Credit Commitments and Lines of Credit The table below summarizes Citigroup’s credit commitments as of December 31, 2010 and December31, 2009:
## Table 0 ##
The majority of unused commitments are contingent upon customers maintaining specific credit standards.
Commercial commitments generally have floating interest rates and fixed expiration dates and may require payment of fees.
Such fees (net of certain direct costs) are deferred and, upon exercise of the commitment, amortized over the life of the loan or, if exercise is deemed remote, amortized over the commitment period.
Commercial and similar letters of credit A commercial letter of credit is an instrument by which Citigroup substitutes its credit for that of a customer to enable the customer to finance the purchase of goods or to incur other commitments.
Citigroup issues a letter on behalf of its client to a supplier and agrees to pay the supplier upon presentation of documentary evidence that the supplier has performed in accordance with the terms of the letter of credit.
When a letter of credit is drawn, the customer is then required to reimburse Citigroup.
One- to four-family residential mortgages A one- to four-family residential mortgage commitment is a written confirmation from Citigroup to a seller of a property that the bank will advance the specified sums enabling the buyer to complete the purchase.
Revolving open-end loans secured by one- to four-family residential properties Revolving open-end loans secured by one- to four-family residential properties are essentially home equity lines of credit.
A home equity line of credit is a loan secured by a primary residence or second home to the extent of the excess of fair market value over the debt outstanding for the first mortgage.
Commercial real estate, construction and land development Commercial real estate, construction and land development include unused portions of commitments to extend credit for the purpose of financing commercial and multifamily residential properties as well as land development projects.
Both secured-by-real-estate and unsecured commitments are included in this line, as well as undistributed loan proceeds, where there is an obligation to advance for construction progress payments.
However, this line only includes those extensions of credit that, once funded, will be classified as Loans on the Consolidated Balance Sheet.
Credit card lines Citigroup provides credit to customers by issuing credit cards.
The credit card lines are unconditionally cancelable by the issuer.
Commercial and other Consumer loan commitments Commercial and other Consumer loan commitments include overdraft and liquidity facilities, as well as commercial commitments to make or purchase loans, to purchase third-party receivables, to provide note issuance or revolving underwriting facilities and to invest in the form of equity.
Amounts include $79billion and $126billion with an original maturity of less than one year at December 31, 2010 and December31, 2009, respectively.
In addition, included in this line item are highly leveraged financing commitments, which are agreements that provide funding to a borrower with higher levels of debt (measured by the ratio of debt capital to equity capital of the borrower) than is generally considered normal for other companies.
This type of financing is commonly employed in corporate acquisitions, management buy-outs and similar transactions.
Non-Accrual Loans and Assets The table below summarizes Citigroup’s view of non-accrual loans as of the periods indicated.
Non-accrual loans are loans in which the borrower has fallen behind in interest payments or, for Corporate and Consumer (commercial market) loans, where Citi has determined that the payment of interest or principal is doubtful, and which are thus considered impaired.
In situations where Citi reasonably expects that only a portion of the principal and interest owed will ultimately be collected, all payments received are reflected as a reduction of principal and not as interest income.
There is no industry-wide definition of non-accrual assets, however, and as such, analysis across the industry is not always comparable.
Corporate and Consumer (commercial markets) non-accrual loans may still be current on interest payments but are considered non-accrual if Citi has determined that the payment of interest or principal is doubtful.
As referenced above, consistent with industry standards, Citi generally accrues interest on credit card loans until such loans are charged-off, which typically occurs at 180 days contractual delinquency.
As such, credit card loans are not included in the tablebelow.
## Table 1 ##
(1) Excludes purchased distressed loans as they are generally accreting interest.
The carrying value of these loans was $469 million at December 31, 2010, $920 million at December 31, 2009, $1.510 billion at December 31, 2008, $2.373 billion at December 31, 2007, and $949 million at December 31, 2006.
Statement continues on the next page
Upon conversion of the 2019 Notes and 2021 Notes, the Company will pay or deliver, as the case may be, cash, shares of its common stock or a combination of cash and shares of its common stock, at the Company’s election.
If the Company satisfies its conversion obligation solely in cash or through payment and delivery, as the case may be, of a combination of cash and shares of its common stock, the amount of cash and shares of common stock, if any, due upon conversion will be based on a daily conversion value (as described herein) calculated on a proportionate basis for each trading day in a 30 trading day observation period.
