ANALOG DEVICES, INC.  NOTES TO CONSOLIDATED FINANCIAL STATEMENTS — (Continued) included in other non-current liabilities, because the Company believes that the ultimate payment or settlement of these liabilities will not occur within the next twelve months.
Prior to the adoption of these provisions, these amounts were included in current income tax payable.
The Company includes interest and penalties related to unrecognized tax benefits within the provision for taxes in the condensed consolidated statements of income, and as a result, no change in classification was made upon adopting these provisions.
The condensed consolidated statements of income for fiscal year 2009 and fiscal year 2008 include $1.7 million and $1.3 million, respectively, of interest and penalties related to these uncertain tax positions.
Due to the complexity associated with its tax uncertainties, the Company cannot make a reasonably reliable estimate as to the period in which it expects to settle the liabilities associated with these uncertain tax positions.
The following table summarizes the changes in the total amounts of uncertain tax positions for fiscal 2008 and fiscal 2009.
## Table 0 ##
Fiscal Year 2004 and 2005 IRS Examination During the fourth quarter of fiscal 2007, the IRS completed its field examination of the Company’s fiscal years 2004 and 2005.
On January 2, 2008, the IRS issued its report for fiscal 2004 and 2005, which included proposed adjustments related to these two fiscal years.
The Company has recorded taxes and penalties related to certain of these proposed adjustments.
There are four items with an additional potential total tax liability of $46 million.
The Company has concluded, based on discussions with its tax advisors, that these four items are not likely to result in any additional tax liability.
Therefore, the Company has not recorded any additional tax liability for these items and is appealing these proposed adjustments through the normal processes for the resolution of differences between the IRS and taxpayers.
The Company’s initial meetings with the appellate division of the IRS were held during fiscal year 2009.
Two of the unresolved matters are one-time issues and pertain to Section 965 of the Internal Revenue Code related to the beneficial tax treatment of dividends from foreign owned companies under The American Jobs Creation Act.
The other matters pertain to the computation of research and development (R&D) tax credits and the profits earned from manufacturing activities carried on outside the United States.
These latter two matters could impact taxes payable for fiscal 2004 and 2005 as well as for subsequent years.
Fiscal Year 2006 and 2007 IRS Examination During the third quarter of fiscal 2009, the IRS completed its field examination of the Company’s fiscal years 2006 and 2007.
The IRS and the Company have agreed on the treatment of a number of issues that have been included in an Issue Resolutions Agreement related to the 2006 and 2007 tax returns.
However, no agreement was reached on the tax treatment of a number of issues, including the same R&D credit and foreign manufacturing issues mentioned above related to fiscal 2004 and 2005, the pricing of intercompany sales (transfer pricing), and the deductibility of certain stock option compensation expenses.
During the third quarter of fiscal 2009, the IRS issued its report for fiscal 2006 and fiscal 2007, which included proposed adjustments related to these two fiscal years.
The Company has recorded taxes and penalties related to certain of these proposed adjustments.
There are four items with an additional potential total tax liability of $195 million.
The Company concluded, based on discussions with its tax advisors, that these four items are not likely to result in any additional tax liability.
Therefore, the Company has not recorded any additional tax liability for these items and is appealing these proposed adjustments through the normal processes for the resolution of differences between the IRS and taxpayers.
With the exception of the
turn monitors, and independently reviews and evaluates, the plans and measurement processes.
One of the key tools we use to manage strategic risk is economic capital allocation.
Through the economic capital allocation process, we effectively manage each business unit’s ability to take on risk.
Review and approval of business plans incorporates approval of economic capital allocation, and economic capital usage is monitored through financial and risk reporting.
Economic capital allocation plans for the business units are incorporated into the Corporation’s operating plan that is approved by the Board on an annual basis.
Liquidity Risk and Capital Management Liquidity Risk Liquidity is the ongoing ability to accommodate liability maturities and deposit withdrawals, fund asset growth and business operations, and meet contractual obligations through unconstrained access to funding at reasonable market rates.
Liquidity management involves forecasting funding requirements and maintaining sufficient capacity to meet the needs and accommodate fluctuations in asset and liability levels due to changes in our business operations or unanticipated events.
