the costs and effects of legal and regulatory developments including the resolution of legal proceedings or regulatory or other governmental inquiries and the results of regulatory examinations or reviews . greater than expected costs or difficulties related to the integration of new products and lines of business . the company 's success at managing the risks involved in the foregoing items . forward-looking statements speak only as of the date on which such statements are made . the company undertakes no obligation to update any forward-looking statement to reflect events or circumstances after the date on which such statement is made or to reflect the occurrence of unanticipated events . recent market developments the dodd-frank act was signed into law on july 21 , 2010. this new law has and will continue to significantly change the current bank regulatory structure and affect the lending , deposit , investment , trading and operating activities of financial institutions and their holding companies , and will fundamentally change the system of regulatory oversight of the company , including through the creation of the financial stability oversight council . the dodd-frank act requires various federal agencies to adopt a broad range of new implementing rules and regulations , and to prepare numerous studies and reports for congress . the federal agencies are given significant discretion in drafting the implementing rules and regulations , and , as a result , many of the details and much of the impact of the dodd-frank act is not yet known . the dodd-frank act , however , could have a material adverse impact either on the financial services industry as a whole , or on first defiance 's business , results of operations , financial condition and liquidity . the dodd-frank act broadens the base for fdic insurance assessments . assessments will now be based on the average consolidated total assets less tangible equity capital of a financial institution . the dodd-frank act also permanently increases the maximum amount of deposit insurance for banks , savings institutions and credit unions to $ 250,000 per depositor , retroactive to january 1 , 2009 , and non-interest bearing transaction accounts have unlimited deposit insurance through december 31 , 2013. the legislation also requires that publicly traded companies give shareholders a non-binding vote on executive compensation and golden parachute payments , and authorizes the securities and exchange commission to promulgate rules that would allow shareholders to nominate their own candidates using a company 's proxy materials . the dodd-frank act also directs the federal reserve board to promulgate rules prohibiting excessive compensation paid to bank holding company executives , regardless of whether the company is publicly traded . the dodd-frank act established a new bureau of consumer financial protection with broad powers to supervise and enforce consumer protection laws . the bureau of consumer financial protection has broad rule-making authority for a wide range of consumer protection laws that apply to all banks and savings institutions , including the authority to prohibit unfair , deceptive or abusive acts and practices . the bureau of consumer financial protection has examination and enforcement authority over all banks and savings institutions with more than $ 10 billion in assets . in addition , the dodd-frank act , among other things : -40- amends the electronic fund transfer act ( efta ) which has resulted in , among other things , the federal reserve board issuing rules aimed at limiting debit-card interchange fees ; applies the same leverage and risk-based capital requirements that apply to insured depository institutions to most financial holding companies ; changes the assessment base for federal deposit insurance from the amount of insured deposits to consolidated assets less tangible capital , eliminates the ceiling on the size of the dif , and increases the floor on the size of the dif , which generally will require an increase in the level of assessments for institutions with assets in excess of $ 10 billion ; repeals the federal prohibitions on the payment of interest on demand deposits , thereby permitting depository institutions to pay interest on business transaction and other accounts ; provides mortgage reform provisions regarding a customer 's ability to repay , restricting variable-rate lending by requiring the ability to repay to be determined for variable-rate loans by using the maximum rate that will apply during the first five years of a variable-rate loan term , and making more loans subject to provisions for higher cost loans , new disclosures , and certain other revisions ; creates the financial stability oversight council , which will recommend to the federal reserve board increasingly strict rules for capital , leverage , liquidity , risk management and other requirements as companies grow in size and complexity ; and eliminate the ots one year from the date of the new law 's enactment , making the occ , which is currently the primary federal regulator for national banks , the primary federal regulator for federal thrifts , including first federal . in addition , the board