If a fundamental change (as defined in the relevant indenture governing the applicable series of Notes) occurs prior to the maturity date, holders of the 2019 Notes and 2021 Notes may require the Company to repurchase all or a portion of their notes for cash at a repurchase price equal to 100% of the principal amount of the notes, plus any accrued and unpaid interest to, but excluding, the repurchase date.
In addition, if specific corporate events occur prior to the applicable maturity date, the Company will be required to increase the conversion rate for holders who elect to convert their notes in certain circumstances.
In accordance with accounting guidance on embedded conversion features, the Company valued and bifurcated the conversion option associated with the 2019 Notes and 2021 Notes from the respective host debt instrument, which is referred to as debt discount, and initially recorded the conversion option of $222.8 million for the 2019 Notes and $283.3 million for the 2021 Notes in stockholders’ equity.
The resulting debt discounts on the 2019 Notes and 2021 Notes are being amortized to interest expense at an effective interest rate of 5.75% and 6.25%, respectively, over the contractual terms of the notes.
The Company allocated $0.1 million of debt issuance costs to the equity component, and the remaining debt issuance costs of $0.4 million are being amortized to interest expense.
During the year ended December 31, 2014, the Company recognized $18.8 million of interest expense related to the amortization of the debt discount.
This interest expense is recorded in interest income (expense), net in the consolidated statements of operations.
As of December 31, 2014, the net carrying value, net of the initial purchasers’ discount and debt discount, of 2019 Notes and 2021 Notes was $709.9 million and $666.1 million, respectively.
The Notes consisted of the following (in thousands):
## Table 2 ##
(1) Included in the consolidated balance sheets within convertible notes and amortized over the remaining lives of the Notes.
(2) Included in the consolidated balance sheets within additional paid-in capital.
As of December 31, 2014, the remaining life of the 2019 Notes and 2021 Notes is approximately 56 months and 80 months, respectively.
Concurrently with the offering of these notes in September and October 2014, the Company entered into convertible note hedge transactions with certain bank counterparties whereby the Company has the option to purchase initially (subject to adjustment for certain specified events) a total of approximately 24.3 million shares of its common stock at a price of approximately $77.64 per share.
The total cost of the convertible note hedge transactions was $407.2 million.
In addition, the Company sold warrants to certain bank counterparties whereby the holders of the warrants have the option to purchase initially (subject to adjustment for certain specified events) a total of approximately 24.3 million shares of the Company’s common stock at a price of $105.28.
The Company received $289.3 million in cash proceeds from the sale of these warrants.
(A) Excludes discontinued operations.
(B) Earnings before interest expense and taxes as a percent of average total assets.
(C) Total debt as a percent of the sum of total debt, shareholders’ equity and non-current deferred income tax liabilities.
The results above include the impact of the specified items detailed below.
Additional discussion regarding the specified items in fiscal years 2017, 2016 and 2015 are provided in Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operations.
## Table 3 ##
Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operations The following commentary should be read in conjunction with the consolidated financial statements and accompanying notes.
Within the tables presented throughout this discussion, certain columns may not add due to the use of rounded numbers for disclosure purposes.
Percentages and earnings per share amounts presented are calculated from the underlying amounts.
References to years throughout this discussion relate to our fiscal years, which end on September 30.
Company Overview Description of the Company and Business Segments Becton, Dickinson and Company (“BD”) is a global medical technology company engaged in the development, manufacture and sale of a broad range of medical supplies, devices, laboratory equipment and diagnostic products used by healthcare institutions, life science researchers, clinical laboratories, the pharmaceutical industry and the general public.
The Company's organizational structure is based upon two principal business segments, BD Medical (“Medical”) and BD Life Sciences (“Life Sciences”).
BD’s products are manufactured and sold worldwide.
Our products are marketed in the United States and internationally through independent distribution channels and directly to end-users by BD and independent sales representatives.
We organize our operations outside the United States as follows: Europe; EMA (which includes the Commonwealth of Independent States, the Middle East and Africa); Greater Asia (which includes Japan and Asia Pacific); Latin America (which includes Mexico, Central America, the Caribbean, and South America); and Canada.
