The Company is required to establish a valuation allowance for any portion of the deferred tax assets that management believes will not be realized.
Included in deferred tax assets is a significant deferred tax asset relating to capital losses that have been recognized for financial statement purposes but not yet for tax return purposes.
Under current U. S.  federal income tax law, capital losses generally must be used against capital gain income within five years of the year in which the capital losses are recognized for tax purposes.
Significant judgment is required in determining if a valuation allowance should be established, and the amount of such allowance if required.
Factors used in making this determination include estimates relating to the performance of the business including the ability to generate capital gains.
Consideration is given to, among other things in making this determination, i) future taxable income exclusive of reversing temporary differences and carryforwards, ii) future reversals of existing taxable temporary differences, iii) taxable income in prior carryback years, and iv) tax planning strategies.
Based on analysis of the Company’s tax position, management believes it is more likely than not that the results of future operations and implementation of tax planning strategies will generate sufficient taxable income to enable the Company to utilize all of its deferred tax assets.
Accordingly, no valuation allowance for deferred tax assets has been established as of December 31, 2009 and 2008.
Included in the Company’s deferred income tax assets are tax benefits related to net operating loss carryforwards of $59 million which will expire beginning December 31, 2025 as well as tax credit carryforwards of $166 million which will expire beginning December 31, 2025.
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits for 2009 is as follows:
## Table 0 ##
If recognized, approximately $81 million, $62 million and $84 million, net of federal tax benefits, of the unrecognized tax benefits as of December 31, 2009, 2008 and 2007, respectively, would affect the effective tax rate.
The Company recognizes interest and penalties related to unrecognized tax benefits as a component of the income tax provision.
The Company recognized $1 million in interest and penalties for the year ended December 31, 2009 and a net reduction of $25 million and $4 million in interest and penalties for the years ended December 31, 2008 and 2007, respectively.
At December 31, 2009 and 2008, the Company had a receivable of $12 million and $13 million, respectively, related to accrued interest and penalties.
It is reasonably possible that the total amounts of unrecognized tax benefits will change in the next 12 months.
However, there are a number of open audits and quantification of a range cannot be made at this time.
The Company or one or more of its subsidiaries files income tax returns in the U. S.  federal jurisdiction, and various states and foreign jurisdictions.
With few exceptions, the Company is no longer subject to U. S.  federal, state and local, or non-U.
S.  income tax examinations by tax authorities for years before 1997.
The Internal Revenue Service (‘‘IRS’’), as part of the overall examination of the American Express Company consolidated return, completed its field examination of the Company’s U. S.  income tax returns for 1997 through 2002 during 2008 and completed its field examination of 2003 through 2004 in the third quarter of 2009.
However, for federal income tax purposes these years continue to remain open as a consequence of certain issues under appeal.
In the fourth quarter of 2008, the IRS commenced an examination of the Company’s U. S.  income tax returns for 2005 through 2007, which is expected to be completed in 2010.
The Company’s or certain of its subsidiaries’ state income tax returns are currently under examination by various jurisdictions for years ranging from 1998 through 2006.
On September 25, 2007, the IRS issued Revenue Ruling 2007-61 in which it announced that it intends to issue regulations with respect to certain computational aspects of the Dividends Received Deduction (‘‘DRD’’) related to separate account assets held in connection with variable contracts of life insurance companies.
Revenue Ruling 2007-61 suspended a revenue ruling issued in August 2007 that purported to change accepted industry and IRS interpretations of the statutes governing these computational questions.
Any regulations that the
The following table presents the changes in wrap account assets:
## Table 1 ##
Our wrap accounts had net inflows of $9.3 billion in 2009 compared to net inflows of $3.7 billion in 2008 and market appreciation of $12.8 billion in 2009 compared to market depreciation of $26.8 billion in 2008.
In 2008, we acquired $2.0 billion in wrap account assets attributable to our acquisition of H&R Block Financial Advisors, Inc.  We provide securities execution and clearing services for our retail and institutional clients through our registered broker-dealer subsidiaries.
As of December 31, 2009, we administered $95.1 billion in assets for clients, an increase of $19.6 billion compared to the prior year primarily due to market appreciation.
The following table presents the results of operations of our Advice & Wealth Management segment:
## Table 2 ##
Our Advice & Wealth Management segment pretax loss was $34 million in 2009 compared to pretax loss of $149 million in 2008.
Net revenues Net revenues were $3.2 billion for the year ended December 31, 2009 compared to $3.1 billion in the prior year, an increase of $106 million, or 3%, driven by an increase in net investment income as well as revenues resulting from our 2008 acquisitions and a decrease in banking and deposit interest expense, partially offset by decreases in management and financial advice fees and distribution fees.
Management and financial advice fees decreased $105 million, or 8%, to $1.2 billion for the year ended December 31, 2009, driven by a 22% decline in the daily average S&P 500 Index on a period-over-period basis, partially offset by net inflows.
