AMERICAN TOWER CORPORATION AND SUBSIDIARIES NOTES TO CONSOLIDATED FINANCIAL STATEMENTS—(Continued) Pro Forma Disclosure—The Company has adopted the disclosure-only provisions of SFAS No.123, as amended by SFAS No.148, and has presented such disclosure in note 1.
The “fair value” of each option grant is estimated on the date of grant using the Black-Scholes option pricing model.
The weighted average fair values of the Company’s options granted during 2004, 2003 and 2002 were $7.05, $6.32, and $2.23 per share, respectively.
Key assumptions used to apply this pricing model are as follows:
## Table 0 ##
Voluntary Option Exchanges—In February 2004, the Company issued to eligible employees 1,032,717 options with an exercise price of $11.19 per share, the fair market value of the Class A common stock on the date of grant.
These options were issued in connection with a voluntary option exchange program entered into by the Company in August 2003, where the Company accepted for surrender and cancelled options (having an exercise price of $10.25 or greater) to purchase 1,831,981 shares of its Class A common stock.
The program, which was offered to both full and part-time employees, excluding the Company’s executive officers and its directors, called for the grant (at least six months and one day from the surrender date to employees still employed on that date) of new options exercisable for two shares of Class A common stock for every three shares of Class A common stock issuable upon exercise of a surrendered option.
No options were granted to any employees who participated in the exchange offer between the cancellation date and the new grant date.
In May 2002, the Company issued to eligible employees 2,027,612 options with an exercise price of $3.84 per share, the fair market value of the Class A common stock on the date of grant.
These options were issued in connection with a voluntary option exchange program entered into by the Company in October 2001, where the Company accepted for surrender and cancelled options to purchase 3,471,211 shares of its Class A common stock.
The program, which was offered to both full and part-time employees, excluding most of the Company’s executive officers, called for the grant (at least six months and one day from the surrender date to employees still employed on that date) of new options exercisable for two shares of Class A common stock for every three shares of Class A common stock issuable upon exercise of a surrendered option.
No options were granted to any employees who participated in the exchange offer between the cancellation date and the new grant date.
ATC Mexico Holding Stock Option Plan—The Company maintains a stock option plan in its ATC Mexico subsidiary (ATC Mexico Plan).
The ATC Mexico Plan provides for the issuance of options to officers, employees, directors and consultants of ATC Mexico.
The ATC Mexico Plan limits the number of shares of common stock which may be granted to an aggregate of 360 shares, subject to adjustment based on changes in ATC Mexico’s capital structure.
During 2002, ATC Mexico granted options to purchase 318 shares of ATC Mexico common stock to officers and employees.
Such options were issued at one time with an exercise price of $10,000 per share.
The exercise price per share was at fair market value as determined by the Board of Directors with the assistance of an independent appraisal performed at the Company’s request.
The fair value of ATC Mexico Plan options granted during 2002 were $3,611 per share as determined by using the Black-Scholes option pricing model.
As described in note 10, all outstanding options were exercised in March 2004.
No options under the ATC Mexico Plan were granted in 2004 or 2003, or exercised or cancelled in 2003 or 2002, and no options were exercisable as of December 31, 2003 or 2002.
(See note 10. )
notional amount of rate lock commitments.
Regions manages market risk on interest rate lock commitments and mortgage loans held for sale with corresponding forward sale commitments, which are recorded at fair value with changes in fair value recorded in mortgage income.
At December 31, 2010 and 2009, Regions had $1.7 billion and $1.1 billion, respectively, in total absolute notional amount related to these forward rate commitments.
On January 1, 2009, Regions made an election to account for mortgage servicing rights at fair market value with any changes to fair value being recorded within mortgage income.
Concurrent with the election to use the fair value measurement method, Regions began using various derivative instruments, in the form of forward rate commitments, futures contracts, swaps and swaptions to mitigate the statement of operations effect of changes in the fair value of its mortgage servicing rights.
As of December 31, 2010 and 2009, the total notional amount related to these contracts was $1.8 billion and $275 million, respectively.
The following tables present the location and amount of gain or (loss) recognized in income on derivatives not designated as hedging instruments in the statement of operations for the years ended December 31:
## Table 1 ##
Credit risk, defined as all positive exposures not collateralized with cash or other assets, totaled approximately $1.0 billion and $956 million at December 31, 2010 and 2009, respectively.