Sources of liquidity include deposits and other customer-based funding, and wholesale market-based funding.
We manage liquidity at two levels.
The first is the liquidity of the parent company, which is the holding company that owns the banking and nonbanking subsidiaries.
The second is the liquidity of the banking subsidiaries.
The management of liquidity at both levels is essential because the parent company and banking subsidiaries each have different funding needs and sources, and each are subject to certain regulatory guidelines and requirements.
Through ALCO, the Finance Committee is responsible for establishing our liquidity policy as well as approving operating and contingency procedures, and monitoring liquidity on an ongoing basis.
Corporate Treasury is responsible for planning and executing our funding activities and strategy.
In order to ensure adequate liquidity through the full range of potential operating environments and market conditions, we conduct our liquidity management and business activities in a manner that will preserve and enhance funding stability, flexibility, and diversity.
Key components of this operating strategy include a strong focus on customer-based funding, maintaining direct relationships with wholesale market funding providers, and maintaining the ability to liquefy certain assets when, and if, requirements warrant.
We develop and maintain contingency funding plans for both the parent company and bank liquidity positions.
These plans evaluate our liquidity position under various operating circumstances and allow us to ensure that we would be able to operate through a period of stress when access to normal sources of funding is constrained.
The plans project funding requirements during a potential period of stress, specify and quan tify sources of liquidity, outline actions and procedures for effectively managing through the problem period, and define roles and responsibilities.
They are reviewed and approved annually by ALCO.
Our borrowing costs and ability to raise funds are directly impacted by our credit ratings.
The credit ratings of Bank of America Corporation and Bank of America, N. A.  are reflected in the table below.
Under normal business conditions, primary sources of funding for the parent company include dividends received from its banking and nonbanking subsidiaries, and proceeds from the issuance of senior and subordinated debt, as well as commercial paper and equity.
Primary uses of funds for the parent company include repayment of maturing debt and commercial paper, share repurchases, dividends paid to shareholders, and subsidiary funding through capital or debt.
The parent company maintains a cushion of excess liquidity that would be sufficient to fully fund holding company and nonbank affiliate operations for an extended period during which funding from normal sources is disrupted.
The primary measure used to assess the parent company’s liquidity is the “Time to Required Funding” during such a period of liquidity disruption.
This measure assumes that the parent company is unable to generate funds from debt or equity issuance, receives no dividend income from subsidiaries, and no longer pays dividends to shareholders while continuing to meet nondiscretionary uses needed to maintain bank operations and repayment of contractual principal and interest payments owed by the parent company and affiliated companies.
Under this scenario, the amount of time the parent company and its nonbank subsidiaries can operate and meet all obligations before the current liquid assets are exhausted is considered the “Time to Required Funding.
” ALCO approves the target range set for this metric, in months, and monitors adherence to the target.
Maintaining excess parent company cash ensures that “Time to Required Funding” remains in the target range of 21 to 27 months and is the primary driver of the timing and amount of the Corporation’s debt issuances.
As of December 31, 2006 “Time to Required Funding” was 24 months compared to 29 months at December 31, 2005.
The reduction reflects the funding in 2005 in anticipation of the $5.2 billion cash payment related to the MBNA merger that was paid on January 1, 2006 combined with an increase in share repurchases.
The primary sources of funding for our banking subsidiaries include customer deposits and wholesale market–based funding.
Primary uses of funds for the banking subsidiaries include growth in the core asset portfolios, including loan demand, and in the ALM portfolio.
We use the ALM portfolio primarily to manage interest rate risk and liquidity risk.
One ratio that can be used to monitor the stability of funding composition is the “loan to domestic deposit” ratio.
This ratio reflects the percent of Loans and Leases that are funded by domestic core deposits, a relatively stable funding source.
A ratio below 100 percent indicates that our loan portfolio is completely funded by domestic core deposits.
The ratio was 118 percent at December 31, 2006 compared to 102 percent at
## Table 1 ##
Table 16 Consumer Net Charge-offs/Net Losses and Related Ratios
## Table 2 ##
(1) Net charge-off/loss ratios are calculated as held net charge-offs or managed net losses divided by average outstanding held or managed loans and leases during the year for each loan and lease category.
