commitments . for a further description of the loan loss reserve and related accounts , see 201cmanaging global risk 201d and notes 1 and 18 to the consolidated financial statements on pages 51 , 122 and 165 , respectively . securitizations the company securitizes a number of different asset classes as a means of strengthening its balance sheet and accessing competitive financing rates in the market . under these securitization programs , assets are sold into a trust and used as collateral by the trust to obtain financing . the cash flows from assets in the trust service the corresponding trust securities . if the structure of the trust meets certain accounting guidelines , trust assets are treated as sold and are no longer reflected as assets of the company . if these guidelines are not met , the assets continue to be recorded as the company 2019s assets , with the financing activity recorded as liabilities on citigroup 2019s balance sheet . citigroup also assists its clients in securitizing their financial assets and packages and securitizes financial assets purchased in the financial markets . the company may also provide administrative , asset management , underwriting , liquidity facilities and/or other services to the resulting securitization entities and may continue to service some of these financial assets . elimination of qspes and changes in the fin 46 ( r ) consolidation model the fasb has issued an exposure draft of a proposed standard that would eliminate qualifying special purpose entities ( qspes ) from the guidance in fasb statement no . 140 , accounting for transfers and servicing of financial assets and extinguishments of liabilities ( sfas 140 ) . while the proposed standard has not been finalized , if it is issued in its current form it will have a significant impact on citigroup 2019s consolidated financial statements as the company will lose sales treatment for certain assets previously sold to a qspe , as well as for certain future sales , and for certain transfers of portions of assets that do not meet the proposed definition of 201cparticipating interests . 201d this proposed revision could become effective on january 1 , 2010 . in connection with the proposed changes to sfas 140 , the fasb has also issued a separate exposure draft of a proposed standard that proposes three key changes to the consolidation model in fasb interpretation no . 46 ( revised december 2003 ) , 201cconsolidation of variable interest entities 201d ( fin 46 ( r ) ) . first , the revised standard would include former qspes in the scope of fin 46 ( r ) . in addition , fin 46 ( r ) would be amended to change the method of analyzing which party to a variable interest entity ( vie ) should consolidate the vie ( such consolidating entity is referred to as the 201cprimary beneficiary 201d ) to a qualitative determination of power combined with benefits or losses instead of the current risks and rewards model . finally , the proposed standard would require that the analysis of primary beneficiaries be re-evaluated whenever circumstances change . the existing standard requires reconsideration only when specified reconsideration events occur . the fasb is currently deliberating these proposed standards , and they are , accordingly , still subject to change . since qspes will likely be eliminated from sfas 140 and thus become subject to fin 46 ( r ) consolidation guidance and because the fin 46 ( r ) method of determining which party must consolidate a vie will likely change should this proposed standard become effective , the company expects to consolidate certain of the currently unconsolidated vies and qspes with which citigroup was involved as of december 31 , 2008 . the company 2019s estimate of the incremental impact of adopting these changes on citigroup 2019s consolidated balance sheets and risk-weighted assets , based on december 31 , 2008 balances , our understanding of the proposed changes to the standards and a proposed january 1 , 2010 effective date , is presented below . the actual impact of adopting the amended standards as of january 1 , 2010 could materially differ . the pro forma impact of the proposed changes on gaap assets and risk- weighted assets , assuming application of existing risk-based capital rules , at january 1 , 2010 ( based on the balances at december 31 , 2008 ) would result in the consolidation of incremental assets as follows: .

Table:
in billions of dollars | incremental gaap assets | incremental risk- weighted assets
credit cards | $ 91.9 | $ 88.9
commercial paper conduits | 59.6 | 2014
private label consumer mortgages | 4.4 | 2.1
student loans | 14.4 | 3.5
muni bonds | 6.2 | 1.9
mutual fund deferred sales commission securitization | 0.8 | 0.8
investment funds | 1.7 | 1.7
total | $ 179.0 | $ 98.9
the table reflects ( i ) the estimated portion of the assets of qspes to which citigroup , acting as principal , has transferred assets and received sales treatment as of december 31 , 2008 ( totaling approximately $ 822.1 billion ) , and ( ii ) the estimated assets of significant unconsolidated vies as of december 31 , 2008 with which citigroup is involved ( totaling approximately $ 288.0 billion ) that would be consolidated under the proposal .
due to the variety of transaction structures and level of the company 2019s involvement in individual qspes and vies , only a subset of the qspes and vies with which the company is involved are expected to be consolidated under the proposed change .
a complete description of the company 2019s accounting for securitized assets can be found in note 1 to the consolidated financial statements on page 122. .

Question: what percentage of incremental risk-weighted assets are student loans at january 1 , 2010?
Answer: 4%
Calculation: divide(3.5, 98.9)