Management’s discussion and analysis 146 JPMorgan Chase & Co. /2010 Annual Report Immediate changes in interest rates present a limited view of risk, and so a number of alternative scenarios are also reviewed.
These scenarios include the implied forward curve, nonparallel rate shifts and severe interest rate shocks on selected key rates.
These scenarios are intended to provide a comprehensive view of JPMorgan Chase’s earnings at risk over a wide range of outcomes.
JPMorgan Chase’s 12-month pretax earnings sensitivity profiles as of December 31, 2010 and 2009, were as follows.
## Table 0 ##
(a) Downward 100- and 200-basis-point parallel shocks result in a Fed Funds target rate of zero, and negative three- and six-month Treasury rates.
The earnings-at-risk results of such a low-probability scenario are not meaningful.
(b) Excludes economic value stress losses.
The change in earnings at risk from December 31, 2009, resulted from investment portfolio repositioning, assumed higher levels of deposit balances and reduced levels of fixed-rate loans.
The Firm’s risk to rising rates was largely the result of widening deposit margins, which are currently compressed due to very low short-term interest rates.
Additionally, another interest rate scenario conducted by the Firm – involving a steeper yield curve with long-term rates rising by 100 basis points and short-term rates staying at current levels – results in a 12- month pretax earnings benefit of $770 million.
The increase in earnings under this scenario is due to reinvestment of maturing assets at the higher long-term rates, with funding costs remaining unchanged.
Risk monitoring and control Limits Market risk is controlled primarily through a series of limits.
Limits reflect the Firm’s risk appetite in the context of the market environment and business strategy.
In setting limits, the Firm takes into consideration factors such as senior management risk appetite, market volatility, product liquidity, accommodation of client business and management experience.
Market risk management regularly reviews and updates risk limits.
Senior management, including the Firm’s Chief Executive Officer and Chief Risk Officer, is responsible for reviewing and approving cetain risk limits on an ongoing basis.
The Firm maintains different levels of limits.
Corporate-level limits include VaR and stress limits.
Similarly, line-of-business limits include VaR and stress limits and may be supplemented by loss advisories, nonstatistical measurements and profit and loss drawdowns.
Businesses are responsible for adhering to established limits, against which exposures are monitored and reported.
Limit breaches are reported in a timely manner to senior management, and the affected line-of-business is required to reduce trading positions or consult with senior management on the appropriate action.
Model review Some of the Firm’s financial instruments cannot be valued based on quoted market prices but are instead valued using pricing models.
These pricing models and VaR models are used for management of risk positions, such as reporting against limits, as well as for valuation.
The Model Risk Group, which is independent of the businesses and market risk management, reviews the models the Firm uses and assesses model appropriateness and consistency.
The model reviews consider a number of factors about the model’s suitability for valuation and risk management of a particular product.
These factors include whether the model accurately reflects the characteristics of the transaction and its significant risks, the suitability and convergence properties of numerical algorithms, reliability of data sources, consistency of the treatment with models for similar products, and sensitivity to input parameters and assumptions that cannot be priced from the market.
Reviews are conducted of new or changed models, as well as previously accepted models, to assess whether there have been any changes in the product or market that may affect the model’s validity and whether there are theoretical or competitive developments that may require reassessment of the model’s adequacy.
For a summary of valuations based on models, see Critical Accounting Estimates Used by the Firm on pages 149–154 of this Annual Report.
Risk reporting Nonstatistical risk measures, VaR, loss advisories and limit excesses are reported daily to the lines of business and to senior management.
Market risk exposure trends, VaR trends, profit-and-loss changes and portfolio concentrations are reported weekly.
Stresstest results are also reported weekly to the lines of business and to senior management.
The following table presents the U. S.  and non-U.
S.  components of income before income tax expense/(benefit) and extraordinary gain for the years ended December 31, 2010, 2009 and 2008.
## Table 1 ##
(a) For purposes of this table, non-U.
S.  income is defined as income generated from operations located outside the U. S.  Note 28 – Restrictions on cash and intercompany funds transfers The business of JPMorgan Chase Bank, National Association (“JPMorgan Chase Bank, N. A.
”) is subject to examination and regulation by the Office of the Comptroller of the Currency (“OCC”).
