I have a serious issue with lending exclusively to existing customers! Fair lending implications because you are not serving your community. Additionally, if your client base is homogeneous and not overly reflective of the community, there would be another issue. Minorities are generally considered as the unbanked, and the bank would have a policy with disparate impact!
The restrictions could better be with property outside the AA.
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Integrity. With it, nothing else matters. Without it, nothing else matters.