CITIZENS FINANCIAL GROUP, INC.  MANAGEMENT'S DISCUSSION AND ANALYSIS 79 Noninterest income of $1.7 billion in 2014 increased $46 million, or 3%, from $1.6 billion in 2013, driven by a $288 million pre-tax gain on the Chicago Divestiture, which was recorded in other income, and a $38 million increase in capital markets fees, partially offset by a $116 million decrease in net securities gains, an $82 million decrease in mortgage banking fees, and a $66 million decrease in service charges and fees.
Mortgage banking fees reflected overall lower origination volume, the decision to hold more loans on-balance sheet, and were also negatively impacted by a reduction in the recovery of mortgage servicing rights valuations from the prior year.
The decrease in service charges and fees are driven by lower personal overdraft fees resulting from a November 2013 change to our check-posting methodology.
Provision for Credit Losses Provision for credit losses of $319 million in 2014 decreased $160 million from $479 million in 2013, driven by a $178 million reduction in net charge-offs.
Additionally, while overall credit quality continued to improve in 2014, the rate of improvement slowed relative to 2013.
As a result, 2014 provision for credit losses included a release of $4 million from the allowance for credit losses (the amount by which net charge-offs exceeded the provision) compared with a release of $22 million in 2013.
The provision for loan and lease losses is the result of a detailed analysis performed to estimate an appropriate and adequate allowance for loan and lease losses (“ALLL”).
The total provision for credit losses included 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 displays the significant components of our noninterest expense for the periods indicated:
## Table 0 ##
Noninterest expense of $3.4 billion in 2014 decreased $4.3 billion from 2013, which included a $4.4 billion pre-tax goodwill impairment charge.
Our 2014 noninterest expense included $169 million of pre-tax restructuring charges and special items largely related to our separation from RBS Group as well as ongoing efforts to improve processes and enhance efficiencies across the organization compared with $26 million of restructuring charges and special items in 2013.
The 2014 charge included $78 million in outside services, $44 million in salaries and employee benefits, $16 million in occupancy, $6 million in software, $4 million in equipment and $21 million in other operating expense.
Excluding the restructuring charges and special items and the goodwill impairment, noninterest expense remained relatively stable, as the benefit of our efficiency initiatives helped offset investment in the business to drive future earnings growth as well as higher regulatory costs.
See Note 21 “Exit Costs and Restructuring Reserves” to our audited Consolidated Financial Statements in Part II, Item 8 — Financial Statements and Supplementary Data, included elsewhere in this report.
Provision (Benefit) for Income Taxes In 2014, we recorded income tax expense of $403 million, compared to an income tax benefit of $42 million in 2013.
The effective tax rates for the years ended December 31, 2014 and 2013 were 31.8% and 1.2%, respectively.
The increase in the effective rate largely reflected the tax rate impact of the goodwill impairment charge taken in 2013.
Goodwill not deductible for tax purposes accounted for 78.4% of the total goodwill impairment charge and generated a reduction of 35.1% in our effective tax rate for the year ended December 31, 2013.
Additionally, the effective income tax rate will be affected in future periods by the impact of the adoption of Accounting Standard Update No.2014-01, “Accounting for Investments in Qualified Affordable Housing Projects.
” We expect this change in accounting method to increase the 2015 effective income tax rate by approximately 2.4 percentage points; however this is not
Comcast Corporation
## Table 1 ##
(a) The early redemption of these senior notes resulted in $47 million of additional interest expense in 2015.
Debt Instruments Revolving Credit Facilities As of December 31, 2015, Comcast and Comcast Cable Communications, LLC had a $6.25 billion revolving credit facility due June 2017 with a syndicate of banks (“Comcast revolving credit facility”).
The interest rate on this facility consists of a base rate plus a borrowing margin that is determined based on our credit rating.
As of December 31, 2015, the borrowing margin for London Interbank Offered Rate (“LIBOR”) based borrowings was 1.00%.
This revolving credit facility requires that we maintain certain financial ratios based on our debt and our operating income before depreciation and amortization, as defined in the credit facility.
We were in compliance with all financial covenants for all periods presented.