We continue to pursue growth opportunities in emerging markets, which include the following geographic regions: Eastern Europe, the Middle East, Africa, Latin America and certain countries within Asia Pacific.
We are primarily focused on certain countries whose healthcare systems are expanding, in particular, China and India.
Strategic Objectives BD remains focused on delivering sustainable growth and shareholder value, while making appropriate investments for the future.
BD management operates the business consistent with the following core strategies: ?
To increase revenue growth by focusing on our core products, services and solutions that deliver greater benefits to patients, healthcare workers and researchers;
PRUDENTIAL FINANCIAL, INC.  Notes to Consolidated Financial Statements 3.
ACQUISITIONS AND DISPOSITIONS Acquisition of AIG Star Life Insurance Co. , Ltd. , AIG Edison Life Insurance Company and Related Entities from AIG On February 1, 2011, Prudential Financial completed the acquisition from American International Group, Inc.  (“AIG”) of AIG Star Life Insurance Co. , Ltd. , AIG Edison Life Insurance Company, AIG Financial Assurance Japan K. K. , and AIG Edison Service Co, Ltd. , pursuant to the stock purchase agreement dated September 30, 2010 between Prudential Financial and AIG.
The total purchase price was approximately $4.8 billion, comprised of approximately $4.2 billion in cash and $0.6 billion in assumed third party debt, substantially all of which is expected to be repaid, over time, with excess capital of the acquired entities.
All acquired entities are Japanese corporations and their businesses are in Japan.
Prudential Financial intends to make a Section 338 election under the Internal Revenue Code with respect to the acquisition resulting in the acquired entities to be treated for U. S.  tax purposes as newly-incorporated companies.
Sale of investment in Wachovia Securities On December 31, 2009 the Company completed the sale of its minority joint venture interest in Wachovia Securities.
See Note 7 for more details on this transaction.
Acquisition of Yamato Life On May 1, 2009, the Company’s Gibraltar Life operations acquired Yamato Life, a Japanese life insurance company that declared bankruptcy in October 2008.
Gibraltar Life served as the reorganization sponsor for Yamato and under the reorganization agreement acquired Yamato by contributing $72 million of capital to Yamato.
At the date of acquisition the Company recognized $2.3 billion of assets and $2.3 billion of liabilities related to Yamato.
Subsequent to the acquisition, the Company renamed the acquired company The Prudential Gibraltar Financial Life Insurance Company, Ltd.  Acquisition of Hyundai Investment and Securities Co. , Ltd.
In 2004, the Company acquired an 80 percent interest in Hyundai Investment and Securities Co. , Ltd. , a Korean asset management firm, from an agency of the Korean government.
On January 25, 2008, the Company acquired the remaining 20 percent for $90 million.
In February 2010, the Company signed a definitive agreement to sell Prudential Investment & Securities Co. , Ltd.  and Prudential Asset Management Co. , Ltd, which together comprise its Korean asset management operations.
This transaction closed on June 1, 2010 and the results of these operations are now reflected in discontinued operations.
See below for a further discussion of the sale of these operations.
Additional Investment in UBI Pramerica On January 18, 2008, the Company made an additional investment of $154 million in its UBI Pramerica operating joint venture in Italy, which is accounted for under the equity method.
This additional investment was necessary to maintain the Company’s ownership interest at 35 percent and was a result of the merger of the Company’s joint venture partner with another Italian bank, and their subsequent consolidation of their asset management companies into the UBI Pramerica joint venture.
Discontinued Operations Income (loss) from discontinued businesses, including charges upon disposition, for the years ended December 31, are as follows:
## Table 4 ##
The Company’s Consolidated Statements of Financial Position include total assets and total liabilities related to discontinued businesses of $79 million and $89 million, respectively, at December 31, 2010 and $937 million and $556 million, respectively, at December 31, 2009.
(1) In the first quarter of 2010, the Company signed a definitive agreement to sell Prudential Investment & Securities Co.  Ltd.  and Prudential Asset Management Co.  Ltd. , which together comprise the Company’s Korean asset management operations.
This transaction closed in
(1) Variable annuities include only those sold as retail investment products.
Investments sold through defined contribution plan products are included with such products within the Retirement segment.
