CITIZENS FINANCIAL GROUP, INC.  MANAGEMENT?S DISCUSSION AND ANALYSIS 97 which we model net interest income from assets, liabilities and hedge derivative positions under various interest rate scenarios over a three-year horizon.
Exposure to interest rate risk is reflected in the variation of forecasted net interest income across scenarios.
Key assumptions in this simulation analysis relate to the behavior of interest rates and spreads, the changes in product balances and the behavior of loan and deposit clients in different rate environments.
The most material of these behavioral assumptions relate to the repricing characteristics and balance fluctuations of deposits with indeterminate (i. e. , non-contractual) maturities as well as the pace of mortgage prepayments.
Assessments are periodically made by running sensitivity analysis of the impact of key assumptions.
The results of these analyses are reported to the Asset Liability Committee.
As the future path of interest rates cannot be known in advance, we use simulation analysis to project net interest income under various interest rate scenarios including a ?most likely?
(implied forward) scenario as well as a variety of deliberately extreme and perhaps unlikely scenarios.
These scenarios may assume gradual ramping of the overall level of interest rates, immediate shocks to the level of rates and various yield curve twists in which movements in short- or long-term rates predominate.
Generally, projected net interest income in any interest rate scenario is compared to net interest income in a base case where market forward rates are realized.
The table below reports net interest income exposures against a variety of interest rate scenarios.
Our policies involve measuring exposures as a percentage change in net interest income over the next year due to either instantaneous or gradual parallel changes in rates relative to the market implied forward yield curve.
With rates rising from historically low levels due to Federal Open Market Committee rate increases, exposure to falling rates has increased.
As the following table illustrates, our balance sheet is asset-sensitive: net interest income would benefit from an increase in interest rates.
Exposure to a decline in interest rates is within limit.
While an instantaneous and severe shift in interest rates was used in this analysis, we believe that any actual shift in interest rates would likely be more gradual and would therefore have a more modest impact as demonstrated in the following table.
The table below presents the sensitivity of net interest income to various parallel yield curve shifts from the market implied forward yield curve:
## Table 0 ##
Asset sensitivity against a 200 basis point gradual increase in rates was 4.9% at December 31, 2018, a slight decrease from 5.1% at December 31, 2017.
As the FRB continues to normalize rates, given improved economic growth and data, the upward trend in rates has benefited our net interest income and net interest margin as a result of this asset sensitivity.
The risk position can be affected by changes in interest rates which impact the repricing sensitivity or beta of the deposit base as well as the cash flows on prepayable assets.
The risk position is managed within our risk limits, and long term view of interest rates, through occasional adjustments to securities investments, interest rate swaps and mix of funding.
We use a valuation measure of exposure to structural interest rate risk, Economic Value of Equity (?EVE?
), as a supplement to net interest income simulations.
EVE complements net interest income simulation analysis as it estimates risk exposure over a long-term horizon.
EVE measures the extent to which the economic value of assets, liabilities and off-balance sheet instruments may change in response to fluctuations in interest rates.
This analysis is highly dependent upon assumptions applied to assets and liabilities with non-contractual maturities.
The change in value is expressed as a percentage of regulatory capital.
CITIZENS FINANCIAL GROUP, INC.  BUSINESS 6 products nationwide.
Consumer Banking operates a multi-channel distribution network with a workforce of approximately 6,200 branch colleagues, approximately 1,100 branches, including about 310 in-store locations, and approximately 2,900 ATMs.
Our network includes approximately 1,320 specialists covering lending, savings and investment needs as well as a broad range of small business products and services.
We serve customers on a national basis through telephone service centers as well as through our online and mobile platforms where we offer customers the convenience of depositing funds, paying bills and transferring money between accounts and from person to person, as well as a host of other everyday transactions.
We believe our strong retail deposit market share in our core regions, which have relatively diverse economies and affluent demographics, is a competitive advantage.
As of June 30, 2018, we ranked second by retail deposit market share in the New England region and ranked in the top five in nine of our ten principal MSAs.
(1) The following table presents information regarding our competitive position in our principal MSAs:
## Table 1 ##
Source: FDIC, June 2018.
Principal MSAs determined by total retail branch count.
Deposits capped at $500 million per branch.
Excludes ?non-retail banks?
as defined by SNL Financial.
The scope of ?non-retail banks?
is subject to the discretion of SNL Financial, but typically includes: industrial bank and non-depository trust charters, institutions with more than 20% brokered deposits (of total deposits), institutions with more than 20% credit card loans (of total loans), institutions deemed not to broadly participate in the banking services market and other nonretail competitor banks.
