cib marine recognizes the inherent imprecision in estimates of losses due to various uncertainties and variability related to the factors used to estimate loan losses . if different assumptions or conditions were to prevail and it is determined that the allowance is not adequate to absorb the new estimate of probable losses , an additional provision for loan losses would be made , which amount may be material to the consolidated financial statements . 28 measurement of fair value a portion of cib marine 's assets and liabilities are carried at fair value on the consolidated balance sheets , with changes in fair value recorded either through earnings or other comprehensive income in accordance with applicable gaap . these include cib marine 's available for sale securities , interest-rate derivatives related to mortgage loan originations , and other equity securities . the estimation of fair value also affects certain other loans held for sale , which are not recorded at fair value but at the lower of cost or market . the determination of fair value is important for certain other assets , including impaired loans , and other real estate owned that are periodically evaluated for impairment using fair value estimates . fair value is generally defined as the amount at which an asset or liability could be exchanged in a current transaction between willing , unrelated parties , other than in a forced or liquidation sale . fair value is based on quoted market prices in an active market , or if market prices are not available , is estimated using models employing techniques such as matrix pricing or discounting expected cash flows . the significant assumptions used in the models , which include assumptions for interest rates , discount rates , prepayments and credit losses , are independently verified against observable market data where possible . where observable market data is not available , the estimate of fair value becomes more subjective and involves a high degree of judgment . in this circumstance , fair value is estimated based on management 's judgment regarding the value that market participants would assign to the asset or liability . this valuation process takes into consideration factors such as market illiquidity . imprecision in estimating these factors can impact the amount recorded on the balance sheet for a particular asset or liability with related impacts to earnings or other comprehensive income . see note 22 to the consolidated financial statements appearing in item 8 of part ii of this form 10-k. securities available for sale available for sale securities are carried at fair value with unrealized net gains and losses reported in other comprehensive income ( loss ) in stockholders ' equity . management evaluates securities for otti at least on a quarterly basis and more frequently when economic or market conditions warrant . declines in the fair value of securities available for sale that are deemed to be other-than-temporary are charged to earnings as a realized loss , and a new cost basis for the securities is established . in evaluating otti , cib marine 's management considers the length of time and extent to which the fair value has been less than cost , the financial condition and near-term prospects of the issuer , whether or not cib marine intends to sell or it is more likely than not cib marine will be required to sell the security prior to a period of time sufficient to allow for any anticipated recovery of fair value , and other factors as detailed in note 4 to the consolidated financial statements appearing in item 8 of part ii of this form 10-k. income taxes cib marine recognizes expense for federal and state income taxes currently payable as well as for deferred federal and state taxes for estimated future tax effects of temporary differences between the tax basis of assets and liabilities and amounts reported in the consolidated balance sheets , as well as loss carryforwards and tax credit carryforwards . realization of deferred tax assets is dependent upon cib marine generating sufficient taxable income in either the carryforward or carryback periods to cover net operating losses generated by the reversal of temporary differences . a valuation allowance is provided by way of a charge to income tax expense if it is determined that it is not more likely than not that some portion or all of the deferred tax asset will be realized . if different assumptions and conditions were to prevail , the valuation allowance may not be adequate to absorb unrealized deferred taxes and the amount of income taxes payable may need to be adjusted by way of a charge or credit to expense . furthermore , income tax returns are subject to audit by the internal revenue service ( “ irs ” ) , state taxing authorities , and foreign government taxing authorities . income tax expense for current and prior periods is subject to adjustment based upon the outcome of such audits . cib marine believes it has adequately accrued for all probable income taxes payable and provided valuation allowances for deferred tax assets where it has been determined to be not more likely than not that such assets are realizable . accrual of income taxes payable and valuation allowances against deferred tax assets are estimates subject to change based upon the outcome of future events . 