THE GOLDMAN SACHS GROUP, INC.  AND SUBSIDIARIES Notes to Consolidated Financial Statements Lending Commitments The firm’s lending commitments are agreements to lend with fixed termination dates and depend on the satisfaction of all contractual conditions to borrowing.
These commitments are presented net of amounts syndicated to third parties.
The total commitment amount does not necessarily reflect actual future cash flows because the firm may syndicate all or substantial additional portions of these commitments.
In addition, commitments can expire unused or be reduced or cancelled at the counterparty’s request.
The table below presents information about lending commitments.
## Table 0 ##
In the table above: ‰ Held for investment lending commitments are accounted for on an accrual basis.
See Note 9 for further information about such commitments.
‰ Held for sale lending commitments are accounted for at the lower of cost or fair value.
‰ Gains or losses related to lending commitments at fair value, if any, are generally recorded, net of any fees in other principal transactions.
‰ Substantially all lending commitments relates to the firm’s Investing & Lending segment.
Commercial Lending.
The firm’s commercial lending commitments were primarily extended to investment-grade corporate borrowers.
Such commitments included $93.99 billion as of December 2018 and $85.98 billion as of December 2017, related to relationship lending activities (principally used for operating and general corporate purposes) and $27.92 billion as of December 2018 and $42.41 billion as of December 2017, related to other investment banking activities (generally extended for contingent acquisition financing and are often intended to be short-term in nature, as borrowers often seek to replace them with other funding sources).
The firm also extends lending commitments in connection with other types of corporate lending, as well as commercial real estate financing.
See Note 9 for further information about funded loans.
Sumitomo Mitsui Financial Group, Inc.  (SMFG) provides the firm with credit loss protection on certain approved loan commitments (primarily investment-grade commercial lending commitments).
The notional amount of such loan commitments was $15.52 billion as of December 2018 and $25.70 billion as of December 2017.
The credit loss protection on loan commitments provided by SMFG is generally limited to 95% of the first loss the firm realizes on such commitments, up to a maximum of approximately $950 million.
In addition, subject to the satisfaction of certain conditions, upon the firm’s request, SMFG will provide protection for 70% of additional losses on such commitments, up to a maximum of $1.0 billion, of which $550 million of protection had been provided as of both December 2018 and December 2017.
The firm also uses other financial instruments to mitigate credit risks related to certain commitments not covered by SMFG.
These instruments primarily include credit default swaps that reference the same or similar underlying instrument or entity, or credit default swaps that reference a market index.
Warehouse Financing.
The firm provides financing to clients who warehouse financial assets.
These arrangements are secured by the warehoused assets, primarily consisting of consumer and corporate loans.
Contingent and Forward Starting Collateralized Agreements / Forward Starting Collateralized Financings Forward starting collateralized agreements includes resale and securities borrowing agreements, and forward starting collateralized financings includes repurchase and secured lending agreements that settle at a future date, generally within three business days.
The firm also enters into commitments to provide contingent financing to its clients and counterparties through resale agreements.
The firm’s funding of these commitments depends on the satisfaction of all contractual conditions to the resale agreement and these commitments can expire unused.
Letters of Credit The firm has commitments under letters of credit issued by various banks which the firm provides to counterparties in lieu of securities or cash to satisfy various collateral and margin deposit requirements.
Investment Commitments Investment commitments includes commitments to invest in private equity, real estate and other assets directly and through funds that the firm raises and manages.
Investment commitments included $2.42 billion as of December 2018 and $2.09 billion as of December 2017, related to commitments to invest in funds managed by the firm.
If these commitments are called, they would be funded at market value on the date of investment.
PRUDENTIAL FINANCIAL, INC.  Notes to Consolidated Financial Statements Retained earnings Retained earnings primarily represents the cumulative net income earned by the Company that has been retained by the Company as of the reporting date.
Other unique items, included but not limited to the adoption of new accounting standards updates, may also impact retained earnings.
In any given period, retained earnings may increase due to net income and may decrease due to net losses or the declaration of dividends.
The declaration and payment of dividends on the Common Stock is limited by New Jersey corporate law, pursuant to which Prudential Financial is prohibited from paying a Common Stock dividend if, after giving effect to that dividend, either (a) the Company would be unable to pay its debts as they become due in the usual course of its business or (b) the Company’s total assets would be less than its liabilities.
