FRB FAQs-If the loan is to a start-up business but no actual revenue information has been provided, should revenue be recorded as “1”?

Compliance > Regulation C - HMDA > FRB FAQs
Q:  If the loan is to a start-up business but no actual revenue information has been provided, should revenue be recorded as “1”?
 
A:  Q&A ___.42(a)(4)-3 (page 11670 of the Federal Register notice ) clearly states that institutions should use the actual gross annual revenue to date (including $0 if the new business has had no revenue to date). Although a start-up business will provide the institution with pro forma projected revenue figures, these figures may not accurately reflect actual gross annual revenue and therefore should not be used.
 
 

This can be found in - CRA FAQ#6 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

 

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