1071 and Indirect auto loans

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    Should we include Indirect auto loans to small businesses in our totals for 1071?


    Yes, all commercial loans that meet the small business definition (<$5 million in gross annual revenues for the preceding fiscal year) are required to be reported for 1071. The exception is if it is HMDA reportable. Those do not require reporting on both LARS. HMDA reportable loans for HMDA reporters go on the HMDA LAR. If you are not a HMDA report, then all your covered commercial loans will go on the SBLAR. NOTICE: This email message, including any attachments, is intended only for the addressee, and may contain confidential and privileged information either as protected work product or confidential client information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, do not read, copy, retain, or disseminate this message or any attachment, and please contact the sender by reply e-mail or at 888.760.5646and destroy all copies of the original message and attachments. Neither the transmission of this message or any attachment, nor any error in transmission or misdelivery shall constitute waiver of any applicable legal privilege. THIS EMAIL AND ITS ATTACHMENTS DO NOT CONSTITUTE LEGAL ADVICE

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