You need to have it defined as to branches in the 5 counties, or people living in the 5 counties.
Reason, the definition may be critical during a fair lending exam. A bank I was at had a similar promotion. When the pricing fair lending sample was pulled by OCC, there was a large unexplained difference, until we referred them to the exact promotion (loans by branches within the area irrespective where the applicant lived).
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Integrity. With it, nothing else matters. Without it, nothing else matters.