of governors of the federal reserve system will supervise and regulate all savings and loan holding companies that were formerly regulated by the ots , including first defiance . the environment in which banking organizations will operate after the financial crisis , including legislative and regulatory changes affecting capital , liquidity , supervision , permissible activities , corporate governance and compensation , changes in fiscal policy and steps to eliminate government support for banking organizations , may have long-term effects on the business model and profitability of banking organizations , the full extent of which can not now be foreseen . many aspects of the dodd-frank act remain subject to rulemaking and will take effect over several years , making it difficult to anticipate the overall financial impact on first defiance , its customers or the financial industry more generally . story_separator_special_tag management utilizes the results of this outside loan review to assess the effectiveness of its internal loan grading system as well as to assist in the assessment of the overall adequacy of the allowance for loan losses associated with these types of loans . the provision for loan losses is determined by management as the amount to be added to the allowance for loan losses after net charge-offs have been deducted to bring the allowance to a level which , in management 's best estimate , is necessary to absorb probable credit losses within the existing loan portfolio in the normal course of business . the allowance for loan loss is made up of two basic components . the first component is the specific allowance in which the company sets aside reserves based on the analysis of individual credits . the second component is the general reserve . the general reserve is used to record loan loss reserves for groups of homogenous loans in which the company estimates the losses incurred in the portfolios based on quantitative and qualitative factors . due to the uncertainty of risks in the loan portfolio , the company 's judgment on the amount of the allowance necessary to absorb loans losses is approximate . table 3 presents the allocation of the specific and general components of the allowance by signification loan types . in establishing specific reserves , first federal analyzes all loans on its classified and special mention lists at least quarterly and makes judgments about the risk of loss based on the cash flow of the borrower , the value of any collateral and the financial strength of any guarantor in determining the amount of impairment of individual loans and the specific reserve to be recorded . for purpose of the general reserve analysis , the loan portfolio is stratified into ten different loan pools based on loan type and by market area to allocate historic loss experience . the loss experience factor applied to the non-impaired loan portfolio was based upon historical losses of the most recent weighted two years used at december 31 , 2010. the stratification of the loan portfolio resulted in a quantitative general allowance of $ 14.0 million at december 31 , 2010 compared to $ 10.5 million at december 31 , 2009. the increase in the quantitative allowance was due to the increase in the historical loss factors relating to commercial , commercial real estate , residential and credit card loans . in addition to the quantitative analysis , a qualitative analysis is performed each quarter to provide additional general reserves on the non-impaired loan portfolio for various factors that have a bearing on its loss content , including but not limited to the following : changes in international , national and local economic and business conditions and developments , including the condition of various market segments changes in the nature and volume of the loan portfolio changes in the trends of the volume and severity of past due and classified loans ; and changes in trends in the volume of non-accrual loans , troubled debt restructurings and other loan modifications the existence and effect of any concentrations of credit and changes in the level of such concentrations changes in the value of underlying collateral for collateral dependent loans changes in the political and regulatory environment changes in lending policies and procedures , including underwriting standards and collection , charge-off and recovery practices changes in the experience , ability and depth of lending management and staff changes in the quality and breadth of the loan review process -46- the qualitative analysis at december 31 , 2010 indicated a general reserve of $ 10.5 million compared with $ 8.7 million at december 31 , 2009. this decrease was mainly driven by improved cash flows and operating results of borrowers in 2010. in light of the continued environment of high unemployment , declining real estate values and sustained economic weakness in the midwest , management feels it is prudent to maintain a higher level of general loan loss reserves . all 14 counties that represent the footprint of the company have seen improvements in their unemployment rates in 2010 , with only three below the national average of 9.1 % . the company operated one branch in hillsdale