General and administrative expense decreased $15 million, or 7%, to $192 million for the year ended December 31, 2009, primarily due to expense controls.
Protection The following table presents the results of operations of our Protection segment:
## Table 0 ##
(1) Adjustments include net realized gains or losses.
Our Protection segment pretax income was $496 million for the year ended December 31, 2009, an increase of $144 million, or 41%, from $352 million in the prior year.
Our Protection segment pretax operating income, which excludes net realized gains or losses, was $469 million for the year ended December 31, 2009 compared to $444 million in the prior year.
Net revenues Net revenues increased $17 million, or 1%, to $2.0 billion for the year ended December 31, 2009.
Operating net revenues, which exclude net realized gains or losses, decreased $102 million, or 5%, to $1.9 billion for the year ended December 31, 2009, due to a decrease in other revenues related to updating valuation assumptions, partially offset by an increase in net investment income and premiums.
Net investment income increased $170 million, or 67%, to $422 million for the year ended December 31, 2009.
Net realized investment gains were $27 million in 2009 compared to net realized investment losses of $92 million in 2008 primarily related to impairments of Available-for-Sale securities.
Operating net investment income, which excludes net realized gains or losses, increased $51 million, or 15%, to $395 million for the year ended December 31, 2009, primarily due to an increase in investment income earned on fixed maturity securities driven by higher yields on the longer-term investments in our fixed income investment portfolio.
Premiums increased $26 million, or 3%, to $1.0 billion for the year ended December 31, 2009, due to growth in Auto and Home premiums compared to the prior year driven by higher volumes.
Auto and Home policy counts increased 9% period-over-period.
Other revenues decreased $161 million, or 29%, to $386 million for the year ended December 31, 2009, due to a $65 million expense from updating valuation assumptions in 2009 compared to a $95 million benefit from updating valuation assumptions and converting to a new valuation system for RiverSource Life products in 2008.
Expenses Total expenses decreased $127 million, or 8%, to $1.5 billion for the year ended December 31, 2009, primarily due to the impact of updating valuation assumptions.
Leasing/Capital Costs Tenant improvements and lease-related costs pertaining to our initial leasing of newly completed space, or vacant space in acquired properties, are referred to as first generation expenditures.
Such first generation expenditures for tenant improvements are included within "development of real estate investments" in our Consolidated Statements of Cash Flows, while such expenditures for lease-related costs are included within "other deferred leasing costs. "
Cash expenditures related to the construction of a building's shell, as well as the associated site improvements, are also included within "development of real estate investments" in our Consolidated Statements of Cash Flows.
Tenant improvements and leasing costs to re-let rental space that we previously leased to tenants are referred to as second generation expenditures.
Building improvements that are not specific to any tenant but serve to improve integral components of our real estate properties are also second generation expenditures.
One of our principal uses of our liquidity is to fund the second generation leasing/capital expenditures of our real estate investments.
The following table summarizes our second generation capital expenditures by type of expenditure (in thousands):
## Table 1 ##
Second generation tenant improvements and leasing costs increased due to a shift in industrial leasing volume from renewal leases to second generation leases (see data in the Key Performance Indicators section of Management's Discussion and Analysis of Financial Condition and Results of Operations), which are generally more capital intensive.
Additionally, although the overall renewal volume was lower, renewals for office leases, which are generally more capital intensive than industrial leases, increased from 2012.
During 2013, we increased our investment across all product types in non-tenant specific building improvements.
The increase in capital expenditures for the development of real estate investments was the result of our increased focus on wholly owned development projects.
We had wholly owned properties under development with an expected cost of $572.6 million at December 31, 2013, compared to projects with an expected cost of $468.8 million and $124.2 million at December 31, 2012 and 2011, respectively.
Cash outflows for real estate development investments were $427.4 million, $264.8 million and $162.1 million for December 31, 2013, 2012 and 2011, respectively.
We capitalized $31.3 million, $30.4 million and $25.3 million of overhead costs related to leasing activities, including both first and second generation leases, during the years ended December 31, 2013, 2012 and 2011, respectively.
We capitalized $27.1 million, $20.0 million and $10.4 million of overhead costs related to development activities, including construction, development and tenant improvement projects on first and second generation space, during the years ended December 31, 2013, 2012 and 2011, respectively.
Combined overhead costs capitalized to leasing and development totaled 35.7%, 31.1% and 20.6% of our overall pool of overhead costs at December 31, 2013, 2012 and 2011, respectively.
Further discussion of the capitalization of overhead costs can be found herein, in the discussion of general and administrative expenses in the comparison sections of Management's Discussion and Analysis of Financial Condition and Results of Operations.
Tables of Contents 66 Financial assets whose fair values we measure using significant unobservable (Level 3) inputs consist of municipal auction rate securities that are no longer liquid.
We estimate the fair values of the auction rate securities using a discounted cash flow model.
