Could be a close call depending on why the bank got the accounts. If they solicited/marketed in the area, it should be considered, especially if there is lending in the area. It might be different if there was no marketing, however, affluent tenants in the same location used the bank for convenience.
If there was concentrated lending, the bank might be subject to a fair lending review based on REMA
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Integrity. With it, nothing else matters. Without it, nothing else matters.