county in 2009 , but that office was closed in january 2010 , therefore , that data is not being presented in this comparison . the unemployment rates in december 2010 for the following counties in ohio were : allen 9.8 % , defiance 9.9 % , fulton 10.6 % , hancock 8.1 % , henry 11.1 % , lucas 10.1 % , ottawa 16.3 % , paulding 9.8 % , putnam 8.4 % , seneca 10.2 % , williams 11.1 % and wood 9.0 % , compared to december 2009 in allen 11.6 % , defiance 12.8 % , fulton 14.3 % , hancock 9.6 % , henry 13.9 % , lucas 12.3 % , ottawa 17.3 % , paulding 12.7 % , putnam 11.0 % , seneca 13.0 % , williams 14.9 % and wood 11.1 % . the company operates in one county in michigan , lenawee which had an unemployment rate of 12.4 % in december 2010 compared to 16.6 % in december 2009. the company operates in one county in indiana , allen , which had an unemployment rate of 9.4 % in december 2010 compared to 10.0 % in december 2009. first defiance 's general reserve percentages for main loan segments not otherwise classified ranged from 0.29 % for construction loans to 1.70 % for commercial loans . credit cards were 10.56 % . as a result of the quantitative and qualitative analyses , along with the change in specific reserves , the company 's provision for loan losses for 2010 was $ 23.2 million , which is unchanged since december 31 , 2009. the allowance for loan losses was $ 41.1 million and

capital resources total shareholders ' equity increased $ 6.2 million to $ 240.3 million at december 31 , 2010. this increase is primarily the result of the company 's $ 8.1 million of net income . this increase was mostly offset by a $ 1.9 million of preferred stock dividends at december 31 , 2010. in 2003 , the company 's board of directors authorized the repurchase of 640,000 shares , 93,124 of which remain available for repurchase . during 2010 , no shares were repurchased but a total of 250 stock options were exercised by three employees , resulting in a $ 3,000 increase in shareholders equity . during 2009 , no shares were repurchased but a total of 400 stock options were exercised by one employee , resulting in a $ 5,000 increase in shareholders equity . participation in the cpp prohibits the company from buying back any of its common shares during the period it has cpp funds outstanding . further , the ots has required first defiance to obtain ots approval prior to the repurchase of any of its common stock . -53- results of operations summary first defiance reported net income of $ 8.1 million for the year ended december 31 , 2010 compared to $ 7.2 million and $ 7.4 million for the years ended december 31 , 2009 and 2008 , respectively . net income applicable to common shares was $ 6.1 million in 2010 compared with $ 5.2 million in 2009 and $ 7.2 million in 2008. on a diluted per common share basis , first defiance earned $ 0.75 in 2010 , $ 0.63 in 2009 and $ 0.91 in 2008. first defiance 's 2010 net income of $ 8.1 million included $ 63,000 of acquisition related costs resulting from the andres o'neil & lowe insurance agency ( aol ) acquisition earlier in 2010. the 2009 net income did not include any acquisition related costs . the 2008 net income amount includes $ 1.1 million of acquisition related costs that were incurred as part of the pavilion acquisition .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```capital resources total shareholders ' equity increased $ 6.2 million to $ 240.3 million at december 31 , 2010. this increase is primarily the result of the company 's $ 8.1 million of net income . this increase was mostly offset by a $ 1.9 million of preferred stock dividends at december 31 , 2010. in 2003 , the company 's board of directors authorized the repurchase of 640,000 shares , 93,124 of which remain available for repurchase . during 2010 , no shares were repurchased but a total of 250 stock options were exercised by three employees , resulting in a $ 3,000 increase in shareholders equity . during 2009 , no shares were repurchased but a total of 400 stock options were exercised by one employee , resulting in a $ 5,000 increase in shareholders equity . participation in the cpp prohibits the company from buying back any of its common shares during the period it has cpp funds outstanding . further , the ots has required first defiance to obtain ots approval prior to the repurchase of any of its common stock . -53- results of operations summary first defiance reported net income of $ 8.1 million for the year ended december 31 , 2010 compared to $ 7.2 million and $ 7.4 million for the years ended december 31 , 2009 and 2008 , respectively . net income applicable to common shares was $ 6.1 million in 2010 compared with $ 5.2 million in 2009 and $ 7.2 million in 2008. on a diluted per common share basis , first defiance earned $ 0.75 in 2010 , $ 0.63 in 2009 and $ 0.91 in 2008. first defiance 's 2010 net income of $ 8.1 million included $ 63,000 of acquisition related costs resulting from the andres o'neil & lowe insurance agency ( aol ) acquisition earlier in 2010. the 2009 net income did not include any acquisition related costs . the 2008 net income amount includes $ 1.1 million of acquisition related costs that were incurred as part of the pavilion acquisition .