(2) Includes cumulative reclassifications of $267 million in 2010 and $259 million in 2009 from variable annuity to fixed annuity account values to conform presentation of certain contracts in annuitization status to current reporting practices.
(3) As of December 31, 2010, variable annuity account values are invested in equity funds ($56 billion or 55%), bond funds ($29 billion or 28%), market value adjusted or fixed-rate accounts ($9 billion or 9%), and other ($8 billion or 8%).2010 to 2009 Annual Comparison Total account values for fixed and variable annuities amounted to $106.2 billion as of December 31, 2010, representing an increase of $22.2 billion from December 31, 2009.
The increase was driven by positive variable annuity net flows and increases in the market value of customers’ variable annuities due to favorable equity markets for 2010.
Individual variable annuity gross sales momentum continued in 2010 as sales increased by $5.5 billion, from $16.1 billion in 2009 to $21.6 billion in 2010.
The increase reflects our product strength, customer value proposition, and position as the primary provider of living benefit guarantees based on highest daily customer account value as well as the further expansion of our distribution networks.
Additionally, we have benefited from some of our competitors implementing product modifications to increase pricing and scale back product features due to market disruptions in late 2008 and the first half of 2009.
Although we have implemented similar modifications, we believe that our product offerings have remained competitively positioned and expect our living benefit features will provide us an attractive risk and profitability profile, as all of our currently-offered optional living benefit features include the automatic rebalancing element described below.
Individual variable annuity surrenders and withdrawals increased by $1.1 billion, from $5.8 billion in 2009 to $6.9 billion in 2010, reflecting the overall impact of higher account values in the current year due to market appreciation over the past twelve months.2009 to 2008 Annual Comparison Total account values for fixed and variable annuities amounted to $84.0 billion as of December 31, 2009, an increase of $20.7 billion from December 31, 2008.
The increase came primarily from increases in the market value of customers’ variable annuities due to equity market appreciation and from positive variable annuity net flows.
Individual variable annuity gross sales increased by $5.9 billion, from $10.2 billion in 2008 to $16.1 billion in 2009.
The increase reflects a benefit from the impact of market disruptions on some of our competitors, certain of which implemented product modifications to increase pricing and scale back product features in the second and third quarters of 2009.
We also experienced increased sales in the third quarter of 2009 related to certain optional living benefit features which we previously announced would be discontinued during the third quarter of 2009.
Individual variable annuity surrenders and withdrawals decreased by $2.2 billion, from $8.0 billion in 2008 to $5.8 billion in 2009, reflecting the overall impact of lower account values in the first half of 2009 due to market depreciation and lower lapses for policies where the current policyholder account value is below the guaranteed minimum death or living benefit value.
Variable Annuity Net Amount at Risk As a result of the volatility and disruption in the global financial markets, in recent years we have seen significant volatility in the net amounts at risk embedded in our variable annuity products with riders that include optional living and guaranteed minimum death benefit features.
The net amount at risk is generally defined as the present value of the guaranteed minimum benefit amount in excess of the contractholder’s current account balance.
As part of our risk management strategy, we hedge or limit our exposure to certain of the risks associated with our variable annuity products primarily through a combination of product design elements, such as an automatic rebalancing element, and externally purchased hedging instruments.
Our hedging programs are discussed below in “—Net impact of embedded derivatives related to our living benefit features and related hedge positions” and “—Capital hedge program.
” The rate of return we realize from our variable annuity contracts can vary by contract based on our risk management strategy, including the impact on any capital markets movements that we may hedge, the impact on that portion of our variable annuity contracts that benefit from the automatic rebalancing element, and the impact of risks that are not able to be hedged.
The automatic rebalancing element, included in the design of certain optional living benefits, transfers assets between the variable investments selected by the annuity contractholder and, depending on the benefit feature, the fixed-rate account in the general account or a bond portfolio within the separate account.
The transfers are based on the static mathematical formula used with the particular optional benefit which considers a number of factors, including the impact of investment performance on the contractholder’s total account value.
In general, negative investment performance may result in transfers to either the fixed-rate account in the general account or a bond portfolio within the separate account, and positive investment performance may result in transfers back to contractholder-selected investments.
Overall, the automatic rebalancing element is designed to help mitigate our exposure to equity market risk and market volatility.
