Consumer Compliance Outlook 2Q 2011 – CRA – If cash flow analysis is performed using gross income, may an institution use “NA” in reporting gross annual revenue?

Compliance > Regulation BB - CRA
Q:  If cash flow analysis is performed using gross income, may an institution use “NA” in reporting gross annual revenue?
 
A:     Q&A ___.42(a)(4)-2 (page 11670 of the Federal Register notice ) discusses the reporting requirements for gross annual revenue for small business or small farm loans. If an institution that is not exempt from data collection and reporting does not request or consider revenue information to make the credit decision regarding a small business or small farm loan, 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. Loans for which the institution did not collect revenue information may not be included in the loans to businesses and farms with gross annual revenues of $1 million or less when reporting these data.
 
 
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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