 2010 webinar on “Tips for Reporting Accurate HMDA and CRA Data,” which may be accessed here:  https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/
Users are advised that references to CRA Interagency Q&As may have been updated since that webinar.
 

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