The Bank is a member of the U. S.  Federal Reserve System, and its deposits in the U. S.  are insured by the FDIC.
The Board of Governors of the Federal Reserve System (the “Federal Reserve”) requires depository institutions to maintain cash reserves with a Federal Reserve Bank.
The average amount of reserve balances deposited by the Firm’s bank subsidiaries with various Federal Reserve Banks was approximately $803 million and $821 million in 2010 and 2009, respectively.
Restrictions imposed by U. S.  federal law prohibit JPMorgan Chase and certain of its affiliates from borrowing from banking subsidiaries unless the loans are secured in specified amounts.
Such secured loans to the Firm or to other affiliates are generally limited to 10% of the banking subsidiary’s total capital, as determined by the riskbased capital guidelines; the aggregate amount of all such loans is limited to 20% of the banking subsidiary’s total capital.
The principal sources of JPMorgan Chase’s income (on a parent company–only basis) are dividends and interest from JPMorgan Chase Bank, N. A. , and the other banking and nonbanking subsidiaries of JPMorgan Chase.
In addition to dividend restrictions set forth in statutes and regulations, the Federal Reserve, the OCC and the FDIC have authority under the Financial Institutions Supervisory Act to prohibit or to limit the payment of dividends by the banking organizations they supervise, including JPMorgan Chase and its subsidiaries that are banks or bank holding companies, if, in the banking regulator’s opinion, payment of a dividend would constitute an unsafe or unsound practice in light of the financial condition of the banking organization.
At January 1, 2011, JPMorgan Chase’s banking subsidiaries could pay, in the aggregate, $2.0 billion in dividends to their respective bank holding companies without the prior approval of their relevant banking regulators.
The capacity to pay dividends in 2011 will be supplemented by the banking subsidiaries’ earnings during the year.
In compliance with rules and regulations established by U. S.  and non-U.
S.  regulators, as of December 31, 2010 and 2009, cash in the amount of $25.0 billion and $24.0 billion, respectively, and securities with a fair value of $9.7 billion and $10.2 billion, respectively, were segregated in special bank accounts for the benefit of securities and futures brokerage customers.
Note 29 – Capital The Federal Reserve establishes capital requirements, including well-capitalized standards for the consolidated financial holding company.
The OCC establishes similar capital requirements and standards for the Firm’s national banks, including JPMorgan Chase Bank, N. A. , and Chase Bank USA, N. A.
There are two categories of risk-based capital: Tier 1 capital and Tier 2 capital.
Tier 1 capital consists of common stockholders’ equity, perpetual preferred stock, noncontrolling interests in subsidiaries and trust preferred capital debt securities, less goodwill and certain other adjustments.
Tier 2 capital consists of preferred stock not qualifying as Tier 1, subordinated long-term debt and other instruments qualifying as Tier 2, and the aggregate allowance for credit losses up to a certain percentage of risk-weighted assets.
Total capital is Tier 1 capital plus Tier 2 capital.
Under the riskbased capital guidelines of the Federal Reserve, JPMorgan Chase is required to maintain minimum ratios of Tier 1 and Total capital to risk-weighted assets, as well as minimum leverage ratios (which are defined as Tier 1 capital divided by adjusted quarterly average assets).
Failure to meet these minimum requirements could cause the Federal Reserve to take action.
Banking subsidiaries also are subject to these capital requirements by their respective primary regulators.
As of December 31, 2010 and 2009, JPMorgan Chase and all of its banking subsidiaries were well-capitalized and met all capital requirements to which each was subject.
The following table presents standby letters of credit and other letters of credit arrangements by the ratings profiles of the Firm’s customers as of December 31, 2010 and 2009.
Standby letters of credit and other financial guarantees and other letters of credit
## Table 2 ##
(a) The ratings scale is based on the Firm’s internal ratings which generally correspond to ratings as defined by S&P and Moody’s.
(b) At December 31, 2010 and 2009, represents the contractual amount net of risk participations totaling $22.4 billion and $24.6 billion, respectively, for standby letters of credit and other financial guarantees; and $1.1 billion and $690 million, respectively, for other letters of credit.
In regulatory filings with the Federal Reserve these commitments are shown gross of risk participations.
