need to be met in order for any repurchase claim to be asserted by investors.
In 2011, there was an increase in repurchase claims from private-label securitization trustees that meet the required standards.
During 2011, the Corporation received $2.1 billion of such repurchase claims.
In addition, there has been an increase in requests for loan files from private-label securitization trustees, as well as requests for tolling agreements to toll the applicable statutes of limitation relating to representations and warranties claims, and the Corporation believes it is likely that these requests will lead to an increase in repurchase claims from private-label securitization trustees that meet required standards.
The representations and warranties, as governed by the private-label securitization agreements, generally require that counterparties have the ability to both assert a claim and actually prove that a loan has an actionable defect under the applicable contracts.
While the Corporation believes the agreements for private-label securitizations generally contain less rigorous representations and warranties and place higher burdens on investors seeking repurchases than the express provisions of comparable agreements with the GSEs without regard to any variations that may have arisen as a result of dealings with the GSEs, the agreements generally include a representation that underwriting practices were prudent and customary.
During 2010, the Corporation received claim demands totaling $1.7 billion from private-label securitization investors in the Covered Trusts.
Non-GSE investors generally do not have the contractual right to demand repurchase of the loans directly or the right to access loan files.
The inclusion of the $1.7 billion in outstanding claims, as reflected in the table on page 202, does not mean that the Corporation believes these claims have satisfied the contractual thresholds required for the private-label securitization investors to direct the securitization trustee to take action or that these claims are otherwise procedurally or substantively valid.
One of these claimants has filed litigation against the Corporation relating to certain of these claims; the claims in this litigation would be extinguished if there is final court approval of the BNY Mellon Settlement.
NOTE 10 Goodwill and Intangible Assets Goodwill The Goodwill table presents goodwill balances by business segment at December 31, 2011 and 2010.
The reporting units utilized for goodwill impairment tests are the business segments or one level below.
The majority of the decline in goodwill during 2011 was due to goodwill impairment charges as described in this Note.
## Table 0 ##
International Consumer Card Businesses In connection with the Corporation’s announcement on August 15, 2011 of its intention to exit the international consumer card businesses, goodwill of approximately $1.9 billion was allocated, on a relative fair value basis, from Card Services to All Other as of September 30, 2011.
Of the $1.9 billion of goodwill allocated to the international consumer card businesses, $526 million of goodwill was allocated, on a relative fair value basis, to the Canadian consumer card business which was sold on December 1, 2011.
During the three months ended December 31, 2011, a goodwill impairment test was performed for the European consumer card businesses reporting unit as it was likely that the carrying amount of the businesses exceeded the fair value due to a decrease in estimated future growth projections.
The Corporation concluded that goodwill was impaired, and accordingly, recorded a non-cash, non-tax deductible goodwill impairment charge of $581 million for the European consumer card businesses.
Consumer Real Estate Services In connection with the sale of Balboa Insurance Company’s lenderplaced insurance business on June 1, 2011, the Corporation allocated, on a relative fair value basis, $193 million of CRES goodwill to the business in determining the gain on the sale.
During the three months ended June 30, 2011, as a consequence of the BNY Mellon Settlement entered into by the Corporation on June 28, 2011, the adverse impact of the incremental mortgage-related charges, and the continued economic slowdown in the mortgage business, the Corporation performed a goodwill impairment test for the CRES reporting unit.
The Corporation concluded that the remaining balance of goodwill of $2.6 billion was impaired, and accordingly, recorded a non-cash, non-tax deductible goodwill impairment charge to reduce the carrying value of the goodwill in CRES to zero.2011 Annual Impairment Test During the three months ended September 30, 2011, the Corporation completed its annual goodwill impairment test as of June 30, 2011 for all reporting units.
Based on the results of step one of the annual goodwill impairment test, the Corporation determined that step two was not required for any of the reporting units as their fair value exceeded their carrying value indicating there was no impairment.2010 Impairment Tests In 2010, the Corporation performed a goodwill impairment test for Card Services due to the continued stress on the business and the uncertain debit card interchange provisions under the DoddFrank Wall Street Reform and Consumer Protection Act (Financial Reform Act).