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 Suspicious Activity Report : the costs and effects of legal and regulatory developments including the resolution of legal proceedings or regulatory or other governmental inquiries and the results of regulatory examinations or reviews . greater than expected costs or difficulties related to the integration of new products and lines of business . the company 's success at managing the risks involved in the foregoing items . forward-looking statements speak only as of the date on which such statements are made . the company undertakes no obligation to update any forward-looking statement to reflect events or circumstances after the date on which such statement is made or to reflect the occurrence of unanticipated events . recent market developments the dodd-frank act was signed into law on july 21 , 2010. this new law has and will continue to significantly change the current bank regulatory structure and affect the lending , deposit , investment , trading and operating activities of financial institutions and their holding companies , and will fundamentally change the system of regulatory oversight of the company , including through the creation of the financial stability oversight council . the dodd-frank act requires various federal agencies to adopt a broad range of new implementing rules and regulations , and to prepare numerous studies and reports for congress . the federal agencies are given significant discretion in drafting the implementing rules and regulations , and , as a result , many of the details and much of the impact of the dodd-frank act is not yet known . the dodd-frank act , however , could have a material adverse impact either on the financial services industry as a whole , or on first defiance 's business , results of operations , financial condition and liquidity . the dodd-frank act broadens the base for fdic insurance assessments . assessments will now be based on the average consolidated total assets less tangible equity capital of a financial institution . the dodd-frank act also permanently increases the maximum amount of deposit insurance for banks , savings institutions and credit unions to $ 250,000 per depositor , retroactive to january 1 , 2009 , and non-interest bearing transaction accounts have unlimited deposit insurance through december 31 , 2013. the legislation also requires that publicly traded companies give shareholders a non-binding vote on executive compensation and golden parachute payments , and authorizes the securities and exchange commission to promulgate rules that would allow shareholders to nominate their own candidates using a company 's proxy materials . the dodd-frank act also directs the federal reserve board to promulgate rules prohibiting excessive compensation paid to bank holding company executives , regardless of whether the company is publicly traded . the dodd-frank act established a new bureau of consumer financial protection with broad powers to supervise and enforce consumer protection laws . the bureau of consumer financial protection has broad rule-making authority for a wide range of consumer protection laws that apply to all banks and savings institutions , including the authority to prohibit unfair , deceptive or abusive acts and practices . the bureau of consumer financial protection has examination and enforcement authority over all banks and savings institutions with more than $ 10 billion in assets . in addition , the dodd-frank act , among other things : -40- amends the electronic fund transfer act ( efta ) which has resulted in , among other things , the federal reserve board issuing rules aimed at limiting debit-card interchange fees ; applies the same leverage and risk-based capital requirements that apply to insured depository institutions to most financial holding companies ; changes the assessment base for federal deposit insurance from the amount of insured deposits to consolidated assets less tangible capital , eliminates the ceiling on the size of the dif , and increases the floor on the size of the dif , which generally will require an increase in the level of assessments for institutions with assets in excess of $ 10 billion ; repeals the federal prohibitions on the payment of interest on demand deposits , thereby permitting depository institutions to pay interest on business transaction and other accounts ; provides mortgage reform provisions regarding a customer 's ability to repay , restricting variable-rate lending by requiring the ability to repay to be determined for variable-rate loans by using the maximum rate that will apply during the first five years of a variable-rate loan term , and making more loans subject to provisions for higher cost loans , new disclosures , and certain other revisions ; creates the financial stability oversight council , which will recommend to the federal reserve board increasingly strict rules for capital , leverage , liquidity , risk management and other requirements as companies grow in size and complexity ; and eliminate the ots one year from the date of the new law 's enactment , making the occ , which is currently the primary federal regulator for national banks , the primary federal regulator for federal thrifts , including first federal . in addition , the board of governors of the federal reserve system will supervise and regulate all savings and loan holding companies that were formerly regulated by the ots , including first defiance . the environment in which banking organizations will operate after the financial crisis , including legislative and regulatory changes affecting capital , liquidity , supervision , permissible activities , corporate governance and compensation , changes in fiscal policy and steps to eliminate government support for banking organizations , may have long-term effects on the business model and profitability of banking organizations , the full extent of which can not now be