(c) At December 31, 2010 and 2009, includes unissued standby letters of credit commitments of $41.6 billion and $38.4 billion, respectively.
Indemnification agreements – general In connection with issuing securities to investors, the Firm may enter into contractual arrangements with third parties that require the Firm to make a payment to them in the event of a change in tax law or an adverse interpretation of tax law.
In certain cases, the contract also may include a termination clause, which would allow the Firm to settle the contract at its fair value in lieu of making a payment under the indemnification clause.
The Firm may also enter into indemnification clauses in connection with the licensing of software to clients (“software licensees”) or when it sells a business or assets to a third party (“third-party purchasers”), pursuant to which it indemnifies software licensees for claims of liability or damages that may occur subsequent to the licensing of the software, or third-party purchasers for losses they may incur due to actions taken by the Firm prior to the sale of the business or assets.
It is difficult to estimate the Firm’s maximum exposure under these indemnification arrangements, since this would require an assessment of future changes in tax law and future claims that may be made against the Firm that have not yet occurred.
However, based on historical experience, management expects the risk of loss to be remote.
Securities lending indemnification Through the Firm’s securities lending program, customers’ securities, via custodial and non-custodial arrangements, may be lent to third parties.
As part of this program, the Firm provides an indemnification in the lending agreements which protects the lender against the failure of the third-party borrower to return the lent securities in the event the Firm did not obtain sufficient collateral.
To minimize its liability under these indemnification agreements, the Firm obtains cash or other highly liquid collateral with a market value exceeding 100% of the value of the securities on loan from the borrower.
Collateral is marked to market daily to help assure that collateralization is adequate.
Additional collateral is called from the borrower if a shortfall exists, or collateral may be released to the borrower in the event of overcollateralization.
If a borrower defaults, the Firm would use the collateral held to purchase replacement securities in the market or to credit the lending customer with the cash equivalent thereof.
Also, as part of this program, the Firm invests cash collateral received from the borrower in accordance with approved guidelines.
Derivatives qualifying as guarantees In addition to the contracts described above, the Firm transacts certain derivative contracts that meet the characteristics of a guarantee under U. S.  GAAP.
These contracts include written put options that require the Firm to purchase assets upon exercise by the option holder at a specified price by a specified date in the future.
The Firm may enter into written put option contracts in order to meet client needs, or for trading purposes.
The terms of written put options are typically five years or less.
Derivative guarantees also include contracts such as stable value derivatives that require the Firm to make a payment of the difference between the market value and the book value of a counterparty’s reference portfolio of assets in the event that market value is less than book value and certain other conditions have been met.
Stable value derivatives, commonly referred to as “stable value wraps”, are transacted in order to allow investors to realize investment returns with less volatility than an unprotected portfolio and are typically longer-term or may have no stated maturity, but allow the Firm to terminate the contract under certain conditions.
Derivative guarantees are recorded on the Consolidated Balance Sheets at fair value in trading assets and trading liabilities.
The total notional amount of the derivatives that the Firm deems to be guarantees was $87.8 billion and $98.1 billion at December 31, 2010 and 2009, respectively.
The notional amount generally represents the Firm’s maximum exposure to derivatives qualifying as guarantees.
However, exposure to certain stable value derivatives is contractually limited to a substantially lower percentage of the notional amount; the notional amount on these stable value contracts was $25.9 billion and $24.9 billion and the maximum exposure to loss was $2.7 billion and $2.5 billion, at December 31, 2010 and 2009, respectively.
The fair values of the contracts reflects the probability of whether the Firm will be required to perform under the contract.
The fair value related to derivative guarantees were derivative payables of $390 million and $974 million and derivative receivables of $96 million and $78 million at
The Firm matches eligible employee contributions up to 5% of eligible compensation (generally base pay; effective January 1, 2015, in addition to base pay, eligible compensation will include certain other types of variable incentive compensation) on an annual basis.
Employees begin to receive matching contributions after completing a one-year-of-service requirement.
Employees with total annual cash compensation of $250,000 or more are not eligible for matching contributions.
Matching contributions vest after three years of service for employees hired on or after May 1, 2009.
The 401(k) Savings Plan also permits discretionary profit-sharing contributions by participating companies for certain employees, subject to a specified vesting schedule.
