implementing further revisions to the Capital Accord in the U. S.  (such further revisions are commonly referred to as “Basel III”).
Basel III revised Basel II by, among other things, narrowing the definition of capital, and increasing capital requirements for specific exposures.
Basel III also includes higher capital ratio requirements and provides that the Tier 1 common capital requirement will be increased to 7%, comprised of a minimum ratio of 4.5% plus a 2.5% capital conservation buffer.
Implementation of the 7% Tier 1 common capital requirement is required by January 1, 2019.
In addition, global systemically important banks (“GSIBs”) will be required to maintain Tier 1 common requirements above the 7% minimum in amounts ranging from an additional 1% to an additional 2.5%.
In November 2012, the Financial Stability Board (“FSB”) indicated that it would require the Firm, as well as three other banks, to hold the additional 2.5% of Tier 1 common; the requirement will be phased in beginning in 2016.
The Basel Committee also stated it intended to require certain GSIBs to hold an additional 1% of Tier 1 common under certain circumstances, to act as a disincentive for the GSIB from taking actions that would further increase its systemic importance.
Currently, no GSIB (including the Firm) is required to hold this additional 1% of Tier 1 common.
In addition, pursuant to the requirements of the Dodd-Frank Act, U. S.  federal banking agencies have proposed certain permanent Basel I floors under Basel II and Basel III capital calculations.
The following table presents a comparison of the Firm’s Tier 1 common under Basel I rules to its estimated Tier 1 common under Basel III rules, along with the Firm’s estimated risk-weighted assets.
Tier 1 common under Basel III includes additional adjustments and deductions not included in Basel I Tier 1 common, such as the inclusion of AOCI related to AFS securities and defined benefit pension and other postretirement employee benefit (“OPEB”) plans.
The Firm estimates that its Tier 1 common ratio under Basel III rules would be 8.7% as of December 31, 2012.
The Tier 1 common ratio under both Basel I and Basel III are nonGAAP financial measures.
However, such measures are used by bank regulators, investors and analysts as a key measure to assess the Firm’s capital position and to compare the Firm’s capital to that of other financial services companies.
## Table 0 ##
(a) Key differences in the calculation of risk-weighted assets between Basel I and Basel III include: (1) Basel III credit risk RWA is based on risk-sensitive approaches which largely rely on the use of internal credit models and parameters, whereas Basel I RWA is based on fixed supervisory risk weightings which vary only by counterparty type and asset class; (2) Basel III market risk RWA reflects the new capital requirements related to trading assets and securitizations, which include incremental capital requirements for stress VaR, correlation trading, and re-securitization positions; and (3) Basel III includes RWA for operational risk, whereas Basel I does not.
The actual impact on the Firm’s capital ratios upon implementation could differ depending on final implementation guidance from the regulators, as well as regulatory approval of certain of the Firm’s internal risk models.
(b) The Tier 1 common ratio is Tier 1 common divided by RWA.
The Firm’s estimate of its Tier 1 common ratio under Basel III reflects its current understanding of the Basel III rules based on information currently published by the Basel Committee and U. S.  federal banking agencies and on the application of such rules to its businesses as currently conducted; it excludes the impact of any changes the Firm may make in the future to its businesses as a result of implementing the Basel III rules, possible enhancements to certain market risk models, and any further implementation guidance from the regulators.
The Basel III capital requirements are subject to prolonged transition periods.
The transition period for banks to meet the Tier 1 common requirement under Basel III was originally scheduled to begin in 2013, with full implementation on January 1, 2019.
In November 2012, the U. S.  federal banking agencies announced a delay in the implementation dates for the Basel III capital requirements.
The additional capital requirements for GSIBs will be phased in starting January 1, 2016, with full implementation on January 1, 2019.
Management’s current objective is for the Firm to reach, by the end of 2013, an estimated Basel III Tier I common ratio of 9.5%.
Additional information regarding the Firm’s capital ratios and the federal regulatory capital standards to which it is subject is presented in Supervision and regulation on pages 1–8 of the 2012 Form 10-K, and Note 28 on pages 306– 308 of this Annual Report.