Commercial Banking Segment Commercial Banking primarily serves companies and institutions with annual revenues of over $25 million to more than $3.0 billion and strives to be our clients?
trusted advisor and preferred provider for their banking needs.
We offer a broad complement of financial products and solutions, including lending and leasing, deposit and treasury management services, foreign exchange and interest rate risk management solutions, as well as corporate finance, merger and acquisition, and debt and equity capital markets capabilities.
Commercial Banking is structured along business lines and product groups.
The business lines, Corporate Banking and Commercial Real Estate, and the product groups, Treasury Solutions and Corporate Finance & Capital Markets, work in teams to understand client needs and provide comprehensive solutions to meet those needs.
We acquire new clients through a coordinated approach to the market, leveraging deep industry knowledge in specialized banking groups and a geographic coverage model.
Our Corporate Banking business line services middle market domestic commercial and industrial clients with annual gross revenues of $25 million to $500 million, and mid-corporate clients with annual revenues of $500 million to more than $3.0 billion.
In several areas, such as Healthcare, Technology, and Franchise Finance, we offer a more dedicated and tailored approach to better meet the unique needs of these client segments.
Smaller commercial clients, with an affinity for local bank branch support, cluster around our 11 state footprint.
Larger clients seeking more specialty financial services expertise are covered nationally.
Corporate Banking is a general lending business which offers a broad range of products, including secured and unsecured lines of credit, term loans, commercial mortgages, domestic and global treasury management solutions, trade services, interest rate products, foreign exchange services and letters of credit.
(1) According to SNL Financial.
CITIZENS FINANCIAL GROUP, INC.  MANAGEMENT?S DISCUSSION AND ANALYSIS 50 Noninterest Income The following table presents the significant components of our noninterest income:
## Table 2 ##
(1) Includes net securities impairment losses on debt securities available for sale recognized in earnings, bank-owned life insurance income and other income.
(2) 2018 noninterest income amounts reflect the adoption of ASU 2014-09, Revenue From Contracts With Customers (Topic 606).
Noninterest income of $1.6 billion in 2018, increased $62 million, or 4%, compared to $1.5 billion in 2017, driven by strength in mortgage banking fees, reflecting the $57 million impact of FAMC, as well as foreign exchange and interest rate products, trust and investment services fees, card fees and letter of credit and loan fees, partially offset by lower capital market fees and service charges and fees.
Excluding the impact of notable items and 2017 aircraft finance lease impairments, Underlying noninterest income* for the year ended 2018 increased $73 million, or 5%.
Provision for Credit Losses Provision for credit losses of $326 million increased $5 million, or 2%, from $321 million in 2017, which reflected moderately lower reserve growth and partially offset slightly higher net charge-offs.
Full year 2018 results reflected a $9 million reserve build, compared to a $16 million reserve build in 2017.
Net charge-offs in 2018 of $317 million were $12 million higher compared to 2017.
On an Underlying basis,* total credit-related costs decreased $21 million, primarily due to the impact of 2017 aircraft lease impairments.
The provision for loan and lease losses is the result of a detailed analysis performed to estimate an appropriate and adequate ALLL.
The total provision for credit losses includes the provision for loan and lease losses as well as the provision for unfunded commitments.
Refer to ?
?Analysis of Financial Condition ?
Allowance for Credit Losses and Nonperforming Assets?
for more information.
Noninterest Expense The following table presents the significant components of our noninterest expense:
## Table 3 ##
(1) Salaries and employee benefits and other operating expense amounts reflect the impact of the adoption of ASU 2017-07, Compensation ?
Retirement Benefits (Topic 715): Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost.
Noninterest expense of $3.6 billion in 2018 increased $145 million, or 4%, compared to 2017, reflecting higher salaries and employee benefits driven by higher revenue-based incentives and merit increases, as well as higher outside services expense, including continued investments to drive growth.
Full year 2018 results also reflected
CITIZENS FINANCIAL GROUP, INC.  MANAGEMENT?S DISCUSSION AND ANALYSIS 74 For commercial loans and leases, we utilize regulatory classification ratings to monitor credit quality.
Loans with a ?pass?
rating are those that we believe will be fully repaid in accordance with the contractual loan terms.
Commercial loans and leases that are ?criticized?
are those that have some weakness or potential weakness that indicate an increased probability of future loss.
?Criticized?
loans are grouped into three categories, ?special mention,?
?substandard?
and ?doubtful. ?
