Skip to content
BOL Conferences
Thread Options
#2294669 - 03/12/24 03:27 PM Revenue - Personal Income Considered for DSCR
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 158
San Antonio, TX
In the underwriting notes of a loan, it was documented that the pertinent DSCR was based on stated income. In the past, this usually signified the usage of stated Revenue as allowed according to bank policy. However, in this case, the stated income mentioned was specific only to the personal income of 3 guarantors. If this was the case for a transaction that you were reporting on the CRA LR, would you report the Revenue Code based on the personal incomes, or would you document the Revenue as being unknown (3)?

Return to Top
CRA
#2294671 - 03/12/24 03:29 PM Re: Revenue - Personal Income Considered for DSCR Help! Compliance
Inherent_Risk Offline
Platinum Poster
Joined: Jan 2017
Posts: 663
Who is the borrower?

Return to Top
#2294675 - 03/12/24 03:53 PM Re: Revenue - Personal Income Considered for DSCR Inherent_Risk
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 158
San Antonio, TX
It is an LLC entity running and icehouse/bar owned by the 3 guarantors.

Return to Top
#2294676 - 03/12/24 03:54 PM Re: Revenue - Personal Income Considered for DSCR Help! Compliance
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 158
San Antonio, TX
Note it is NOT a start-up.

Return to Top
#2294686 - 03/12/24 05:01 PM Re: Revenue - Personal Income Considered for DSCR Help! Compliance
NFletcher Offline
Junior Member
Joined: Apr 2023
Posts: 36
From looking at the Q&A on GAR-

I would not report any guarantor income. Income is not revenues.

If the GAR for the entity was not collected, report 'not known'.

If the GAR was collected for the entity in the normal course of business, even though it was not relied on in the credit decision, you could report that amount for CRA purposes.

I would appreciate if someone would confirm if I am on the right track, and for the original poster's sake. This is something I have been trying to get more consistent with in our procedures as well.

Return to Top
#2294711 - 03/13/24 01:18 PM Re: Revenue - Personal Income Considered for DSCR Help! Compliance
Inherent_Risk Offline
Platinum Poster
Joined: Jan 2017
Posts: 663
I would agree. Use what you have for the borrower. Don't use income from individual guarantors. If they are unknown, then put unknown.

Return to Top
#2294729 - 03/13/24 02:43 PM Re: Revenue - Personal Income Considered for DSCR Help! Compliance
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,137
Connecticut
Never use guarantor income if it is an individual guarantor. You should use the guarantor income if it is a business affiliate of the borrower and if you collected and relied on that income and the affiliate guaranteed the loan.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top