REMA Issues and Advertising

If all of a lender's marketing is targeted outside the US, aside from marketing within its "claimed" assessment area, could the lender be subject to REMA redlining review? I've read guidance that implies marketing doesn't have to be a factor for a REMA redlining exam to be conducted... • "REMA...defines who and where you serve, and as such, is different from a defined Market Area..." • "Where the lender actually marketed and provided credit, and where it could reasonably be expected to have marketed and provided credit based on its distribution of loans and applications " • Redlining analysis will look at lending and level of services in majority-minority census tracts compared to peers, among other items.