Broker-dealer regulatory capital JPMorgan Chase’s principal U. S.  broker-dealer subsidiaries are J. P.  Morgan Securities LLC (“JPMorgan Securities”) and J. P.  Morgan Clearing Corp.  (“JPMorgan Clearing”).
JPMorgan Clearing is a subsidiary of JPMorgan Securities and provides clearing and settlement services.
JPMorgan Securities and JPMorgan Clearing are each subject to Rule 15c3-1 under the Securities Exchange Act of 1934 (the “Net Capital Rule”).
JPMorgan Securities and JPMorgan Clearing are also each registered as futures commission merchants and subject to Rule 1.17 of the Commodity Futures Trading Commission (“CFTC”).
JPMorgan Securities and JPMorgan Clearing have elected to compute their minimum net capital requirements in accordance with the “Alternative Net Capital Requirements” of the Net Capital Rule.
At December 31, 2012, JPMorgan Securities’ net capital, as defined by the Net Capital Rule, was $13.5 billion, exceeding the minimum requirement by
Management’s discussion and analysis 120 JPMorgan Chase & Co. /2012 Annual Report $12.0 billion, and JPMorgan Clearing’s net capital was $6.6 billion, exceeding the minimum requirement by $5.0 billion.
In addition to its minimum net capital requirement, JPMorgan Securities is required to hold tentative net capital in excess of $1.0 billion and is also required to notify the SEC in the event that tentative net capital is less than $5.0 billion, in accordance with the market and credit risk standards of Appendix E of the Net Capital Rule.
As of December 31, 2012, JPMorgan Securities had tentative net capital in excess of the minimum and notification requirements.
J. P.  Morgan Securities plc (formerly J. P.  Morgan Securities Ltd. ) is a wholly-owned subsidiary of JPMorgan Chase Bank, N. A.  and is the Firm’s principal operating subsidiary in the U. K.  It has authority to engage in banking, investment banking and broker-dealer activities.
J. P.  Morgan Securities plc is regulated by the U. K.  Financial Services Authority (“FSA”).
At December 31, 2012, it had total capital of $20.8 billion, or a Total capital ratio of 15.5% which exceeded the 8% well-capitalized standard applicable to it under Basel 2.5.
Economic risk capital JPMorgan Chase assesses its capital adequacy relative to the risks underlying its business activities using internal risk-assessment methodologies.
The Firm measures economic capital primarily based on four risk factors: credit, market, operational and private equity risk.
## Table 1 ##
(a) Reflects additional capital required, in the Firm’s view, to meet its regulatory and debt rating objectives.
Credit risk capital Credit risk capital is estimated separately for the wholesale businesses (CIB, CB and AM) and consumer business (CCB).
Credit risk capital for the wholesale credit portfolio is defined in terms of unexpected credit losses, both from defaults and from declines in the value of the portfolio due to credit deterioration, measured over a one-year period at a confidence level consistent with an “AA” credit rating standard.
Unexpected losses are losses in excess of those for which the allowance for credit losses is maintained.
The capital methodology is based on several principal drivers of credit risk: exposure at default (or loan-equivalent amount), default likelihood, credit spreads, loss severity and portfolio correlation.
Credit risk capital for the consumer portfolio is based on product and other relevant risk segmentation.
Actual segment-level default and severity experience are used to estimate unexpected losses for a one-year horizon at a confidence level consistent with an “AA” credit rating standard.
The decrease in credit risk capital in 2012 was driven by consumer portfolio runoff and continued model enhancements to better estimate future stress credit losses in the consumer portfolio.
See Credit Risk Management on pages 134–135 of this Annual Report for more information about these credit risk measures.
Market risk capital The Firm calculates market risk capital guided by the principle that capital should reflect the risk of loss in the value of the portfolios and financial instruments caused by adverse movements in market variables, such as interest and foreign exchange rates, credit spreads, and securities and commodities prices, taking into account the liquidity of the financial instruments.
Results from daily VaR, weekly stress tests, issuer credit spreads and default risk calculations, as well as other factors, are used to determine appropriate capital levels.
Market risk capital is allocated to each business segment based on its risk assessment.
The increase in market risk capital in 2012 was driven by increased risk in the synthetic credit portfolio.
