We are proposing to conduct some direct mailing based on zip code/census tract, income level and other demographics. In the past we have targeted LMI areas for CRA purposes. I was wondering if there were any issues with the opposite. Direct mailing individuals who have a high income or live in high income areas?

I am also interested in a response to this question.

Targeted marketing is fine. You just need to make sure that your overall marketing umbrella does not exclude any area or demographic in the longer term.

If the plan is to send out targeted direct mailers to everyone in a 5 or 10 mile radius of select branches, so the prospect households that have a higher income level would get an advertisement related to one of our higher end deposit accounts and prospect households with lower income would get an advertisement for one of our entry level deposit accounts. Then if there are any customers within that radius, they would get a cross-sell advertisement for a deposit or credit card advertisement that they do not currently have. Would this be acceptable?

I don't understand? How in the world do you know what any specific household's income might be???

We are using a third party and I believe they are using census data.

Inaccurate at best at the household level. Without examining your actual criteria, this is a very difficult subject.