OPEB plans JPMorgan Chase offers postretirement medical and life insurance benefits to certain retirees and postretirement medical benefits to qualifying U. S.  employees.
These benefits vary with the length of service and the date of hire and provide for limits on the Firm’s share of covered medical benefits.
The medical and life insurance benefits are both contributory.
Postretirement medical benefits also are offered to qualifying United Kingdom (“U.
K. ”) employees.
JPMorgan Chase’s U. S.  OPEB obligation is funded with corporate-owned life insurance (“COLI”) purchased on the lives of eligible employees and retirees.
While the Firm owns the COLI policies, COLI proceeds (death benefits, withdrawals and other distributions) may be used only to reimburse the Firm for its net postretirement benefit claim payments and related administrative expense.
The U. K.  OPEB plan is unfunded.
The following table presents the changes in benefit obligations, plan assets and funded status amounts reported on the Consolidated balance sheets for the Firm’s U. S.  and non-U.
S.  defined benefit pension and OPEB plans.
## Table 3 ##
(a) Represents plans with an aggregate overfunded balance of $3.9 billion and $5.1 billion at December 31, 2014 and 2013, respectively, and plans with an aggregate underfunded balance of $708 million and $540 million at December 31, 2014 and 2013, respectively.
(b) At December 31, 2014 and 2013, approximately $336 million and $429 million, respectively, of U. S.  plan assets included participation rights under participating annuity contracts.
(c) At December 31, 2014 and 2013, defined benefit pension plan amounts not measured at fair value included $106 million and $96 million, respectively, of accrued receivables, and $257 million and $104 million, respectively, of accrued liabilities, for U. S.  plans.
(d) Includes an unfunded accumulated postretirement benefit obligation of $37 million and $34 million at December 31, 2014 and 2013, respectively, for the U. K.  plan.

<table><tr><td></td><td colspan="6">Immediate change in rates</td></tr><tr><td>December 31, (in millions)</td><td>+200bp</td><td>+100bp</td><td>-100bp</td><td></td><td>-200bp</td><td></td></tr><tr><td> 2010</td><td>$2,465</td><td>$1,483</td><td> NM</td><td><sup>(a)(b)</sup></td><td> NM</td><td><sup>(a)(b)</sup></td></tr><tr><td>2009</td><td>$-1,594</td><td>$-554</td><td>NM</td><td><sup>(a)</sup></td><td>NM</td><td><sup>(a)</sup></td></tr></table>
<table><tr><td>Year ended December 31, (in millions)</td><td>2010</td><td>2009</td><td>2008</td></tr><tr><td>U.S.</td><td>$16,568</td><td>$6,263</td><td>$-2,094</td></tr><tr><td>Non-U.S.<sup>(a)</sup></td><td>8,291</td><td>9,804</td><td>4,867</td></tr><tr><td>Income before incometax expense/(benefit)andextraordinary gain</td><td>$24,859</td><td>$16,067</td><td>$2,773</td></tr></table>
<table><tr><td></td><td colspan="3"> 2010</td><td colspan="3">2009</td></tr><tr><td>December 31, (in millions)</td><td colspan="2">Standby letters of credit and other financial guarantees</td><td>Other letters of credit</td><td colspan="2">Standby letters of credit and other financial guarantees</td><td>Other letters of credit</td></tr><tr><td>Investment-grade<sup>(a)</sup></td><td>$70,236</td><td></td><td>$5,289</td><td>$66,786</td><td></td><td>$3,861</td></tr><tr><td>Noninvestment-grade<sup>(a)</sup></td><td>24,601</td><td></td><td>1,374</td><td>24,699</td><td></td><td>1,306</td></tr><tr><td> Total contractual amount<sup>(b)</sup></td><td>94,837</td><td><sup>(c)</sup></td><td>6,663</td><td>91,485</td><td><sup>(c)</sup></td><td>5,167</td></tr><tr><td>Allowance for lending-related commitments</td><td>345</td><td></td><td>2</td><td>552</td><td></td><td>1</td></tr><tr><td>Commitments with collateral</td><td>37,815</td><td></td><td>2,127</td><td>31,454</td><td></td><td>1,315</td></tr></table>