See Market Risk Management on pages 163–169 of this Annual Report for more information about these market risk measures.
Operational risk capital Operational risk is the risk of loss resulting from inadequate or failed processes or systems, human factors or external events.
The operational risk capital model is based on actual losses and potential scenario-based losses, with adjustments to the capital calculation to reflect changes in the quality of the control environment.
The increase in operational risk capital in 2012 was primarily due to continued model enhancements to better capture large historical loss events, including mortgage-related litigation costs.
The increases that occurred during 2012 will be fully reflected in average operational risk capital in 2013.
See Operational Risk Management on pages 175–176 of this Annual Report for more information about operational risk.
Private equity risk capital Capital is allocated to privately- and publicly-held securities, third-party fund investments, and commitments in the private equity portfolio, within the Corporate/Private Equity segment, to cover the potential loss associated with a decline in equity markets and related asset devaluations.
In addition to negative market fluctuations, potential losses in private equity investment portfolios can be magnified by liquidity risk.
Consumer, excluding credit card, loan portfolio Consumer loans, excluding credit card loans, consist primarily of residential mortgages, home equity loans and lines of credit, auto loans, business banking loans, and student and other loans, with a primary focus on serving the prime consumer credit market.
The portfolio also includes home equity loans secured by junior liens and mortgage loans with interest-only payment options to predominantly prime borrowers, as well as certain payment-option loans originated by Washington Mutual that may result in negative amortization.
The table below provides information about retained consumer loans, excluding credit card, by class.
## Table 2 ##
Delinquency rates are a primary credit quality indicator for consumer loans.
Loans that are more than 30 days past due provide an early warning of borrowers who may be experiencing financial difficulties and/or who may be unable or unwilling to repay the loan.
As the loan continues to age, it becomes more clear that the borrower is likely either unable or unwilling to pay.
In the case of residential real estate loans, late-stage delinquencies (greater than 150 days past due) are a strong indicator of loans that will ultimately result in a foreclosure or similar liquidation transaction.
In addition to delinquency rates, other credit quality indicators for consumer loans vary based on the class of loan, as follows: ?
For residential real estate loans, including both non-PCI and PCI portfolios, the current estimated LTV ratio, or the combined LTV ratio in the case of junior lien loans, is an indicator of the potential loss severity in the event of default.
Additionally, LTV or combined LTV can provide insight into a borrower’s continued willingness to pay, as the delinquency rate of high-LTV loans tends to be greater than that for loans where the borrower has equity in the collateral.
The geographic distribution of the loan collateral also provides insight as to the credit quality of the portfolio, as factors such as the regional economy, home price changes and specific events such as natural disasters, will affect credit quality.
The borrower’s current or “refreshed” FICO score is a secondary credit-quality indicator for certain loans, as FICO scores are an indication of the borrower’s credit payment history.
Thus, a loan to a borrower with a low FICO score (660 or below) is considered to be of higher risk than a loan to a borrower with a high FICO score.
Further, a loan to a borrower with a high LTV ratio and a low FICO score is at greater risk of default than a loan to a borrower that has both a high LTV ratio and a high FICO score.  ?
For scored auto, scored business banking and student loans, geographic distribution is an indicator of the credit performance of the portfolio.
Similar to residential real estate loans, geographic distribution provides insights into the portfolio performance based on regional economic activity and events.  ?
Risk-rated business banking and auto loans are similar to wholesale loans in that the primary credit quality indicators are the risk rating that is assigned to the loan and whether the loans are considered to be criticized and/or nonaccrual.
Risk ratings are reviewed on a regular and ongoing basis by Credit and Risk Management and are adjusted as necessary for updated information about borrowers’ ability to fulfill their obligations.
For further information about risk-rated wholesale loan credit quality indicators, see page 271 of this Note.
Residential real estate – excluding PCI loans The following table provides information by class for residential real estate – excluding retained PCI loans in the consumer, excluding credit card, portfolio segment.