29 cib marine has entered into tax allocation agreements with its subsidiary entities included in the consolidated u.s. federal and unitary and combined state income tax returns , including u.s. operations of companies held for sale or disposal . these agreements govern the timing and amount of income tax payments required by the various entities . due to the significant losses incurred in 2006 through 2008 , as well as the operating losses from continuing operations in 2009 , management has determined that it is not more likely than not that the entire net deferred tax asset of $ 67.6 story_separator_special_tag cib marine 's net interest margin decreased by 20 basis points during 2008 compared to 2007 and its net interest spread increased by 7 basis points during the same period . the net interest margin decrease was primarily due to the increased reliance on interest bearing liabilities to fund the interest earning assets and the decline in the average yield on interest earning assets funded by non-interest bearing liabilities and capital . provision for loan losses the provision for loan losses represents charges made to earnings in order to maintain an allowance for loan losses and losses on unfunded commitments and standby letters of credit . the provision for loan losses increased $ 5.3 million from $ 22.1 million for the year ended december 31 , 2008 to $ 27.4 million for the year ended december 31 , 2009 and increased $ 15.7 million during 2008 from $ 6.4 million for the year ended december 31 , 2007. the provision for loan losses has been adversely affected by the economic environment and in particular for the following loan portfolio segments : home equity loan pools , construction and development loans , and commercial real estate loans . during 2009 , real estate markets continued to show signs of stress and deterioration , contributing to increased charge-offs and provisions . in particular , provisions during 2009 of $ 10.8 million , $ 6.2 million and $ 7.2 million were made due to deterioration in the credit quality of the home equity loan pools , construction and development loans , and commercial real estate loans , respectively . the provisions made for the year 2008 in each of these loan portfolio segments was $ 11.3 million , $ 11.0 million and a reversal of $ 2.2 million , respectively ; and provisions made for the year 2007 in each of these loan portfolio segments was $ 6.2 million , $ 2.2 million and a reversal of $ 1.4 million , respectively . 33 the $ 6.2 million provision allocated to the home equity pools in 2007 was primarily due to the purchase of the second pool of home equity loans in february 2007 and a sharp deterioration in credit quality beginning in the second quarter of 2007 ; while the $ 10.8 million and $ 11.3 million provision recorded in 2009 and 2008 , respectively , related to deterioration in the credit quality of these pools and the decision by cib marine to change its policy to charge-off 100 % of the outstanding principal balance of each loan in the pool when the loan is classified as 90 days past due on the servicer report received during the period . during 2009 , $ 11.7 million of these loans were charged-off compared to $ 12.4 million and $ 2.0 million during 2008 and 2007 , respectively . at december 31 , 2009 and 2008 , the remaining balance of these two purchased pools was $ 35.1 million and $ 52.2 million , respectively , with an allocated allowance of $ 3.9 million and $ 4.5 million , respectively . noninterest income noninterest income decreased $ 2.9 million from $ 4.4 million for the year ended december 31 , 2008 to $ 1.5 million for the year ended december 31 , 2009. the decrease was primarily due to a $ 4.1 million gain cib marine recognized during 2008 primarily from the sale of all of the branches and substantially all of the loans and deposits of its florida banking subsidiary with no comparable gain recognized in 2009. this was partially offset by a decrease of $ 1.4 million in otti from december 31 , 2008 to december 31 , 2009. noninterest income increased $ 1.3 million , or 43.1 % , from $ 3.1 million for the year ended december 31 , 2007 to $ 4.4 million for the year ended december 31 , 2008. the increase was mainly due to gain on sale of branches , offset partially by otti of $ 1.8 million for the year ended december 31 , 2008 compared to no otti in 2007. see securities available for sale section in item 7 of this form 10-k for further information regarding such adjustments . cib marine recognized a $ 4.1 million gain primarily from the sale of all of the branches and substantially all of the loans and deposits of its florida banking subsidiary in 2008. this compares to a $ 1.3 million gain recognized in 2007 primarily from the sale of two branches owned by marine bank . noninterest expense total noninterest expense decreased $ 8.9 million , or 22.2 % , from $ 39.9 million in 2008 , to $ 31.0 million in 2009. the decrease was primarily the result of the following : · compensation and employee benefits decreased $ 3.4 million , or 20.9 % , during 2009 compared to 2008 , primarily due to staff reductions due to the sale of cib marine 's florida banking subsidiary during the third quarter of 2008 and a reduction in force in the first quarter of 2009. the total number of full-time equivalent employees decreased from 197 at december 31 , 2008 to 165 at december 31 , 2009 . · equipment and occupancy expense together decreased $ 1.0 million , or 22.3 % , during 2009 compared to 2008 primarily due to the sale of cib marine 's florida banking subsidiary during the third quarter of 2008 . · a litigation reserve of $ 3.4 million was recorded and paid in 2008. there was no litigation reserve in 2009 . · fdic deposit insurance expense was $ 1.8 million for 2009 compared to $ 0.7 million for 2008. the increase of $ 1.1 million was the result of an effort by the fdic to replenish the deposit insurance fund in the wake of the recent increase in bank failures in the u.s. the fdic changed its rate structure in december 2008 to generally increase premiums

