loan losses are charged against the allowance when management determines all or a portion of the loan balance to be uncollectible . subsequent recoveries , if any , are credited to the allowance for cash received on previously charged-off amounts . if the allowance is considered inadequate to absorb future loan losses on existing loans for any reason , including but not limited to , increases in the size of the loan portfolio , increases in charge-offs or changes in the risk characteristics of the loan portfolio , then the provision for loan losses is increased . a loan is considered impaired when , based on current information and events , it is probable that the company will be unable to collect all amounts due according to the original contractual terms of the loan agreement . the collection of all amounts due according to original contractual terms means that both the contractual interest and principal payments of a loan will be collected as scheduled in the loan agreement . an impaired loan is measured based on the present value of expected future cash flows discounted at the loan 's effective interest rate , or , as a practical expedient , at the loan 's observable market price , or the fair value of the underlying collateral , reduced by costs to sell on a discounted basis , is used if a loan is collateral dependent . 47 investment securities impairment periodically , the company may need to assess whether there have been any events or economic circumstances to indicate that a security on which there is an unrealized loss is impaired on an other than temporary basis . in any such instance , the company would consider many factors , including the length of time and the extent to which the fair value has been less than the amortized cost basis , the market liquidity for the security , the financial condition and the near-term prospects of the issuer , expected cash flows , and the intent and ability to hold the investment for a period of time sufficient to recover the temporary loss . securities on which there is an unrealized loss that is deemed to be other than temporary are written down to fair value , with the write-down recorded as a realized loss in securities gains ( losses ) . the fair values of investment securities are generally determined by various pricing models . the company evaluates the methodologies used to develop the resulting fair values . the company performs a semi-annual analysis on the pricing of investment securities to ensure that the prices represent reasonable estimates of fair value . the procedures include initial and ongoing reviews of pricing methodologies and trends . the company seeks to ensure prices represent reasonable estimates of fair value through the use of broker quotes , current sales transactions from the portfolio and pricing techniques , which are based on the net present value of future expected cash flows discounted at a rate of return market participants would require . as a result of this analysis , if the company determines there is a more appropriate fair value , the price is adjusted accordingly . deferred tax asset the company uses the asset and liability method of accounting for income taxes as prescribed by gaap . under this method , deferred tax assets and liabilities are recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax basis . if currently available information indicates it is “ more likely than not ” that the deferred tax asset will not be realized , a valuation allowance is established . deferred tax assets and liabilities are measured using enacted tax rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled . accounting for deferred income taxes is a critical accounting estimate because the company exercises significant judgment in evaluating the amount and timing of recognition of the resulting tax liabilities and assets . management 's determination of the realization of deferred tax assets is based upon management 's judgment of various future events and uncertainties , including the timing and amount of future income , reversing temporary differences which may offset , and the implementation of various tax plans to maximize realization of the deferred tax asset . these judgments and estimates are inherently subjective and reviewed on a continual basis as regulatory and business factors change . any reduction in estimated future taxable income may require the company to record a valuation allowance against the deferred tax assets . a valuation allowance would result in additional income tax expense in such period , which would negatively affect earnings . results of operations net income 2019 compared to 2018 net income was $ 31.4 million for the year ended december 31 , 2019 , a 16.7 % increase over net income of $ 26.9 million for the year ended december 31 , 2018. net income per diluted common share for the year ended december 31 , 2019 was $ 1.05 , a 14.5 % increase , compared to $ 0.91 per diluted common share for the year ended december 31 , 2018. roa was 1.49 % and 1.51 % for the years ended december 31 , 2019 and 2018 , respectively . roe was 13.50 % and 13.87 % for the years ended december 31 , 2019 and 2018 , respectively . story_separator_special_tag the allowance for loan losses at december 31 , 2018 represented 1.20 % of gross loans outstanding , compared to 1.22 % at december 31 , 2017. the following table presents a summary of the activity in the allowance for loan losses for the years ended december 31 , 2019 , 2018 , and 2017 : replace_table_token_8_th noninterest income 2019 compared to 2018 noninterest income was $ 3.8 million for the year ended december 31 , 2019 , compared to $ 2.5 million for the year ended december 31 , 2018 , an increase of $ 1.3 million , or 50.5 % . the increase was primarily due to an increase in 54 gains on sales of securities and foreclosed assets and an increase in swap fees , partially offset by decreased letter of credit fees . 