Even though the examiner is performing what they call a redlining exam, it sounds much more like a targeted fair lending exam. The line between exam focus has blurred in recent years.
There are a few settlements that are good examples of this shift in recent years Citizens bank (
http://www.justice.gov/opa/pr/2011/May/11-crt-576.html)& Midwest BankCentre (
http://www.justice.gov/opa/pr/2011/June/11-crt-784.html).
These came from a referral from the Fed, so it is not necessarily just the DOJ defining the exam approach.
Within data analysis, Asian borrowers do tend to show good access to credit. Pricing models tend to show Asian borrowers with lower pricing than White Non-Hispanic borrowers (both within discretionary pricing models and scored pricing models). This probably why they are excluding them from consideration within the review. Remember also the Nara Bank auto lending case, where Asian borrowers were the control group within the DOJ case.
Things have certainly changed within the past few years for Fair Lending examinations. Data analysis is really the key, and knowing how your institution stacks up is very necessary. How do you rate against peer institutions? What is the owner occupied percentage within each MSA you operate? Not only in MMT, but all areas? And if not with mortgage related products, what other consumer loans do you have as evidence of serving the community? These are items you should know before being in front of your examier.