(2) Net charge-off ratios excluding the SOP 03-3 portfolio were 2.73 percent for home equity, 1.33 percent for discontinued real estate and 2.29 percent for the total held portfolio for 2008.
These are the only product classifications materially impacted by SOP 03-3 for 2008.
For these loan and lease categories the dollar amounts of the net charge-offs were unchanged.
n/a = not applicable Table 16 presents net charge-offs and related ratios for our consumer loans and leases and net losses and related ratios for our managed credit card portfolio for 2008 and 2007.
The reported net charge-off ratios for residential mortgage, home equity and discontinued real estate benefit from the addition of the Countrywide SOP 03-3 portfolio as the initial fair value adjustments recorded on those loans at acquisition would have already included the estimated credit losses.
The reported net charge-offs for residential mortgage do not include the benefits of amounts reimbursable under cash collateralized synthetic securitizations.
Adjusting for the benefit of this credit protection, the residential mortgage net charge-off ratio in 2008 would have been reduced by four bps.
In certain cases, the inclusion of the SOP 03-3 portfolio, which was written down to fair value at acquisition, may impact portfolio credit statistics and trends.
We believe that the presentation of information adjusted to exclude the impacts of the SOP 03-3 portfolio is more representative of the ongoing operations and credit quality of the business.
As a result, in the discussions below of the residential mortgage, home equity and discontinued real estate portfolios, we supplement certain reported statistics with information that is adjusted to exclude the impacts of the SOP 03-3 portfolio.
In addition, beginning on page 65, we separately disclose information on the SOP 03-3 portfolio.
Residential Mortgage The residential mortgage portfolio, which excludes the discontinued real estate portfolio acquired with Countrywide, makes up the largest percentage of our consumer loan portfolio at 42 percent of consumer loans and leases (44 percent excluding the SOP 03-3 portfolio) at December 31, 2008.
Approximately 14 percent of the residential portfolio is in GWIM and represents residential mortgages that are originated for the home purchase and refinancing needs of our affluent customers.
The remaining portion of the portfolio is mostly in All Other, and is comprised of both purchased loans, including certain loans from the Countrywide portfolio, as well as residential loans originated for our customers which are used in our overall ALM activities.
Outstanding loans and leases decreased $27.0 billion at December 31, 2008 compared to 2007 due to sales and conversions of loans into retained mortgage backed securities totaling $56.8 billion as well as paydowns partially offset by new loan originations and the addition of the Countrywide portfolio.
The Countrywide acquisition added $26.8 billion of residential mortgage outstandings, of which $9.9 billion are included in the SOP 03-3 portfolio.
Nonperforming balances increased $5.0 billion due to the impacts of weak housing and economic conditions and the addition of the non SOP 03-3 Countrywide portfolio due to subsequent credit deterioration after acquisition.
At December 31, 2008 and 2007, loans past due 90 days or more and still accruing interest of $372 million and $237 million were related to repurchases pursuant to our servicing agreements with Government National Mortgage Association (GNMA) mortgage pools where repayments are insured by the FHA or guaranteed by the Department of Veterans Affairs.
Net charge-offs increased $869 million to $925 million for 2008, or 0.36 percent of total average residential mortgage loans compared to 0.02 percent for 2007.
The increase was reflective of the impacts of the weak housing markets and the slowing economy.
See page 65 for more information on the SOP 03-3 residential mortgage portfolio.
We mitigate a portion of our credit risk through synthetic securitizations which are cash collateralized and provide mezzanine risk protection which will reimburse us in the event that losses exceed 10 bps of the original pool balance.
As of December 31, 2008 and 2007, $109.3 billion and $140.5 billion of mortgage loans were protected by these agreements.
As of December 31, 2008, $146 million of credit and other related costs recognized in 2008 were reimbursable under these structures.
In addition, we have entered into credit protection agreements with GSEs on $9.6 billion and $32.9 billion as of December 31, 2008 and 2007, providing full protection on conforming residential mortgage loans that become severely delinquent.
Combined these structures provided risk mitigation for approximately 48 percent and 63 percent of our residential mortgage portfolio at December 31, 2008 and 2007.