The following factors should be considered in analyzing certain credit statistics applicable to the Firm’s residential real estate – excluding PCI loans portfolio: (i) junior lien home equity loans may be fully charged off when the loan becomes 180 days past due, and the value of the collateral does not support the repayment of the loan, resulting in relatively high charge-off rates for this product class; and (ii) the lengthening of loss-mitigation timelines may result in higher delinquency rates for loans carried at the net realizable value of the collateral that remain on the Firm’s Consolidated Balance Sheets.
During the years ended December 31, 2012, 2011 and 2010, the Firm recorded approximately $18.5 billion, $24.5 billion and $22.0 billion, respectively, of managed revenue derived from clients, customers and counterparties domiciled outside of North America.
Of those amounts, approximately 57%, 66% and 64%, respectively, were derived from Europe/Middle East/Africa (“EMEA”); approximately 30%, 25% and 28%, respectively, from Asia/Pacific; and approximately 13%, 9% and 8%, respectively, from Latin America/Caribbean.
For additional information regarding international operations, see Note 32 on page 326 of this Annual Report.
International wholesale activities The Firm is committed to further expanding its wholesale business activities outside of the United States, and it continues to add additional client-serving bankers, as well as product and sales support personnel, to address the needs of the Firm’s clients located in these regions.
With a comprehensive and coordinated international business strategy and growth plan, efforts and investments for growth outside of the United States will continue to be accelerated and prioritized.
Set forth below are certain key metrics related to the Firm’s wholesale international operations, including, for each of EMEA, Asia/Pacific and Latin America/Caribbean, the number of countries in each such region in which they operate, front-office headcount, number of clients, revenue and selected balance-sheet data.
## Table 3 ##
Note: International wholesale operations is comprised of CIB, AM, CB and Treasury and CIO, and prior-period amounts have been revised to conform with current allocation methodologies.
(a) Revenue is based predominantly on the domicile of the client, the location from which the client relationship is managed, or the location of the trading desk.
(b) Total headcount includes all employees, including those in service centers, located in the region.
(c) Significant clients are defined as companies with over $1 million in revenue over a trailing 12-month period in the region (excludes private banking clients).
(d) Deposits are based on the location from which the client relationship is managed.
(e) Loans outstanding are based predominantly on the domicile of the borrower and exclude loans held-for-sale and loans carried at fair value.

<table><tr><td>Tier 1 common under Basel I rules</td><td>$140,342</td></tr><tr><td>Adjustments related to AOCI for AFS securities and defined benefit pension and OPEB plans</td><td>4,077</td></tr><tr><td>All other adjustments</td><td>-453</td></tr><tr><td>Estimated Tier 1 common under Basel III rules</td><td>$143,966</td></tr><tr><td>Estimated risk-weighted assets under Basel III rules<sup>(a)</sup></td><td>$1,647,903</td></tr><tr><td>Estimated Tier 1 common ratio under Basel III rules<sup>(b)</sup></td><td>8.7%</td></tr></table>
