whether or not any claims asserted against us or others to whom we may have indemnification obligations, whether in the proceedings or other matters described above or otherwise, will have a material adverse effect on our results of operations in any future reporting period, which will depend on, among other things, the amount of the loss resulting from the claim and the amount of income otherwise reported for the reporting period.
See Note 23 Commitments and Guarantees for additional information regarding the Visa indemnification and our other obligations to provide indemnification, including to current and former officers, directors, employees and agents of PNC and companies we have acquired, including National City.
NOTE 23 COMMITMENTS AND GUARANTEES EQUITY FUNDING AND OTHER COMMITMENTS Our unfunded commitments at December 31, 2011 included private equity investments of $247 million, and other investments of $3 million.
STANDBY LETTERS OF CREDIT We issue standby letters of credit and have risk participations in standby letters of credit and bankers’ acceptances issued by other financial institutions, in each case to support obligations of our customers to third parties, such as remarketing programs for customers’ variable rate demand notes.
Net outstanding standby letters of credit and internal credit ratings were as follows: Net Outstanding Standby Letters of Credit
## Table 0 ##
(a) Indicates that expected risk of loss is currently low.
(b) Indicates a higher degree of risk of default.
If the customer fails to meet its financial or performance obligation to the third party under the terms of the contract or there is a need to support a remarketing program, then upon the request of the guaranteed party, we would be obligated to make payment to them.
The standby letters of credit and risk participations in standby letters of credit and bankers’ acceptances outstanding on December 31, 2011 had terms ranging from less than 1 year to 7 years.
The aggregate maximum amount of future payments PNC could be required to make under outstanding standby letters of credit and risk participations in standby letters of credit and bankers’ acceptances was $14.4 billion at December 31, 2011, of which $7.4 billion support remarketing programs.
As of December 31, 2011, assets of $2.0 billion secured certain specifically identified standby letters of credit.
Recourse provisions from third parties of $3.6 billion were also available for this purpose as of December 31, 2011.
In addition, a portion of the remaining standby letters of credit and letter of credit risk participations issued on behalf of specific customers is also secured by collateral or guarantees that secure the customers’ other obligations to us.
The carrying amount of the liability for our obligations related to standby letters of credit and risk participations in standby letters of credit and bankers’ acceptances was $247 million at December 31, 2011.
STANDBY BOND PURCHASE AGREEMENTS AND OTHER LIQUIDITY FACILITIES We enter into standby bond purchase agreements to support municipal bond obligations.
At December 31, 2011, the aggregate of our commitments under these facilities was $543 million.
We also enter into certain other liquidity facilities to support individual pools of receivables acquired by commercial paper conduits.
At December 31, 2011, our total commitments under these facilities were $199 million.
INDEMNIFICATIONS We are a party to numerous acquisition or divestiture agreements under which we have purchased or sold, or agreed to purchase or sell, various types of assets.
These agreements can cover the purchase or sale of: ?
Entire businesses, ?
Loan portfolios, ?
Branch banks, ?
Partial interests in companies, or ?
Other types of assets.
These agreements generally include indemnification provisions under which we indemnify the third parties to these agreements against a variety of risks to the indemnified parties as a result of the transaction in question.
When PNC is the seller, the indemnification provisions will generally also provide the buyer with protection relating to the quality of the assets we are selling and the extent of any liabilities being assumed by the buyer.
Due to the nature of these indemnification provisions, we cannot quantify the total potential exposure to us resulting from them.
We provide indemnification in connection with securities offering transactions in which we are involved.
When we are the issuer of the securities, we provide indemnification to the underwriters or placement agents analogous to the indemnification provided to the purchasers of businesses from us, as described above.
When we are an underwriter or placement agent, we provide a limited indemnification to the issuer related to our actions in connection with the offering and, if there are other underwriters, indemnification to the other underwriters intended to result in an appropriate sharing of the risk of participating in the offering.
Due to the nature of these indemnification provisions, we cannot quantify the total potential exposure to us resulting from them.
In the ordinary course of business, we enter into certain types of agreements that include provisions for indemnifying third
## Table 1 ##
(a) Includes the impact of National City, which we acquired on December 31, 2008.
(b) Includes the impact of National City except for the following Selected Ratios: Net Interest Margin, Noninterest income to total revenue, Efficiency, Return on Average common shareholders’ equity, Return on Average assets, Dividend payout, and Average common shareholders’ equity to average assets.
(c) Represents the sum of interest-bearing money market deposits, interest-bearing demand deposits, and noninterest-bearing deposits.
(d) Includes long-term borrowings of $20.9 billion, $24.8 billion, $26.3 billion, $33.6 billion, and $12.6 billion for 2011, 2010, 2009, 2008 and 2007, respectively.
Borrowings which mature more than one year after December 31, 2011 are considered to be long-term.
(e) Amounts for 2011 and 2010 include cash and money market balances.
(f) Calculated as taxable-equivalent net interest income divided by average earning assets.
The interest income earned on certain earning assets is completely or partially exempt from federal income tax.
As such, these tax-exempt instruments typically yield lower returns than taxable investments.