In addition, the terms of the Company’s outstanding junior subordinated debt include a “dividend stopper” provision that restricts the payment of dividends on the Common Stock if interest payments are not made on the junior subordinated debt.
Other than the above limitations, the Company’s Retained earnings balance is free of restrictions for the payment of Common Stock dividends; however, Common Stock dividends will be dependent upon financial conditions, results of operations, cash needs, future prospects and other factors, including cash available to Prudential Financial, the parent holding company.
The principal sources of funds available to Prudential Financial are dividends and returns of capital from its subsidiaries, loans from its subsidiaries, repayments of operating loans from its subsidiaries, and cash and other highly liquid assets.
The primary uses of funds at Prudential Financial include servicing its debt, operating expenses, capital contributions and loans to subsidiaries, the payment of declared shareholder dividends and repurchases of outstanding shares of Common Stock if executed under Board authority.
As of December 31, 2018, Prudential Financial had highly liquid assets (excluding amounts held in an intercompany liquidity account) of $5,548 million predominantly including cash, shortterm investments, U. S.  Treasury securities, obligations of other U. S.  government authorities and agencies, and/or foreign government bonds.
Future cash available at Prudential Financial to support the payment of future Common Stock dividends is dependent on the receipt of dividends or other funds from its subsidiaries, the majority of which are subject to comprehensive regulation, including limitations on their payment of dividends and other transfers of funds, which are discussed in this Note further below.
Non-controlling interests For certain subsidiaries, the Company owns a controlling interest that is less than 100% ownership of the subsidiary but must consolidate 100% of the subsidiary’s financial statements in accordance with U. S.  GAAP.
Non-controlling interests represent the portion of equity ownership in a consolidated subsidiary that is not attributable to the Company.
Insurance Subsidiaries—Statutory Financial Information and Restrictions on Payments of Dividends U. S.  Insurance Subsidiaries—Statutory Financial Information The Company’s domestic insurance subsidiaries are required to prepare statutory financial statements in accordance with statutory accounting practices prescribed or permitted by the insurance department of the state of domicile.
Statutory accounting practices primarily differ from U. S.  GAAP by charging policy acquisition costs to expense as incurred, establishing future policy benefit liabilities using different actuarial assumptions as well as valuing investments and certain assets and accounting for deferred taxes on a different basis.
The risk-based capital (“RBC”) ratio is a primary measure by which the Company and its insurance regulators evaluate the capital adequacy of Prudential Insurance and the Company’s other domestic insurance subsidiaries.
RBC is determined by NAIC-prescribed formulas that consider, among other things, risks related to the type and quality of the invested assets, insurance-related risks associated with an insurer’s products and liabilities, interest rate risks and general business risks.
Insurers that have less statutory capital than required are considered to have inadequate capital and are subject to varying degrees of regulatory action depending upon the level of capital inadequacy.
The Company expects to report RBC ratios as of December 31, 2018 above the regulatory required minimums that would require corrective action and above our “AA” financial strength target levels for both Prudential Insurance and Prudential Annuities Life Assurance Corporation (“PALAC”).
The following table summarizes certain statutory financial information for the Company’s two largest U. S.  insurance subsidiaries for the periods indicated:
## Table 1 ##
contractholder’s total account value.
The objective of the automatic rebalancing feature is to reduce our exposure to equity market risk and market volatility.
Other product design features we utilize include, among others, asset allocation restrictions, minimum issuance age requirements and certain limitations on the amount of contractholder deposits, as well as a required minimum allocation to our general account for certain of our products.
We continue to introduce products that diversify our risk profile and have incorporated provisions in product design allowing frequent revisions of key pricing elements for certain of our products.
In addition, there is diversity in our fee arrangements, as certain fees are primarily based on the benefit guarantee amount, the contractholder account value and/or premiums, which helps preserve certain revenue streams when market fluctuations cause account values to decline.
Asset Liability Management (“ALM”) Strategy (including fixed income instruments and derivatives) Under our historical hedging program to manage certain capital market risks associated with certain variable annuity living benefit guarantees, we utilized the U. S.  GAAP valuation, with certain modifications, to derive a hedge target that was more reflective of our best estimate of future benefit payments, net of fees collected.
