Table 72: Financial Impact and TDRs by Concession Type (a)
## Table 0 ##
(a) Impact of partial charge-offs at TDR date are included in this table.
(b) Represents the recorded investment of the loans as of the quarter end prior to the TDR designation, and excludes immaterial amounts of accrued interest receivable.
(c) Represents the recorded investment of the TDRs as of the quarter end the TDR occurs, and excludes immaterial amounts of accrued interest receivable.
(d) During 2011, the Post-TDR amounts for the Equipment lease financing loan class total less than $1 million.
(e) Includes loans modified during 2011 that were determined to be TDRs under the requirements of ASU 2011-02, which was adopted on July 1, 2011 and prospectively applied to all modifications entered into on and after January 1, 2011.
TDRs may result in charge-offs and interest income not being recognized.
At or around the time of modification, there was $22 million in recorded investment of commercial TDRs, $10 million in recorded investment of commercial real estate TDRs and $5 million of equipment lease financing TDRs charged off during 2012.
Comparable amounts for 2011 were $26 million, $15 million and zero respectively.
For residential real estate TDRs, there was $7 million of recorded investment charged off during 2012, related to modifications in which principal was partially deferred and deemed uncollectible.
The comparable amount for 2011 was $17 million.
Charge-offs around the time of modification related to home equity, credit card, and other consumer TDR portfolios were immaterial for both periods.
A financial effect of rate reduction TDRs is that interest income is not recognized.
Interest income not recognized that otherwise would have been earned in the year endedDecember 31, 2012 and 2011 related to both commercial TDRs and consumer TDRs was not material.
Pursuant to regulatory guidance issued in the third quarter of 2012, management compiled TDR information related to changes in treatment of certain loans where a borrower has been discharged from personal liability in bankruptcy and has not formally reaffirmed its loan obligation to PNC.
This information has been reflected in period end balance disclosures for the year ended December 31, 2012.
Because of the timing of the compilation of the TDR information and the fact that it covers several periods, $366 million of TDRs, net of $128.1 million of charge-offs, related to this new regulatory guidance, has not been reflected as part of 2012 activity included in Table 72: Financial Impact and TDRs by Concession Type and Table 73: TDRs which have Subsequently Defaulted.
At December 31, 2012, the fair value of the qualified pension plan assets was less than both the accumulated benefit obligation and the projected benefit obligation.
The nonqualified pension plan is unfunded.
Contributions from PNC and, in the case of postretirement benefit plans, participant contributions cover all benefits paid under the nonqualified pension plan and postretirement benefit plans.
The postretirement plan provides benefits to certain retirees that are at least actuarially equivalent to those provided by Medicare Part D and accordingly, we receive a federal subsidy as shown in the table.
In March 2010, the Patient Protection and Affordable Care Act (PPACA) was enacted.
Key aspects of the PPACA which are reflected in our financials include the excise tax on highcost health plans beginning in 2018 and fees for the Transitional Reinsurance Program and the Patient-Centered Outcomes Fund.
These provisions did not have a significant effect on our postretirement medical liability or cost.
The Early Retiree Reinsurance Program (ERRP) was established by the PPACA.
Congress appropriated funding of $5 billion for this temporary ERRP to provide financial assistance to employers, unions, and state and local governments to help them maintain coverage for early retirees age 55 and older who are not yet eligible for Medicare, including their spouses, surviving spouses, and dependents.
PNC submitted an application for reimbursement from the ERRP in 2012 for the 2010 and 2011 plan years.
In 2012, PNC received reimbursement of $.9 million related to the 2011 plan year and received reimbursement of $.6 million related to the 2010 plan year.
PNC PENSION PLAN ASSETS Assets related to our qualified pension plan (the Plan) are held in trust (the Trust).
Effective July 1, 2011, the trustee is The Bank of New York Mellon; prior to that date, the trustee was PNC Bank, National Association, (PNC Bank, N. A).