2018 compared to 2017 noninterest income was $ 2.5 million for the years ended december 31 , 2018 and 2017 , an increase of $ 7,000. the marginal increase was largely due to increased fees related to customer deposit accounts as a result of the overall increase in the number of our deposit clients , increased fees earned for letters of credit due to increased volume , and a decrease in losses on sales of securities . this activity was offset by an increased loss on sales of foreclosed assets . the following table presents the major components of noninterest income for the year ended december 31 , 2019 , compared to the year ended december 31 , 2018 , and for the year ended december 31 , 2018 , compared to the year ended december 31 , 2017 : replace_table_token_9_th noninterest expense 2019 compared to 2018 noninterest expense totaled $ 36.9 million for the year ended december 31 , 2019 , a $ 5.4 million , or 17.0 % increase from $ 31.6 million for the year ended december 31 , 2018. the increase was primarily driven by a $ 3.5 million increase in salaries and employee benefits as the result of merit increases and increased staff to meet the needs of the company 's growth , a $ 734,000 increase in occupancy and equipment and a $ 565,000 increase in professional and consulting fees . the increases were partially offset by a decrease of $ 180,000 in fdic insurance assessment due to a credit from the fdic for a portion of premiums previously paid to the dif that became refundable when the dif exceeded 1.38 % of insured deposits , which occurred during the year ended december 31 , 2019. the company has no remaining credits as of december 31 , 2019. full-time equivalent employees increased from 140 as of december 31 , 2018 , to 160 as of december 31 , 2019. the increase includes key strategic hires in deposit gathering roles , lending , information technology and other supportive functions as the company continues to attract talent and capitalize on the m & a disruption in its market area . efficiency ratio . the efficiency ratio , a non-gaap financial measure , reports total noninterest expense , less amortization of intangible assets , as a percentage of net interest income plus total noninterest income less gains ( losses ) on sales of securities . management believes this non-gaap financial measure provides a meaningful comparison of operational performance and facilitates investors ' assessments of business performance and trends in comparison to peers in the banking industry . the company 's efficiency ratio , and its comparability to some peers , is negatively impacted by the amortization of tax credit investments within noninterest expense . the efficiency ratio was 47.4 % for the year ended december 31 , 2019 , a marginal increase over 46.5 % for the year ended december 31 , 2018. the amortization of tax credit investments elevated the level of operating expenses in 55 both years , and while the recognition of the tax credits increases operating expenses , and concurrently the efficiency ratio , it directly reduces income tax expense and the effective tax rate . the adjusted efficiency ratio , a non-gaap financial measure , which excludes the impact of the amortization of tax credit investments , increased slightly to 43.3 % for the year ended december 31 , 2019 , compared to 41.7 % for the year ended december 31 , 2018 . 2018 compared to 2017 noninterest expense totaled $ 31.6 million for the year ended december 31 , 2018 , a $ 6.1 million , or 23.8 % increase from $ 25.5 million for the year ended december 31 , 2017. the increase was primarily driven by a $ 4.6 million increase in salaries and employee benefits as the result of merit increases and increased staff to meet the needs of the company 's growth , a $ 1.4 million increase in amortization of tax credit investments , a $ 261,000 increase in information technology and telecommunication expenses to support the company 's growing infrastructure , and a $ 359,000 increase in marketing expenses to increase brand recognition in its market area . the increases were partially offset by a decrease of $ 1.1 million in professional and consulting fees due to higher expenses incurred during 2017 for preparation of the company 's initial public offering , in comparison to 2018. full-time equivalent employees increased from 114 as of december 31 , 2017 , to 140 as of december 31 , 2018. efficiency ratio . the efficiency ratio was 46.5 % for the year ended december 31 , 2018 , a marginal increase over 44.4 % for the year ended december 31 , 2017. the amortization of tax credit investments elevated the level of operating expenses in both years , and while the recognition of the tax credits increases operating expenses , and concurrently the efficiency ratio , it directly reduces income tax expense and the effective tax rate . the adjusted efficiency ratio , a non-gaap financial measure , which excludes

liquidity liquidity is the company 's capacity to meet cash and collateral obligations at a reasonable cost . maintaining an adequate level of liquidity depends on the company 's ability to efficiently meet both expected and unexpected cash flows and collateral needs without adversely affecting either daily operations or financial condition . the bank 's alm committee , which is comprised of members of senior management , is responsible for managing commitments to meet the needs of customers while achieving the company 's financial objectives . the alm committee meets regularly to review balance sheet composition , funding capacities , and current and forecasted loan demand . the company manages liquidity by maintaining adequate levels of cash and other assets from on and off-balance sheet arrangements . specifically , on-balance sheet liquidity consists of cash and due from banks and unpledged investment securities available for sale , which are referred to as primary liquidity . in regard to off-balance sheet capacity , the company maintains available borrowing capacity under secured borrowing lines with the fhlb and the federal reserve bank of minneapolis , as well as unsecured lines of credit for the purpose of overnight funds with various correspondent banks , which the company refers to as secondary liquidity . in addition , the bank is a member of the american financial exchange , or afx , through which it may either borrow or lend funds on an overnight or short-term basis with a group of approved commercial banks . the availability of funds changes daily .