Beginning in 2009, our offerings of optional living benefit features associated with currently-sold variable annuity products all include an automatic rebalancing element, and in 2009 we discontinued any new sales of optional living benefit features without an automatic rebalancing element.
Variable annuity account values with living benefit features were $75.1 billion, $52.5 billion and $33.1 billion as of December 31, 2010, 2009 and 2008, respectively.
The following table sets forth the account values of our variable annuities with living benefit features and the net amounts at risk of the living benefit features split between those that include an automatic rebalancing element and those that do not, as of the dates indicated.
## Table 5 ##
(1) As of December 31, 2010, 2009 and 2008, asset values that have rebalanced to the general account or a separate account bond portfolio due to the automatic rebalancing element represent 12% or $6.7 billion of the $57.3 billion total account value, 23% or $8.2 billion of the $34.9 billion total account value, and 78% or $13.8 billion of the $17.7 billion total account value, respectively.
## Table 6 ##
(1) The amount of Level 3 assets taken as a percentage of total assets measured at fair value on a recurring basis totaled 5% and 2% for Financial Services Businesses and Closed Block Business, respectively.
Excluding separate account assets for which the risk is borne by the policyholder, the amount of Level 3 assets taken as a percentage of total assets measured at fair value on a recurring basis totaled 2% for our Financial Services Businesses.
The amount of Level 3 liabilities was immaterial to our balance sheet.
(2) “Netting” amounts represent cash collateral and the impact of offsetting asset and liability positions held with the same counterparty.
(3) 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 us 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 our Consolidated Statement of Financial Position.

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td>December 31, 2010</td><td></td></tr><tr><td>In millions of dollars</td><td>U.S.</td><td>Outside of U.S.</td><td>Total</td><td>December 31, 2009</td></tr><tr><td>Commercial and similar letters of credit</td><td>$1,544</td><td>$7,430</td><td>$8,974</td><td>$7,211</td></tr><tr><td>One- to four-family residential mortgages</td><td>2,582</td><td>398</td><td>2,980</td><td>1,070</td></tr><tr><td>Revolving open-end loans secured by one- to four-family residential properties</td><td>17,986</td><td>2,948</td><td>20,934</td><td>23,916</td></tr><tr><td>Commercial real estate, construction and land development</td><td>1,813</td><td>594</td><td>2,407</td><td>1,704</td></tr><tr><td>Credit card lines</td><td>573,945</td><td>124,728</td><td>698,673</td><td>785,495</td></tr><tr><td>Commercial and other Consumer loan commitments</td><td>124,142</td><td>86,262</td><td>210,404</td><td>257,342</td></tr><tr><td>Total</td><td>$722,012</td><td>$222,360</td><td>$944,372</td><td>$1,076,738</td></tr></table>
<table><tr><td>In millions of dollars</td><td>2010</td><td>2009</td><td>2008</td><td>2007</td><td>2006</td></tr><tr><td>Citicorp</td><td>$4,909</td><td>$5,353</td><td>$3,193</td><td>$2,027</td><td>$1,141</td></tr><tr><td>Citi Holdings</td><td>14,498</td><td>26,387</td><td>19,104</td><td>6,941</td><td>3,906</td></tr><tr><td>Total non-accrual loans (NAL)</td><td>$19,407</td><td>$31,740</td><td>$22,297</td><td>$8,968</td><td>$5,047</td></tr><tr><td>Corporate non-accrual loans-1</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>North America</td><td>$2,112</td><td>$5,621</td><td>$2,660</td><td>$291</td><td>$68</td></tr><tr><td>EMEA</td><td>5,327</td><td>6,308</td><td>6,330</td><td>1,152</td><td>128</td></tr><tr><td>Latin