The Trust is exempt from tax pursuant to section 501(a) of the Internal Revenue Code (the Code).
The Plan is qualified under section 401(a) of the Code.
Plan assets consist primarily of listed domestic and international equity securities, U. S.  government and agency securities, corporate debt securities, and real estate investments.
Plan assets as of December 31, 2011 included $11 million of PNC common stock.
The Plan held no PNC common stock as of December 31, 2012.
The PNC Financial Services Group, Inc.
Administrative Committee (the Administrative Committee) adopted the Pension Plan Investment Policy Statement, including target allocations and allowable ranges, on August 13, 2008.
On February 25, 2010, the Administrative Committee amended the investment policy to include a dynamic asset allocation approach and also updated target allocation ranges for certain asset categories.
On March 1, 2011, the Administrative Committee amended the investment policy to update the target allocation ranges for certain asset categories.
The long-term investment strategy for pension plan assets is to: ?
Meet present and future benefit obligations to all participants and beneficiaries, ?
Cover reasonable expenses incurred to provide such benefits, including expenses incurred in the administration of the Trust and the Plan, ?
Provide sufficient liquidity to meet benefit and expense payment requirements on a timely basis, and ?
Provide a total return that, over the long term, maximizes the ratio of trust assets to liabilities by maximizing investment return, at an appropriate level of risk.
Under the dynamic asset allocation strategy, scenarios are outlined in which the Administrative Committee has the ability to make short to intermediate term asset allocation shifts based on factors such as the Plan’s funded status, the Administrative Committee’s view of return on equities relative to long term expectations, the Administrative Committee’s view on the direction of interest rates and credit spreads, and other relevant financial or economic factors which would be expected to impact the ability of the Trust to meet its obligation to beneficiaries.
Accordingly, the allowable asset allocation ranges have been updated to incorporate the flexibility required by the dynamic allocation policy.
The Plan’s specific investment objective is to meet or exceed the investment policy benchmark over the long term.
The investment policy benchmark compares actual performance to a weighted market index, and measures the contribution of active investment management and policy implementation.
This investment objective is expected to be achieved over the long term (one or more market cycles) and is measured over rolling five-year periods.
Total return calculations are timeweighted and are net of investment-related fees and expenses.
The asset strategy allocations for the Trust at the end of 2012 and 2011, and the target allocation range at the end of 2012, by asset category, are as follows.
Table 119: Asset Strategy Allocations
## Table 1 ##
In some cases, indemnification obligations of the types described above arise under arrangements entered into by predecessor companies for which we become responsible as a result of the acquisition.
Pursuant to their bylaws, PNC and its subsidiaries provide indemnification to directors, officers and, in some cases, employees and agents against certain liabilities incurred as a result of their service on behalf of or at the request of PNC and its subsidiaries.
PNC and its subsidiaries also advance on behalf of covered individuals costs incurred in connection with certain claims or proceedings, subject to written undertakings by each such individual to repay all amounts advanced if it is ultimately determined that the individual is not entitled to indemnification.
We generally are responsible for similar indemnifications and advancement obligations that companies we acquire had to their officers, directors and sometimes employees and agents at the time of acquisition.
We advanced such costs on behalf of several such individuals with respect to pending litigation or investigations during 2012.
It is not possible for us to determine the aggregate potential exposure resulting from the obligation to provide this indemnity or to advance such costs.
VISA INDEMNIFICATION Our payment services business issues and acquires credit and debit card transactions through Visa U. S. A.  Inc.  card association or its affiliates (Visa).
In October 2007, Visa completed a restructuring and issued shares of Visa Inc.  common stock to its financial institution members (Visa Reorganization) in contemplation of its initial public offering (IPO).
As part of the Visa Reorganization, we received our proportionate share of a class of Visa Inc.  common stock allocated to the US members.
Prior to the IPO, the US members, which included PNC, were obligated to indemnify Visa for judgments and settlements related to the specified litigation.
As a result of the acquisition of National City, we became party to judgment and loss sharing agreements with Visa and certain other banks.