The Corporation concluded that goodwill was impaired, and accordingly, recorded a non-cash, non-tax deductible goodwill impairment charge of $10.4 billion to reduce the carrying value of the goodwill in Card Services.
These decreases were partially offset by ongoing reductions in our debt footprint and lower interest rates paid on deposits.
The net interest yield on a FTE basis decreased 30 bps to 2.48 percent for 2011 compared to 2010 as the yield continues to be under pressure due to the aforementioned items and the low rate environment.
We expect net interest income to continue to be muted based on the current forward yield curve in 2012.
Noninterest Income
## Table 1 ##
Noninterest income decreased $9.9 billion to $48.8 billion for 2011 compared to 2010.
The following highlights the significant changes.
Card income decreased $924 million primarily due to the implementation of new interchange fee rules under the Durbin Amendment, which became effective on October 1, 2011 and the CARD Act provisions that were implemented during 2010.
Service charges decreased $1.3 billion largely due to the impact of overdraft policy changes in conjunction with Regulation E, which became effective in the third quarter of 2010.
Equity investment income increased $2.1 billion.
The results for 2011 included $6.5 billion of gains on the sale of CCB shares, $836 million of CCB dividends and a $377 million gain on the sale of our investment in BlackRock, Inc.  (BlackRock), partially offset by $1.1 billion of impairment charges on our merchant services joint venture.
The prior year included $2.5 billion of net gains which included the sales of certain strategic investments, $2.3 billion of gains in our Global Principal Investments (GPI) portfolio which included both cash gains and fair value adjustments, and $535 million of CCB dividends.
Trading account profits decreased $3.4 billion primarily due to adverse market conditions and extreme volatility in the credit markets compared to the prior year.
DVA gains, net of hedges, on derivatives were $1.0 billion in 2011 compared to $262 million in 2010 as a result of a widening of our credit spreads.
In conjunction with regulatory reform measures GBAM exited its stand-alone proprietary trading business as of June 30, 2011.
Proprietary trading revenue was $434 million for the six months ended June 30, 2011 compared to $1.4 billion for 2010.
Mortgage banking income decreased $11.6 billion primarily due to an $8.8 billion increase in the representations and warranties provision which was largely related to the BNY Mellon Settlement.
Also contributing to the decline was lower production income due to a reduction in new loan origination volumes partially offset by an increase in servicing income.
Other income increased $4.5 billion primarily due to positive fair value adjustments of $3.3 billion related to widening of our own credit spreads on structured liabilities compared to $18 million in 2010.
In addition, 2011 included a $771 million gain on the sale of Balboa as well as a $1.2 billion gain on the exchange of certain trust preferred securities for common stock and debt.
Provision for Credit Losses The provision for credit losses decreased $15.0 billion to $13.4 billion for 2011 compared to 2010.
The provision for credit losses was $7.4 billion lower than net charge-offs for 2011, resulting in a reduction in the allowance for credit losses driven primarily by lower delinquencies, improved collection rates and fewer bankruptcy filings across the Card Services portfolio, and improvement in overall credit quality in the commercial real estate portfolio partially offset by additions to consumer PCI loan portfolio reserves.
This compared to a $5.9 billion reduction in the allowance for credit losses in 2010.
We expect reductions in the allowance for credit losses to be lower in 2012.
The provision for credit losses related to our consumer portfolio decreased $11.1 billion to $14.3 billion for 2011 compared to 2010.
The provision for credit losses related to our commercial portfolio including the provision for unfunded lending commitments decreased $3.9 billion to a benefit of $915 million for 2011 compared to 2010.
Net charge-offs totaled $20.8 billion, or 2.24 percent of average loans and leases for 2011 compared to $34.3 billion, or 3.60 percent for 2010.
The decrease in net charge-offs was primarily driven by improvements in general economic conditions that resulted in lower delinquencies, improved collection rates and fewer bankruptcy filings across the Card Services portfolio as well as lower losses in the home equity portfolio driven primarily by fewer delinquent loans.
