Standard of Care Developments The SEC, federal and state lawmakers and state insurance regulators continue their efforts at evaluating what is an appropriate regulatory framework around a standard of care for the sale of investment products and services.
For example, on April 18, 2018, the SEC proposed a package of rulemakings and interpretations designed to address the standard of care issues and the transparency of retail investors’ relationships with investment advisors and broker-dealers.
Additionally, on July 18, 2018, the New York State Department of Financial Services adopted a best interest standard of care regulation applicable to annuity and life transactions through issuance of the First Amendment to Insurance Regulation 187 – Suitability and Best Interests in Life Insurance and Annuity Transactions (Regulation 187).
The compliance date for Regulation 187 is August 1, 2019 for annuity products and February 1, 2020 for life products.
As amended, Regulation 187 requires producers to act in their client’s best interest when making point-of-sale and inforce recommendations, and provide in writing the basis for the recommendation, as well as the facts and analysis to support the recommendation.
The amended regulation also imposes additional duties on life insurance companies in relation to these transactions, such as requiring insurers to establish and maintain procedures designed to prevent financial exploitation and abuse.
We will implement and enhance processes and procedures, where needed, to comply with this regulation.
Other states, such as Nevada, Maryland and New Jersey, have also proposed similar standard of care regulations applicable to insurance producers and/or insurance companies.
We continue to closely follow these proposals and other relevant federal and state-level regulatory and legislative developments in this area.
While we cannot predict the long-term impact of these developments on our Life and Retirement businesses, we believe our diverse product offerings and distribution relationships position us to compete effectively in this evolving marketplace.
Impact of Currency Volatility Currency volatility remains acute.
Such volatility affected line item components of income for those businesses with substantial international operations.
In particular, growth trends in net premiums written reported in U. S.  dollars can differ significantly from those measured in original currencies.
The net effect on underwriting results, however, is significantly mitigated, as both revenues and expenses are similarly affected.
These currencies may continue to fluctuate, in either direction, especially as a result of the UK’s announced exit from the EU, and such fluctuations will affect net premiums written growth trends reported in U. S.  dollars, as well as financial statement line item comparability.
General Insurance businesses are transacted in most major foreign currencies.
The following table presents the average of the quarterly weighted average exchange rates of the Major Currencies, which have the most significant impact on our businesses:
## Table 0 ##
Unless otherwise noted, references to the effects of foreign exchange in the General Insurance discussion of results of operations are with respect to movements in the Major Currencies included in the preceding table.
Other Industry Developments On September 7, 2017, the UK Ministry of Justice announced a proposal to increase the Ogden rate from negative 0.75 percent to between zero and one percent.
Following this announcement, on December 20, 2018 the UK Parliament passed the Civil Liability Act 2018 which implements a new framework for determining the Ogden rate and requires the UK Ministry of Justice to start a review of the Ogden rate within 90 days of its commencement and review periodically thereafter.
The Ministry of Justice concluded a public call for evidence on January 30, 2019 prior to beginning its first review.
We will continue to monitor the progress of potential changes to the Ogden rate.
Entergy Texas, Inc.  Management's Financial Discussion and Analysis 366 dividends or other distributions on its common stock.
Currently, all of Entergy Texas' retained earnings are available for distribution.
Sources of Capital Entergy Texas' sources to meet its capital requirements include: x internally generated funds; x cash on hand; x debt or preferred stock issuances; and x bank financing under new or existing facilities.
Entergy Texas may refinance or redeem debt prior to maturity, to the extent market conditions and interest and dividend rates are favorable.
All debt and common and preferred stock issuances by Entergy Texas require prior regulatory approval.
Preferred stock and debt issuances are also subject to issuance tests set forth in its corporate charter, bond indentures, and other agreements.
Entergy Texas has sufficient capacity under these tests to meet its foreseeable capital needs.
Entergy Gulf States, Inc.  filed with the FERC an application, on behalf of Entergy Texas, for authority to issue up to $200 million of short-term debt, up to $300 million of tax-exempt bonds, and up to $1.3 billion of other longterm securities, including common and preferred or preference stock and long-term debt.
On November 8, 2007, the FERC issued orders granting the requested authority for a two-year period ending November 8, 2009.
Entergy Texas' receivables from or (payables to) the money pool were as follows as of December 31 for each of the following years:
## Table 1 ##
See Note 4 to the financial statements for a description of the money pool.
Entergy Texas has a credit facility in the amount of $100 million scheduled to expire in August 2012.
As of December 31, 2008, $100 million was outstanding on the credit facility.
In February 2009, Entergy Texas repaid its credit facility with the proceeds from the bond issuance discussed below.