Derivative positions were entered into that sought to offset the change in value of the hedge target.
During the third quarter of 2016, we implemented a new ALM strategy that utilizes a combination of both traditional fixed income instruments and derivatives to help defray potential claims associated with our variable annuity living benefit guarantees.
The economic liability we manage with this ALM strategy consists of expected living benefit claims under less severe market conditions, which are managed through the accumulation of fixed income instruments, and potential living benefit claims resulting from more severe market conditions, which are hedged using derivative instruments.
For the portion of our ALM strategy executed with derivatives, we enter into a range of exchange-traded, cleared, and OTC equity and interest rate derivatives, including, but not limited to: equity and treasury futures; total return and interest rate swaps; and options, including equity options, swaptions, and floors and caps.
The intent of this strategy is to more efficiently manage the capital and liquidity associated with these products while continuing to mitigate fluctuations in net income due to movements in capital markets.
The change in hedge strategy had no impact on how we value or account for the living benefit guarantees under U. S.  GAAP.
However, under the ALM strategy that began in the third quarter of 2016, adjusted operating income includes the fees earned that are in excess of the estimated portion of fees required to cover expected claims and hedge costs for the economic liability.
The portion of fees required to cover such costs is updated quarterly to reflect updated estimates and actual experience.
The effectiveness of our hedging program as measured by comparing the change in value of our hedging assets to the change in value of the liability we are attempting to hedge will ultimately be reflected in adjusted operating income over time through the inclusion of actual hedge costs.
Expected costs are updated periodically along with our expectation of claims.
For adjusted operating income purposes, DAC and other costs are fully amortized over the life of the contracts proportional to our actual and estimated gross profits under the adjusted operating income framework described above.
Overall, we generally expect this strategy to result in a higher portion of fees being recognized in adjusted operating income than under our prior strategy.
The following table provides a reconciliation between the liability reported under U. S.  GAAP and the economic liability we manage through our ALM strategy
## Table 2 ##
As of December 31, 2018, our fixed income instruments and derivative assets exceed the economic liability within the entities in which the risks reside.
Under our ALM strategy, we expect differences in the U. S.  GAAP net income impact between the changes in value of the fixed income instruments and derivatives, as compared to the changes in the embedded derivative liability these assets support.
These differences can be primarily attributed to three distinct areas: ?
Different valuation methodologies in measuring the liability we intend to cover with fixed income instruments and derivatives versus the liability reported under U. S.  GAAP—The valuation methodology utilized in estimating the economic liability we intend to defray with fixed income instruments and derivatives is different from that required to be utilized to measure the liability under U. S.  GAAP.
Additionally, the valuation of the economic liability excludes certain items that are included within the U. S.  GAAP liability, such as NPR (in order to maximize protection irrespective of the possibility of our own default), as well as risk margins (required by U. S.  GAAP but different from our best estimate).  ?
Different accounting treatment between liabilities and assets supporting those liabilities—Under U. S.  GAAP, changes in value of the embedded derivative liability and derivative instruments used to hedge a portion of the economic liability are immediately reflected in net income.
In contrast, changes in fair value of fixed income instruments that support a portion of the economic liability are designated as available-for-sale and are recorded as unrealized gains (losses) in other comprehensive income rather than within net income.
Sales Results The following table sets forth annualized new business premiums, as defined under “—Results of Operations—Segment Measures” above, on an actual and constant exchange rate basis for the periods indicated.
## Table 3 ##
(1) Amounts are presented on a consistent basis reflecting the elimination of the one-month reporting lag for Gibraltar Life and Other operations.
The amount of annualized new business premiums and the sales mix in terms of types and currency denomination of products for any given period can be significantly impacted by several factors, including but not limited to: the addition of new products, discontinuation of existing products, changes in credited interest rates for certain products and other product modifications, changes in premium rates, changes in interest rates or fluctuations in currency markets, changes in tax laws, changes in life insurance regulations or changes in the competitive environment.
Sales volume may increase or decrease prior to certain of these changes becoming effective, and then fluctuate in the other direction following such changes.
Our diverse product portfolio in Japan, in terms of currency mix and premium payment structure, allows us to adapt to changing market and competitive dynamics, including the extremely low interest rate environment.