For more information on the provision for credit losses, see Provision for Credit Losses on page 102.
Noninterest Expense
## Table 2 ##
Noninterest expense decreased $2.8 billion to $80.3 billion for 2011 compared to 2010.
The prior year included goodwill impairment charges of $12.4 billion compared to $3.2 billion for 2011.
Personnel expense increased $1.8 billion for 2011 attributable to personnel costs related to the continued build-out of certain businesses, technology costs as well as increases in default-
Basel III Liquidity Standards In December 2010, the Basel Committee issued “International framework for liquidity risk measurement, standards and monitoring,” which includes two proposed measures of liquidity risk.
These two minimum liquidity measures were initially introduced in guidance in December 2009 and are considered part of Basel III.
The first proposed liquidity measure is the Liquidity Coverage Ratio (LCR), which is calculated as the amount of a financial institution’s unencumbered, high-quality, liquid assets relative to the net cash outflows the institution could encounter under an acute 30-day stress scenario.
The second proposed liquidity measure is the Net Stable Funding Ratio (NSFR), which measures the amount of longer-term, stable sources of funding employed by a financial institution relative to the liquidity profiles of the assets funded and the potential for contingent calls on funding liquidity arising from off-balance sheet commitments and obligations over a one-year period.
The Basel Committee expects the LCR requirement to be implemented in January 2015 and the NSFR requirement to be implemented in January 2018, following an observation period that began in 2011.
We continue to monitor the development and the potential impact of these proposals, and assuming adoption by U. S.  banking regulators, we expect to meet the final standards within the regulatory timelines.
Diversified Funding Sources We fund our assets primarily with a mix of deposits and secured and unsecured liabilities through a globally coordinated funding strategy.
We diversify our funding globally across products, programs, markets, currencies and investor groups.
We fund a substantial portion of our lending activities through our deposit base, which was $1,033 billion and $1,010 billion at December 31, 2011 and 2010.
Deposits are primarily generated by our Deposits, Global Commercial Banking, GWIM and GBAM segments.
These deposits are diversified by clients, product type and geography and the majority of our U. S.  deposits are insured by the FDIC.
We consider a substantial portion of our deposits to be a stable, low-cost and consistent source of funding.
We believe this deposit funding is generally less sensitive to interest rate changes, market volatility or changes in our credit ratings than wholesale funding sources.
Our lending activities may also be financed through secured borrowings, including securitizations and FHLB loans.
Our trading activities in broker/dealer subsidiaries are primarily funded on a secured basis through securities lending and repurchase agreements and these amounts will vary based on customer activity and market conditions.
We believe funding these activities in the secured financing markets is more cost efficient and less sensitive to changes in our credit ratings than unsecured financing.
Repurchase agreements are generally short-term and often overnight.
Disruptions in secured financing markets for financial institutions have occurred in prior market cycles which resulted in adverse changes in terms or significant reductions in the availability of such financing.
We manage the liquidity risks arising from secured funding by sourcing funding globally from a diverse group of counterparties, providing a range of securities collateral and pursuing longer durations, when appropriate.
We reduced our use of unsecured short-term borrowings at the parent company and broker/dealer subsidiaries, including commercial paper and master notes, to relatively insignificant amounts in 2011.
These short-term borrowings were used to support customer activities, short-term financing requirements and cash management objectives.
For average and period-end balance discussions, see Balance Sheet Overview on page 28.
For more information, see Note 12 – Federal Funds Sold, Securities Borrowed or Purchased Under Agreements to Resell and Short-term Borrowings to the Consolidated Financial Statements.
Our mortgage business accesses a liquid market for the sale of newly originated mortgages through contracts with the GSEs and FHA.
Contracts with the GSEs are subject to the seller/servicer guides issued by the GSEs.
We issue the majority of our long-term unsecured debt at the parent company.
During 2011, the parent company issued $21.0 billion of long-term unsecured debt.
