CITIZENS FINANCIAL GROUP, INC.  NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 209 NOTE 18 - RELATED PARTY TRANSACTIONS The Company is an indirect subsidiary of RBSG.
In September 2014, the Company entered into certain agreements with RBS Group that will provide a framework for its ongoing relationship with RBS Group.
Specifically, the Company entered into the following agreements with RBSG or other affiliates of RBS Group: Separation and Shareholder Agreement, Registration Rights Agreement, Trade Mark License Agreement, Amended and Restated Master Services Agreement, and Transitional Services Agreements.
These agreements were filed as exhibits in Part II, Item 6 — Exhibits to the Company's Quarterly Report on Form 10-Q/A filed November 14, 2014.
The following is a summary of inter-company borrowed funds:
## Table 0 ##
Total interest expense recorded on inter-company subordinated debt was $64 million, $16 million and $9 million for the years ended December 31, 2014, 2013 and 2012, respectively.
During the fourth quarter of 2014, the Company purchased a portfolio of performing commercial loans to customers in the oil and gas industry from RBS.
The Company paid $413 million, which was the estimated fair value corroborated by an independent appraiser, as of the purchase dates, to purchase 17 customer relationships with outstanding principal balances of $417 million and unfunded commitments totaling $458 million.
Also related to these loans, the Company entered into offsetting customer derivative contracts with an aggregate notional amount of $946 million, and an aggregate fair value of ($17) thousand on the purchase dates.
The Company maintained a $50 million revolving line of credit at December 31, 2013 with RBS.
This line of credit was not drawn upon at December 31, 2013, expired on January 31, 2014, and was not renewed.
No interest expense was incurred on this revolving line of credit for the year ended December 31, 2013.
The Company enters into interest rate swap agreements with RBS for the purpose of reducing the Company’s exposure to interest rate fluctuations.
As of December 31, 2014, the total notional amount of swaps outstanding was $5.8 billion with fixed rates ranging from 1.66% to 4.30%.
Included in this balance were $4.0 billion of receive-fixed swaps with rates ranging from 1.78% to 2.04% maturing in 2023 and $1.0 billion of pay fixed swaps with fixed rates ranging from 4.18% to 4.30% maturing in 2016.
The company also has a medium term swap agreement with a notional of $750 million and a receive-fixed rate of 1.66% that had been executed as of December 31, 2014.
As of December 31, 2013, the total notional amount of swaps outstanding was $5.5 billion, with fixed rates ranging from 1.78% to 5.47%.
Included in this balance were $1.5 billion of pay-fixed swaps with fixed rates ranging from 4.18% to 5.47% with maturities from 2014 through 2016 and $4.0 billion of receive-fixed swaps with fixed rates ranging from 1.78% to 2.04% maturing in 2023.
The Company recorded net interest expense of $27 million, $146 million, and $311 million for the years ended December 31, 2014, 2013, and 2012, respectively.
The lower pay-fixed swaps expense and higher interest income on the receive-fixed swaps resulted in lower expense in 2014 and 2013 compared to 2012.
In order to meet the financing needs of its customers, the Company enters into interest rate swap and cap agreements with its customers and simultaneously enters into offsetting swap and cap agreements with RBS.
The Company earns a spread equal to the difference between rates charged to the customer and rates charged by RBS.
The notional amount of these interest rate swap and cap agreements outstanding with RBS was $9.8 billion and $13.4 billion at December 31, 2014 and 2013, respectively.
The Company recorded expense of $209 million, $32 million, and $285 million within other income for the years ended December 31, 2014, 2013, and 2012, respectively.
Also to meet the financing needs of its customers, the Company enters into a variety of foreign currency denominated products, such as loans, deposits and foreign exchange contracts.
To manage the foreign exchange risk associated with these products, the Company simultaneously enters into offsetting foreign exchange contracts with RBS.
The Company earns a spread equal to the difference between rates charged to the customer and rates charged by RBS.
The notional amount of foreign exchange contracts outstanding with RBS was $4.7 billion and $4.6 billion at December 31, 2014 and 2013, respectively.