 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 liquidity is the company 's capacity to meet cash and collateral obligations at a reasonable cost . maintaining an adequate level of liquidity depends on the company 's ability to efficiently meet both expected and unexpected cash flows and collateral needs without adversely affecting either daily operations or financial condition . the bank 's alm committee , which is comprised of members of senior management , is responsible for managing commitments to meet the needs of customers while achieving the company 's financial objectives . the alm committee meets regularly to review balance sheet composition , funding capacities , and current and forecasted loan demand . the company manages liquidity by maintaining adequate levels of cash and other assets from on and off-balance sheet arrangements . specifically , on-balance sheet liquidity consists of cash and due from banks and unpledged investment securities available for sale , which are referred to as primary liquidity . in regard to off-balance sheet capacity , the company maintains available borrowing capacity under secured borrowing lines with the fhlb and the federal reserve bank of minneapolis , as well as unsecured lines of credit for the purpose of overnight funds with various correspondent banks , which the company refers to as secondary liquidity . in addition , the bank is a member of the american financial exchange , or afx , through which it may either borrow or lend funds on an overnight or short-term basis with a group of approved commercial banks . the availability of funds changes daily .
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 Suspicious Activity Report : loan losses are charged against the allowance when management determines all or a portion of the loan balance to be uncollectible . subsequent recoveries , if any , are credited to the allowance for cash received on previously charged-off amounts . if the allowance is considered inadequate to absorb future loan losses on existing loans for any reason , including but not limited to , increases in the size of the loan portfolio , increases in charge-offs or changes in the risk characteristics of the loan portfolio , then the provision for loan losses is increased . a loan is considered impaired when , based on current information and events , it is probable that the company will be unable to collect all amounts due according to the original contractual terms of the loan agreement . the collection of all amounts due according to original contractual terms means that both the contractual interest and principal payments of a loan will be collected as scheduled in the loan agreement . an impaired loan is measured based on the present value of expected future cash flows discounted at the loan 's effective interest rate , or , as a practical expedient , at the loan 's observable market price , or the fair value of the underlying collateral , reduced by costs to sell on a discounted basis , is used if a loan is collateral dependent . 47 investment securities impairment periodically , the company may need to assess whether there have been any events or economic circumstances to indicate that a security on which there is an unrealized loss is impaired on an other than temporary basis . in any such instance , the company would consider many factors , including the length of time and the extent to which the fair value has been less than the amortized cost basis , the market liquidity for the security , the financial condition and the near-term prospects of the issuer , expected cash flows , and the intent and ability to hold the investment for a period of time sufficient to recover the temporary loss . securities on which there is an unrealized loss that is deemed to be other than temporary are written down to fair value , with the write-down recorded as a realized loss in securities gains ( losses ) . the fair values of investment securities are generally determined by various pricing models . the company evaluates the methodologies used to develop the resulting fair values . the company performs a semi-annual analysis on the pricing of investment securities to ensure that the prices represent reasonable estimates of fair value . the procedures include initial and ongoing reviews of pricing methodologies and trends . the company seeks to ensure prices represent reasonable estimates of fair value through the use of broker quotes , current sales transactions from the portfolio and pricing techniques , which are based on the net present value of future expected cash flows discounted at a rate of return market participants would require . as a result of this analysis , if the company determines there is a more appropriate fair value , the price is adjusted accordingly . deferred tax asset the company uses the asset and liability method of accounting for income taxes as prescribed by gaap . under this method , deferred tax assets and liabilities are recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax basis . if currently available information indicates it is “ more likely than not ” that the deferred tax asset will not be realized , a valuation allowance is established . deferred tax assets and liabilities are measured using enacted tax rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled . accounting for deferred income taxes is a critical accounting estimate because the company exercises significant judgment in evaluating the amount and timing of recognition of the resulting tax liabilities and assets . management 's determination of the realization of deferred tax assets is based upon management 's judgment of various future events and uncertainties , including the timing and amount of future income , reversing temporary differences which may offset , and the implementation of various tax plans to maximize realization of the deferred tax asset . these judgments and estimates are inherently subjective and reviewed on a continual basis as regulatory and business factors change . any reduction in estimated future taxable income may require the company to record a valuation allowance against the deferred tax assets . a valuation allowance would result in additional income tax expense in such period , which would