We may also issue long-term unsecured debt at BANA, although there were no new issuances during 2011.
We issue long-term unsecured debt in a variety of maturities and currencies to achieve cost-efficient funding and to maintain an appropriate maturity profile.
While the cost and availability of unsecured funding may be negatively impacted by general market conditions or by matters specific to the financial services industry or the Corporation, we seek to mitigate refinancing risk by actively managing the amount of our borrowings that we anticipate will mature within any month or quarter.
The primary benefits of our centralized funding strategy include greater control, reduced funding costs, wider name recognition by investors and greater flexibility to meet the variable funding requirements of subsidiaries.
Where regulations, time zone differences or other business considerations make parent company funding impractical, certain other subsidiaries may issue their own debt.
At December 31, 2011 and 2010, our long-term debt was in the currencies presented in Table 19.
## Table 3 ##
Total long-term debt decreased $76.2 billion, or 17 percent in 2011.
This decrease reflects our ongoing initiative to reduce our debt footprint over time, and we anticipate that we will continue to reduce our debt footprint as appropriate through 2013.
We may, from time to time, purchase outstanding debt securities in various transactions, depending on prevailing market conditions, liquidity and other factors.
In addition, we also may make markets in our debt instruments to provide liquidity for investors.
For additional information on long-term debt funding, see Note 13 – Long-term Debt to the Consolidated Financial Statements.
We use derivative transactions to manage the duration, interest rate and currency risks of our borrowings, considering the characteristics of the assets they are funding.
For further details on our ALM activities, see Interest Rate Risk Management for Nontrading Activities on page 110.
Reservable criticized balances, net charge-offs and nonperforming loans, leases and foreclosed property balances in the commercial credit portfolio declined in 2011.
The reductions in reservable criticized and nonperforming loans, leases and foreclosed property were primarily in the commercial real estate and U. S.  commercial portfolios.
Commercial real estate continued to show improvement during 2011 compared to 2010 in both the homebuilder and non-homebuilder portfolios.
However, levels of stressed commercial real estate loans remain elevated.
The reduction in reservable criticized U. S.  commercial loans was driven by broad-based improvements in terms of clients, industries and businesses.
Most other credit indicators across the remaining commercial portfolios also improved.
Table 38 presents our commercial loans and leases, and related credit quality information at December 31, 2011 and 2010.
## Table 4 ##
(1) Includes U. S.  commercial real estate loans of $37.8 billion and $46.9 billion and non-U.
S.  commercial real estate loans of $1.8 billion and $2.5 billion at December 31, 2011 and 2010.
(2) Includes card-related products.
(3) Commercial loans accounted for under the fair value option include U. S.  commercial loans of $2.2 billion and $1.6 billion, non-U.
S.  commercial loans of $4.4 billion and $1.7 billion, and commercial real estate loans of $0 and $79 million at December 31, 2011 and 2010.
See Note 23 – Fair Value Option to the Consolidated Financial Statements for additional information on the fair value option.
Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases were 2.02 percent and 3.32 percent (2.04 percent and 3.35 percent excluding loans accounted for under the fair value option) at December 31, 2011 and 2010.
Accruing commercial loans and leases past due 90 days or more as a percentage of outstanding commercial loans and leases were 0.10 percent and 0.21 percent (0.10 percent and 0.22 percent excluding loans accounted for under the fair value option) at December 31, 2011 and 2010.
Table 39 presents net charge-offs and related ratios for our commercial loans and leases for 2011 and 2010.
Improving portfolio trends drove lower charge-offs and higher recoveries across most of the portfolio.
Commercial real estate net chargeoffs during 2011 declined in both the homebuilder and nonhomebuilder portfolios.
U. S.  small business commercial net charge-offs declined primarily due to improvements in delinquencies, collections and bankruptcies.
U. S.  commercial charge-offs decreased during 2011 due to broad-based declines from improvements in client profiles, industries and businesses.
## Table 5 ##
(1) Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.
