When reporting a renewal, I am struggling to understand what GAR to report if there were no updated financials used to make the credit decision.
For example, a small business loan was reported with a GAR of >$1 million. At renewal, this amount was once again relied on to make the credit decision to extend the loan. I feel like the original GAR would then be used for reporting the renewal transaction. Does this sound correct? I feel like this would be more accurate than reporting 'Not Known' simply because the financials were not updated.

Any feedback is appreciated- I am just trying to get this to make sense and I think I have thought about it too much.

If the GAR is stale, meaning more than a year old, and you didn't rely on it to make the credit decision I would chose revenue code 3 as appropriate. It won't matter too much however, because the only thing the examiners are interested in is your penetration rate lending to businesses with GAR<=$1 million. So entering code 2 or code 3 will produce the same results for LT 4. BTW, the only thing reported in the A&D data is code 1.

Thank you for responding!! I must state that I made a mistake in that original post and meant to give my example as a less than 1 million in revenue.

My gut was to report as Not Known since we would have no way to document that the revenues were still under 1 million- let's say after a year or so). If we reported income without updated financials that would be speculating that the business had no growth and seems too similar to 'predicted' income that is a no go (for start ups).

But there are just some cases where the revenue is well under- like for a small farm bringing in around 80k/year. In that case, I feel like it is reasonable and appropriate to mark as under 1 million. But that creates a whole can of worms because it is inconsistent practices on our part if we are making exceptions for some, but others are 'not known'. I don't like that no matter how reasonable it may seem.

I hope that makes sense.