I am trying to determine the correct GAR figure to report on a business purpose auto loan. The loan was purchased by our Bank along with a group of other consumer purpose auto loans. It appears the loan initially started off as a regular consumer purpose auto loan, but evolved into a business purpose auto loan when the customer decided that he wanted to change the borrower name to his business name (an LLC), since the vehicle would be used primarily for business purpose. The loan documents the LLC as the primary borrower and the individual as a co-borrower and guarantor however the individuals income (from his personal tax return) was used in the credit decision. The loan file includes the Financial Statements for the LLC even though this information was not used in the credit decision. Again, this is a purchased loan. Do I report the Revenue figure used in the credit decision, or do I go back and obtain the GAR from the LLC's financial statements. I'm fairly new to CRA data collection and would appreciate any feedback.

If you read the CRA Guide it states that "generally an institution should rely on the revenues it considered in making the credit decision when indicating whether a small business or small farm borrower had gross annual revenues of $1 million or less." Notice the word "generally" which does not mean "always". The CRA Guide also states that the purpose of reporting income data is to inform exmainers and the public whether a lender is lending to small farms and small businesses or only making small loans to larger businesses and farms. Therefore, it would be appropriate to report the revenue code using the gross annual revenues of the borrowing company even if the bank relied only on the guarantee of the principal. If, on the other hand, this had been a loan to a wholly owned subsidiary of a large company and the parent company income had been a consideration in the credit decision, then the gross annual revenues of that company would be included when determining the correct revenue code to submit.

This information is very helpful. I am finding that CRA data collection "in general" is not too difficult. It is the "what if" or varying situations that you often spend a lot of time researching - - only to find that you have more questions than you originally started out with - - this is the challenge, at least for me.
Thank you Len - - you're prompt response is very much appreciated! It is also very nice to have this forum available.