liquidity cib marine monitors and manages its liquidity position so that funds will be available at a reasonable cost to meet financial commitments , to finance business expansion and to take advantage of unforeseen opportunities . liquidity management involves projecting funding requirements and maintaining sufficient capacity to meet those needs and accommodate fluctuations in asset and liability levels due to changes in business operations or unanticipated events . sources of liquidity include deposits and other customer-based funding , and wholesale market funding . cib marine manages liquidity at two levels , the cib marine parent company and cibm bank . the management of liquidity at both levels is essential because the parent company and the bank have different funding needs and sources , and are subject to certain regulatory guidelines and requirements . the asset-liability management committee is responsible for establishing a liquidity policy , approving operating and contingency procedures and monitoring liquidity on an ongoing basis . in order to maintain adequate liquidity through a wide range of potential operating environments and market conditions , cib marine conducts liquidity management and business activities in a manner designed to preserve and enhance funding stability , flexibility and diversity of funding sources . key components of this operating strategy include a strong focus on customer-based funding , maximizing secured borrowing capacity , maintaining relationships with wholesale market funding providers , and maintaining the ability to liquidate certain assets if conditions warrant . the objective of liquidity risk management at cibm bank is to ensure that it has adequate funding capacity for commitments to extend credit , deposit account withdrawals , maturities of borrowings and other obligations in a timely manner . the liquidity position of cibm bank is actively managed by estimating , measuring and monitoring its sources and uses of funds . cibm bank 's funding requirements are primarily met by the inflow from deposits , loan repayments and investment debt service payments and maturities . cibm bank also makes use of noncore funding sources in a manner consistent with its liquidity , funding and market risk policies .


 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.
     ```liquidity cib marine monitors and manages its liquidity position so that funds will be available at a reasonable cost to meet financial commitments , to finance business expansion and to take advantage of unforeseen opportunities . liquidity management involves projecting funding requirements and maintaining sufficient capacity to meet those needs and accommodate fluctuations in asset and liability levels due to changes in business operations or unanticipated events . sources of liquidity include deposits and other customer-based funding , and wholesale market funding . cib marine manages liquidity at two levels , the cib marine parent company and cibm bank . the management of liquidity at both levels is essential because the parent company and the bank have different funding needs and sources , and are subject to certain regulatory guidelines and requirements . the asset-liability management committee is responsible for establishing a liquidity policy , approving operating and contingency procedures and monitoring liquidity on an ongoing basis . in order to maintain adequate liquidity through a wide range of potential operating environments and market conditions , cib marine conducts liquidity management and business activities in a manner designed to preserve and enhance funding stability , flexibility and diversity of funding sources . key components of this operating strategy include a strong focus on customer-based funding , maximizing secured borrowing capacity , maintaining relationships with wholesale market funding providers , and maintaining the ability to liquidate certain assets if conditions warrant . the objective of liquidity risk management at cibm bank is to ensure that it has adequate funding capacity for commitments to extend credit , deposit account withdrawals , maturities of borrowings and other obligations in a timely manner . the liquidity position of cibm bank is actively managed by estimating , measuring and monitoring its sources and uses of funds . cibm bank 's funding requirements are primarily met by the inflow from deposits , loan repayments and investment debt service payments and maturities . cibm bank also makes use of noncore funding sources in a manner consistent with its liquidity , funding and market risk policies .