To provide more meaningful comparisons of net interest margins for all earning assets, we use net interest income on a taxable-equivalent basis in calculating net interest margin by increasing the interest income earned on tax-exempt assets to make it fully equivalent to interest income earned on taxable investments.
This adjustment is not permitted under accounting principles generally accepted in the United States of America (GAAP) on the Consolidated Income Statement.
The taxable-equivalent adjustments to net interest income for the years 2011, 2010, 2009, 2008 and 2007 were $104 million, $81 million, $65 million, $36 million and $27 million, respectively.
Our contractual obligations totaled $84.6 billion at December 31, 2010.
The decline in the comparison is primarily attributable to decreases in the remaining contractual maturities of time deposits and borrowed funds.
## Table 2 ##
(a) Other commitments are funding commitments that could potentially require performance in the event of demands by third parties or contingent events.
Loan commitments are reported net of syndications, assignments and participations.
(b) Includes $7.4 billion of standby letters of credit that support remarketing programs for customers’ variable rate demand notes.
(c) Reinsurance agreements are with third-party insurers related to insurance sold to our customers.
(d) Includes unfunded commitments related to private equity investments of $247 million and other investments of $3 million that are not on our Consolidated Balance Sheet.
Also includes commitments related to tax credit investments of $420 million and other direct equity investments of $37 million that are included in Other liabilities on our Consolidated Balance Sheet.
MARKET RISK MANAGEMENT OVERVIEW Market risk is the risk of a loss in earnings or economic value due to adverse movements in market factors such as interest rates, credit spreads, foreign exchange rates, and equity prices.
We are exposed to market risk primarily by our involvement in the following activities, among others: ?
Traditional banking activities of taking deposits and extending loans, ?
Equity and other investments and activities whose economic values are directly impacted by market factors, and ?
Trading in fixed income products, equities, derivatives, and foreign exchange, as a result of customer activities and underwriting.
We have established enterprise-wide policies and methodologies to identify, measure, monitor, and report market risk.
Market Risk Management provides independent oversight by monitoring compliance with these limits and guidelines, and reporting significant risks in the business to the Risk Committee of the Board.
MARKET RISK MANAGEMENT – INTEREST RATE RISK Interest rate risk results primarily from our traditional banking activities of gathering deposits and extending loans.
Many factors, including economic and financial conditions, movements in interest rates, and consumer preferences, affect the difference between the interest that we earn on assets and the interest that we pay on liabilities and the level of our noninterest-bearing funding sources.
Due to the repricing term mismatches and embedded options inherent in certain of these products, changes in market interest rates not only affect expected near-term earnings, but also the economic values of these assets and liabilities.
Asset and Liability Management centrally manages interest rate risk set forth in our risk management policies approved by management’s Asset and Liability Committee and the Risk Committee of the Board.
Sensitivity results and market interest rate benchmarks for the fourth quarters of 2011 and 2010 follow: Interest Sensitivity Analysis

Tables referenced above, in order (Table 0 first):
<table><tr><td>Dollars in billions</td><td>December 31 2011</td><td>December 312010</td></tr><tr><td>Net outstanding standby letters of credit</td><td>$10.8</td><td>$10.1</td></tr><tr><td>Internal credit ratings (as a percentage of portfolio):</td><td></td><td></td></tr><tr><td>Pass (a)</td><td>94%</td><td>90%</td></tr><tr><td>Below pass (b)</td><td>6%</td><td>10%</td></tr></table>
