The following table shows reporting units with goodwill balances as of December 31, 2010, and the excess of fair value as a percentage over allocated book value as of the annual impairment test.
(1) Local Consumer Lending—Other is excluded from the table as there is no goodwill
## Table 0 ##
allocated to it.
While no impairment was noted in step one of Citigroup’s Local Consumer Lending—Cards reporting unit impairment test at July 1, 2010, goodwill present in the reporting unit may be sensitive to further deterioration as the valuation of the reporting unit is particularly dependent upon economic conditions that affect consumer credit risk and behavior.
Citigroup engaged the services of an independent valuation specialist to assist in the valuation of the reporting unit at July 1, 2010, using a combination of the market approach and income approach consistent with the valuation model used in past practice, which considered the impact of the penalty fee provisions associated with the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) that were implemented during 2010.
Under the market approach for valuing this reporting unit, the key assumption is the selected price multiple.
The selection of the multiple considers the operating performance and financial condition of the Local Consumer Lending—Cards operations as compared with those of a group of selected publicly traded guideline companies and a group of selected acquired companies.
Among other factors, the level and expected growth in return on tangible equity relative to those of the guideline companies and guideline transactions is considered.
Since the guideline company prices used are on a minority interest basis, the selection of the multiple considers the guideline acquisition prices, which reflect control rights and privileges, in arriving at a multiple that reflects an appropriate control premium.
For the Local Consumer Lending—Cards valuation under the income approach, the assumptions used as the basis for the model include cash flows for the forecasted period, the assumptions embedded in arriving at an estimation of the terminal value and the discount rate.
The cash flows for the forecasted period are estimated based on management’s most recent projections available as of the testing date, giving consideration to targeted equity capital requirements based on selected public guideline companies for the reporting unit.
In arriving at the terminal value for Local Consumer Lending—Cards, using 2013 as the terminal year, the assumptions used include a long-term growth rate and a price-to-tangible book multiple based on selected public guideline companies for the reporting unit.
The discount rate is based on the reporting unit’s estimated cost of equity capital computed under the capital asset pricing model.
Embedded in the key assumptions underlying the valuation model, described above, is the inherent uncertainty regarding the possibility that economic conditions may deteriorate or other events will occur that will impact the business model for Local Consumer Lending—Cards.
While there is inherent uncertainty embedded in the assumptions used in developing management’s forecasts, the Company utilized a discount rate at July 1, 2010 that it believes reflects the risk characteristics and uncertainty specific to management’s forecasts and assumptions for the Local Consumer Lending—Cards reporting unit.
Two primary categories of events exist—economic conditions in the U. S.  and regulatory actions—which, if they were to occur, could negatively affect key assumptions used in the valuation of Local Consumer Lending—Cards.
Small deterioration in the assumptions used in the valuations, in particular the discount-rate and growth-rate assumptions used in the net income projections, could significantly affect Citigroup’s impairment evaluation and, hence, results.
If the future were to differ adversely from management’s best estimate of key economic assumptions, and associated cash flows were to decrease by a small margin, Citi could potentially experience future material impairment charges with respect to $4,560 million of goodwill remaining in the Local Consumer Lending— Cards reporting unit.
Any such charges, by themselves, would not negatively affect Citi’s Tier 1 and Total Capital regulatory ratios, Tier 1 Common ratio, its Tangible Common Equity or Citi’s liquidity position.
## Table 1 ##
Represents netting of: (i)聽the amounts due under securities purchased under agreements to resell and the amounts owed under securities sold under agreements to repurchase, and (ii)聽derivative exposures covered by a qualifying master netting agreement, cash collateral, and the market value adjustment.
There is no allowance for loan losses recorded for loans reported at fair value.
Percentage is calculated based on total assets and liabilities at fair value, excluding collateral paid/received on derivatives.
## Table 2 ##
Paycom Software, Inc.  Notes to the Consolidated Financial Statements The following table summarizes vesting activity for Market-Based Shares during the year ended December 31, 2018, the associated compensation cost recognized in connection with the vesting event and the number of shares withheld to satisfy tax withholding obligations:
## Table 3 ##
1 All shares withheld to satisfy tax withholding obligations are held as treasury stock.
The vesting conditions for Time-Based Shares issued in 2018 vary based on the category of the recipient.
The Time-Based Shares issued to executive officers and non-executive sales employees in 2018 will vest in three equal annual tranches beginning on a specified initial vesting date and thereafter on the first and second anniversaries of such date, provided that the executive officer or non-executive sales employee is employed by, or providing services to, the Company on the applicable vesting date.