Wrap account assets increased $22.1 billion, or 30%, compared to the prior year due to net inflows and market appreciation.
Financial planning fees were lower for the year ended December 31, 2009 compared to the prior year resulting from accelerated financial plan delivery standards in 2008.
Distribution fees decreased $179 million, or 9%, to $1.7 billion for the year ended December 31, 2009, primarily due to lower client activity levels and lower asset-based fees driven by lower equity markets, partially offset by revenues resulting from our 2008 acquisitions.
Liquidity and Capital Resources Overview We maintained substantial liquidity during 2009.
At December 31, 2009, we had $3.1 billion in cash and cash equivalents compared to $6.2 billion at December 31, 2008.
Excluding collateral received from derivative counterparties, cash and cash equivalents were $3.0 billion and $4.4 billion at December 31, 2009 and 2008, respectively.
We have additional liquidity available through an unsecured revolving credit facility for $750 million that expires in September 2010, which we anticipate re-establishing before expiration.
Under the terms of the underlying credit agreement, we can increase this facility to $1.0 billion.
Available borrowings under this facility are reduced by any outstanding letters of credit.
We have had no borrowings under this credit facility and had $2 million of outstanding letters of credit at December 31, 2009.
In June 2009, we issued $200 million of 7.75% senior notes due 2039 and $300 million of 7.30% senior notes due 2019 (collectively, ‘‘senior notes’’).
In July 2009, we used a portion of the proceeds from the issuance of our senior notes to repurchase $450 million aggregate principal amount of our 5.35% senior notes due 2010 pursuant to a cash tender offer.
In addition, in June 2009, we received cash of $869 million from the issuance and sale of 36 million shares of our common stock.
In September 2009, we announced the all-cash acquisition of the long-term asset management business of Columbia Management, which is expected to close in the spring of 2010.
The total consideration to be paid will be between $900 million and $1.2 billion, which is expected to be funded through the use of cash on hand.
In 2009, our subsidiaries, Ameriprise Bank, FSB and RiverSource Life, became members of the Federal Home Loan Bank of Des Moines (‘‘FHLB of Des Moines’’), which provides these subsidiaries with access to collateralized borrowings.
As of December 31, 2009, we had no borrowings from the FHLB of Des Moines.
We believe cash flows from operating activities, available cash balances and our availability of revolver borrowings will be sufficient to fund our operating liquidity needs.
Various ratings organizations publish financial strength ratings, which measure an insurance company’s ability to meet contractholder and policyholder obligations, and credit ratings.
The following table summarizes the ratings for Ameriprise Financial, Inc.  and certain of its insurance subsidiaries as of the date of this filing:
## Table 3 ##
As of December 31, 2009, A. M.  Best Company, Inc. , Standard & Poor’s Ratings Services, Moody’s Investors Service and Fitch Ratings Ltd.  retained negative outlooks on Ameriprise Financial, Inc.  and RiverSource Life and the life insurance industry as a whole.
For information on how changes in our financial strength or credit ratings could affect our financial condition and results of operations, see the ‘‘Risk Factors’’ discussion included in Part 1, Item 1A in our Annual Report on Form 10-K.  Dividends from Subsidiaries Ameriprise Financial is primarily a parent holding company for the operations carried out by our wholly owned subsidiaries.
Because of our holding company structure, our ability to meet our cash requirements, including the payment of dividends on our common stock, substantially depends upon the receipt of dividends or return of capital from our subsidiaries, particularly our life insurance subsidiary, RiverSource Life, our face-amount certificate subsidiary, Ameriprise Certificate Company (‘‘ACC’’), AMPF Holding Corporation, which is the parent company of our retail introducing broker-dealer subsidiary, Ameriprise Financial Services, Inc.  (‘‘AFSI’’) and our clearing broker-dealer subsidiary, American Enterprise Investment Services, Inc.  (‘‘AEIS’’), our auto and home insurance subsidiary, IDS Property Casualty Insurance Company (‘‘IDS Property Casualty’’), doing business as Ameriprise Auto & Home Insurance, Threadneedle, RiverSource Service Corporation and our investment advisory company, RiverSource Investments, LLC.
The payment of dividends by many of our subsidiaries is restricted and certain of our subsidiaries are subject to regulatory capital requirements.
Kendal Vroman, 39 Mr.  Vroman has served as our Managing Director, Commodity Products, OTC Services & Information Products since February 2010.
Mr.  Vroman previously served as Managing Director and Chief Corporate Development Officer from 2008 to 2010.
Mr.  Vroman joined us in 2001 and since then has held positions of increasing responsibility, including most recently as Managing Director, Corporate Development and Managing Director, Information and Technology Services.
Scot E.  Warren, 47 Mr.  Warren has served as our Managing Director, Equity Index Products and Index Services since February 2010.
Mr.  Warren previously served as our Managing Director, Equity Products since joining us in 2007.