Special mention loans have potential weaknesses that, if left uncorrected, may result in deterioration of our credit position at some future date.
Substandard loans are inadequately protected loans; these loans have well-defined weaknesses that could hinder normal repayment or collection of the debt.
Doubtful loans have the same weaknesses as substandard, with the added characteristics that the possibility of loss is high and collection of the full amount of the loan is improbable.
These credit quality indicators for commercial loans are continually updated and monitored.
See Note 5 ?Allowance for Credit Losses, Nonperforming Assets, and Concentrations of Credit Risk?
to our Consolidated Financial Statements in Part II, Item 8 ?
Financial Statements and Supplementary Data, of this Report.
Nonperforming commercial loans and leases decreased $64 million to $201 million as of December 31, 2018 from $265 million as of December 31, 2017, largely tied to a reduction in nonperforming commodities-related credits.
As of December 31, 2018, total commercial nonperforming loans were 0.4% of the commercial loan portfolio compared to 0.5% as of December 31, 2017.
Total 2018 commercial loan and lease portfolio net charge-offs of $33 million remained stable with $35 million in 2017.
The recorded investment in commercial loans and leases based on regulatory classification ratings is presented below:
## Table 4 ##
December 31, 2017
## Table 5 ##
Total commercial criticized loans and leases of $2.8 billion as of December 31, 2018 were stable compared with December 31, 2017.
Commercial criticized loans and leases over total commercial loans and leases of 5.0% at December 31, 2018 improved from 5.4% at December 31, 2017, driven by loan growth.
Commercial criticized balances of $2.3 billion, or 5.5% of the commercial loan portfolio as of December 31, 2018, increased from $2.1 billion, or 5.7%, as of December 31, 2017.
Commercial real estate criticized balances of $500 million, or 3.8% of the commercial real estate portfolio, decreased from $602 million, or 5.3%, as of December 31, 2017.
Commercial criticized loans represented 80% of total criticized loans as of December 31, 2018 compared to 75% as of December 31, 2017.
Commercial real estate accounted for 18% of total criticized loans as of December 31, 2018 compared to 21% as of December 31, 2017.
Retail Loan Asset Quality For retail loans, we primarily utilize payment and delinquency status to regularly review and monitor credit quality trends.
Historical experience indicates that the longer a loan is past due, the greater the likelihood of future credit loss.
The largest portion of the retail portfolio is represented by borrowers located in the New England, MidAtlantic and Midwest regions, although we have continued to grow selectively in areas outside the footprint primarily in the auto finance, education lending and unsecured portfolios.
were issued in an initial aggregate principal amount of $500 million at a 2.25% fixed, annual interest rate and will mature on May 1, 2023.
The 2043 senior notes were issued in an initial aggregate principal amount of $500 million at a 3.625% fixed, annual interest rate and will mature on May 1, 2043.
Interest on the senior notes is payable semi-annually on May 1 and November 1 of each year.
The issuance resulted in gross proceeds before expenses of $998 million.
On November 1, 2011, we entered into a committed credit facility agreement with a syndicate of banks which provides for up to $1 billion of borrowings with the option to increase borrowings to $1.5 billion with lender approval.
The facility matures November 1, 2017.
As of and for the periods ended May 31, 2015 and 2014, we had no amounts outstanding under our committed credit facility.
We currently have long-term debt ratings of AA- and A1 from Standard and Poor’s Corporation and Moody’s Investor Services, respectively.
If our longterm debt ratings were to decline, the facility fee and interest rate under our committed credit facility would increase.
Conversely, if our long-term debt rating were to improve, the facility fee and interest rate would decrease.
Changes in our long-term debt rating would not trigger acceleration of maturity of any then-outstanding borrowings or any future borrowings under the committed credit facility.
Under this committed revolving credit facility, we have agreed to various covenants.
These covenants include limits on our disposal of fixed assets, the amount of debt secured by liens we may incur, as well as a minimum capitalization ratio.
In the event we were to have any borrowings outstanding under this facility and failed to meet any covenant, and were unable to obtain a waiver from a majority of the banks in the syndicate, any borrowings would become immediately due and payable.
As of May 31, 2015, we were in full compliance with each of these covenants and believe it is unlikely we will fail to meet any of these covenants in the foreseeable future.
Liquidity is also provided by our $1 billion commercial paper program.
During the year ended May 31, 2015, we did not issue commercial paper, and as of May 31, 2015, there were no outstanding borrowings under this program.
We may issue commercial paper or other debt securities during fiscal 2016 depending on general corporate needs.
