Modest incomes, not poorer places
Similar lenders here are state non-member banks making between half and twice as many loans. Of the bank's borrowers, 41.2% had low or moderate incomes, against 27.3% at those peers, higher than more than four in five. Yet only 5.9% of its loans were in poorer neighborhoods (low- and moderate-income, or LMI, tracts), against 18.6%. The two need not conflict: a borrower's income and a neighborhood's are measured separately, and a lender whose largest market is non-metro Michigan may serve modest earners in tracts that do not count as poor.