As of December 31, 2015, NBCUniversal Enterprise had a $1.35 billion revolving credit facility due March 2018 with a syndicate of banks (“NBCUniversal Enterprise revolving credit facility”).
The interest rate on this facility consists of a base rate plus a borrowing margin that is determined based on our credit rating.
As of December 31, 2015, the borrowing margin for LIBOR-based borrowings was 1.00%.
As of December 31, 2015, amounts available under our consolidated credit facilities, net of amounts outstanding under our commercial paper programs and outstanding letters of credit, totaled $6.4 billion, which included $775 million available under the NBCUniversal Enterprise revolving credit facility.
Term Loans As a result of the Universal Studios Japan transaction, we consolidated ￥400 billion of term loans having a final maturity of November 2020.
In accordance with acquisition accounting, these debt securities were recorded at fair value as of the acquisition date.
These term loans contain financial and operating covenants and are secured by the assets of Universal Studios Japan and the equity interests of the investors.
We do not guarantee these term loans and they are otherwise nonrecourse to us.
Commercial Paper Programs Our commercial paper programs provide a lower-cost source of borrowing to fund our short-term working capital requirements.
The maximum borrowing capacity under the Comcast commercial paper program is $6.25 billion and it is supported by the Comcast revolving credit facility.
The maximum borrowing capacity under the NBCUniversal Enterprise commercial paper program is $1.35 billion and it is supported by the NBCUniversal Enterprise revolving credit facility.
Letters of Credit As of December 31, 2015, we and certain of our subsidiaries had unused irrevocable standby letters of credit totaling $464 million to cover potential fundings under various agreements.
Management’s discussion and analysis 180 JPMorgan Chase & Co. /2012 Annual Report ?
A 50 basis point deterioration in forecasted credit card loss rates could imply an increase to modeled annualized credit card loan loss estimates of approximately $800 million.  ?
A one-notch downgrade in the Firm’s internal risk ratings for its entire wholesale loan portfolio could imply an increase in the Firm’s modeled loss estimates of approximately $2.1 billion.
The purpose of these sensitivity analyses is to provide an indication of the isolated impacts of hypothetical alternative assumptions on modeled loss estimates.
The changes in the inputs presented above are not intended to imply management’s expectation of future deterioration of those risk factors.
These analyses are not intended to estimate changes in the overall allowance for loan losses, which would also be influenced by the judgment management applies to the modeled loss estimates to reflect the uncertainty and imprecision of these modeled loss estimates based on then current circumstances and conditions.
It is difficult to estimate how potential changes in specific factors might affect the allowance for credit losses because management considers a variety of factors and inputs in estimating the allowance for credit losses.
Changes in these factors and inputs may not occur at the same rate and may not be consistent across all geographies or product types, and changes in factors may be directionally inconsistent, such that improvement in one factor may offset deterioration in other factors.
In addition, it is difficult to predict how changes in specific economic conditions or assumptions could affect borrower behavior or other factors considered by management in estimating the allowance for credit losses.
Given the process the Firm follows in evaluating the risk factors related to its loans, including risk ratings, home price assumptions, and credit card loss estimates, management believes that its current estimate of the allowance for credit loss is appropriate.
Fair value of financial instruments, MSRs and commodities inventory JPMorgan Chase carries a portion of its assets and liabilities at fair value.
The majority of such assets and liabilities are measured at fair value on a recurring basis.
Certain assets and liabilities are measured at fair value on a nonrecurring basis, including certain mortgage, home equity and other loans, where the carrying value is based on the fair value of the underlying collateral.
Assets measured at fair value The following table includes the Firm’s assets measured at fair value and the portion of such assets that are classified within level 3 of the valuation hierarchy.
For further information, see Note 3 on pages 196–214 of this Annual Report.
## Table 2 ##
Valuation Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.
The Firm has an established and welldocumented process for determining fair value, for further details see Note 3 on pages 196–214 of this Annual Report.
Fair value is based on quoted market prices, where available.
If listed prices or quotes are not available for an instrument or a similar instrument, fair value is generally based on models that consider relevant transaction characteristics (such as maturity) and use as inputs marketbased or independently sourced parameters.
Estimating fair value requires the application of judgment.
