Answer:
Know your loans and market area. There will be some tracts you don’t lend in. Determine WHY! It could be proximity to the branch, competition, housing types, loan products, marketing, outreach, and others. Identify your applications as a percentage of total HMDA applications in the area, then measure the Majority-Minority tracts. If the lending in any of them is well below the penetration in the overall area, they may be considered as underserved. Read how regulators and the DOJ are taking redlining much more seriously.
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