The judgment and loss sharing agreements were designed to apportion financial responsibilities arising from any potential adverse judgment or negotiated settlements related to the specified litigation.
In July 2012, Visa funded $150 million into their litigation escrow account and reduced the conversion rate of Visa B to A shares.
We continue to have an obligation to indemnify Visa for judgments and settlements for the remaining specified litigation, therefore we may have additional exposure to the specified Visa litigation.
RECOURSE AND REPURCHASE OBLIGATIONS As discussed in Note 3 Loan Sale and Servicing Activities and Variable Interest Entities, PNC has sold commercial mortgage, residential mortgage and home equity loans directly or indirectly through securitization and loan sale transactions in which we have continuing involvement.
One form of continuing involvement includes certain recourse and loan repurchase obligations associated with the transferred assets.
COMMERCIAL MORTGAGE LOAN RECOURSE OBLIGATIONS We originate, close and service certain multi-family commercial mortgage loans which are sold to FNMA under FNMA’s DUS program.
We participated in a similar program with the FHLMC.
Under these programs, we generally assume up to a one-third pari passu risk of loss on unpaid principal balances through a loss share arrangement.
At December 31, 2012 and December 31, 2011, the unpaid principal balance outstanding of loans sold as a participant in these programs was $12.8 billion and $13.0 billion, respectively.
The potential maximum exposure under the loss share arrangements was $3.9 billion at December 31, 2012 and $4.0 billion at December 31, 2011.
We maintain a reserve for estimated losses based upon our exposure.
The reserve for losses under these programs totaled $43 million and $47 million as of December 31, 2012 and December 31, 2011, respectively, and is included in Other liabilities on our Consolidated Balance Sheet.
If payment is required under these programs, we would not have a contractual interest in the collateral underlying the mortgage loans on which losses occurred, although the value of the collateral is taken into account in determining our share of such losses.
Our exposure and activity associated with these recourse obligations are reported in the Corporate & Institutional Banking segment.
Table 154: Analysis of Commercial Mortgage Recourse Obligations
## Table 2 ##
RESIDENTIAL MORTGAGE LOAN AND HOME EQUITY REPURCHASE OBLIGATIONS While residential mortgage loans are sold on a non-recourse basis, we assume certain loan repurchase obligations associated with mortgage loans we have sold to investors.
These loan repurchase obligations primarily relate to situations where PNC is alleged to have breached certain origination covenants and representations and warranties made to purchasers of the loans in the respective purchase and sale agreements.
Residential mortgage loans covered by these loan repurchase obligations include first and second-lien mortgage loans we have sold through Agency securitizations, Non-agency securitizations, and loan sale transactions.
As discussed in Note 3 Loans Sale and Servicing Activities and

