How can you report GAR as ‘not provided’ if you need to know this number in order to determine if it is reportable for Section 1071? It is my understanding that you do not have to verify GAR, so if a borrower tells you about $3M, then wouldn’t that be the amount to report instead of ‘not provided’?

The Bureau has made it clear that you can enter in the GAR field information “not provided by applicant and otherwise underdetermined,” (see Small Business Lending Rule: Data Points Chart). In subsection 107(a)(14) the Official Interpretations it is stated that “if a financial institution is nonetheless unable to collect or determine gross annual revenue of the applicant, the financial institution reports that gross annual revenue is not provided by applicant and is otherwise undetermined. How the Bureau can rationalize that answer while at
the same time instructing lenders to collect and report the application as if it were a “covered transaction from a small business” when the lender is stating they don’t know the answer is something only a bureaucrat could explain.