We currently have short-term debt ratings of A1+ and P1 from Standard and Poor’s Corporation and Moody’s Investor Services, respectively.
As of May 31, 2015, we had cash, cash equivalents and short-term investments totaling $5.9 billion, of which $4.2 billion was held by our foreign subsidiaries.
Included in Cash and equivalents as of May 31, 2015 was $968 million of cash collateral received from counterparties as a result of hedging activity.
Cash equivalents and Short-term investments consist primarily of deposits held at major banks, money market funds, commercial paper, corporate notes, U. S.  Treasury obligations, U. S.  government sponsored enterprise obligations and other investment grade fixed income securities.
Our fixed income investments are exposed to both credit and interest rate risk.
All of our investments are investment grade to minimize our credit risk.
While individual securities have varying durations, as of May 31, 2015 the weighted average remaining duration of our short-term investments and cash equivalents portfolio was 79 days.
To date we have not experienced difficulty accessing the credit markets or incurred higher interest costs.
Future volatility in the capital markets, however, may increase costs associated with issuing commercial paper or other debt instruments or affect our ability to access those markets.
We believe that existing cash, cash equivalents, short-term investments and cash generated by operations, together with access to external sources of funds as described above, will be sufficient to meet our domestic and foreign capital needs in the foreseeable future.
We utilize a variety of tax planning and financing strategies to manage our worldwide cash and deploy funds to locations where they are needed.
We routinely repatriate a portion of our foreign earnings for which U. S.  taxes have previously been provided.
We also indefinitely reinvest a significant portion of our foreign earnings, and our current plans do not demonstrate a need to repatriate these earnings.
Should we require additional capital in the United States, we may elect to repatriate indefinitely reinvested foreign funds or raise capital in the United States through debt.
If we were to repatriate indefinitely reinvested foreign funds, we would be required to accrue and pay additional U. S.  taxes less applicable foreign tax credits.
If we elect to raise capital in the United States through debt, we would incur additional interest expense.
Off-Balance Sheet Arrangements In connection with various contracts and agreements, we routinely provide indemnification relating to the enforceability of intellectual property rights, coverage for legal issues that arise and other items where we are acting as the guarantor.
Currently, we have several such agreements in place.
However, based on our historical experience and the estimated probability of future loss, we have determined that the fair value of such indemnification is not material to our financial position or results of operations.
Contractual Obligations Our significant long-term contractual obligations as of May 31, 2015 and significant endorsement contracts, including related marketing commitments, entered into through the date of this report are as follows:

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td colspan="2">Estimated % Change inNet Interest Income over 12 Months December 31,</td></tr><tr><td>Basis points</td><td>2018</td><td>2017</td></tr><tr><td>Instantaneous Change in Interest Rates</td><td></td><td></td></tr><tr><td>+200</td><td>9.5%</td><td>9.6%</td></tr><tr><td>+100</td><td>4.8</td><td>4.9</td></tr><tr><td>-100</td><td>-4.5</td><td>-5.9</td></tr><tr><td>Gradual Change in Interest Rates</td><td></td><td></td></tr><tr><td>+200</td><td>4.9</td><td>5.1</td></tr><tr><td>+100</td><td>2.5</td><td>2.7</td></tr><tr><td>-100</td><td>-1.1</td><td>-1.8</td></tr></table>
