KB -
HMDA 29% number, 24% dollar in AA. Huge AA for Intermediate bank and most LMI & MM tracts don't even have an app, let alone a loan. Non-HMDA lending insignificant.
I can understand the premise - it's Ok to lend outside if you are taking care of your AA first, but that did not appear to be the case, and bank gets SAT!
Cannot figure it out, and feel bad for banks who are constrained by the reg.
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Integrity. With it, nothing else matters. Without it, nothing else matters.