The type and level of judgment required is largely dependent on the amount of observable market information available to the Firm.
For instruments valued using internally developed models that use significant unobservable inputs and are therefore classified within level 3 of the valuation hierarchy, judgments used to estimate fair value are more significant than those required when estimating the fair value of instruments classified within levels 1 and 2.
In arriving at an estimate of fair value for an instrument within level 3, management must first determine the appropriate model to use.
Second, due to the lack of observability of significant inputs, management must assess all relevant empirical data in deriving valuation inputs — including, for example, transaction details, yield curves, interest rates, prepayment rates, default rates, volatilities, correlations, equity or debt prices, valuations of comparable instruments, foreign exchange rates and credit

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td colspan="2">Year Ended December 31,</td><td></td><td></td></tr><tr><td>(dollars in millions)</td><td>2014</td><td>2013</td><td>Change</td><td>Percent</td></tr><tr><td>Salaries and employee benefits</td><td>$1,678</td><td>$1,652</td><td>$26</td><td>2%</td></tr><tr><td>Outside services</td><td>420</td><td>360</td><td>60</td><td>17</td></tr><tr><td>Occupancy</td><td>326</td><td>327</td><td>-1</td><td>—</td></tr><tr><td>Equipment expense</td><td>250</td><td>275</td><td>-25</td><td>-9</td></tr><tr><td>Amortization of software</td><td>145</td><td>102</td><td>43</td><td>42</td></tr><tr><td>Goodwill impairment</td><td>—</td><td>4,435</td><td>-4,435</td><td>-100</td></tr><tr><td>Other operating expense</td><td>573</td><td>528</td><td>45</td><td>9</td></tr><tr><td>Noninterest expense</td><td>$3,392</td><td>$7,679</td><td>-$4,287</td><td>-56%</td></tr></table>
<table><tr><td>NBCUniversal 3.65% senior notes due 2015</td><td>$1,000</td></tr><tr><td>Comcast 5.90% senior notes due 2016<sup>(a)</sup></td><td>1,000</td></tr><tr><td>Comcast 6.50% senior notes due 2015</td><td>900</td></tr><tr><td>Comcast 5.85% senior notes due 2015<sup>(a)</sup></td><td>750</td></tr><tr><td>Comcast 8.75% senior notes due 2015</td><td>673</td></tr><tr><td>Other</td><td>55</td></tr><tr><td>Total</td><td>$4,378</td></tr></table>
<table><tr><td>December 31, 2012(in billions, except ratio data)</td><td>Total assets at fair value</td><td colspan="2">Total level 3 assets</td></tr><tr><td>Trading debt and equity instruments</td><td>$375.0</td><td>$25.6</td><td></td></tr><tr><td>Derivative receivables</td><td>75.0</td><td>23.3</td><td></td></tr><tr><td>Trading assets</td><td>450.0</td><td>48.9</td><td></td></tr><tr><td>AFS securities</td><td>371.1</td><td>28.9</td><td></td></tr><tr><td>Loans</td><td>2.6</td><td>2.3</td><td></td></tr><tr><td>MSRs</td><td>7.6</td><td>7.6</td><td></td></tr><tr><td>Private equity investments</td><td>7.8</td><td>7.2</td><td></td></tr><tr><td>Other</td><td>43.1</td><td>4.2</td><td></td></tr><tr><td>Total assets measuredat fair value on a recurring basis</td><td>882.2</td><td>99.1</td><td></td></tr><tr><td>Total assets measured at fair value on a nonrecurring basis</td><td>5.1</td><td>4.4</td><td></td></tr><tr><td>Total assets measuredat fair value</td><td>$887.3</td><td>$103.5</td><td><sup>(a)</sup></td></tr><tr><td>Total Firm assets</td><td>$2,359.1</td><td></td><td></td></tr><tr><td>Level 3 assets as a percentage of total Firm assets</td><td></td><td>4.4%</td><td></td></tr><tr><td>Level 3 assets as a percentage of total Firm assets at fair value</td><td></td><td>11.7%</td><td></td></tr></table>

Question: What is the highest total amount of Other operating expense? (in dollars in millions)
Answer: 573