Within foreign exchange and trade finance fees, the Company recorded income of $58 million for the year ended December 31, 2014 and expense of $15 million and $9 million for the years ended December 31, 2013 and 2012, respectively
CITIZENS FINANCIAL GROUP, INC.  MANAGEMENT’S DISCUSSION AND ANALYSIS 43 FINANCIAL PERFORMANCE 2017 compared with 2016 - Key Highlights 2017 net income of $1.7 billion increased 58% from $1.0 billion in 2016, with earnings per diluted common share of $3.25, up 65% from $1.97 per diluted common share for 2016.2017 results include $340 million, or $0.67 per diluted common share, after-tax benefit related to notable items compared with an after-tax benefit of $19 million in 2016 as outlined in the tables below.2017 ROTCE of 12.3% improved from 7.7% in 2016.
* The following table presents selected GAAP and non-GAAP measures:*
## Table 1 ##
After-tax notable items excluded from “Underlying” results reflect a fourth quarter 2017 $10 million gain on a TDR portfolio sale offset by $11 million of other notable items (“TDR Transaction II”) and a $331 million benefit relating to the December 2017 Tax Legislation, partially offset by $13 million of other notable items.
“Underlying” results, as applicable, also exclude a first quarter 2017 $23 million benefit related to the settlement of certain state tax matters and reclassify second quarter 2017 results for the pre-tax impact of $26 million of lease asset impairments to reflect their credit-related impact.
Third quarter 2016 after-tax notable items excluded from our “Adjusted” results reflect a $19 million gain on an TDR portfolio sale less other notable items (“TDR Transaction”).
Where there is a reference to “Adjusted”, “Underlying” and/or “Adjusted/Underlying” results in a paragraph, all measures that follow these references are on the same basis when applicable.
For more information on the computation of key performance metrics and non-GAAP financial measures, see “—Introduction — Key Performance Metrics Used by Management and Non-GAAP Financial Measures” and “—Key Performance Metrics, Non-GAAP Financial Measures and Reconciliations.
”
## Table 2 ##
?2017 results reflected a 59% increase in net income available to common stockholders, which included the impact of the 2017 Tax Legislation and other notable items as well as the 2016 TDR Transaction.  ?
On an Adjusted/Underlying basis,* net income of $1.3 billion increased 28%, earnings per diluted common share of $2.58 was up 34%, and ROTCE of 10% improved by 219 basis points.
Adjusted/Underlying results exclude a net $340 million after-tax benefit related to notable items in 2017 compared with a net $19 million after-tax benefit in 2016.
CITIZENS FINANCIAL GROUP, INC.  NOTES TO CONSOLIDATED FINANCIAL STATEMENTS 170 There are 49,742,766 shares of Company common stock available for awards to be granted under the Omnibus Plan and Directors Plan.
In addition, there are 6,255,128 shares available for awards under the ESPP.
Upon settlement of share-based awards, the Company generally issues new shares, but may also issue shares from treasury stock.
Compensation Expense Citizens measures compensation expense related to stock awards based upon the fair value of the awards on the grant date.
Compensation expense is adjusted for forfeitures as they occur.
The related expense is charged to earnings on a straight-line basis over the requisite service period (e. g. , vesting period) of the award.
With respect to performance-based stock awards, compensation expense is adjusted upward or downward based upon the probability of achievement of performance.
Awards that continue to vest after retirement are expensed over the shorter of the period of time from grant date to the final vesting date or from the grant date to the date when an employee is retirement eligible.
Awards granted to employees who are retirement eligible at the grant date are generally expensed immediately upon grant.
Compensation expense related to the share plans (including the ESPP) was $41 million, $39 million, and $23 million for the years ended December 31, 2018, 2017, and 2016, respectively.
At December 31, 2018, the total unrecognized compensation expense for nonvested equity awards granted was $41 million.
This expense is expected to be recognized over a weighted-average period of two years.
No share-based compensation costs were capitalized during the years ended December 31, 2018, 2017, and 2016.
The income tax benefit recognized in earnings based on the compensation expense recognized for all sharebased compensation arrangements amounted to $3 million, $9 million and $8 million for the years ended December 31, 2018, 2017, and 2016, respectively.
NOTE 18 - COMMITMENTS AND CONTINGENCIES A summary of outstanding off-balance sheet arrangements is presented below:
## Table 3 ##
Commitments to Extend Credit Commitments to extend credit are agreements to lend to customers in accordance with conditions contractually agreed upon in advance.
Generally, the commitments have fixed expiration dates or termination clauses and may require payment of a fee.
Since many of these commitments are expected to expire without being drawn upon, the contract amounts are not necessarily indicative of future cash requirements.
Letters of Credit Letters of credit in the table above reflect commercial, standby financial and standby performance letters of credit.