On June 2, 2008 and December 8, 2008, under the terms of the debt assumption agreement between Entergy Texas and Entergy Gulf States Louisiana that is discussed in Note 5 to the financial statements, Entergy Texas paid at maturity $148.8 million and $160.3 million, respectively, of Entergy Gulf States Louisiana first mortgage bonds, which results in a corresponding decrease in Entergy Texas' debt assumption liability.
In December 2008, Entergy Texas borrowed $160 million from its parent company, Entergy Corporation, under a $300 million revolving credit facility pursuant to an Inter-Company Credit Agreement between Entergy Corporation and Entergy Texas.
This borrowing would have matured on December 3, 2013.
Entergy Texas used these borrowings, together with other available corporate funds, to pay at maturity the portion of the $350 million Floating Rate series of First Mortgage Bonds due December 2008 that had been assumed by Entergy Texas, and that bond series is no longer outstanding.
In January 2009, Entergy Texas repaid its $160 million note payable to Entergy Corporation with the proceeds from the bond issuance discussed below.
In January 2009, Entergy Texas issued $500 million of 7.125% Series Mortgage Bonds due February 2019.
Entergy Texas used a portion of the proceeds to repay its $160 million note payable to Entergy Corporation, to repay the $100 million outstanding on its credit facility, and to repay short-term borrowings under the Entergy System money pool.
Entergy Texas intends to use the remaining proceeds to repay on or prior to maturity approximately $70 million of obligations that had been assumed by Entergy Texas under the debt assumption agreement with Entergy Gulf States Louisiana and for other general corporate purposes.
A reconciliation of the statutory U. S.  federal tax rate and effective tax rates is as follows:
## Table 2 ##
1 Includes tax expense of $265 million (or 1.9 percent), primarily related to deferred tax expense on certain current year undistributed foreign earnings that are not considered indefinitely reinvested and amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties.2 Includes an approximate 0.1 percent impact to our effective tax rate related to charges recorded by our equity method investees.
Refer to Note 17.3 Includes a tax benefit of $34 million related to the remeasurement of our equity investment in CCE to fair value upon our acquisition of CCE’s North American business.
The tax benefit reflects the impact of reversing deferred tax liabilities associated with our equity investment in CCE prior to the acquisition.
Refer to Note 2.4 Includes an approximate 37 percent effective tax rate on charges related to preexisting relationships with CCE.
Refer to Note 2.5 Includes an approximate 0.4 percent impact to our effective tax rate related to the sale of our Norwegian and Swedish bottling operations.
Refer to Note 2.6 Includes an approximate 0.5 percent impact to our effective tax rate, primarily related to the Company’s productivity, integration and restructuring initiatives, transaction costs and charitable contributions.
Refer to Note 17.7 Includes an approximate 0.5 percent impact to our effective tax rate on charges related to the repurchase of certain long-term debt and costs associated with the settlement of treasury rate locks issued in connection with the debt tender offer, the loss related to the remeasurement of our Venezuelan subsidiary’s net assets, other-than-temporary impairment charges and a donation of preferred shares in one of our equity method investees.
Refer to Note 17.8 Includes a $31 million (or 0.2 percent) tax expense related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties, and other tax matters in certain domestic jurisdictions.9 Includes a $16 million (or 0.2 percent) tax benefit related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties, in various international jurisdictions.10 Includes an approximate 0.1 percent impact to our effective tax rate related to charges recorded by our equity method investees.
Refer to Note 17.11 Includes an approximate 0.6 percent impact to our effective tax rate related to restructuring charges and asset impairments.
Refer to Note 17.12 Includes an approximate negative 0.2 percent impact to our effective tax rate related to the sale of all or a portion of certain investments.
Refer to Note 3.13 Includes an approximate 0.1 percent impact to our effective tax rate related to an other-than-temporary impairment of a cost method investment.
Refer to Note 17.14 Includes a $17 million (or 0.2 percent) tax charge related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties, in various international jurisdictions.15 Includes an approximate 0.2 percent impact on our effective tax rate related to impairments of assets and investments in our bottling operations.
Refer to Note 17.16 Includes a $10 million (or 0.1 percent) impact on our effective tax rate related to recording valuation allowances offsetting deferred tax assets booked in prior periods.17 Includes an approximate 2.7 percent impact to our effective tax rate related to charges recorded by our equity method investees.
Refer to Note 17.18 Includes an approximate 0.7 percent impact to our effective tax rate related to restructuring charges, contract termination fees, productivity initiatives and asset impairments.
Refer to Note 17.19 Includes a $22 million (or 0.3 percent) tax benefit related to amounts required to be recorded for changes to our uncertain tax positions, including interest and penalties, in certain domestic jurisdictions.20 Includes an approximate negative 0.2 percent impact to our effective tax rate related to the sale of all or a portion of our investments in certain bottling operations.