The reduction in the protection was driven by an increase in loan sales and securitizations during the period, some of which were insured, and the percentage of protection was also impacted by the addition of Countrywide mortgages resulting from the acquisition.
Our regulatory riskweighted assets are reduced as a result of these risk protection transactions because we transferred a portion of our credit risk to unaffiliated parties.
At December 31, 2008 and 2007, these transactions had the cumulative effect of reducing our risk-weighted assets by
Other Risk Management Derivatives Other risk management derivatives are used by the Corporation to reduce certain risk exposures.
These derivatives are not qualifying accounting hedges because either they did not qualify for or were not designated as accounting hedges.
The table below presents gains (losses) on these derivatives for 2014, 2013 and 2012.
These gains (losses) are largely offset by the income or expense that is recorded on the hedged item.
The change in the impact of interest rate and foreign currency risk on ALM activities was primarily driven by decreasing interest rates and foreign currency weakening against the U. S.  Dollar throughout 2014 compared to strengthening during 2013.

<table><tr><td>Balance, November 3, 2007</td><td>$9,889</td></tr><tr><td>Additions for tax positions of current year</td><td>3,861</td></tr><tr><td>Balance, November 1, 2008</td><td>13,750</td></tr><tr><td>Additions for tax positions of current year</td><td>4,411</td></tr><tr><td>Balance, October 31, 2009</td><td>$18,161</td></tr></table>
<table><tr><td></td><td colspan="5"> December 31,2006</td></tr><tr><td></td><td colspan="3"> Bank of America Corporation</td><td colspan="2"> Bank of America, N.A.</td></tr><tr><td></td><td> Senior Debt</td><td> Subordinated Debt</td><td> Commercial Paper</td><td> Short-term Borrowings</td><td> Long-term Debt</td></tr><tr><td>Moody’s</td><td>Aa2</td><td>Aa3</td><td>P-1</td><td>P-1</td><td>Aa1</td></tr><tr><td>Standard & Poor’s<sup>-1</sup></td><td>AA-</td><td>A+</td><td>A-1+</td><td>A-1+</td><td>AA</td></tr><tr><td>Fitch, Inc.<sup>-2</sup></td><td>AA-</td><td>A+</td><td>F1+</td><td>F1+</td><td>AA-</td></tr></table>
<table><tr><td></td><td colspan="2"> Net Charge-offs/Losses</td><td colspan="2"> Net Charge-off/Loss Ratios<sup>-1, 2</sup></td></tr><tr><td>(Dollars in millions)</td><td> 2008</td><td>2007</td><td>2008</td><td>2007</td></tr><tr><td> Held basis</td><td></td><td></td><td></td><td></td></tr><tr><td>Residential mortgage</td><td>$925</td><td>$56</td><td>0.36%</td><td>0.02%</td></tr><tr><td>Home equity</td><td>3,496</td><td>274</td><td>2.59</td><td>0.28</td></tr><tr><td>Discontinued real estate</td><td>16</td><td>n/a</td><td>0.15</td><td>n/a</td></tr><tr><td>Credit card – domestic</td><td>4,161</td><td>3,063</td><td>6.57</td><td>5.29</td></tr><tr><td>Credit card – foreign</td><td>551</td><td>379</td><td>3.34</td><td>3.06</td></tr><tr><td>Direct/Indirect consumer</td><td>3,114</td><td>1,373</td><td>3.77</td><td>1.96</td></tr><tr><td>Other consumer</td><td>399</td><td>278</td><td>10.46</td><td>6.18</td></tr><tr><td> Total held</td><td>$12,662</td><td>$5,423</td><td>2.21</td><td>1.07</td></tr><tr><td> Supplemental managed basis data</td><td></td><td></td><td></td><td></td></tr><tr><td>Credit card – domestic</td><td>$10,054</td><td>$6,960</td><td>6.60</td><td>4.91</td></tr><tr><td>Credit card – foreign</td><td>1,328</td><td>1,254</td><td>4.17</td><td>4.24</td></tr><tr><td> Total credit card – managed</td><td>$11,382</td><td>$8,214</td><td>6.18</td><td>4.79</td></tr></table>

Question: What's the increasing rate of Home equity of Net Charge-offs/Losses in 2008?
Answer: 11.75912