Time-Based Shares issued to certain non-executive, non-sales employees during 2018 will vest 25% on a specified initial vesting date and 25% on each of the first three anniversaries of such initial vesting date, provided that the recipient is employed by, or providing services to, the Company on the applicable vesting date.
Time-based shares issued to non-employee members of our Board of Directors will cliff-vest on the seventh day following the first anniversary of the date of grant, provided that such director is providing services to the Company through the applicable vesting date.
Our total compensation expense related to restricted stock was $36.4 million, $36.0 million and $20.8 million for the years ended December 31, 2018, 2017 and 2016, respectively.
There was $41.4 million of unrecognized compensation cost, net of estimated forfeitures, related to unvested shares of restricted stock outstanding as of December 31, 2018.
The unrecognized compensation cost is expected to be recognized over a weighted average period of 1.8 years as of December 31, 2018.
We capitalized stock-based compensation costs related to software developed for internal use of $3.7 million, $3.3 million and $1.8 million for the years ended December 31, 2018, 2017 and 2016, respectively.
The following table presents non-cash stock-based compensation expense resulting from restricted stock awards, which is included in the following line items in the accompanying consolidated statements of income for the years ended December 31, 2018, 2017 and 2016:

<table><tr><td>Reporting unit-1</td><td>Fair value as a % of allocated book value</td><td>Goodwill</td></tr><tr><td>North America Regional Consumer Banking</td><td>170%</td><td>$2,518</td></tr><tr><td>EMEA Regional Consumer Banking</td><td>168</td><td>338</td></tr><tr><td>Asia Regional Consumer Banking</td><td>344</td><td>6,045</td></tr><tr><td>Latin America Regional Consumer Banking</td><td>230</td><td>1,800</td></tr><tr><td>Securities and Banking</td><td>223</td><td>9,259</td></tr><tr><td>Transaction Services</td><td>1,716</td><td>1,567</td></tr><tr><td>Brokerage and Asset Management</td><td>151</td><td>65</td></tr><tr><td>Local Consumer Lending—Cards</td><td>121</td><td>4,560</td></tr></table>
<table><tr><td>In millions of dollars at December 31, 2010</td><td>Level 1</td><td>Level 2</td><td>Level 3</td><td>Gross inventory</td><td>Netting-1</td><td>Net balance</td></tr><tr><td>State and municipal</td><td>$—</td><td>$12,731</td><td>$504</td><td>$13,235</td><td>$—</td><td>$13,235</td></tr><tr><td>Foreign government</td><td>51,419</td><td>47,902</td><td>358</td><td>99,679</td><td>—</td><td>99,679</td></tr><tr><td>Corporate</td><td>—</td><td>15,152</td><td>1,018</td><td>16,170</td><td>—</td><td>16,170</td></tr><tr><td>Equity securities</td><td>3,721</td><td>184</td><td>2,055</td><td>5,960</td><td>—</td><td>5,960</td></tr><tr><td>Asset-backed securities</td><td>—</td><td>3,624</td><td>5,424</td><td>9,048</td><td>—</td><td>9,048</td></tr><tr><td>Other debt securities</td><td>—</td><td>1,185</td><td>727</td><td>1,912</td><td>—</td><td>1,912</td></tr><tr><td>Non-marketable equity securities</td><td>—</td><td>135</td><td>6,467</td><td>6,602</td><td>—</td><td>6,602</td></tr><tr><td>Total investments</td><td>$69,241</td><td>$194,647</td><td>$17,286</td><td>$281,174</td><td>$—</td><td>$281,174</td></tr><tr><td>Loans-2</td><td>$—</td><td>$1,159</td><td>$3,213</td><td>$4,372</td><td>$—</td><td>$4,372</td></tr><tr><td>Mortgage servicing rights</td><td>—</td><td>—</td><td>4,554</td><td>4,554</td><td>—</td><td>4,554</td></tr><tr><td>Other financial assets measured on a recurring basis</td><td>—</td><td>19,425</td><td>2,509</td><td>21,934</td><td>-2,615</td><td>19,319</td></tr><tr><td>Total assets</td><td>$188,992</td><td>$1,111,027</td><td>$70,784</td><td>$1,421,105</td><td>$-706,902</td><td>$714,203</td></tr><tr><td>Total as a percentage of gross assets-3</td><td>13.8%</td><td>81.0%</td><td>5.2%</td><td>100%</td><td></td><td></td></tr><tr><td>Liabilities</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Interest-bearing deposits</td><td>$—</td><td>$988</td><td>$277</td><td>$1,265</td><td>$—</td><td>$1,265</td></tr><tr><td>Federal funds