We have a commercial customer, with one TIN, operating under one name, who sells both new and used cars. We have two separate floor plan lines - one for new and one for used. Examiner states we have to report the two different NAICS codes. Is this correct?

We have always operated on selecting the NAICS code associated with the business type that generates the majority of the revenue for the business.

However, in this case we would likely call the customer a used car dealer since that business type in itself is a higher risk business type.

It is also my understanding that NAICS code is not a requirement of due diligence/KYC however, it is widely used among banks to document a customer's business type and assign appropriate risks. Again, I would use the high risk NAICS of used car dealer as the primary NAICS and document in the customer file that they also sell new cars.

Thank you, Linz. Makes absolute sense!

Examiner states we have to report the two different NAICS codes.

Report where and what type of examiner are we talking about?