<table><tr><td></td><td>Yearly Average</td></tr><tr><td>Year ended December 31,(in billions)</td><td>2012</td><td>2011</td><td>2010</td></tr><tr><td>Credit risk</td><td>$46.6</td><td>$48.2</td><td>$49.7</td></tr><tr><td>Market risk</td><td>17.5</td><td>14.5</td><td>15.1</td></tr><tr><td>Operational risk</td><td>15.9</td><td>8.5</td><td>7.4</td></tr><tr><td>Private equity risk</td><td>6.0</td><td>6.9</td><td>6.2</td></tr><tr><td>Economic risk capital</td><td>86.0</td><td>78.1</td><td>78.4</td></tr><tr><td>Goodwill</td><td>48.2</td><td>48.6</td><td>48.6</td></tr><tr><td>Other<sup>(a)</sup></td><td>50.2</td><td>46.6</td><td>34.5</td></tr><tr><td>Total common stockholders’equity</td><td>$184.4</td><td>$173.3</td><td>$161.5</td></tr></table>
<table><tr><td>December 31, (in millions)</td><td>2012</td><td>2011</td></tr><tr><td>Residential real estate – excluding PCI</td><td></td><td></td></tr><tr><td>Home equity:</td><td></td><td></td></tr><tr><td>Senior lien</td><td>$19,385</td><td>$21,765</td></tr><tr><td>Junior lien</td><td>48,000</td><td>56,035</td></tr><tr><td>Mortgages:</td><td></td><td></td></tr><tr><td>Prime, including option ARMs</td><td>76,256</td><td>76,196</td></tr><tr><td>Subprime</td><td>8,255</td><td>9,664</td></tr><tr><td>Other consumer loans</td><td></td><td></td></tr><tr><td>Auto</td><td>49,913</td><td>47,426</td></tr><tr><td>Business banking</td><td>18,883</td><td>17,652</td></tr><tr><td>Student and other</td><td>12,191</td><td>14,143</td></tr><tr><td>Residential real estate – PCI</td><td></td><td></td></tr><tr><td>Home equity</td><td>20,971</td><td>22,697</td></tr><tr><td>Prime mortgage</td><td>13,674</td><td>15,180</td></tr><tr><td>Subprime mortgage</td><td>4,626</td><td>4,976</td></tr><tr><td>Option ARMs</td><td>20,466</td><td>22,693</td></tr><tr><td>Total retained loans</td><td>$292,620</td><td>$308,427</td></tr></table>
<table><tr><td>As of or for the year ended December 31,</td><td colspan="3">EMEA</td><td colspan="3">Asia/Pacific</td><td colspan="3">Latin America/Caribbean</td></tr><tr><td>(in millions, except headcount and where otherwise noted)</td><td>2012</td><td>2011</td><td>2010</td><td>2012</td><td>2011</td><td>2010</td><td>2012</td><td>2011</td><td>2010</td></tr><tr><td>Revenue<sup>(a)</sup></td><td>$10,398</td><td>$16,141</td><td>$14,149</td><td>$5,590</td><td>$5,971</td><td>$6,082</td><td>$2,327</td><td>$2,232</td><td>$1,697</td></tr><tr><td>Countries of operation</td><td>33</td><td>33</td><td>33</td><td>17</td><td>16</td><td>16</td><td>9</td><td>9</td><td>8</td></tr><tr><td>New offices</td><td>—</td><td>1</td><td>6</td><td>2</td><td>2</td><td>7</td><td>—</td><td>4</td><td>2</td></tr><tr><td>Total headcount<sup>(b)</sup></td><td>15,533</td><td>16,178</td><td>16,122</td><td>20,548</td><td>20,172</td><td>19,153</td><td>1,436</td><td>1,378</td><td>1,201</td></tr><tr><td>Front-office headcount</td><td>5,917</td><td>5,993</td><td>5,872</td><td>4,195</td><td>4,253</td><td>4,168</td><td>644</td><td>569</td><td>486</td></tr><tr><td>Significant clients<sup>(c)</sup></td><td>992</td><td>938</td><td>900</td><td>492</td><td>479</td><td>451</td><td>164</td><td>140</td><td>126</td></tr><tr><td>Deposits (average)<sup>(d)</sup></td><td>$169,693</td><td>$168,882</td><td>$142,859</td><td>$57,329</td><td>$57,684</td><td>$53,268</td><td>$4,823</td><td>$5,318</td><td>$6,263</td></tr><tr><td>Loans (period-end)<sup>(e)</sup></td><td>40,760</td><td>36,637</td><td>27,934</td><td>30,287</td><td>31,119</td><td>20,552</td><td>30,322</td><td>25,141</td><td>16,480</td></tr><tr><td>Assets under management (in billions)</td><td>258</td><td>278</td><td>282</td><td>114</td><td>105</td><td>111</td><td>45</td><td>34</td><td>35</td></tr><tr><td>Assets under supervision (in billions)</td><td>317</td><td>329</td><td>331</td><td>160</td><td>139</td><td>147</td><td>110</td><td>89</td><td>84</td></tr><tr><td>Assets under custody (in billions)</td><td>6,502</td><td>5,430</td><td>4,810</td><td>1,577</td><td>1,426</td><td>1,321</td><td>252</td><td>279</td><td>153</td></tr></table>

Question: how much more money would jp morgan need to meet management 2019s plan to reach an estimated basel iii tier i common ratio of 9.5%?
Answer: 12584.785