negatively affect earnings . results of operations net income 2019 compared to 2018 net income was $ 31.4 million for the year ended december 31 , 2019 , a 16.7 % increase over net income of $ 26.9 million for the year ended december 31 , 2018. net income per diluted common share for the year ended december 31 , 2019 was $ 1.05 , a 14.5 % increase , compared to $ 0.91 per diluted common share for the year ended december 31 , 2018. roa was 1.49 % and 1.51 % for the years ended december 31 , 2019 and 2018 , respectively . roe was 13.50 % and 13.87 % for the years ended december 31 , 2019 and 2018 , respectively . story_separator_special_tag the allowance for loan losses at december 31 , 2018 represented 1.20 % of gross loans outstanding , compared to 1.22 % at december 31 , 2017. the following table presents a summary of the activity in the allowance for loan losses for the years ended december 31 , 2019 , 2018 , and 2017 : replace_table_token_8_th noninterest income 2019 compared to 2018 noninterest income was $ 3.8 million for the year ended december 31 , 2019 , compared to $ 2.5 million for the year ended december 31 , 2018 , an increase of $ 1.3 million , or 50.5 % . the increase was primarily due to an increase in 54 gains on sales of securities and foreclosed assets and an increase in swap fees , partially offset by decreased letter of credit fees . 2018 compared to 2017 noninterest income was $ 2.5 million for the years ended december 31 , 2018 and 2017 , an increase of $ 7,000. the marginal increase was largely due to increased fees related to customer deposit accounts as a result of the overall increase in the number of our deposit clients , increased fees earned for letters of credit due to increased volume , and a decrease in losses on sales of securities . this activity was offset by an increased loss on sales of foreclosed assets . the following table presents the major components of noninterest income for the year ended december 31 , 2019 , compared to the year ended december 31 , 2018 , and for the year ended december 31 , 2018 , compared to the year ended december 31 , 2017 : replace_table_token_9_th noninterest expense 2019 compared to 2018 noninterest expense totaled $ 36.9 million for the year ended december 31 , 2019 , a $ 5.4 million , or 17.0 % increase from $ 31.6 million for the year ended december 31 , 2018. the increase was primarily driven by a $ 3.5 million increase in salaries and employee benefits as the result of merit increases and increased staff to meet the needs of the company 's growth , a $ 734,000 increase in occupancy and equipment and a $ 565,000 increase in professional and consulting fees . the increases were partially offset by a decrease of $ 180,000 in fdic insurance assessment due to a credit from the fdic for a portion of premiums previously paid to the dif that became refundable when the dif exceeded 1.38 % of insured deposits , which occurred during the year ended december 31 , 2019. the company has no remaining credits as of december 31 , 2019. full-time equivalent employees increased from 140 as of december 31 , 2018 , to 160 as of december 31 , 2019. the increase includes key strategic hires in deposit gathering roles , lending , information technology and other supportive functions as the company continues to attract talent and capitalize on the m & a disruption in its market area . efficiency ratio . the efficiency ratio , a non-gaap financial measure , reports total noninterest expense , less amortization of intangible assets , as a percentage of net interest income plus total noninterest income less gains ( losses ) on sales of securities . management believes this non-gaap financial measure provides a meaningful comparison of operational performance and facilitates investors ' assessments of business performance and trends in comparison to peers in the banking industry . the company 's efficiency ratio , and its comparability to some peers , is negatively impacted by the amortization of tax credit investments within noninterest expense . the efficiency ratio was 47.4 % for the year ended december 31 , 2019 , a marginal increase over 46.5 % for the year ended december 31 , 2018. the amortization of tax credit investments elevated the level of operating expenses in 55 both years , and while the recognition of the tax credits increases operating expenses , and concurrently the efficiency ratio , it directly reduces income tax expense and the effective tax rate . the adjusted efficiency ratio , a non-gaap financial measure , which excludes the impact of the amortization of tax credit investments , increased slightly to 43.3 % for the year ended december 31 , 2019 , compared to 41.7 % for the year ended december 31 , 2018 . 2018 compared to 2017 noninterest expense totaled $ 31.6 million for the year ended december 31 , 2018 , a $ 6.1 million , or 23.8 % increase from $ 25.5 million for the year ended december 31 , 2017. the increase was primarily driven by a $ 4.6 million increase in salaries and employee benefits as the result of merit increases and increased staff to meet the needs of the company 's growth , a $ 1.4 million increase in amortization of tax credit investments , a $ 261,000 increase in information technology and telecommunication expenses to support the company 's growing infrastructure , and a $ 359,000 increase in marketing expenses to increase brand recognition in its market area . the increases were partially offset by a decrease of $ 1.1 million in professional and consulting fees due to higher expenses incurred during 2017 for preparation of the company 's initial public offering , in comparison to 2018. full-time equivalent employees increased from 114 as of december 31 , 2017 , to 140 as of december 31 , 2018. efficiency ratio . the efficiency ratio was 46.5 % for the year ended december 31 , 2018 , a marginal increase over 44.4 % for the year ended december 31 , 2017. the amortization of tax credit investments elevated the level of operating expenses in both years , and while the recognition of the tax credits increases operating expenses , and concurrently the efficiency ratio , it directly reduces income tax expense and the effective tax rate . the adjusted efficiency ratio , a non-gaap financial measure , which excludes