Using our discounted cash flow model, we determined that the fair values of the municipal auction rate securities we held at July 31, 2017, 2016, and 2015 were approximately equal to their par values and as a result we recorded no decrease in their fair values during the twelve months then ended.
We continue to classify them as long-term investments based on the maturities of the underlying securities at that date.
We do not intend to sell our municipal auction rate securities.
In addition, it is more likely than not that we will not be required to sell them before recovery at par, which may be at maturity.
There were no transfers between Level 1, Level 2, and Level 3 of the fair value hierarchy during the twelve months ended July 31, 2017, 2016 or 2015.
Assets and Liabilities Measured at Fair Value on a Non-Recurring Basis Assets measured at fair value on a non-recurring basis include reporting units measured at fair value in a goodwill impairment test.
Estimates of fair value for reporting units fall under Level 3 of the fair value hierarchy.
During the fourth quarters of fiscal 2017, fiscal 2016, and fiscal 2015 we performed our annual goodwill impairment tests.
Using the methodology described in Note 1, we determined that the estimated fair values of all of our reporting units exceeded their carrying values and that they were not impaired.
During the third quarter of fiscal 2015 there was a significant decline in the revenue and operating income forecast for our Consumer Ecosystem reporting unit.
As a result of this development, we performed an interim impairment test of goodwill and acquired intangible assets for that reporting unit.
We concluded that the carrying value of goodwill associated with our Consumer Ecosystem reporting unit was impaired and we recorded an impairment charge of $263 million that reduced the carrying value of goodwill to $211 million as of April 30, 2015.
The amount of the impairment charge was determined by comparing the carrying value of goodwill assigned to the reporting unit with the implied fair value of the goodwill.
We used a weighted combination of a discounted cash flow model (income approach) and comparisons to publicly traded companies engaged in similar businesses (market approach) to estimate the fair value of our Consumer Ecosystem reporting unit.
Key assumptions that we used in the income approach included the amount and timing of estimated future cash flows to be generated by the business over an extended period of time, long-term growth rates for the business, and a rate of return that considered the relative risk of achieving the cash flows and the time value of money.
For the market approach, we estimated the fair value of the reporting unit based on market multiples of revenue, operating income, and earnings for comparable publicly traded companies engaged in similar businesses.
We believe that the assumptions used to determine the impairment amount for the goodwill of this reporting unit are reasonable.
During the fourth quarter of fiscal 2015 management approved a plan to sell our Quicken business, which was part of our Consumer Ecosystem reporting unit, and we accounted for it as discontinued operations.
As a result, we reclassified a portion of the goodwill impairment charge that we recorded in the third quarter of fiscal 2015 to discontinued operations based on the relative fair values of Quicken and the remaining components of our Consumer Ecosystem reporting unit.
On April 1, 2016 we completed the sale for cash consideration that was not significant.3.
Cash and Cash Equivalents, Investments, and Funds Held for Customers The following table summarizes our cash and cash equivalents, investments and funds held for customers by balance sheet classification at the dates indicated.
## Table 2 ##
VISA INC.  NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—(Continued) September 30, 2018 Note 13—Share-based Compensation 2007 Equity Incentive Compensation Plan The Company’s 2007 Equity Incentive Compensation Plan, or the EIP, authorizes the compensation committee of the board of directors to grant non-qualified stock options (“options”), restricted stock awards (“RSAs”), restricted stock units (“RSUs”) and performance-based shares to its employees and non-employee directors, for up to 236 million shares of class A common stock.
Shares available for award may be either authorized and unissued or previously issued shares subsequently acquired by the Company.
The EIP will continue to be in effect until all of the common stock available under the EIP is delivered and all restrictions on those shares have lapsed, unless the EIP is terminated earlier by the Company’s board of directors.
Awards may be granted under the plan until January 31, 2022.
Share-based compensation cost is recorded net of estimated forfeitures on a straight-line basis for awards with service conditions only, and on a graded-vesting basis for awards with service, performance and market conditions.
For fiscal 2018, 2017 and 2016, the Company recorded sharebased compensation cost related to the EIP of $312 million, $224 million and $211 million, respectively, in personnel expense on its consolidated statements of operations.
The related tax benefits were $53 million, $67 million and $62 million for fiscal 2018, 2017 and 2016, respectively.
The amount of capitalized share-based compensation cost was immaterial during fiscal 2018, 2017 and 2016.
Options Options issued under the EIP expire 10 years from the date of grant and primarily vest ratably over 3 years from the date of grant, subject to earlier vesting in full under certain conditions.