This amount represents the net credit risk on all trading and other derivative positions held by Regions.
CREDIT DERIVATIVES Regions has both bought and sold credit protection in the form of participations on interest rate swaps (swap participations).
These swap participations, which meet the definition of credit derivatives, were entered into in the ordinary course of business to serve the credit needs of customers.
Credit derivatives, whereby Regions has purchased credit protection, entitle Regions to receive a payment from the counterparty when the customer fails to make payment on any amounts due to Regions upon early termination of the swap transaction and have maturities between 2012 and 2026.  Credit derivatives whereby Regions has sold credit protection have maturities between 2011 and 2016.
For contracts where Regions sold credit protection, Regions would be required to make payment to the counterparty when the customer fails to make payment on any amounts due to the counterparty upon early termination of the swap transaction.
Regions bases the current status of the prepayment/performance risk on bought and sold credit derivatives on recently issued internal risk ratings consistent with the risk management practices of unfunded commitments.
Regions’ maximum potential amount of future payments under these contracts is approximately $37 million.
This scenario would only occur if variable interest rates were at zero percent and all counterparties defaulted with
total revenue on a taxable-equivalent basis (non-GAAP), which is the denominator for the adjusted efficiency and adjusted fee income ratios.
Tangible common stockholders’ equity ratios have become a focus of some investors in analyzing the capital position of the Company absent the effects of intangible assets and preferred stock.
Traditionally, the Federal Reserve and other banking regulatory bodies have assessed a bank’s capital adequacy based on Tier 1 capital, the calculation of which is codified in federal banking regulations.
Analysts and banking regulators have assessed Regions’ capital adequacy using the tangible common stockholders’ equity measure.
Because tangible common stockholders’ equity is not formally defined by GAAP, this measure is considered to be a non-GAAP financial measure and other entities may calculate it differently than Regions’ disclosed calculations.
Since analysts and banking regulators may assess Regions’ capital adequacy using tangible common stockholders’ equity, Regions believes that it is useful to provide investors the ability to assess Regions’ capital adequacy on this same basis.
The Basel Committee's Basel III framework will strengthen international capital and liquidity regulations.
When fully phased in, Basel III will increase capital requirements through higher minimum capital levels as well as through increases in risk-weights for certain exposures.
Additionally, the Basel III rules place greater emphasis on common equity.
The Federal Reserve released its final Basel III Rules detailing the U. S.  implementation of Basel III in 2013.
Regions, as a standardized approach bank, began transitioning to the Basel III framework in January 2015 subject to a phase-in period extending through January 2019.
Because the Basel III implementation regulations will not be fully phased in until 2019 and, are not formally defined by GAAP, these measures are considered to be non-GAAP financial measures.
Since analysts and banking regulators may assess Regions’ capital adequacy using the fully phased-in Basel III framework, Regions believes that it is useful to provide investors information enabling them to assess Regions’ capital adequacy on the same basis.
Non-GAAPfinancial measures have inherent limitations, are not required to be uniformly applied and are not audited.
Although these non-GAAP financial measures are frequently used by stakeholders in the evaluation of a company, they have limitations as analytical tools, and should not be considered in isolation, or as a substitute for analyses of results as reported under GAAP.
In particular, a measure of earnings that excludes selected items does not represent the amount that effectively accrues directly to stockholders.
The following tables provide: 1) a reconciliation of allowance for loan losses (GAAP) to adjusted allowance for loan losses (non-GAAP), 2) a reconciliation of non-accrual loans (GAAP) to adjusted non-accrual loans (non-GAAP), 3) a computation of adjusted allowance for loan losses to non-performing loans, excluding loans held for sale (non-GAAP), 4) a reconciliation of net income (GAAP) to net income available to common shareholders (GAAP), 5) a reconciliation of non-interest expense (GAAP) to adjusted non-interest expense (non-GAAP), 6) a reconciliation of net interest income and other financing income/margin, taxable equivalent basis (GAAP) to adjusted net interest income and other financing income/margin, taxable equivalent basis (non-GAAP), 7) a reconciliation of non-interest income (GAAP) to adjusted non-interest income (non-GAAP), 8) a computation of adjusted total revenue (non-GAAP), 9) a computation of the adjusted efficiency ratio (non-GAAP), 10) a computation of the adjusted fee income ratio (non-GAAP), 11) a reconciliation of average and ending stockholders’equity (GAAP) to average and ending tangible common stockholders’equity (non-GAAP) and calculations of related ratios (non-GAAP), 12) a reconciliation of stockholders’equity (GAAP) to Basel III CET1, on a fully phased-in basis (non-GAAP), and calculation of the related ratio based on Regions’current understanding of the Basel III requirements (non-GAAP).
