commitments .for a further description of the loan loss reserve and related accounts , see 201cmanaging global risk 201d and notes 1 and 18 to the consolidated financial statements on pages 51 , 122 and 165 , respectively .securitizations the company securitizes a number of different asset classes as a means of strengthening its balance sheet and accessing competitive financing rates in the market .under these securitization programs , assets are sold into a trust and used as collateral by the trust to obtain financing .the cash flows from assets in the trust service the corresponding trust securities .if the structure of the trust meets certain accounting guidelines , trust assets are treated as sold and are no longer reflected as assets of the company .if these guidelines are not met , the assets continue to be recorded as the company 2019s assets , with the financing activity recorded as liabilities on citigroup 2019s balance sheet .citigroup also assists its clients in securitizing their financial assets and packages and securitizes financial assets purchased in the financial markets .the company may also provide administrative , asset management , underwriting , liquidity facilities and/or other services to the resulting securitization entities and may continue to service some of these financial assets .elimination of qspes and changes in the fin 46 ( r ) consolidation model the fasb has issued an exposure draft of a proposed standard that would eliminate qualifying special purpose entities ( qspes ) from the guidance in fasb statement no .140 , accounting for transfers and servicing of financial assets and extinguishments of liabilities ( sfas 140 ) .while the proposed standard has not been finalized , if it is issued in its current form it will have a significant impact on citigroup 2019s consolidated financial statements as the company will lose sales treatment for certain assets previously sold to a qspe , as well as for certain future sales , and for certain transfers of portions of assets that do not meet the proposed definition of 201cparticipating interests . 201d this proposed revision could become effective on january 1 , 2010 .in connection with the proposed changes to sfas 140 , the fasb has also issued a separate exposure draft of a proposed standard that proposes three key changes to the consolidation model in fasb interpretation no .46 ( revised december 2003 ) , 201cconsolidation of variable interest entities 201d ( fin 46 ( r ) ) .first , the revised standard would include former qspes in the scope of fin 46 ( r ) .in addition , fin 46 ( r ) would be amended to change the method of analyzing which party to a variable interest entity ( vie ) should consolidate the vie ( such consolidating entity is referred to as the 201cprimary beneficiary 201d ) to a qualitative determination of power combined with benefits or losses instead of the current risks and rewards model .finally , the proposed standard would require that the analysis of primary beneficiaries be re-evaluated whenever circumstances change .the existing standard requires reconsideration only when specified reconsideration events occur .the fasb is currently deliberating these proposed standards , and they are , accordingly , still subject to change .since qspes will likely be eliminated from sfas 140 and thus become subject to fin 46 ( r ) consolidation guidance and because the fin 46 ( r ) method of determining which party must consolidate a vie will likely change should this proposed standard become effective , the company expects to consolidate certain of the currently unconsolidated vies and qspes with which citigroup was involved as of december 31 , 2008 .the company 2019s estimate of the incremental impact of adopting these changes on citigroup 2019s consolidated balance sheets and risk-weighted assets , based on december 31 , 2008 balances , our understanding of the proposed changes to the standards and a proposed january 1 , 2010 effective date , is presented below .the actual impact of adopting the amended standards as of january 1 , 2010 could materially differ .the pro forma impact of the proposed changes on gaap assets and risk- weighted assets , assuming application of existing risk-based capital rules , at january 1 , 2010 ( based on the balances at december 31 , 2008 ) would result in the consolidation of incremental assets as follows: .
[['in billions of dollars', 'incremental gaap assets', 'incremental risk- weighted assets'], ['credit cards', '$ 91.9', '$ 88.9'], ['commercial paper conduits', '59.6', '2014'], ['private label consumer mortgages', '4.4', '2.1'], ['student loans', '14.4', '3.5'], ['muni bonds', '6.2', '1.9'], ['mutual fund deferred sales commission securitization', '0.8', '0.8'], ['investment funds', '1.7', '1.7'], ['total', '$ 179.0', '$ 98.9']]
the table reflects ( i ) the estimated portion of the assets of qspes to which citigroup , acting as principal , has transferred assets and received sales treatment as of december 31 , 2008 ( totaling approximately $ 822.1 billion ) , and ( ii ) the estimated assets of significant unconsolidated vies as of december 31 , 2008 with which citigroup is involved ( totaling approximately $ 288.0 billion ) that would be consolidated under the proposal .due to the variety of transaction structures and level of the company 2019s involvement in individual qspes and vies , only a subset of the qspes and vies with which the company is involved are expected to be consolidated under the proposed change .a complete description of the company 2019s accounting for securitized assets can be found in note 1 to the consolidated financial statements on page 122. .

Question: what percentage of incremental risk-weighted assets are student loans at january 1 , 2010?
Answer: 4%