Standby letters of credit, both financial and performance, are issued by the Company for its customers.
They are used as conditional guarantees of payment to a third party in the event the customer either fails to make specific payments (financial) or fails to complete a specific project (performance).
Commercial letters of credit are used to facilitate the import of goods.
The commercial letter of credit is used as the method of payment to the Company?scustomers?
suppliers.
The Company?sexposure to credit loss in the event of counterparty nonperformance in connection with the above instruments is represented by the contractual amount of those instruments, net of the value of collateral held.
Standby letters of credit and commercial letters of credit are issued for terms of up to ten years and one year, respectively.
Generally, letters of credit are collateralized by cash, accounts receivable, inventory or investment securities.
Credit risk associated with letters of credit is considered in determining the appropriate amounts of reserves for unfunded commitments.
FIDELITY NATIONAL INFORMATION SERVICES, INC.  AND SUBSIDIARIES AND AFFILIATES CONSOLIDATED AND COMBINED FINANCIAL STATEMENTS NOTES TO CONSOLIDATED AND COMBINED FINANCIAL STATEMENTS — (Continued) for the valuation of the 4,199,466 performance-based options granted in 2005: the risk free interest rate was 4.2%, the volatility factor for the expected market price of the common stock was 44%, the expected dividend yield was zero and the objective time to exercise was 4.7 years with an objective in the money assumption of 2.95 years.
It was also expected that the initial public offering assumption would occur within a 9 month period from grant date.
The fair value of the performance-based options was calculated to be $5.85.
The fair value for FIS options granted in 2006 was estimated at the date of grant using a Black-Scholes optionpricing model with the following weighted average assumptions.
The risk free interest rates used in the calculation are the rate that corresponds to the weighted average expected life of an option.
The risk free interest rate used for options granted during 2006 was 4.9%.
A volatility factor for the expected market price of the common stock of 30% was used for options granted in 2006.
The expected dividend yield used for 2006 was 0.5%.
A weighted average expected life of 6.4 years was used for 2006.
The weighted average fair value of each option granted during 2006 was $15.52.
At December 31, 2006, the total unrecognized compensation cost related to non-vested stock option grants is $86.1 million, which is expected to be recognized in pre-tax income over a weighted average period of 1.9 years.
The Company intends to limit dilution caused by option exercises, including anticipated exercises, by repurchasing shares on the open market or in privately negotiated transactions.
During 2006, the Company repurchased 4,261,200 shares at an average price of $37.60.
On October 25, 2006, the Company’s Board of Directors approved a plan authorizing the repurchase of up to an additional $200 million worth of the Company’s common stock.
Defined Benefit Plans Certegy Pension Plan In connection with the Certegy Merger, the Company announced that it will terminate and settle the Certegy U. S.  Retirement Income Plan (USRIP).
The estimated impact of this settlement was reflected in the purchase price allocation as an increase in the pension liability, less the fair value of the pension plan assets, based on estimates of the total cost to settle the liability through the purchase of annuity contracts or lump sum settlements to the beneficiaries.
The final settlement will not occur until after an IRS determination has been obtained, which is expected to be received in 2007.
In addition to the net pension plan obligation of $21.6 million, the Company assumed liabilities of $8.0 million for Certegy’s Supplemental Executive Retirement Plan (“SERP”) and $3.0 million for a Postretirement Benefit Plan.
A reconciliation of the changes in the fair value of plan assets of the USRIP for the period from February 1, 2006 through December 31, 2006 is as follows (in thousands):
## Table 4 ##
Benefits paid in the above table include only those amounts paid directly from plan assets.
As of December 31, 2006 and for 2007 through the pay out of the pension liability, the assets are being invested in U. S.  Treasury bonds due to the short duration until final payment.

