CRA and COVID 7 – For PPP loans…with loan amounts of $1 million or less, made to an existing bank customer, should a bank report revenue…based on what it had previously gathered about that business?

Compliance > Regulation BB - CRA
Q:   For PPP loans reported as small business loans (Type 01), with loan amounts of $1 million or less, made to an existing bank customer, should a bank report revenue on the CRA loan register based on what it had previously gathered about that business? For a new PPP borrower, which has an unknown revenue, may banks use a revenue estimate and report it as having gross annual revenues of “1” (gross annual revenues of $1 million or less) or must they use a CRA revenue code of “3” ( unknown/not used in credit decision)
 
A:   Generally, a bank should rely on and report the gross annual revenues that it considered in making its credit decision. Loans for which the bank did not collect revenue information may not be included when evaluating a bank’s performance in lending to businesses and farms with gross annual revenues of $1 million or less unless the small business or small farm provides supplemental information or the bank has another source demonstrating the borrower’s revenue, such as information on existing customers. Banks that have access to an applicant’s gross annual revenue information may, but are not required to, report that information. When evaluating CRA performance, the agencies will take into account the unique circumstances affecting borrowers and banks resulting from the COVID-19 emergency and will not penalize a bank for making a large volume of loans for which gross annual revenue information is not available. The agencies will also take into account a bank’s good faith efforts demonstrably designed to support low- and moderate-income individuals and small businesses and small farms and its efforts to comply with applicable consumer protection laws.
 
 
This Q&A was contained in the Interagency “Community Reinvestment Act (CRA) Consideration for Activities in Response to the Coronavirus Pandemic Frequently Asked Questions (FAQs)” initially issued May 27, 2020, and later updated.  This issuance may be found here: 
 

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