We regularly examine our product offerings and their related profitability and, as a result, we have repriced or discontinued sales of certain products that do not meet our profit expectations.
The impact of these actions, coupled with the introduction of certain new products, has generally resulted in an increase in sales of products denominated in U. S.  dollars relative to products denominated in other currencies.2018 to 2017 Annual Comparison.
The table below presents annualized new business premiums on a constant exchange rate basis, by product category and distribution channel, for the periods indicated.
## Table 4 ##
(1) Includes retirement income, endowment and savings variable universal life.
(2) Amounts are presented on a consistent basis reflecting the elimination of the one-month reporting lag for Gibraltar Life and Other operations.
Annualized new business premiums, on a constant exchange rate basis, from our Life Planner operations decreased $123 million, primarily reflecting sales in our Japan operations in the prior year period in advance of premium rate increases on yen-based products in the second quarter of 2017 and lower sales of these yen-based products post repricing.
The decrease was partially offset by higher sales of U. S.  dollar-denominated products in our Japan operations.
Annualized new business premiums, on a constant exchange rate basis, from our Gibraltar Life operations decreased $118 million.
Life Consultants sales increased $39 million, primarily reflecting higher sales of U. S.  dollar-denominated annuity products and U. S.  dollardenominated life products.
The increase was partially offset by lower sales of yen-denominated life products after the second quarter of 2017 repricing discussed above.
Bank channel sales decreased $135 million, primarily from lower sales of U. S.  dollar-denominated life products due to increased competition in recurring pay life products and the discontinuation of a single pay life product in the fourth quarter of 2017.
Independent Agency sales decreased $22 million, primarily reflecting lower sales of yen-denominated life products after the second quarter of 2017 repricing discussed above and increased competition, partially offset by higher sales of U. S.  dollar-denominated life and annuity products.
Capital Protection Framework “Realized investment gains (losses), net and related adjustments,” which are excluded from adjusted operating income, included a net gain of $121 and net losses of $154 million and $1,649 million for the years ended December 31, 2018, 2017 and 2016, respectively, primarily related to impacts of interest rate movements, which are considered within our Capital Protection Framework.
The favorable changes in 2018 and 2017 results compared to 2016 are primarily attributed to changes in our Individual Annuities risk management strategy implemented in 2016, whereby we terminated the existing intercompany derivative transactions between Corporate and Other operations and the Individual Annuities business segment related to managing interest rate risk and we now manage this risk within the Individual Annuities business segment.
The net loss in 2016, while the intercompany derivative transactions between Corporate and Other operations and the Individual Annuities business segment were in place, primarily resulted from our utilization of capital management strategies to manage a portion of our interest rate risk and reflects changes in interest rates with respect to the exposures outstanding in 2016.
For more information on our Individual Annuities risk management strategy, see “—Individual Annuities.
” For more information on our Capital Protection Framework, see “—Liquidity and Capital Resources—Capital Protection Framework.
” Divested and Run-off Businesses Divested and Run-off Businesses Included in Corporate and Other Income from our Divested and Run-off Businesses includes results from several businesses that have been or will be sold or exited, including businesses that have been placed in wind down status that do not qualify for “discontinued operations” accounting treatment under U. S.  GAAP.
The results of these Divested and Run-off Businesses are reflected in our Corporate and Other operations, but are excluded from adjusted operating income.