<table><tr><td></td><td></td><td></td><td colspan="4">Post-TDR Recorded Investment (c)</td></tr><tr><td>During the year ended December 31, 2012Dollars in millions</td><td>Numberof Loans</td><td>Pre-TDRRecordedInvestment (b)</td><td>PrincipalForgiveness</td><td>RateReduction</td><td>Other</td><td>Total</td></tr><tr><td>Commercial lending</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Commercial</td><td>212</td><td>$355</td><td>$13</td><td>$90</td><td>$198</td><td>$301</td></tr><tr><td>Commercial real estate</td><td>67</td><td>201</td><td>23</td><td>43</td><td>118</td><td>184</td></tr><tr><td>Equipment lease financing</td><td>10</td><td>24</td><td>2</td><td>2</td><td>12</td><td>16</td></tr><tr><td>Total commercial lending</td><td>289</td><td>580</td><td>38</td><td>135</td><td>328</td><td>501</td></tr><tr><td>Consumer lending</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Home equity</td><td>4,813</td><td>313</td><td></td><td>200</td><td>110</td><td>310</td></tr><tr><td>Residential real estate</td><td>754</td><td>147</td><td></td><td>60</td><td>83</td><td>143</td></tr><tr><td>Credit card</td><td>13,306</td><td>93</td><td></td><td>90</td><td></td><td>90</td></tr><tr><td>Other consumer</td><td>835</td><td>20</td><td></td><td>2</td><td>19</td><td>21</td></tr><tr><td>Total consumer lending</td><td>19,708</td><td>573</td><td></td><td>352</td><td>212</td><td>564</td></tr><tr><td>Total TDRs</td><td>19,997</td><td>$1,153</td><td>$38</td><td>$487</td><td>$540</td><td>$1,065</td></tr><tr><td>During the year ended December 31, 2011 (e)Dollars in millions</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Commercial lending</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Commercial</td><td>599</td><td>$129</td><td>$19</td><td>$33</td><td>$60</td><td>$112</td></tr><tr><td>Commercial real estate</td><td>78</td><td>286</td><td>83</td><td>123</td><td>54</td><td>260</td></tr><tr><td>Equipment lease financing (d)</td><td>2</td><td>1</td><td></td><td></td><td></td><td></td></tr><tr><td>Total commercial lending</td><td>679</td><td>416</td><td>102</td><td>156</td><td>114</td><td>372</td></tr><tr><td>Consumer lending</td><td></td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Home equity</td><td>4,013</td><td>321</td><td></td><td>281</td><td>39</td><td>320</td></tr><tr><td>Residential real estate</td><td>1,590</td><td>376</td><td></td><td>236</td><td>115</td><td>351</td></tr><tr><td>Credit card</td><td>11,761</td><td>87</td><td></td><td>84</td><td></td><td>84</td></tr><tr><td>Other consumer</td><td>472</td><td>13</td><td></td><td>1</td><td>12</td><td>13</td></tr><tr><td>Total consumer lending</td><td>17,836</td><td>797</td><td></td><td>602</td><td>166</td><td>768</td></tr><tr><td>Total TDRs</td><td>18,515</td><td>$1,213</td><td>$102</td><td>$758</td><td>$280</td><td>$1,140</td></tr></table>
<table><tr><td></td><td>Target Allocation Range</td><td colspan="2">Percentage of Plan Assets by Strategy at December 31</td></tr><tr><td> PNC Pension Plan</td><td></td><td>2012</td><td>2011</td></tr><tr><td>Asset Category</td><td></td><td></td><td></td></tr><tr><td>Domestic Equity</td><td>20 - 40%</td><td>34%</td><td>41%</td></tr><tr><td>International Equity</td><td>10 - 25%</td><td>22%</td><td>21%</td></tr><tr><td>Private Equity</td><td>0 - 10%</td><td>3%</td><td>3%</td></tr><tr><td>Total Equity</td><td>40 - 70%</td><td>59%</td><td>65%</td></tr><tr><td>Domestic Fixed Income</td><td>20 - 40%</td><td>21%</td><td>20%</td></tr><tr><td>High Yield Fixed Income</td><td>0 - 15%</td><td>14%</td><td>12%</td></tr><tr><td>Total Fixed Income</td><td>20 - 55%</td><td>35%</td><td>32%</td></tr><tr><td>Real estate</td><td>0 - 10%</td><td>5%</td><td>3%</td></tr><tr><td>Other</td><td>0 - 5%</td><td>1%</td><td>0%</td></tr><tr><td>Total</td><td></td><td>100%</td><td>100%</td></tr></table>
<table><tr><td>In millions</td><td>2012</td><td>2011</td></tr><tr><td>January 1</td><td>$47</td><td>$54</td></tr><tr><td>Reserve adjustments, net</td><td>4</td><td>1</td></tr><tr><td>Losses – loan repurchases and settlements</td><td>-8</td><td>-8</td></tr><tr><td>December 31</td><td>$43</td><td>$47</td></tr></table>

Question: As As the chart 0 shows,the value of the Total consumer lending for Rate Reduction during which year ended December 31, which year ranks higher?
Answer: 2011