A community bank's loan officer regularly originates mortgages in a mixed-income metropolitan area. Analysis of the bank's HMDA data shows that over a 3-year period, the bank originated zero loans in 15 predominantly minority census tracts within its assessment area, despite receiving 23 applications from those areas — all of which were withdrawn or discouraged before reaching underwriting. The bank claims it serves all areas equally. Which fair lending theory MOST directly addresses this pattern, and what evidence would BEST support the regulatory concern?

Predatory lending, supported by evidence that loans in minority tracts had higher interest rates than those in majority tracts Reverse redlining, supported by evidence that the bank offered subprime products exclusively to applicants from those 15 census tracts Redlining, supported by evidence that loan officers were discouraged from marketing in or accepting applications from the minority census tracts, combined with low application and origination rates in those areas relative to similarly situated areas Disparate impact, supported by evidence that the bank's minimum loan amount policy disproportionately excluded minority borrowers in those tracts