By secondary lending area, what do you mean?
If you "market" in the areas, the regulators could consider it a REMA (Reasonably Expected Market Area), and consider it in your fair lending analysis even though it's not your AA.
If you mean you would "consider" a loan there, as long as you're not intentionally excluding any MM tracts, it should be OK.
L2C,IMHO, the bank needs to identify what they are planning to do, and documented with WHY. What is the non-discriminatory business decision. It appears confusing (without additional input) to say your secondary lending area is in a different state, but the bank is restricting what they are lending.
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Integrity. With it, nothing else matters. Without it, nothing else matters.