Gross Profit Gross profit as a percentage of net sales was 73.8 percent in 2004, compared to 72.8 percent in 2003 and68.1percent for the three month period ended December 31,2003(the first quarter of combined Zimmer and Centerpulse operations).
The following table reconciles the gross margin for the year ended December 31,2004 and for the three month period ended December 31,2003.
Three month period ended December 31,2003

<table><tr><td></td><td colspan="2">December 31</td></tr><tr><td>(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td>Deposits</td><td>$17,875</td><td>$17,875</td></tr><tr><td>Card Services</td><td>10,014</td><td>10,014</td></tr><tr><td>Consumer Real Estate Services</td><td>—</td><td>2,796</td></tr><tr><td>Global Commercial Banking</td><td>20,668</td><td>20,668</td></tr><tr><td>Global Banking & Markets</td><td>10,672</td><td>10,672</td></tr><tr><td>Global Wealth & Investment Management</td><td>9,928</td><td>9,928</td></tr><tr><td>All Other</td><td>810</td><td>1,908</td></tr><tr><td>Total goodwill</td><td>$69,967</td><td>$73,861</td></tr></table>
<table><tr><td>Table 4</td><td>Noninterest Income</td><td></td><td></td></tr><tr><td colspan="2">(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td colspan="2">Card income</td><td>$7,184</td><td>$8,108</td></tr><tr><td colspan="2">Service charges</td><td>8,094</td><td>9,390</td></tr><tr><td colspan="2">Investment and brokerage services</td><td>11,826</td><td>11,622</td></tr><tr><td colspan="2">Investment banking income</td><td>5,217</td><td>5,520</td></tr><tr><td colspan="2">Equity investment income</td><td>7,360</td><td>5,260</td></tr><tr><td colspan="2">Trading account profits</td><td>6,697</td><td>10,054</td></tr><tr><td colspan="2">Mortgage banking income (loss)</td><td>-8,830</td><td>2,734</td></tr><tr><td colspan="2">Insurance income</td><td>1,346</td><td>2,066</td></tr><tr><td colspan="2">Gains on sales of debt securities</td><td>3,374</td><td>2,526</td></tr><tr><td colspan="2">Other income</td><td>6,869</td><td>2,384</td></tr><tr><td colspan="2">Net impairment losses recognized in earnings on available-for-sale debt securities</td><td>-299</td><td>-967</td></tr><tr><td colspan="2">Total noninterest income</td><td>$48,838</td><td>$58,697</td></tr></table>
<table><tr><td>Table 5</td><td>Noninterest Expense</td><td></td><td></td></tr><tr><td colspan="2">(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td colspan="2">Personnel</td><td>$36,965</td><td>$35,149</td></tr><tr><td colspan="2">Occupancy</td><td>4,748</td><td>4,716</td></tr><tr><td colspan="2">Equipment</td><td>2,340</td><td>2,452</td></tr><tr><td colspan="2">Marketing</td><td>2,203</td><td>1,963</td></tr><tr><td colspan="2">Professional fees</td><td>3,381</td><td>2,695</td></tr><tr><td colspan="2">Amortization of intangibles</td><td>1,509</td><td>1,731</td></tr><tr><td colspan="2">Data processing</td><td>2,652</td><td>2,544</td></tr><tr><td colspan="2">Telecommunications</td><td>1,553</td><td>1,416</td></tr><tr><td colspan="2">Other general operating</td><td>21,101</td><td>16,222</td></tr><tr><td colspan="2">Goodwill impairment</td><td>3,184</td><td>12,400</td></tr><tr><td colspan="2">Merger and restructuring charges</td><td>638</td><td>1,820</td></tr><tr><td colspan="2">Total noninterest expense</td><td>$80,274</td><td>$83,108</td></tr></table>