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td></td><td></td><td></td><td colspan="2">December 31,</td></tr><tr><td>(dollars in millions)</td><td>Related Party</td><td>Interest Rate</td><td>Maturity Date</td><td>2014</td><td>2013</td></tr><tr><td>Subordinated debt</td><td>RBSG</td><td>4.082%</td><td>January 2025</td><td>$334</td><td>$—</td></tr><tr><td></td><td>RBSG</td><td>4.023%</td><td>October 2024</td><td>333</td><td>—</td></tr><tr><td></td><td>RBSG</td><td>4.153%</td><td>July 2024</td><td>333</td><td>—</td></tr><tr><td></td><td>RBSG</td><td>4.691%</td><td>January 2024</td><td>334</td><td>334</td></tr><tr><td></td><td>RBSG</td><td>4.771%</td><td>October 2023</td><td>333</td><td>333</td></tr><tr><td></td><td>RBS</td><td>5.158%</td><td>June 2023</td><td>333</td><td>333</td></tr></table>
<table><tr><td></td><td colspan="5">Year Ended December 31, 2017</td></tr><tr><td>(in millions)</td><td>Noninterest income</td><td>Noninterest expense</td><td>Credit-related costs</td><td>Income tax expense</td><td>Net Income</td></tr><tr><td>Reported results (GAAP)</td><td>$1,534</td><td>$3,474</td><td>$321</td><td>$260</td><td>$1,652</td></tr><tr><td>Less: Notable items</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>2017 Tax Legislation:</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Tax Legislation DTL adjustment</td><td>—</td><td>—</td><td>—</td><td>-331</td><td>331</td></tr><tr><td>Colleague and community reinvestment</td><td>—</td><td>22</td><td>—</td><td>-9</td><td>-13</td></tr><tr><td>Gain on mortgage/home equity TDR Transaction</td><td>17</td><td>—</td><td>—</td><td>7</td><td>10</td></tr><tr><td>Home equity operational items</td><td>—</td><td>3</td><td>—</td><td>-1</td><td>-2</td></tr><tr><td>TOP IV efficiency initiatives</td><td>—</td><td>15</td><td>—</td><td>-6</td><td>-9</td></tr><tr><td>Settlement of certain tax matters</td><td>—</td><td>—</td><td>—</td><td>-23</td><td>23</td></tr><tr><td>Lease impairment credit-related costs</td><td>-11</td><td>15</td><td>-26</td><td>—</td><td>—</td></tr><tr><td>Total notable items</td><td>$6</td><td>$55</td><td>-$26</td><td>-$363</td><td>$340</td></tr><tr><td>Underlying results (non-GAAP)</td><td>$1,528</td><td>$3,419</td><td>$347</td><td>$623</td><td>$1,312</td></tr></table>
<table><tr><td></td><td colspan="5">Year Ended December 31, 2016</td></tr><tr><td>(in millions)</td><td>Noninterest income</td><td>Noninterest expense</td><td>Credit-related costs</td><td>Income tax expense</td><td>Net Income</td></tr><tr><td>Reported results (GAAP)</td><td>$1,497</td><td>$3,352</td><td>$369</td><td>$489</td><td>$1,045</td></tr><tr><td>Less: notable items</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>Gain on mortgage/home equity TDR Transaction</td><td>72</td><td>—</td><td>—</td><td>27</td><td>45</td></tr><tr><td>Home equity operational items</td><td>—</td><td>8</td><td>—</td><td>-3</td><td>-5</td></tr><tr><td>Asset Finance repositioning</td><td>-5</td><td>11</td><td>—</td><td>-6</td><td>-10</td></tr><tr><td>TOP III efficiency initiatives</td><td>—</td><td>17</td><td>—</td><td>-6</td><td>-11</td></tr><tr><td>Total notable items</td><td>67</td><td>36</td><td>—</td><td>12</td><td>19</td></tr><tr><td>Adjusted results (non-GAAP)</td><td>$1,430</td><td>$3,316</td><td>$369</td><td>$477</td><td>$1,026</td></tr></table>
<table><tr><td></td><td colspan="2">December 31,</td></tr><tr><td>(in millions)</td><td>2018</td><td>2017</td></tr><tr><td>Undrawn commitments to extend credit</td><td>$69,553</td><td>$62,959</td></tr><tr><td>Letters of credit</td><td>2,125</td><td>2,136</td></tr><tr><td>Marketing rights</td><td>37</td><td>41</td></tr><tr><td>Risk participation agreements</td><td>19</td><td>16</td></tr><tr><td>Residential mortgage loans sold with recourse</td><td>5</td><td>7</td></tr><tr><td>Total</td><td>$71,739</td><td>$65,159</td></tr></table>
<table><tr><td></td><td>2006</td></tr><tr><td>Fair value of plan assets at acquisition date</td><td>$57,369</td></tr><tr><td>Actual return on plan assets</td><td>8,200</td></tr><tr><td>Benefits paid</td><td>-797</td></tr><tr><td>Fair value of plan assets at end of year</td><td>$64,772</td></tr></table>

Question: In which section the sum of notable items in non-interest expense has the highest value?
Answer: TOP III efficiency initiatives