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 Suspicious Activity Report : cib marine recognizes the inherent imprecision in estimates of losses due to various uncertainties and variability related to the factors used to estimate loan losses . if different assumptions or conditions were to prevail and it is determined that the allowance is not adequate to absorb the new estimate of probable losses , an additional provision for loan losses would be made , which amount may be material to the consolidated financial statements . 28 measurement of fair value a portion of cib marine 's assets and liabilities are carried at fair value on the consolidated balance sheets , with changes in fair value recorded either through earnings or other comprehensive income in accordance with applicable gaap . these include cib marine 's available for sale securities , interest-rate derivatives related to mortgage loan originations , and other equity securities . the estimation of fair value also affects certain other loans held for sale , which are not recorded at fair value but at the lower of cost or market . the determination of fair value is important for certain other assets , including impaired loans , and other real estate owned that are periodically evaluated for impairment using fair value estimates . fair value is generally defined as the amount at which an asset or liability could be exchanged in a current transaction between willing , unrelated parties , other than in a forced or liquidation sale . fair value is based on quoted market prices in an active market , or if market prices are not available , is estimated using models employing techniques such as matrix pricing or discounting expected cash flows . the significant assumptions used in the models , which include assumptions for interest rates , discount rates , prepayments and credit losses , are independently verified against observable market data where possible . where observable market data is not available , the estimate of fair value becomes more subjective and involves a high degree of judgment . in this circumstance , fair value is estimated based on management 's judgment regarding the value that market participants would assign to the asset or liability . this valuation process takes into consideration factors such as market illiquidity . imprecision in estimating these factors can impact the amount recorded on the balance sheet for a particular asset or liability with related impacts to earnings or other comprehensive income . see note 22 to the consolidated financial statements appearing in item 8 of part ii of this form 10-k. securities available for sale available for sale securities are carried at fair value with unrealized net gains and losses reported in other comprehensive income ( loss ) in stockholders ' equity . management evaluates securities for otti at least on a quarterly basis and more frequently when economic or market conditions warrant . declines in the fair value of securities available for sale that are deemed to be other-than-temporary are charged to earnings as a realized loss , and a new cost basis for the securities is established . in evaluating otti , cib marine 's management considers the length of time and extent to which the fair value has been less than cost , the financial condition and near-term prospects of the issuer , whether or not cib marine intends to sell or it is more likely than not cib marine will be required to sell the security prior to a period of time sufficient to allow for any anticipated recovery of fair value , and other factors as detailed in note 4 to the consolidated financial statements appearing in item 8 of part ii of this form 10-k. income taxes cib marine recognizes expense for federal and state income taxes currently payable as well as for deferred federal and state taxes for estimated future tax effects of temporary differences between the tax basis of assets and liabilities and amounts reported in the consolidated balance sheets , as well as loss carryforwards and tax credit carryforwards . realization of deferred tax assets is dependent upon cib marine generating sufficient taxable income in either the carryforward or carryback periods to cover net operating losses generated by the reversal of temporary differences . a valuation allowance is provided by way of a charge to income tax expense if it is determined that it is not more likely than not that some portion or all of the deferred tax asset will be realized . if different assumptions and conditions were to prevail , the valuation allowance may not be adequate to absorb unrealized deferred taxes and the amount of income taxes payable may need to be adjusted by way of a charge or credit to expense . furthermore , income tax returns are subject to audit by the internal revenue service ( “ irs ” ) , state taxing authorities , and foreign government taxing authorities . income tax expense for current and prior periods is subject to adjustment based upon the outcome of such audits . cib marine believes it has adequately accrued for all probable income taxes payable and provided valuation allowances for deferred tax assets where it has been determined to be not more likely than not that such assets are realizable . accrual of income taxes payable and valuation allowances against deferred tax assets are estimates subject to change based upon the outcome of future events . 