America</td><td>701</td><td>569</td><td>229</td><td>119</td><td>152</td></tr><tr><td>Asia</td><td>470</td><td>981</td><td>513</td><td>103</td><td>88</td></tr><tr><td></td><td>$8,610</td><td>$13,479</td><td>$9,732</td><td>$1,665</td><td>$436</td></tr><tr><td>Citicorp</td><td>$3,081</td><td>$3,238</td><td>$1,364</td><td>$247</td><td>$133</td></tr><tr><td>Citi Holdings</td><td>5,529</td><td>10,241</td><td>8,368</td><td>1,418</td><td>303</td></tr><tr><td></td><td>$8,610</td><td>$13,479</td><td>$9,732</td><td>$1,665</td><td>$436</td></tr><tr><td>Consumer non-accrual loans-1</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>North America</td><td>$8,540</td><td>$15,111</td><td>$9,617</td><td>$4,841</td><td>$3,139</td></tr><tr><td>EMEA</td><td>662</td><td>1,159</td><td>948</td><td>696</td><td>441</td></tr><tr><td>Latin America</td><td>1,019</td><td>1,340</td><td>1,290</td><td>1,133</td><td>643</td></tr><tr><td>Asia</td><td>576</td><td>651</td><td>710</td><td>633</td><td>388</td></tr><tr><td></td><td>$10,797</td><td>$18,261</td><td>$12,565</td><td>$7,303</td><td>$4,611</td></tr><tr><td>Citicorp</td><td>$1,828</td><td>$2,115</td><td>$1,829</td><td>$1,780</td><td>$1,008</td></tr><tr><td>Citi Holdings</td><td>8,969</td><td>16,146</td><td>10,736</td><td>5,523</td><td>3,603</td></tr><tr><td></td><td>$10,797</td><td>$18,261</td><td>$12,565</td><td>$7,303</td><td>$4,611</td></tr></table>
<table><tr><td></td><td colspan="2">December 31, 2014</td></tr><tr><td></td><td>2019 Notes</td><td>2021 Notes</td></tr><tr><td>Principal amounts:</td><td></td><td></td></tr><tr><td>Principal</td><td>$935,000</td><td>$954,000</td></tr><tr><td>Unamortized initial purchasers' discount and debt discount<sup>-1</sup></td><td>-225,104</td><td>-287,876</td></tr><tr><td>Net carrying amount</td><td>$709,896</td><td>$666,124</td></tr><tr><td>Carrying amount of the equity component<sup>-2</sup></td><td>$222,826</td><td>$283,283</td></tr></table>
<table><tr><td></td><td>Years Ended September 30</td></tr><tr><td>Millions of dollars, except per share amounts</td><td>2017</td><td>2016</td><td>2015</td><td>2014</td><td>2013</td></tr><tr><td>Total specified items</td><td>$1,466</td><td>$1,261</td><td>$1,186</td><td>$153</td><td>$442</td></tr><tr><td>After-tax impact of specified items</td><td>$971</td><td>$892</td><td>$786</td><td>$101</td><td>$279</td></tr><tr><td>Impact of specified items on diluted earnings per share</td><td>$-4.34</td><td>$-4.10</td><td>$-3.79</td><td>$-0.51</td><td>$-1.40</td></tr><tr><td>Impact of dilution from share issuances</td><td>$-0.54</td><td>$—</td><td>$-0.02</td><td>$—</td><td>$—</td></tr></table>
<table><tr><td></td><td>2010</td><td>2009</td><td>2008</td></tr><tr><td></td><td colspan="3">(in millions)</td></tr><tr><td>Korean asset management operations-1</td><td>$37</td><td>$17</td><td>$87</td></tr><tr><td>Equity sales, trading and research operations-2</td><td>1</td><td>3</td><td>-1</td></tr><tr><td>Real estate investments sold or held for sale-3</td><td>7</td><td>22</td><td>42</td></tr><tr><td>Mexican asset management operations-4</td><td>6</td><td>12</td><td>-13</td></tr><tr><td>International securities operations-5</td><td>-1</td><td>-1</td><td>-1</td></tr><tr><td>Healthcare operations-6</td><td>1</td><td>0</td><td>2</td></tr><tr><td>Income from discontinued operations before income taxes</td><td>51</td><td>53</td><td>116</td></tr><tr><td>Income tax expense</td><td>41</td><td>92</td><td>41</td></tr><tr><td>Income (loss) from discontinued operations, net of taxes</td><td>$10</td><td>$-39</td><td>$75</td></tr></table>