A summary of the results of the Divested and Run-off Businesses reflected in our Corporate and Other operations is as follows for the periods indicated:

<table><tr><td></td><td>As of December</td></tr><tr><td><i>$ in millions</i></td><td>2018</td><td>2017</td></tr><tr><td>Held for investment</td><td>$120,997</td><td>$124,504</td></tr><tr><td>Held for sale</td><td>8,602</td><td>9,838</td></tr><tr><td>At fair value</td><td>7,983</td><td>9,404</td></tr><tr><td>Total</td><td>$137,582</td><td>$143,746</td></tr></table>
<table><tr><td></td><td colspan="3">Prudential Insurance</td><td colspan="3">PALAC</td></tr><tr><td>In millions and presented as of or for the year ended</td><td>December 31, 2018</td><td>December 31, 2017</td><td>December 31, 2016</td><td>December 31, 2018</td><td>December 31, 2017</td><td>December 31, 2016</td></tr><tr><td>Statutory net income (loss)</td><td>$1,324</td><td>$-217</td><td>$5,214</td><td>$-852</td><td>$3,911</td><td>$-2,018</td></tr><tr><td>Statutory capital and surplus</td><td>$10,465</td><td>$9,948</td><td>$11,290</td><td>$6,396</td><td>$8,059</td><td>$5,718</td></tr></table>
<table><tr><td></td><td colspan="2">As of December 31,</td></tr><tr><td></td><td>2018</td><td>2017</td></tr><tr><td></td><td colspan="2">(in millions)</td></tr><tr><td>U.S. GAAP liability (including non-performance risk)</td><td>$8,860</td><td>$8,663</td></tr><tr><td>Non-performance risk adjustment</td><td>4,619</td><td>3,228</td></tr><tr><td>Subtotal</td><td>13,479</td><td>11,891</td></tr><tr><td>Adjustments including risk margins and valuation methodology differences</td><td>-4,084</td><td>-2,742</td></tr><tr><td>Economic liability managed through the ALM strategy</td><td>$9,395</td><td>$9,149</td></tr></table>
<table><tr><td></td><td colspan="3">Year ended December 31,</td></tr><tr><td></td><td>2018</td><td>2017</td><td>2016</td></tr><tr><td></td><td colspan="3">(in millions)</td></tr><tr><td>Annualized new business premiums:</td><td></td><td></td><td></td></tr><tr><td>On an actual exchange rate basis:</td><td></td><td></td><td></td></tr><tr><td>Life Planner operations</td><td>$1,257</td><td>$1,391</td><td>$1,276</td></tr><tr><td>Gibraltar Life-1</td><td>1,483</td><td>1,595</td><td>1,726</td></tr><tr><td>Total-1</td><td>$2,740</td><td>$2,986</td><td>$3,002</td></tr><tr><td>On a constant exchange rate basis:</td><td></td><td></td><td></td></tr><tr><td>Life Planner operations</td><td>1,250</td><td>1,373</td><td>1,262</td></tr><tr><td>Gibraltar Life-1</td><td>1,481</td><td>1,599</td><td>1,710</td></tr><tr><td>Total-1</td><td>$2,731</td><td>$2,972</td><td>$2,972</td></tr></table>
<table><tr><td></td><td colspan="5">Year Ended December 31, 2018</td><td colspan="5">Year Ended December 31, 2017</td></tr><tr><td></td><td>Life</td><td>Accident&Health</td><td>Retirement-1</td><td>Annuity</td><td>Total</td><td>Life</td><td>Accident&Health</td><td>Retirement-1</td><td>Annuity</td><td>Total</td></tr><tr><td></td><td colspan="10">(in millions)</td></tr><tr><td>Life Planner</td><td>$699</td><td>$118</td><td>$344</td><td>$89</td><td>$1,250</td><td>$812</td><td>$122</td><td>$353</td><td>$86</td><td>$1,373</td></tr><tr><td>Gibraltar Life-2:</td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Life Consultants</td><td>308</td><td>44</td><td>101</td><td>329</td><td>782</td><td>369</td><td>50</td><td>113</td><td>211</td><td>743</td></tr><tr><td>Banks</td><td>412</td><td>1</td><td>29</td><td>38</td><td>480</td><td>525</td><td>1</td><td>31</td><td>58</td><td>615</td></tr><tr><td>Independent Agency</td><td>113</td><td>10</td><td>62</td><td>34</td><td>219</td><td>134</td><td>19</td><td>66</td><td>22</td><td>241</td></tr><tr><td>Subtotal-2</td><td>833</td><td>55</td><td>192</td><td>401</td><td>1,481</td><td>1,028</td><td>70</td><td>210</td><td>291</td><td>1,599</td></tr><tr><td>Total</td><td>$1,532</td><td>$173</td><td>$536</td><td>$490</td><td>$2,731</td><td>$1,840</td><td>$192</td><td>$563</td><td>$377</td><td>$2,972</td></tr></table>

Question: What is the percentage of Life Consultants in relation to the total in 2018?
Answer: 0.28634