purchased and securities loaned or sold under</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>agreements to repurchase</td><td>—</td><td>169,162</td><td>1,261</td><td>170,423</td><td>-49,230</td><td>121,193</td></tr><tr><td>Trading account liabilities</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Securities sold, not yet purchased</td><td>59,968</td><td>9,169</td><td>187</td><td>69,324</td><td>—</td><td>69,324</td></tr><tr><td>Derivatives</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Interest rate contracts</td><td>489</td><td>472,936</td><td>3,314</td><td>476,739</td><td></td><td></td></tr><tr><td>Foreign exchange contracts</td><td>2</td><td>87,411</td><td>861</td><td>88,274</td><td></td><td></td></tr><tr><td>Equity contracts</td><td>2,551</td><td>27,486</td><td>3,397</td><td>33,434</td><td></td><td></td></tr><tr><td>Commodity contracts</td><td>482</td><td>10,968</td><td>2,068</td><td>13,518</td><td></td><td></td></tr><tr><td>Credit derivatives</td><td>—</td><td>48,535</td><td>10,926</td><td>59,461</td><td></td><td></td></tr><tr><td>Total gross derivatives</td><td>$3,524</td><td>$647,336</td><td>$20,566</td><td>$671,426</td><td></td><td></td></tr><tr><td>Cash collateral received</td><td></td><td></td><td></td><td>38,319</td><td></td><td></td></tr><tr><td>Netting agreements and market value adjustments</td><td></td><td></td><td></td><td></td><td>-650,015</td><td></td></tr><tr><td>Total derivatives</td><td>$3,524</td><td>$647,336</td><td>$20,566</td><td>$709,745</td><td>$-650,015</td><td>$59,730</td></tr><tr><td>Short-term borrowings</td><td>—</td><td>1,627</td><td>802</td><td>2,429</td><td>—</td><td>2,429</td></tr><tr><td>Long-term debt</td><td>—</td><td>17,612</td><td>8,385</td><td>25,997</td><td>—</td><td>25,997</td></tr><tr><td>Other financial liabilities measured on a recurring basis</td><td>—</td><td>12,306</td><td>19</td><td>12,325</td><td>-2,615</td><td>9,710</td></tr><tr><td>Total liabilities</td><td>$63,492</td><td>$858,200</td><td>$31,497</td><td>$991,508</td><td>$-701,860</td><td>$289,648</td></tr><tr><td>Total as a percentage of gross liabilities-3</td><td>6.7%</td><td>90.0%</td><td>3.3%</td><td>100%</td><td></td><td></td></tr></table>
<table><tr><td>In millions of dollars at December 31, 2009</td><td>Level 1</td><td>Level 2</td><td>Level 3</td><td>Gross inventory</td><td>Netting-1</td><td>Net balance</td></tr><tr><td>Assets</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Federal funds sold and securities borrowed or purchased under</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>agreements to resell</td><td>$—</td><td>$138,525</td><td>$—</td><td>$138,525</td><td>$-50,713</td><td>$87,812</td></tr><tr><td>Trading securities</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Trading mortgage-backed securities</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>U.S. government-sponsored agency guaranteed</td><td>—</td><td>19,666</td><td>972</td><td>20,638</td><td>—</td><td>20,638</td></tr><tr><td>Prime</td><td>—</td><td>772</td><td>384</td><td>1,156</td><td>—</td><td>1,156</td></tr><tr><td>Alt-A</td><td>—</td><td>842</td><td>387</td><td>1,229</td><td>—</td><td>1,229</td></tr><tr><td>Subprime</td><td>—</td><td>736</td><td>8,998</td><td>9,734</td><td>—</td><td>9,734</td></tr><tr><td>Non-U.S. residential</td><td>—</td><td>1,796</td><td>572</td><td>2,368</td><td>—</td><td>2,368</td></tr><tr><td>Commercial</td><td>—</td><td>611</td><td>2,451</td><td>3,062</td><td>—</td><td>3,062</td></tr><tr><td>Total trading mortgage-backed securities</td><td>$—</td><td>$24,423</td><td>$13,764</td><td>$38,187</td><td>$—</td><td>$38,187</td></tr></table>
<table><tr><td>Vesting Condition</td><td>Date Vested</td><td>Number of Shares Vested</td><td>Compensation Cost Recognized Upon Vesting</td><td>Shares Withheld for Taxes<sup>1</sup></td></tr><tr><td>Market-based (TEV = $5.9 billion)</td><td>March 14, 2018</td><td>141,599</td><td>$9.7 million</td><td>54,000</td></tr><tr><td>Market-based (TEV = $6.2 billion)</td><td>March 23, 2018</td><td>141,481</td><td>$10.1 million</td><td>54,909</td></tr></table>

Question: What is the average amount of Securities and Banking of Goodwill, and Foreign government of Level 2 ?
Answer: 28580.5