29 cib marine has entered into tax allocation agreements with its subsidiary entities included in the consolidated u.s. federal and unitary and combined state income tax returns , including u.s. operations of companies held for sale or disposal . these agreements govern the timing and amount of income tax payments required by the various entities . due to the significant losses incurred in 2006 through 2008 , as well as the operating losses from continuing operations in 2009 , management has determined that it is not more likely than not that the entire net deferred tax asset of $ 67.6 story_separator_special_tag cib marine 's net interest margin decreased by 20 basis points during 2008 compared to 2007 and its net interest spread increased by 7 basis points during the same period . the net interest margin decrease was primarily due to the increased reliance on interest bearing liabilities to fund the interest earning assets and the decline in the average yield on interest earning assets funded by non-interest bearing liabilities and capital . provision for loan losses the provision for loan losses represents charges made to earnings in order to maintain an allowance for loan losses and losses on unfunded commitments and standby letters of credit . the provision for loan losses increased $ 5.3 million from $ 22.1 million for the year ended december 31 , 2008 to $ 27.4 million for the year ended december 31 , 2009 and increased $ 15.7 million during 2008 from $ 6.4 million for the year ended december 31 , 2007. the provision for loan losses has been adversely affected by the economic environment and in particular for the following loan portfolio segments : home equity loan pools , construction and development loans , and commercial real estate loans . during 2009 , real estate markets continued to show signs of stress and deterioration , contributing to increased charge-offs and provisions . in particular , provisions during 2009 of $ 10.8 million , $ 6.2 million and $ 7.2 million were made due to deterioration in the credit quality of the home equity loan pools , construction and development loans , and commercial real estate loans , respectively . the provisions made for the year 2008 in each of these loan portfolio segments was $ 11.3 million , $ 11.0 million and a reversal of $ 2.2 million , respectively ; and provisions made for the year 2007 in each of these loan portfolio segments was $ 6.2 million , $ 2.2 million and a reversal of $ 1.4 million , respectively . 33 the $ 6.2 million provision allocated to the home equity pools in 2007 was primarily due to the purchase of the second pool of home equity loans in february 2007 and a sharp deterioration in credit quality beginning in the second quarter of 2007 ; while the $ 10.8 million and $ 11.3 million provision recorded in 2009 and 2008 , respectively , related to deterioration in the credit quality of these pools and the decision by cib marine to change its policy to charge-off 100 % of the outstanding principal balance of each loan in the pool when the loan is classified as 90 days past due on the servicer report received during the period . during 2009 , $ 11.7 million of these loans were charged-off compared to $ 12.4 million and $ 2.0 million during 2008 and 2007 , respectively . at december 31 , 2009 and 2008 , the remaining balance of these two purchased pools was $ 35.1 million and $ 52.2 million , respectively , with an allocated allowance of $ 3.9 million and $ 4.5 million , respectively . noninterest income noninterest income decreased $ 2.9 million from $ 4.4 million for the year ended december 31 , 2008 to $ 1.5 million for the year ended december 31 , 2009. the decrease was primarily due to a $ 4.1 million gain cib marine recognized during 2008 primarily from the sale of all of the branches and substantially all of the loans and deposits of its florida banking subsidiary with no comparable gain recognized in 2009. this was partially offset by a decrease of $ 1.4 million in otti from december 31 , 2008 to december 31 , 2009. noninterest income increased $ 1.3 million , or 43.1 % , from $ 3.1 million for the year ended december 31 , 2007 to $ 4.4 million for the year ended december 31 , 2008. the increase was mainly due to gain on sale of branches , offset partially by otti of $ 1.8 million for the year ended december 31 , 2008 compared to no otti in 2007. see securities available for sale section in item 7 of this form 10-k for further information regarding such adjustments . cib marine recognized a $ 4.1 million gain primarily from the sale of all of the branches and substantially all of the loans and deposits of its florida banking subsidiary in 2008. this compares to a $ 1.3 million gain recognized in 2007 primarily from the sale of two branches owned by marine bank . noninterest expense total noninterest expense decreased $ 8.9 million , or 22.2 % , from $ 39.9 million in 2008 , to $ 31.0 million in 2009. the decrease was primarily the result of the following : · compensation and employee benefits decreased $ 3.4 million , or 20.9 % , during 2009 compared to 2008 , primarily due to staff reductions due to the sale of cib marine 's florida banking subsidiary during the third quarter of 2008 and a reduction in force in the first quarter of 2009. the total number of full-time equivalent employees decreased from 197 at december 31 , 2008 to 165 at december 31 , 2009 . · equipment and occupancy expense together decreased $ 1.0 million , or 22.3 % , during 2009 compared to 2008 primarily due to the sale of cib marine 's florida banking subsidiary during the third quarter of 2008 . · a litigation reserve of $ 3.4 million was recorded and paid in 2008. there was no litigation reserve in 2009 . · fdic deposit insurance expense was $ 1.8 million for 2009 compared to $ 0.7 million for 2008. the increase of $ 1.1 million was the result of an effort by the fdic to replenish the deposit insurance fund in the wake of the recent increase in bank failures in the u.s. the fdic changed its rate structure in december 2008 to generally increase premiums

