If we are an Intermediate Small Bank (ISB), and we have had "qualified investments" of $2 million during the past two exams, (the first exam under a Large Bank and the second exam under a Small Bank requirements) if management decides to cash-in that investment because of the economy, what are our risks in terms of future CRA exams? Isn't "Qualified Investments" required and included in the Community Development Test for ISB's? How would you advise management?

Goal Keeper, I am visiting in Santa Fe this week. As an ISB the importance of community development is magnified. Since I don't know how the other elements of your community development performance look it is impossible to give you an opinion about how critical the liquidation of the investments is. You really need to evaluate your bank's CD performance and determine if these investments are critical to attaining a satisfactory level of CD activity. As an ISB the CD test is "more flexible" in that it allows different combinations of CD activity, so strictly speaking you don't have to have CD investments if you have very strong CD lending and services. But again it is impossible to give you a professional opinion without knowing the details.