Refer to Note 17.
PRUDENTIAL FINANCIAL, INC.  Notes to Consolidated Financial Statements 20.
FAIR VALUE OF ASSETS AND LIABILITIES (continued)
## Table 3 ##
(1) Separate account assets represent segregated funds that are invested for certain customers.
Investment risks associated with market value changes are borne by the customers, except to the extent of minimum guarantees made by the Company with respect to certain accounts.
Separate account assets classified as Level 3 consist primarily of real estate and real estate investment funds.
Separate account liabilities are not included in the above table as they are reported at contract value and not fair value in the Company’s Consolidated Statement of Financial Position.
(2) “Netting” amounts represent cash collateral and the impact of offsetting asset and liability positions held with the same counterparty.
(3) Includes reclassifications to conform to current period presentation.
The methods and assumptions the Company uses to estimate fair value of assets and liabilities measured at fair value on a recurring basis are summarized below.
Information regarding Separate Account Assets is excluded as the risk of assets for these categories is primarily borne by our customers and policyholders.

Tables referenced above, in order (Table 0 first):
<table><tr><td> Years Ended December 31,</td><td></td><td></td><td></td><td colspan="2">Percentage Change</td></tr><tr><td>Rate for 1 USD</td><td> 2018</td><td>2017</td><td>2016</td><td>2018 vs. 2017</td><td>2017 vs. 2016</td></tr><tr><td> Currency:</td><td> </td><td></td><td></td><td></td><td></td></tr><tr><td>GBP</td><td> 0.75</td><td>0.78</td><td>0.73</td><td>-4%</td><td>7%</td></tr><tr><td>EUR</td><td> 0.84</td><td>0.90</td><td>0.90</td><td>-7%</td><td>-%</td></tr><tr><td>JPY</td><td> 110.50</td><td>112.44</td><td>109.19</td><td>-2%</td><td>3%</td></tr></table>
<table><tr><td>2008</td><td>2007</td><td>2006</td><td>2005</td></tr><tr><td>(In Thousands)</td></tr><tr><td>-$50,794</td><td>$154,176</td><td>$97,277</td><td>$136,545</td></tr></table>
<table><tr><td>Year Ended December 31,</td><td>2010</td><td>2009</td><td>2008</td></tr><tr><td>Statutory U.S. federal tax rate</td><td>35.0%</td><td>35.0%</td><td>35.0%</td></tr><tr><td>State and local income taxes — net of federal benefit</td><td>0.6</td><td>0.7</td><td>0.8</td></tr><tr><td>Earnings in jurisdictions taxed at rates different from the statutory U.S. federal rate</td><td>-5.6 1</td><td>-11.6 9</td><td>-14.5 14,15,16</td></tr><tr><td>Equity income or loss</td><td>-1.9 2</td><td>-2.3 10</td><td>0.217</td></tr><tr><td>CCE transaction</td><td>-12.5 3,4</td><td>—</td><td>—</td></tr><tr><td>Nordic bottler sale</td><td>0.45</td><td>—</td><td>—</td></tr><tr><td>Other operating charges</td><td>0.46</td><td>0.611</td><td>0.718</td></tr><tr><td>Other — net</td><td>0.37,8</td><td>0.412,13</td><td>-0.5 19,20</td></tr><tr><td>Effective tax rates</td><td>16.7%</td><td>22.8%</td><td>21.7%</td></tr></table>
<table><tr><td></td><td colspan="5"> As of December 31, 2009-3</td></tr><tr><td></td><td> Level 1</td><td> Level 2</td><td> Level 3</td><td>Netting-2</td><td> Total</td></tr><tr><td></td><td colspan="5"> (in millions)</td></tr><tr><td>Fixed maturities, available for sale:</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>U.S. Treasury securities and obligations of U.S. government authorities and agencies</td><td>$0</td><td>$8,268</td><td>$0</td><td></td><td>$$8,268</td></tr><tr><td>Obligations of U.S. states and their political subdivisions</td><td>0</td><td>1,375</td><td>0</td><td></td><td>1,375</td></tr><tr><td>Foreign government bonds</td><td>0</td><td>42,007</td><td>47</td><td></td><td>42,054</td></tr><tr><td>Corporate securities</td><td>5</td><td>89,794</td><td>902</td><td></td><td>90,701</td></tr><tr><td>Asset-backed securities</td><td>0</td><td>3,875</td><td>6,363</td><td></td><td>10,238</td></tr><tr><td>Commercial mortgage-backed securities</td><td>0</td><td>10,713</td><td>305</td><td></td><td>11,018</td></tr><tr><td>Residential