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Bank management must recognize that the investment account is primarily a secondary reserve for liquidity rather than a vehicle to generate speculative profits. However, risks in the investment portfolio should be minimized to ensure that liquidity and marketability are maintained.
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In both examinations, examiners concluded that the bank had not engaged in redlining. In addition to conducting additional analyses, the examiners considered other factors to support or contradict interpreting identified disparities to be the result of intentional discrimination.
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