Table 2—GAAP to Non-GAAP Reconciliation
## Table 2 ##

<table><tr><td></td><td>2004</td><td>2003</td><td>2002</td></tr><tr><td>Approximate risk-free interest rate</td><td>4.23%</td><td>4.00%</td><td>4.53%</td></tr><tr><td>Expected life of option grants</td><td>4 years</td><td>4 years</td><td>5 years</td></tr><tr><td>Expected volatility of underlying stock (the Company Plan)</td><td>80.6%</td><td>86.6%</td><td>92.3%</td></tr><tr><td>Expected volatility of underlying stock (ATC Mexico and ATC South America Plans)</td><td>N/A</td><td>N/A</td><td>N/A</td></tr><tr><td>Expected dividends</td><td>N/A</td><td>N/A</td><td>N/A</td></tr></table>
<table><tr><td> Derivatives Not Designated as Hedging Instruments</td><td>2010</td><td>2009</td></tr><tr><td></td><td colspan="2">(In millions)</td></tr><tr><td>Brokerage income</td><td></td><td></td></tr><tr><td>Interest rate swaps</td><td>$-10</td><td>$4</td></tr><tr><td>Interest rate options</td><td>3</td><td>-43</td></tr><tr><td>Interest rate futures and forward commitments</td><td>-3</td><td>7</td></tr><tr><td>Other contracts</td><td>11</td><td>2</td></tr><tr><td>Total brokerage income</td><td>1</td><td>-30</td></tr><tr><td>Mortgage income</td><td></td><td></td></tr><tr><td>Interest rate swaps</td><td>18</td><td>—</td></tr><tr><td>Interest rate options</td><td>2</td><td>-8</td></tr><tr><td>Interest rate futures and forward commitments</td><td>68</td><td>50</td></tr><tr><td>Total mortgage income</td><td>88</td><td>42</td></tr><tr><td></td><td>$89</td><td>$12</td></tr></table>
<table><tr><td></td><td></td><td colspan="5">Year Ended December 31</td></tr><tr><td></td><td></td><td>2017</td><td>2016</td><td>2015</td><td>2014</td><td>2013</td></tr><tr><td></td><td></td><td colspan="5">(Dollars in millions)</td></tr><tr><td>Allowance for loan losses (GAAP)</td><td>A</td><td>$934</td><td>$1,091</td><td>$1,106</td><td>$1,103</td><td>$1,341</td></tr><tr><td>Less: Direct energy portion</td><td></td><td>82</td><td>147</td><td>151</td><td>28</td><td>15</td></tr><tr><td>Adjusted allowance for loan losses (non-GAAP)</td><td>B</td><td>$852</td><td>$944</td><td>$955</td><td>$1,075</td><td>$1,326</td></tr><tr><td>Total non-accrual loans, excluding loans held for sale (GAAP)</td><td>C</td><td>$650</td><td>$995</td><td>$782</td><td>$829</td><td>$1,082</td></tr><tr><td>Less: Direct energy non-accrual loans</td><td></td><td>220</td><td>311</td><td>83</td><td>37</td><td>—</td></tr><tr><td>Adjusted total non-accrual loans, excluding loans held for sale (non-GAAP)</td><td>D</td><td>$430</td><td>$684</td><td>$699</td><td>$792</td><td>$1,082</td></tr><tr><td>Allowance for loan losses to non-performing loans, excluding loans held for sale (GAAP)</td><td>A/C</td><td>1.44x</td><td>1.10x</td><td>1.41x</td><td>1.33x</td><td>1.24x</td></tr><tr><td>Adjusted allowance for loan losses to non-performing loans, excluding loans held for sale (non-GAAP)</td><td>B/D</td><td>1.98x</td><td>1.38x</td><td>1.37x</td><td>1.36x</td><td>1.23x</td></tr></table>

Question: What is the average value of Less: Direct energy non-accrual loans in 2017,2016 and 2015? (in million)
Answer: 204.66667