<table><tr><td></td><td colspan="2"> December 31, 2010</td><td colspan="2"> December 31, 2009</td><td colspan="2"> December 31, 2008</td></tr><tr><td></td><td> Account Value</td><td> Net Amount at Risk</td><td> Account Value</td><td> Net Amount at Risk</td><td> Account Value</td><td> Net Amount at Risk</td></tr><tr><td></td><td colspan="6"> (in millions)</td></tr><tr><td>Automatic rebalancing element-1</td><td>$57,336</td><td>$1,217</td><td>$34,901</td><td>$1,061</td><td>$17,653</td><td>$1,328</td></tr><tr><td>No automatic rebalancing element</td><td>17,735</td><td>1,825</td><td>17,570</td><td>2,785</td><td>15,401</td><td>4,973</td></tr><tr><td>Total variable annuity account values with living benefit features</td><td>$75,071</td><td>$3,042</td><td>$52,471</td><td>$3,846</td><td>$33,054</td><td>$6,301</td></tr></table>
<table><tr><td></td><td colspan="5">Closed Block Business as of December 31, 2010</td></tr><tr><td></td><td> Level 1</td><td>Level 2</td><td> Level 3-1</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>$6,034</td><td>$0</td><td></td><td>$$6,034</td></tr><tr><td>Obligations of U.S. states and their political subdivisions</td><td>0</td><td>657</td><td>0</td><td></td><td>657</td></tr><tr><td>Foreign government bonds</td><td>0</td><td>663</td><td>14</td><td></td><td>677</td></tr><tr><td>Corporate securities</td><td>0</td><td>27,182</td><td>493</td><td></td><td>27,675</td></tr><tr><td>Asset-backed securities</td><td>0</td><td>3,525</td><td>405</td><td></td><td>3,930</td></tr><tr><td>Commercial mortgage-backed securities</td><td>0</td><td>3,779</td><td>0</td><td></td><td>3,779</td></tr><tr><td>Residential mortgage-backed securities</td><td>0</td><td>2,422</td><td>3</td><td></td><td>2,425</td></tr><tr><td>Subtotal</td><td>0</td><td>44,262</td><td>915</td><td></td><td>45,177</td></tr><tr><td>Trading account assets supporting insurance liabilities</td><td>0</td><td>0</td><td>0</td><td></td><td>0</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>0</td><td>0</td><td></td><td>0</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>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Corporate securities</td><td>0</td><td>118</td><td>0</td><td></td><td>118</td></tr><tr><td>Asset-backed securities</td><td>0</td><td>33</td><td>4</td><td></td><td>37</td></tr><tr><td>Commercial mortgage-backed securities</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Residential mortgage-backed securities</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Equity securities</td><td>1</td><td>0</td><td>0</td><td></td><td>1</td></tr><tr><td>All other</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Subtotal</td><td>1</td><td>151</td><td>4</td><td></td><td>156</td></tr><tr><td>Equity securities, available for sale</td><td>3,420</td><td>140</td><td>33</td><td></td><td>3,593</td></tr><tr><td>Commercial mortgage and other loans</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Other long-term investments</td><td>0</td><td>-40</td><td>0</td><td></td><td>-40</td></tr><tr><td>Short-term investments</td><td>1,136</td><td>28</td><td>0</td><td></td><td>1,164</td></tr><tr><td>Cash equivalents</td><td>137</td><td>308</td><td>0</td><td></td><td>445</td></tr><tr><td>Other assets</td><td>0</td><td>107</td><td>11</td><td></td><td>118</td></tr><tr><td>Subtotal excluding separate account assets</td><td>4,694</td><td>44,956</td><td>963</td><td></td><td>50,613</td></tr><tr><td>Separate account assets-3</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Total assets</td><td>$4,694</td><td>$44,956</td><td>$963</td><td></td><td>$$50,613</td></tr><tr><td>Future policy benefits</td><td>$0</td><td>$0</td><td>$0</td><td></td><td>$$0</td></tr><tr><td>Long-term debt</td><td>0</td><td>0</td><td>0</td><td></td><td>0</td></tr><tr><td>Other liabilities</td><td>0</td><td>0</td><td>1</td><td></td><td>1</td></tr><tr><td>Total liabilities</td><td>$0</td><td>$0</td><td>$1</td><td></td><td>$$1</td></tr></table>

Question: What is the growing rate of Corporate non-accrual loans in the year with the most total non-accrual loans (NAL)?
Answer: -0.36123
Reasoning program: subtract(8610,13479), divide(#0,13479)