<table><tr><td>Table 19</td><td colspan="2">Long-term Debt by Major Currency December 31</td></tr><tr><td>(Dollars in millions)</td><td>2011</td><td>2010</td></tr><tr><td>U.S. Dollar</td><td>$255,262</td><td>$302,487</td></tr><tr><td>Euro</td><td>68,799</td><td>87,482</td></tr><tr><td>Japanese Yen</td><td>19,568</td><td>19,901</td></tr><tr><td>British Pound</td><td>12,554</td><td>16,505</td></tr><tr><td>Australian Dollar</td><td>4,900</td><td>6,924</td></tr><tr><td>Canadian Dollar</td><td>4,621</td><td>6,628</td></tr><tr><td>Swiss Franc</td><td>2,268</td><td>3,069</td></tr><tr><td>Other</td><td>4,293</td><td>5,435</td></tr><tr><td>Total long-term debt</td><td>$372,265</td><td>$448,431</td></tr></table>
<table><tr><td>Table 38</td><td colspan="6">Commercial Loans and Leases December 31</td></tr><tr><td></td><td colspan="2">Outstandings</td><td colspan="2">Nonperforming</td><td colspan="2">Accruing Past Due90 Days or More</td></tr><tr><td>(Dollars in millions)</td><td>2011</td><td>2010</td><td>2011</td><td>2010</td><td>2011</td><td>2010</td></tr><tr><td>U.S. commercial</td><td>$179,948</td><td>$175,586</td><td>$2,174</td><td>$3,453</td><td>$75</td><td>$236</td></tr><tr><td>Commercial real estate<sup>-1</sup></td><td>39,596</td><td>49,393</td><td>3,880</td><td>5,829</td><td>7</td><td>47</td></tr><tr><td>Commercial lease financing</td><td>21,989</td><td>21,942</td><td>26</td><td>117</td><td>14</td><td>18</td></tr><tr><td>Non-U.S. commercial</td><td>55,418</td><td>32,029</td><td>143</td><td>233</td><td>—</td><td>6</td></tr><tr><td></td><td>296,951</td><td>278,950</td><td>6,223</td><td>9,632</td><td>96</td><td>307</td></tr><tr><td>U.S. small business commercial<sup>-2</sup></td><td>13,251</td><td>14,719</td><td>114</td><td>204</td><td>216</td><td>325</td></tr><tr><td>Commercial loans excluding loans accounted for under the fair value option</td><td>310,202</td><td>293,669</td><td>6,337</td><td>9,836</td><td>312</td><td>632</td></tr><tr><td>Loans accounted for under the fair value option<sup>-3</sup></td><td>6,614</td><td>3,321</td><td>73</td><td>30</td><td>—</td><td>—</td></tr><tr><td>Total commercial loans and leases</td><td>$316,816</td><td>$296,990</td><td>$6,410</td><td>$9,866</td><td>$312</td><td>$632</td></tr></table>
<table><tr><td>Table 39</td><td colspan="4">Commercial Net Charge-offs and Related Ratios</td></tr><tr><td></td><td colspan="2">Net Charge-offs</td><td colspan="2">Net Charge-off Ratios<sup>-1</sup></td></tr><tr><td>(Dollars in millions)</td><td>2011</td><td>2010</td><td>2011</td><td>2010</td></tr><tr><td>U.S. commercial</td><td>$195</td><td>$881</td><td>0.11%</td><td>0.50%</td></tr><tr><td>Commercial real estate</td><td>947</td><td>2,017</td><td>2.13</td><td>3.37</td></tr><tr><td>Commercial lease financing</td><td>24</td><td>57</td><td>0.11</td><td>0.27</td></tr><tr><td>Non-U.S. commercial</td><td>152</td><td>111</td><td>0.36</td><td>0.39</td></tr><tr><td></td><td>1,318</td><td>3,066</td><td>0.46</td><td>1.07</td></tr><tr><td>U.S. small business commercial</td><td>995</td><td>1,918</td><td>7.12</td><td>12.00</td></tr><tr><td>Total commercial</td><td>$2,313</td><td>$4,984</td><td>0.77</td><td>1.64</td></tr></table>

Question: What's the growth rate of Non-U.S. commercial in terms of Net Charge-offs in 2011?
Answer: 0.36937