mortgage-backed securities</td><td>0</td><td>11,467</td><td>104</td><td></td><td>11,571</td></tr><tr><td>Subtotal</td><td>5</td><td>167,499</td><td>7,721</td><td></td><td>175,225</td></tr><tr><td>Trading account assets supporting insurance liabilities:</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>U.S. Treasury securities and obligations of U.S. government authorities and agencies</td><td>0</td><td>128</td><td>0</td><td></td><td>128</td></tr><tr><td>Obligations of U.S. states and their political subdivisions</td><td>0</td><td>31</td><td>0</td><td></td><td>31</td></tr><tr><td>Foreign government bonds</td><td>0</td><td>517</td><td>0</td><td></td><td>517</td></tr><tr><td>Corporate securities</td><td>0</td><td>9,419</td><td>83</td><td></td><td>9,502</td></tr><tr><td>Asset-backed securities</td><td>0</td><td>576</td><td>281</td><td></td><td>857</td></tr><tr><td>Commercial mortgage-backed securities</td><td>0</td><td>1,888</td><td>5</td><td></td><td>1,893</td></tr><tr><td>Residential mortgage-backed securities</td><td>0</td><td>1,412</td><td>20</td><td></td><td>1,432</td></tr><tr><td>Equity securities</td><td>700</td><td>232</td><td>3</td><td></td><td>935</td></tr><tr><td>Short-term investments and cash equivalents</td><td>338</td><td>387</td><td>0</td><td></td><td>725</td></tr><tr><td>Subtotal</td><td>1,038</td><td>14,590</td><td>392</td><td></td><td>16,020</td></tr><tr><td>Other trading account assets:</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>U.S. Treasury securities and obligations of U.S. government authorities and agencies</td><td>0</td><td>95</td><td>0</td><td></td><td>95</td></tr><tr><td>Obligations of U.S. states and their political subdivisions</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Foreign government bonds</td><td>1</td><td>23</td><td>0</td><td></td><td>24</td></tr><tr><td>Corporate securities</td><td>16</td><td>309</td><td>34</td><td></td><td>359</td></tr><tr><td>Asset-backed securities</td><td>0</td><td>894</td><td>97</td><td></td><td>991</td></tr><tr><td>Commercial mortgage-backed securities</td><td>0</td><td>109</td><td>27</td><td></td><td>136</td></tr><tr><td>Residential mortgage-backed securities</td><td>0</td><td>146</td><td>12</td><td></td><td>158</td></tr><tr><td>Equity securities</td><td>311</td><td>136</td><td>24</td><td></td><td>471</td></tr><tr><td>All other</td><td>37</td><td>4,707</td><td>297</td><td>-4,242</td><td>799</td></tr><tr><td>Subtotal</td><td>365</td><td>6,419</td><td>491</td><td>-4,242</td><td>3,033</td></tr><tr><td>Equity securities, available for sale</td><td>3,755</td><td>2,747</td><td>393</td><td></td><td>6,895</td></tr><tr><td>Commercial mortgage and other loans</td><td>0</td><td>114</td><td>338</td><td></td><td>452</td></tr><tr><td>Other long-term investments</td><td>36</td><td>66</td><td>498</td><td></td><td>600</td></tr><tr><td>Short-term investments</td><td>3,561</td><td>2,831</td><td>0</td><td></td><td>6,392</td></tr><tr><td>Cash equivalents</td><td>5,671</td><td>4,468</td><td>0</td><td></td><td>10,139</td></tr><tr><td>Other assets</td><td>2,391</td><td>176</td><td>27</td><td></td><td>2,594</td></tr><tr><td>Subtotal excluding separate account assets</td><td>16,822</td><td>198,910</td><td>9,860</td><td>-4,242</td><td>221,350</td></tr><tr><td>Separate account assets-1</td><td>33,641</td><td>127,381</td><td>13,052</td><td></td><td>174,074</td></tr><tr><td>Total assets</td><td>$50,463</td><td>$326,291</td><td>$22,912</td><td>$-4,242</td><td>$395,424</td></tr><tr><td>Future policy benefits</td><td>$0</td><td>$0</td><td>$55</td><td></td><td>$$55</td></tr><tr><td>Long-term debt</td><td>0</td><td>0</td><td>429</td><td></td><td>429</td></tr><tr><td>Other liabilities</td><td>0</td><td>4,764</td><td>6</td><td>-3,841</td><td>929</td></tr><tr><td>Total liabilities</td><td>$0</td><td>$4,764</td><td>$490</td><td>$-3,841</td><td>$1,413</td></tr></table>

Question: What is the Total assets as of December 31, 2009 for the Level where the Total assets as of December 31, 2009 is the least? (in million)
Answer: 22912