Compliance Alliance Question of the Week

Question:
Our bank has a question for CRA reporting.  When we have a start-up businesses, do we report the revenue as "unknown" since there is no real revenue information (only projections)?
 
Answer:
For start-ups, the bank should use $0 if the business is pre-revenue. The bank will not use any pro-forma or projected revenue figures.
 
For a start-up business, the institution should use the actual gross annual revenue to date (including $0 if a new business has had no revenue to date). Although start-up businesses will provide the institution with pro forma projected revenue figures, these figures may not accurately reflect actual gross revenue and therefore should not be used.
 
A Guide to CRA Data Collection and Reporting (Page 14 of 2015 version): https://www.ffiec.gov/cra/pdf/2015_CRA_Guide.pdf