<table><tr><td>(dollars in billions)</td><td></td><td rowspan="2">Total Deposits</td><td rowspan="2">Total Deposit Rank</td><td rowspan="2">Deposit Market Share</td></tr><tr><td>MSA</td><td>Total Branches</td></tr><tr><td>Boston, MA</td><td>202</td><td>$22.1</td><td>2</td><td>14.0%</td></tr><tr><td>Philadelphia, PA</td><td>171</td><td>15.0</td><td>4</td><td>11.0</td></tr><tr><td>Pittsburgh, PA</td><td>118</td><td>8.7</td><td>2</td><td>16.2</td></tr><tr><td>Providence, RI</td><td>93</td><td>8.6</td><td>1</td><td>26.0</td></tr><tr><td>Detroit, MI</td><td>81</td><td>5.5</td><td>6</td><td>7.0</td></tr><tr><td>Cleveland, OH</td><td>51</td><td>3.9</td><td>4</td><td>10.1</td></tr><tr><td>Manchester, NH</td><td>20</td><td>2.5</td><td>1</td><td>30.2</td></tr><tr><td>Buffalo, NY</td><td>41</td><td>1.9</td><td>4</td><td>8.9</td></tr><tr><td>Albany, NY</td><td>22</td><td>1.9</td><td>3</td><td>12.3</td></tr><tr><td>Rochester, NY</td><td>25</td><td>1.7</td><td>5</td><td>9.6</td></tr></table>
<table><tr><td></td><td colspan="2">Year Ended December 31,</td><td></td><td></td></tr><tr><td>(in millions)</td><td>2018</td><td>2017</td><td>Change</td><td>Percent</td></tr><tr><td>Service charges and fees</td><td>$513</td><td>$516</td><td>-$3</td><td>-1%</td></tr><tr><td>Card fees</td><td>244</td><td>233</td><td>11</td><td>5</td></tr><tr><td>Capital markets fees</td><td>179</td><td>194</td><td>-15</td><td>-8</td></tr><tr><td>Trust and investment services fees</td><td>171</td><td>158</td><td>13</td><td>8</td></tr><tr><td>Mortgage banking fees</td><td>152</td><td>108</td><td>44</td><td>41</td></tr><tr><td>Letter of credit and loan fees</td><td>128</td><td>121</td><td>7</td><td>6</td></tr><tr><td>Foreign exchange and interest rate products</td><td>126</td><td>109</td><td>17</td><td>16</td></tr><tr><td>Securities gains, net</td><td>19</td><td>11</td><td>8</td><td>73</td></tr><tr><td>Other income<sup>-1</sup></td><td>64</td><td>84</td><td>-20</td><td>-24</td></tr><tr><td>Noninterest income<sup>-2</sup></td><td>$1,596</td><td>$1,534</td><td>$62</td><td>4%</td></tr></table>
<table><tr><td></td><td colspan="2">Year Ended December 31,</td><td></td><td></td></tr><tr><td>(in millions)</td><td>2018</td><td>2017</td><td>Change</td><td>Percent</td></tr><tr><td>Salaries and employee benefits<sup>-1</sup></td><td>$1,880</td><td>$1,766</td><td>$114</td><td>6%</td></tr><tr><td>Outside services</td><td>447</td><td>404</td><td>43</td><td>11</td></tr><tr><td>Occupancy</td><td>333</td><td>319</td><td>14</td><td>4</td></tr><tr><td>Equipment expense</td><td>275</td><td>263</td><td>12</td><td>5</td></tr><tr><td>Amortization of software</td><td>189</td><td>180</td><td>9</td><td>5</td></tr><tr><td>Other operating expense<sup>-1</sup></td><td>495</td><td>542</td><td>-47</td><td>-9</td></tr><tr><td>Noninterest expense</td><td>$3,619</td><td>$3,474</td><td>$145</td><td>4%</td></tr></table>
<table><tr><td></td><td colspan="5">December 31, 2018</td></tr><tr><td></td><td></td><td colspan="3">Criticized</td><td></td></tr><tr><td>(in millions)</td><td>Pass</td><td>Special Mention</td><td>Substandard</td><td>Doubtful</td><td>Total</td></tr><tr><td>Commercial</td><td>$38,600</td><td>$1,231</td><td>$828</td><td>$198</td><td>$40,857</td></tr><tr><td>Commercial real estate</td><td>12,523</td><td>412</td><td>82</td><td>6</td><td>13,023</td></tr><tr><td>Leases</td><td>2,823</td><td>39</td><td>41</td><td>—</td><td>2,903</td></tr><tr><td>Total commercial loans and leases</td><td>$53,946</td><td>$1,682</td><td>$951</td><td>$204</td><td>$56,783</td></tr></table>
<table><tr><td></td><td colspan="5">December 31, 2017</td></tr><tr><td></td><td></td><td colspan="3">Criticized</td><td></td></tr><tr><td>(in millions)</td><td>Pass</td><td>Special Mention</td><td>Substandard</td><td>Doubtful</td><td>Total</td></tr><tr><td>Commercial</td><td>$35,430</td><td>$1,143</td><td>$785</td><td>$204</td><td>$37,562</td></tr><tr><td>Commercial real estate</td><td>10,706</td><td>500</td><td>74</td><td>28</td><td>11,308</td></tr><tr><td>Leases</td><td>3,069</td><td>73</td><td>19</td><td>—</td><td>3,161</td></tr><tr><td>Total commercial loans and leases</td><td>$49,205</td><td>$1,716</td><td>$878</td><td>$232</td><td>$52,031</td></tr></table>

Question: What is the growing rate of Outside services in the year with the most Salaries and employee benefits?
Answer: 0.10644
Reasoning program: subtract(447,404), divide(#0,404)