During fiscal 2018, 2017 and 2016, the fair value of each stock option was estimated on the date of grant using a Black-Scholes option pricing model with the following weighted-average assumptions:

<table><tr><td> </td><td colspan="6">Years Ended December 31,</td><td></td><td></td></tr><tr><td> </td><td colspan="3">2009 </td><td colspan="3">2008 </td><td></td><td></td></tr><tr><td> </td><td>GAAP </td><td>Less: Adjustments-1 </td><td>Operating </td><td>GAAP </td><td>Less: Adjustments -1</td><td>Operating </td><td colspan="2">Operating Change</td></tr><tr><td> </td><td colspan="8">(in millions, except percentages)</td></tr><tr><td> Revenues</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Management and financial advice fees</td><td>$47</td><td>$—</td><td>$47</td><td>$56</td><td>$—</td><td>$56</td><td>$-9</td><td>-16%</td></tr><tr><td>Distribution fees</td><td>97</td><td>—</td><td>97</td><td>106</td><td>—</td><td>106</td><td>-9</td><td>-8</td></tr><tr><td>Net investment income</td><td>422</td><td>27</td><td>395</td><td>252</td><td>-92</td><td>344</td><td>51</td><td>15</td></tr><tr><td>Premiums</td><td>1,020</td><td>—</td><td>1,020</td><td>994</td><td>—</td><td>994</td><td>26</td><td>3</td></tr><tr><td>Other revenues</td><td>386</td><td>—</td><td>386</td><td>547</td><td>—</td><td>547</td><td>-161</td><td>-29</td></tr><tr><td>Total revenues</td><td>1,972</td><td>27</td><td>1,945</td><td>1,955</td><td>-92</td><td>2,047</td><td>-102</td><td>-5</td></tr><tr><td>Banking and deposit interest expense</td><td>1</td><td>—</td><td>1</td><td>1</td><td>—</td><td>1</td><td>—</td><td>—</td></tr><tr><td>Total net revenues</td><td>1,971</td><td>27</td><td>1,944</td><td>1,954</td><td>-92</td><td>2,046</td><td>-102</td><td>-5</td></tr><tr><td> Expenses</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Distribution expenses</td><td>22</td><td>—</td><td>22</td><td>18</td><td>—</td><td>18</td><td>4</td><td>22</td></tr><tr><td>Interest credited to fixed accounts</td><td>144</td><td>—</td><td>144</td><td>144</td><td>—</td><td>144</td><td>—</td><td>—</td></tr><tr><td>Benefits, claims, losses and settlement expenses</td><td>924</td><td>—</td><td>924</td><td>856</td><td>—</td><td>856</td><td>68</td><td>8</td></tr><tr><td>Amortization of deferred acquisition costs</td><td>159</td><td>—</td><td>159</td><td>333</td><td>—</td><td>333</td><td>-174</td><td>-52</td></tr><tr><td>General and administrative expense</td><td>226</td><td>—</td><td>226</td><td>251</td><td>—</td><td>251</td><td>-25</td><td>-10</td></tr><tr><td>Total expenses</td><td>1,475</td><td>—</td><td>1,475</td><td>1,602</td><td>—</td><td>1,602</td><td>-127</td><td>-8</td></tr><tr><td>Pretax income</td><td>$496</td><td>$27</td><td>$469</td><td>$352</td><td>$-92</td><td>$444</td><td>$25</td><td>6%</td></tr></table>
<table><tr><td></td><td>2013</td><td>2012</td><td>2011</td></tr><tr><td>Second generation tenant improvements</td><td>$39,892</td><td>$26,643</td><td>$50,079</td></tr><tr><td>Second generation leasing costs</td><td>38,617</td><td>31,059</td><td>38,130</td></tr><tr><td>Building improvements</td><td>13,289</td><td>6,182</td><td>11,055</td></tr><tr><td>Total second generation capital expenditures</td><td>$91,798</td><td>$63,884</td><td>$99,264</td></tr><tr><td>Development of real estate investments</td><td>$427,355</td><td>$264,755</td><td>$162,070</td></tr><tr><td>Other deferred leasing costs</td><td>$35,376</td><td>$27,772</td><td>$26,311</td></tr></table>
<table><tr><td></td><td colspan="2">July 31, 2017</td><td colspan="2">July 31, 2016</td></tr><tr><td>(In millions)</td><td>Amortized Cost</td><td>Fair Value</td><td>Amortized Cost</td><td>Fair Value</td></tr><tr><td>Classification on balance sheets:</td><td></td><td></td><td></td><td></td></tr><tr><td>Cash and cash equivalents</td><td>$529</td><td>$529</td><td>$638</td><td>$638</td></tr><tr><td>Investments</td><td>247</td><td>248</td><td>441</td><td>442</td></tr><tr><td>Funds held for customers</td><td>372</td><td>372</td><td>304</td><td>304</td></tr><tr><td>Long-term investments</td><td>31</td><td>31</td><td>28</td><td>28</td></tr><tr><td>Total cash and cash equivalents, investments, and fundsheld for customers</td><td>$1,179</td><td>$1,180</td><td>$1,411</td><td>$1,412</td></tr></table>

Question: What's the average of Management and financial advice fees and Distribution fees and Net investment income of GAAP in 2009? (in millions)
Answer: 188.66667