<table><tr><td></td><td colspan="5">Defined benefit pension plans</td><td colspan="2"></td></tr><tr><td>As of or for the year ended December 31,</td><td colspan="2">U.S.</td><td></td><td colspan="2">Non-U.S.</td><td colspan="2">OPEB plans<sup>(d)</sup></td></tr><tr><td>(in millions)</td><td>2014</td><td>2013</td><td></td><td>2014</td><td>2013</td><td>2014</td><td>2013</td></tr><tr><td>Change in benefit obligation</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Benefit obligation, beginning of year</td><td>$-10,776</td><td>$-11,478</td><td></td><td>$-3,433</td><td>$-3,243</td><td>$-826</td><td>$-990</td></tr><tr><td>Benefits earned during the year</td><td>-281</td><td>-314</td><td></td><td>-33</td><td>-34</td><td>—</td><td>-1</td></tr><tr><td>Interest cost on benefit obligations</td><td>-534</td><td>-447</td><td></td><td>-137</td><td>-125</td><td>-38</td><td>-35</td></tr><tr><td>Plan amendments</td><td>-53</td><td>—</td><td></td><td>—</td><td>—</td><td>—</td><td>—</td></tr><tr><td>Special termination benefits</td><td>—</td><td>—</td><td></td><td>-1</td><td>—</td><td>—</td><td>—</td></tr><tr><td>Curtailments</td><td>—</td><td>—</td><td></td><td>—</td><td>—</td><td>-3</td><td>—</td></tr><tr><td>Employee contributions</td><td>NA</td><td>NA</td><td></td><td>-7</td><td>-7</td><td>-62</td><td>-72</td></tr><tr><td>Net gain/(loss)</td><td>-1,669</td><td>794</td><td></td><td>-408</td><td>-62</td><td>-58</td><td>138</td></tr><tr><td>Benefits paid</td><td>777</td><td>669</td><td></td><td>119</td><td>106</td><td>145</td><td>144</td></tr><tr><td>Expected Medicare Part D subsidy receipts</td><td>NA</td><td>NA</td><td></td><td>NA</td><td>NA</td><td>-2</td><td>-10</td></tr><tr><td>Foreign exchange impact and other</td><td>—</td><td>—</td><td></td><td>260</td><td>-68</td><td>2</td><td>—</td></tr><tr><td>Benefit obligation, end of year</td><td>$-12,536</td><td>$-10,776</td><td></td><td>$-3,640</td><td>$-3,433</td><td>$-842</td><td>$-826</td></tr><tr><td>Change in plan assets</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Fair value of plan assets, beginning of year</td><td>$14,354</td><td>$13,012</td><td></td><td>$3,532</td><td>$3,330</td><td>$1,757</td><td>$1,563</td></tr><tr><td>Actual return on plan assets</td><td>1,010</td><td>1,979</td><td></td><td>518</td><td>187</td><td>159</td><td>211</td></tr><tr><td>Firm contributions</td><td>36</td><td>32</td><td></td><td>46</td><td>45</td><td>3</td><td>2</td></tr><tr><td>Employee contributions</td><td>—</td><td>—</td><td></td><td>7</td><td>7</td><td>—</td><td>—</td></tr><tr><td>Benefits paid</td><td>-777</td><td>-669</td><td></td><td>-119</td><td>-106</td><td>-16</td><td>-19</td></tr><tr><td>Foreign exchange impact and other</td><td>—</td><td>—</td><td></td><td>-266</td><td>69</td><td>—</td><td>—</td></tr><tr><td>Fair value of plan assets, end of year</td><td>$14,623</td><td>$14,354</td><td><sup>(b)(c)</sup></td><td>$3,718</td><td>$3,532</td><td>$1,903</td><td>$1,757</td></tr><tr><td>Net funded status<sup>(a)</sup></td><td>$2,087</td><td>$3,578</td><td></td><td>$78</td><td>$99</td><td>$1,061</td><td>$931</td></tr><tr><td>Accumulated benefit obligation, end of year</td><td>$-12,375</td><td>$-10,685</td><td></td><td>$-3,615</td><td>$-3,406</td><td>NA</td><td>NA</td></tr></table>

Question: What is the difference between the greatest Non-U.S. in 2014 and 2013？ (in million)