We do a lot of loans to large truck lease and rental companies. We've previously always reported the address of the leasing company. Recently there has been discussions that we should possibly be reporting the address of the company that our borrower lease's the vehicles to instead.

I'm hesitant to do that since they aren't our borrower and have never done so in the past and have never had issues.

Thoughts???

I disagree.

You loan the money to your customer and in my mind the buck stops there. If you didn't loan money to that customer they wouldn't be in business. Your loan is enabling them to open their doors and rent vehicles to others, your loan does not directly fund the operations of your customer's customer.

First, does the business meet the "size" test by fitting into the standards of the SBDC, SBIC, or have less than 1MM in revenue? If so then does it meet the "purpose" test. By providing financing are they specifically stating that they will be able to hire more people, or retain their current employees. If this is a floor loan that does not qualify for the lending test as they are agreements, but may be provided to examiners as supplementary information.

Second, you would geocode the leasing company, and not the leasing customers address as the loan would benefit an area that would include the AA. Remember, we can qualify a loan if its benefit is helping an area such as a greater metropolitan area that also includes the AA. For instance, if you lend to a CDFI you would more often than not state that the benefit is state/region/nationwide rather than the office of the CDFI.