Prior to that, Mr.  Warren worked for Goldman Sachs as its President, Manager Trading and Business Analysis Team.
Prior to Goldman Sachs, Mr.  Warren managed equity and option execution and clearing businesses for ABN Amro in Chicago and was a Senior Consultant for Arthur Andersen & Co.  for financial services firms.
FINANCIAL INFORMATION ABOUT GEOGRAPHIC AREAS Due to the nature of its business, CME Group does not track revenues based upon geographic location.
We do, however, track trading volume generated outside of traditional U. S.  trading hours and through our international telecommunication hubs.
Our customers can directly access our exchanges throughout the world.
The following table shows the percentage of our total trading volume on our Globex electronic trading platform generated during non-U.
S.  hours and through our international hubs.

Tables referenced above, in order (Table 0 first):
<table><tr><td></td><td>2009</td><td>2008</td><td>2007</td></tr><tr><td></td><td colspan="3">(in millions)</td></tr><tr><td>Balance at January 1</td><td>$-56</td><td>$164</td><td>$113</td></tr><tr><td>Additions (reductions) based on tax positions related to the current year</td><td>1</td><td>-164</td><td>42</td></tr><tr><td>Additions for tax positions of prior years</td><td>45</td><td>64</td><td>56</td></tr><tr><td>Reductions for tax positions of prior years</td><td>-23</td><td>-120</td><td>-45</td></tr><tr><td>Settlements</td><td>—</td><td>—</td><td>-2</td></tr><tr><td>Balance at December 31</td><td>$-33</td><td>$-56</td><td>$164</td></tr></table>
<table><tr><td> </td><td> 2009</td><td>2008</td></tr><tr><td> </td><td colspan="2">(in billions)</td></tr><tr><td>Balance at January 1</td><td>$72.8</td><td>$93.9</td></tr><tr><td>Net flows</td><td>9.3</td><td>3.7</td></tr><tr><td>Market appreciation/(depreciation)</td><td>12.8</td><td>-26.8</td></tr><tr><td>Other</td><td>—</td><td>2.0</td></tr><tr><td>Balance at December 31</td><td>$94.9</td><td>$72.8</td></tr></table>
<table><tr><td> </td><td colspan="2">Years Ended December 31,</td><td></td><td></td></tr><tr><td> </td><td>2009</td><td>2008</td><td colspan="2">Change</td></tr><tr><td> </td><td colspan="4">(in millions, except percentages)</td></tr><tr><td> Revenues</td><td></td><td></td><td></td><td></td></tr><tr><td>Management and financial advice fees</td><td>$1,234</td><td>$1,339</td><td>$-105</td><td>-8%</td></tr><tr><td>Distribution fees</td><td>1,733</td><td>1,912</td><td>-179</td><td>-9</td></tr><tr><td>Net investment income</td><td>297</td><td>-43</td><td>340</td><td>NM</td></tr><tr><td>Other revenues</td><td>85</td><td>80</td><td>5</td><td>6</td></tr><tr><td>Total revenues</td><td>3,349</td><td>3,288</td><td>61</td><td>2</td></tr><tr><td>Banking and deposit interest expense</td><td>133</td><td>178</td><td>-45</td><td>-25</td></tr><tr><td>Total net revenues</td><td>3,216</td><td>3,110</td><td>106</td><td>3</td></tr><tr><td> Expenses</td><td></td><td></td><td></td><td></td></tr><tr><td>Distribution expenses</td><td>1,968</td><td>2,121</td><td>-153</td><td>-7</td></tr><tr><td>General and administrative expense</td><td>1,282</td><td>1,138</td><td>144</td><td>13</td></tr><tr><td>Total expenses</td><td>3,250</td><td>3,259</td><td>-9</td><td>—</td></tr><tr><td>Pretax loss</td><td>$-34</td><td>$-149</td><td>$115</td><td>77%</td></tr></table>
<table><tr><td> </td><td> A.M. Best Company, Inc.</td><td> Standard & Poor's Ratings Services</td><td> Moody's Investors Service</td><td> Fitch Ratings Ltd.</td></tr><tr><td> Financial Strength Ratings</td><td></td><td></td><td></td><td></td></tr><tr><td>RiverSource Life</td><td>A+</td><td>AA-</td><td>Aa3</td><td>AA-</td></tr><tr><td>IDS Property Casualty Insurance Company</td><td>A</td><td>N/R</td><td>N/R</td><td>N/R</td></tr><tr><td> Credit Ratings</td><td></td><td></td><td></td><td></td></tr><tr><td>Ameriprise Financial, Inc.</td><td>a-</td><td>A</td><td>A3</td><td>A-</td></tr></table>

Question: In the year with the most Net flows, what is the growth rate of Market appreciation/(depreciation)?
Answer: 3.09375
Reasoning program: add(12.8,26.8), divide(#0,12.8)