<table><tr><td></td><td colspan="5">At or for the year ended December 31</td></tr><tr><td>Dollars in millions, except as noted</td><td>2011 (a)</td><td>2010 (a)</td><td>2009 (a)</td><td>2008 (b)</td><td>2007</td></tr><tr><td> BALANCESHEETHIGHLIGHTS</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Assets</td><td>$271,205</td><td>$264,284</td><td>$269,863</td><td>$291,081</td><td>$138,920</td></tr><tr><td>Loans</td><td>159,014</td><td>150,595</td><td>157,543</td><td>175,489</td><td>68,319</td></tr><tr><td>Allowance for loan and lease losses</td><td>4,347</td><td>4,887</td><td>5,072</td><td>3,917</td><td>830</td></tr><tr><td>Interest-earning deposits with banks</td><td>1,169</td><td>1,610</td><td>4,488</td><td>14,859</td><td>346</td></tr><tr><td>Investment securities</td><td>60,634</td><td>64,262</td><td>56,027</td><td>43,473</td><td>30,225</td></tr><tr><td>Loans held for sale</td><td>2,936</td><td>3,492</td><td>2,539</td><td>4,366</td><td>3,927</td></tr><tr><td>Goodwill and other intangible assets</td><td>10,144</td><td>10,753</td><td>12,909</td><td>11,688</td><td>9,551</td></tr><tr><td>Equity investments</td><td>10,134</td><td>9,220</td><td>10,254</td><td>8,554</td><td>6,045</td></tr><tr><td>Noninterest-bearing deposits</td><td>59,048</td><td>50,019</td><td>44,384</td><td>37,148</td><td>19,440</td></tr><tr><td>Interest-bearing deposits</td><td>128,918</td><td>133,371</td><td>142,538</td><td>155,717</td><td>63,256</td></tr><tr><td>Total deposits</td><td>187,966</td><td>183,390</td><td>186,922</td><td>192,865</td><td>82,696</td></tr><tr><td>Transaction deposits (c)</td><td>147,637</td><td>134,654</td><td>126,244</td><td>110,997</td><td>53,672</td></tr><tr><td>Borrowed funds (d)</td><td>36,704</td><td>39,488</td><td>39,261</td><td>52,240</td><td>30,931</td></tr><tr><td>Total shareholders’ equity</td><td>34,053</td><td>30,242</td><td>29,942</td><td>25,422</td><td>14,854</td></tr><tr><td>Common shareholders’ equity</td><td>32,417</td><td>29,596</td><td>22,011</td><td>17,490</td><td>14,847</td></tr><tr><td> CLIENTASSETS(billions)</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Discretionary assets under management</td><td>$107</td><td>$108</td><td>$103</td><td>$103</td><td>$74</td></tr><tr><td>Nondiscretionary assets under management</td><td>103</td><td>104</td><td>102</td><td>125</td><td>112</td></tr><tr><td>Total assets under administration</td><td>210</td><td>212</td><td>205</td><td>228</td><td>186</td></tr><tr><td>Brokerage account assets (e)</td><td>34</td><td>34</td><td>32</td><td>29</td><td>19</td></tr><tr><td>Total client assets</td><td>$244</td><td>$246</td><td>$237</td><td>$257</td><td>$205</td></tr><tr><td> SELECTEDRATIOS</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Net interest margin (f)</td><td>3.92%</td><td>4.14%</td><td>3.82%</td><td>3.37%</td><td>3.00%</td></tr><tr><td>Noninterest income to total revenue</td><td>39</td><td>39</td><td>44</td><td>39</td><td>50</td></tr><tr><td>Efficiency</td><td>64</td><td>57</td><td>56</td><td>59</td><td>62</td></tr><tr><td>Return on</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Average common shareholders’ equity</td><td>9.56</td><td>10.88</td><td>9.78</td><td>6.52</td><td>10.70</td></tr><tr><td>Average assets</td><td>1.16</td><td>1.28</td><td>.87</td><td>.64</td><td>1.21</td></tr><tr><td>Loans to deposits</td><td>85</td><td>82</td><td>84</td><td>91</td><td>83</td></tr><tr><td>Dividend payout</td><td>20.2</td><td>6.8</td><td>21.4</td><td>104.6</td><td>55.0</td></tr><tr><td>Tier 1 common</td><td>10.3</td><td>9.8</td><td>6.0</td><td>4.8</td><td>5.4</td></tr><tr><td>Tier 1 risk-based</td><td>12.6</td><td>12.1</td><td>11.4</td><td>9.7</td><td>6.8</td></tr><tr><td>Common shareholders’ equity to total assets</td><td>12.0</td><td>11.2</td><td>8.2</td><td>6.0</td><td>10.7</td></tr><tr><td>Average common shareholders’ equity to average assets</td><td>11.9</td><td>10.4</td><td>7.2</td><td>9.6</td><td>11.3</td></tr><tr><td> SELECTEDSTATISTICS</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Employees</td><td>51,891</td><td>50,769</td><td>55,820</td><td>59,595</td><td>28,320</td></tr><tr><td>Retail Banking branches</td><td>2,511</td><td>2,470</td><td>2,513</td><td>2,581</td><td>1,102</td></tr><tr><td>ATMs</td><td>6,806</td><td>6,673</td><td>6,473</td><td>6,233</td><td>3,900</td></tr><tr><td>Residential mortgage servicing portfolio (billions)</td><td>$131</td><td>$139</td><td>$158</td><td>$187</td><td></td></tr><tr><td>Commercial mortgage servicing portfolio (billions)</td><td>$267</td><td>$266</td><td>$287</td><td>$270</td><td>$243</td></tr></table>
<table><tr><td> <i>Other Commitments (a)</i></td><td></td><td colspan="4">Amount Of Commitment Expiration By Period</td></tr><tr><td>December 31, 2011 – in millions</td><td>Total Amounts Committed</td><td>Less than one year</td><td>One to three years</td><td>Four to five years</td><td>After five years</td></tr><tr><td>Net unfunded credit commitments</td><td>$103,271</td><td>$48,011</td><td>$31,491</td><td>$23,167</td><td>$602</td></tr><tr><td>Standby letters of credit (b)</td><td>10,769</td><td>4,537</td><td>5,004</td><td>1,107</td><td>121</td></tr><tr><td>Reinsurance agreements (c)</td><td>6,432</td><td>2,959</td><td>105</td><td>50</td><td>3,318</td></tr><tr><td>Other commitments (d)</td><td>707</td><td>367</td><td>251</td><td>85</td><td>4</td></tr><tr><td>Total commitments</td><td>$121,179</td><td>$55,874</td><td>$36,851</td><td>$24,409</td><td>$4,045</td></tr></table>

Question: How many CLIENTASSETS exceed the average of CLIENTASSETS in 2009?
Answer: 2