foreseen . many aspects of the dodd-frank act remain subject to rulemaking and will take effect over several years , making it difficult to anticipate the overall financial impact on first defiance , its customers or the financial industry more generally . story_separator_special_tag management utilizes the results of this outside loan review to assess the effectiveness of its internal loan grading system as well as to assist in the assessment of the overall adequacy of the allowance for loan losses associated with these types of loans . the provision for loan losses is determined by management as the amount to be added to the allowance for loan losses after net charge-offs have been deducted to bring the allowance to a level which , in management 's best estimate , is necessary to absorb probable credit losses within the existing loan portfolio in the normal course of business . the allowance for loan loss is made up of two basic components . the first component is the specific allowance in which the company sets aside reserves based on the analysis of individual credits . the second component is the general reserve . the general reserve is used to record loan loss reserves for groups of homogenous loans in which the company estimates the losses incurred in the portfolios based on quantitative and qualitative factors . due to the uncertainty of risks in the loan portfolio , the company 's judgment on the amount of the allowance necessary to absorb loans losses is approximate . table 3 presents the allocation of the specific and general components of the allowance by signification loan types . in establishing specific reserves , first federal analyzes all loans on its classified and special mention lists at least quarterly and makes judgments about the risk of loss based on the cash flow of the borrower , the value of any collateral and the financial strength of any guarantor in determining the amount of impairment of individual loans and the specific reserve to be recorded . for purpose of the general reserve analysis , the loan portfolio is stratified into ten different loan pools based on loan type and by market area to allocate historic loss experience . the loss experience factor applied to the non-impaired loan portfolio was based upon historical losses of the most recent weighted two years used at december 31 , 2010. the stratification of the loan portfolio resulted in a quantitative general allowance of $ 14.0 million at december 31 , 2010 compared to $ 10.5 million at december 31 , 2009. the increase in the quantitative allowance was due to the increase in the historical loss factors relating to commercial , commercial real estate , residential and credit card loans . in addition to the quantitative analysis , a qualitative analysis is performed each quarter to provide additional general reserves on the non-impaired loan portfolio for various factors that have a bearing on its loss content , including but not limited to the following : changes in international , national and local economic and business conditions and developments , including the condition of various market segments changes in the nature and volume of the loan portfolio changes in the trends of the volume and severity of past due and classified loans ; and changes in trends in the volume of non-accrual loans , troubled debt restructurings and other loan modifications the existence and effect of any concentrations of credit and changes in the level of such concentrations changes in the value of underlying collateral for collateral dependent loans changes in the political and regulatory environment changes in lending policies and procedures , including underwriting standards and collection , charge-off and recovery practices changes in the experience , ability and depth of lending management and staff changes in the quality and breadth of the loan review process -46- the qualitative analysis at december 31 , 2010 indicated a general reserve of $ 10.5 million compared with $ 8.7 million at december 31 , 2009. this decrease was mainly driven by improved cash flows and operating results of borrowers in 2010. in light of the continued environment of high unemployment , declining real estate values and sustained economic weakness in the midwest , management feels it is prudent to maintain a higher level of general loan loss reserves . all 14 counties that represent the footprint of the company have seen improvements in their unemployment rates in 2010 , with only three below the national average of 9.1 % . the company operated one branch in hillsdale county in 2009 , but that office was closed in january 2010 , therefore , that data is not being presented in this comparison . the unemployment rates in december 2010 for the following counties in ohio were : allen 9.8 % , defiance 9.9 % , fulton 10.6 % , hancock 8.1 % , henry 11.1 % , lucas 10.1 % , ottawa 16.3 % , paulding 9.8 % , putnam 8.4 % , seneca 10.2 % , williams 11.1 % and wood 9.0 % , compared to december 2009 in allen 11.6 % , defiance 12.8 % , fulton 14.3 % , hancock 9.6 % , henry 13.9 % , lucas 12.3 % , ottawa 17.3 % , paulding 12.7 % , putnam 11.0 % , seneca 13.0 % , williams 14.9 % and wood 11.1 % . the company operates in one county in michigan , lenawee which had an unemployment rate of 12.4 % in december 2010 compared to 16.6 % in december 2009. the company operates in one county in indiana , allen , which had an unemployment rate of 9.4 % in december 2010 compared to 10.0 % in december 2009. first defiance 's general reserve percentages for main loan segments not otherwise classified ranged from 0.29 % for construction loans to 1.70 % for commercial loans . credit cards were 10.56 % . as a result of the quantitative and qualitative analyses , along with the change in specific reserves , the company 's provision for loan losses for 2010 was $ 23.2 million , which is unchanged since december 31 , 2009. the allowance for loan losses was $ 41.1 million and

